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Opinion of the European Economic and Social Committee – Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – Report on Competition Policy 2024 (COM(2025) 181 final)

EESC 2025/02299

OJ C, C/2026/872, 27.2.2026, ELI: http://data.europa.eu/eli/C/2026/872/oj (BG, ES, CS, DA, DE, ET, EL, EN, FR, GA, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)

ELI: http://data.europa.eu/eli/C/2026/872/oj

Date of document:: 03/12/2025; Date of vote
Date of vote:: 03/12/2025
Date lodged:: 29/08/2025

Author:: European Economic and Social Committee
Responsible body:: Section for the Single Market, Production and Consumption, EESC_INT
Rapporteur:: Andrea MONE
Form:: Opinion
Internal reference:: INT/1096, AVIS-SECTION 2025/2299 FIN
Session:: 601

Treaty:

Treaty on the Functioning of the European Union

Legal basis:

12016E304

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Earlier related instruments:

52025DC0181 ESC Opinion

Instruments cited:

EUROVOC descriptor:

Subject matter:

Competition

Directory code:

08.10.00.00 Competition policy / Competition principles

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Official Journal
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C/2026/872

27.2.2026

Opinion of the European Economic and Social Committee

Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – Report on Competition Policy 2024

(COM(2025) 181 final)

(C/2026/872)

Rapporteur:

Andrea MONE

Advisor	Samuel CORNELLA (to the rapporteur)
Referral	European Commission, 29.8.2025
Legal basis	Article 304 of the Treaty on the Functioning of the European Union
Section responsible	Single Market, Production and Consumption
Adopted in section	14.11.2025
Adopted at plenary session	3.12.2025
Plenary session No	601
Outcome of vote (for/against/abstentions)	220/1/3

1. Conclusions and recommendations

1.1.

The European Economic and Social Committee (EESC) welcomes the approach to enforcement adopted by the Commission in 2024, which aims to effectively integrate competition policy with the broader objectives of creating a more digital, green and resilient EU, while maintaining a well-functioning internal market.

1.2.

The EESC praises the Commission’s efforts, in 2024, to estimate the savings for consumers in terms of the direct effects of antitrust enforcement (regarding cartels and abusive unilateral conduct) and merger control, based on a common method adopted by the Organisation for Economic Co-operation and Development (OECD).

1.3.

The EESC supports the Commission’s efforts to promote international forums on competition in order to strengthen the international perspective on the subject, as well as ongoing engagement between enforcement authorities and stakeholders against the backdrop of increasingly globalised markets. The coordination role of the Commission within the European Competition Network (ECN) is also crucial.

1.4.

The EESC considers the new approach in competition policy supporting companies scaling up in global markets, while ensuring a level playing field, to be positive. This should be reflected in merger assessment so that innovation and resilience are fully considered, while stressing that market concentration resulting in higher prices or lower quality should be avoided. It should also be ensured that all interested parties in the process, and in particular social partners, are duly heard and have the necessary opportunities to convey their considerations in the relevant cases, including on social and labour issues, in order to manage all issues underlying these processes in a sustainable manner.

1.5.

The EESC encourages the Commission to continue working on its new guidelines on exclusionary abuses of dominance, following the publication of the draft guidelines in August 2024. These guidelines represent an important opportunity to improve predictability regarding the enforcement of Article 102 TFEU. By promoting an advanced ‘effects-based approach’, the guidelines can help ensure that Article 102 TFEU is enforced effectively, focusing on cases that tangibly harm competition in key markets.

1.6.

The EESC is pleased that the Commission is continuing to focus on competition enforcement in digital markets. Such markets have specific structural features and business models, which often lead to the emergence of dominant players able to create barriers to entry for their competitors, potentially harming competition.

1.7.

Following the Illumina-GRAIL judgment of the ECJ, the EESC encourages the Commission to develop a legal framework for examining mergers which, while not meeting the notification thresholds of the Merger Regulation, could nevertheless have an adverse impact on competition.

1.8.

The EESC observes that the recent revision of the three horizontal/Services of General Economic Interest (SGEI)/Agricultural de minimis Regulations (all increasing the exemption ceilings) are long-awaited and useful measures, especially as a response to the inflationary pressures following the COVID-19 pandemic.

1.9.

