Business leaders across Europe and the UK are navigating an increasingly intricate regulatory landscape as global competition policies evolve. Merger control, once viewed as a purely technical legal process, is now recognized as a crucial mechanism for achieving broader policy goals, including innovation, resilience, competitiveness, and economic growth. As economic challenges persist within the European Union and the UK, competition authorities are reassessing their approaches to merger control, both in terms of procedures and substantive considerations.
EU’s merger policy under scrutiny
The debate surrounding the role of merger control in the EU has gained momentum since the 2019 prohibition of the Siemens/Alstom merger, which exposed the conflict between maintaining effective competition in the single market and fostering the development of “European champions.” This pivotal moment prompted the European Commission to confront political pressure to revise its framework in light of increasing global competition from the US and China. The Draghi report on European competitiveness, released in 2024, advocated for the modernization of competition policy to align with strategic objectives such as innovation, investment, and resilience.
Recent actions by the Commission indicate a willingness to adapt to these challenges. The 2025 Competitiveness Compass reiterated the need to address the innovation gap, pursue decarbonization while safeguarding competitiveness, reduce strategic dependencies, and bolster economic security. In May 2025, the Commission initiated a comprehensive review of its Horizontal and Non-Horizontal Merger Guidelines, aimed at aligning merger control with contemporary market realities, including digitalization, globalization, and sustainability. This review addresses how to evaluate dynamic effects—such as innovation and competitiveness—and their implications for labor markets, marking a significant shift in focus.
The UK’s shift towards pro-growth policies
Post-Brexit, the UK Competition and Markets Authority (CMA) has positioned itself as a leading global authority, as demonstrated by its interventions in high-profile mergers like Meta/Giphy in 2021 and Microsoft/Activision in 2023. The Labour government, which took office in July 2024, has redirected merger control discussions towards a broader narrative of economic growth and investment. Ministers have indicated that competition policy should complement this pro-growth agenda, leading to significant changes in the CMA’s leadership and approach.
The CMA’s introduction of the 4Ps framework—focusing on improved pace, predictability, proportionality, and process—highlights its commitment to reforming merger control to better facilitate investment. The authority plans to concentrate on mergers that have a clear UK impact, thereby easing the regulatory burden on global deals lacking a direct nexus to the UK market. Additionally, the CMA is reviewing its stance on merger remedies, showing an increased openness to behavioral solutions that promote pro-competitive efficiencies and support investment growth.
For business leaders, these developments in both Brussels and London signal a significant shift in how mergers will be evaluated. Although a definitive framework for merger control reform in the EU has yet to be established, companies will benefit by demonstrating how their transactions can enhance innovation, resilience, and competitiveness. In the UK, the CMA’s reforms suggest a more growth-oriented approach, allowing businesses to craft narratives around investment and their roles in global deals.
As the competitive landscape evolves, firms must adapt their strategies to effectively navigate the regulatory environment. BRG’s team of economists, stationed across Europe, offers invaluable expertise to help businesses leverage these changes into strategic advantages. By quantifying dynamic effects, developing data-driven submissions, designing effective remedies, and aligning with evolving regulatory priorities, BRG assists clients in demonstrating pro-competitive efficiencies and positioning transactions to support broader policy goals.
In a world where competition policies are becoming increasingly intertwined with economic growth strategies, understanding and adapting to these shifts is crucial for companies aiming to thrive in a competitive marketplace.