The EESC stresses the importance of the important projects of common European interest (IPCEIs) when it comes to State aid, encouraging the Commission to strengthen its close cooperation with the Member States in the Joint European Forum for Important Projects of Common European Interest (JEF-IPCEI), with a view to increasing transparency and speeding up procedures.

1.10.

Looking at the new Clean Industrial Deal State Aid Framework (CISAF) regime, the EESC emphasises that achieving the objectives of the Clean Industrial Deal will require unprecedented levels of investment. Neither public funding nor private funding on their own will be sufficient in this respect and will need to be supplemented by: i) reforms aimed at cutting red tape while promoting social and labour standards; ii) the completion of the single market, Banking Union and Capital Markets Union; iii) coordinated efforts at national and EU level through additional instruments, such as the proposed Competitiveness Fund and a reinforced 2028-2034 multiannual financial framework (MFF).

1.11.

More specifically, the EESC deems that the Commission should consider introducing, within CISAF rules, provisions to encourage the broad participation of more Member States in relevant projects in order to address fragmentation concerns, thus creating spillover effects across borders in aid schemes.

2. General comments

2.1. Approach to competition policy and tools used to analyse it

2.1.1.

The EESC welcomes the approach to enforcement adopted by the Commission during 2024, which aims to effectively integrate competition policy with the broader objectives of creating a more digital, green and resilient EU, while maintaining a well-functioning internal market. As the Commission points out, ‘Competition policy does not operate... in a vacuum. Sector-specific regulations and competition enforcement work together and reinforce each other’. This holistic approach is essential to ensuring that competition policy is aligned with the EU’s political priorities and, in this respect, that the competition rules constitute a pillar of Europe’s competitiveness and go hand in hand with its industrial policies and decarbonisation processes, as also underlined in the Draghi report. In this respect, the ongoing review and modernisation of some of the main competition rules and tools, such as antitrust enforcement and the mergers guidelines, is strongly supported by the EESC.

2.1.2.

The EESC welcomes the Commission’s efforts, in 2024, to estimate the savings for consumers in terms of the direct effects of antitrust enforcement (regarding cartels and abusive unilateral conduct) and merger control, based on a common method adopted by the OECD. This approach seems useful not only for seeking to measure the impact of competition policy with quantitative tools, but also for focusing empirically on a key concept of competition law and economics: consumer welfare.

2.1.3.

The EESC is very interested in the Commission’s report on Protecting competition in a changing world – evidence on the evolution of competition in the EU during the past 25 years (1), as it provides a useful historical context for competition enforcement. Comparing market concentration trends, competition dynamics and market structures over time, the report highlights the main structural changes that have taken place over the past 25 years (most recently, there has been a growing gap between the leading firms and their competitors, i.e. greater concentration in the market). This analysis could be particularly helpful for shaping the current and future direction of EU competition policy.

2.1.4.

In the same vein, the Commission’s efforts to collaborate with national competition authorities within the ECN and to promote international forums in relation to competition (International Competition Network (ICN), OECD, United Nations Conference on Trade and Development (UNCTAD) are also significant and should be supported in order to strengthen a consistent European and international perspective on the subject, ensuring at the same time a leading role for European competition authorities in increasingly globalised markets.

2.1.5.

The EESC hopes that, in future, competition enforcement will increasingly take into account not only the impact on consumers, on competing businesses and on the functioning of markets, but also the issue of employment and labour. This has happened, for example, in other jurisdictions with regard to issues such as ‘no-poach agreements’ between digital companies – which have the effect of limiting the employment options of their employees – unilateral conduct that restricts or even eliminates the scope for collective protection among digital platform workers, and cases of monopsony, which lead to a deterioration in the conditions of certain workers (2).

2.2. Market definition

2.2.1.

The EESC welcomes the Commission’s adoption of the new Notice on the definition of the relevant market (Market Definition Notice or MDN), revised in February 2024, as a useful update of a key concept in competition enforcement (the previous notice dates back to 1997). This is particularly significant for addressing abuse of dominant position under Article 102 TFEU, as well as for merger control. The updated notice on defining the relevant market, which places a stronger emphasis on non-price parameters, better reflects the latest and most significant societal and technological developments, in particular with regard to digital and high-innovation markets.

2.3. Application of Article 101 TFEU

2.3.1.

The EESC notes the attention paid by the Commission to anti-competitive agreements in the agri-food sector in 2024, recognising that such practices are particularly harmful to consumers, especially those in the most vulnerable sections of society. This is in line with President von der Leyen’s mission letter to the Commissioner responsible for competition, which specifically singles out the agri-food sector as potentially subject to anti-competitive practices (‘work with relevant Commissioners to tackle anticompetitive practices, such as those which affect the competitiveness and sustainability of the food and farming sector’).

2.3.2.

The EESC points out that the Commission’s evaluation of the Motor Vehicle Block Exemption Regulation (MVBER), launched in January 2024, together with the extension of the supplementary guidelines for the sector, are necessary measures. These measures are particularly worthwhile in terms of addressing the increasing influence of digital features and connectivity in vehicles, which are reshaping the automotive industry. They will also help to refine the approach to competition enforcement in a sector undergoing a profound transformation and facing increasing international competition, as also highlighted in the Draghi report.

2.4. Enforcement of Article 102 TFEU

2.4.1.

The EESC encourages the Commission to continue working on its new guidelines on exclusionary abuses of dominance, following the publication of the draft guidelines in August 2024. These guidelines represent an important opportunity to improve predictability and legal certainty regarding the enforcement of Article 102 TFEU. By promoting an advanced ‘effects-based approach’, the guidelines can help ensure that Article 102 TFEU is enforced effectively, focusing on cases that tangibly harm competition in key and strategic markets.

2.4.2.

The EESC is pleased that the Commission is continuing to focus on competition enforcement in digital markets. These markets have specific structural features and business models, which often lead to the emergence of dominant players that can create barriers to entry for their competitors, and this has the potential to harm and distort competition. The EESC also notes that the Commission’s approach is clearly in line with the growing social and economic significance of digital services. Bolstering competition enforcement in this area is therefore essential for consumer welfare, innovation and an effective level playing field.

2.5. Merger control

2.5.1.

Following the Illumina-GRAIL judgment of the European Court of Justice, the EESC encourages the Commission to develop a legal framework for examining mergers which, while not meeting the notification thresholds of the Merger Regulation, could nevertheless have an adverse impact on competition. This would make it possible to examine acquisitions by large competitors targeting innovative companies in the early stages of their development, when their potential as a competitor is not (yet) reflected in their revenues (so-called ‘killer acquisitions’). Closing this gap in merger enforcement could be a particularly effective way of safeguarding the dynamics of competition, substantially benefiting consumers in the long run, particularly in strategic markets such as pharmaceuticals, life sciences and digital services.

2.5.2.

Paragraph 114 of the document Topic G: Public policy, security and labour market considerations (3), which forms part of the Commission’s ongoing consultation on the merger guidelines, states that ‘While the protection of competition generally contributes to the provision of good and well-paying jobs in Europe, the application of labour market theories of harm may enable the Commission to prevent negative effects on workers in certain specific merger cases’; the EESC calls on the Commission to examine this specific issue, which has not been considered to date. On this specific point, the EESC would point out that the 2023 Merger Guidelines issued by the US Department of Justice and Federal Trade Commission (FTC) include a section (2.10) devoted to the potential harmful effects that mergers may have on workers by reducing competition in labour markets.

2.6. State aid

2.6.1.

The EESC notes that the revision of the general de minimis Regulation (increasing the exemption ceiling from EUR 200 000 to EUR 300 000 over a period of three years, since January 2024) is a long-awaited measure, especially as a response to the inflationary pressures following the COVID-19 pandemic. The introduction of national registers, to be rolled out from 2026, is a useful complementary measure to improve transparency and predictability not only for public authorities, but also for the beneficiary companies.

2.6.2.

The EESC also welcomes the revision of the SGEI de minimis Regulation, which raises the exemption ceiling from EUR 500 000 to EUR 750 000. This will help to simplify the process of compensation for operators with significant public service obligations, which are often essential to social and economic cohesion at local level. As rightly stressed in the Letta report, ‘The objectives of the Single Market should align with the freedom of movement as well as the freedom to stay in the community of one’s choice. Accessible, affordable, and adaptable Services of General Interest (SGI) across all EU regions are crucial for ensuring the freedom to stay, necessitating an Action Plan for high-quality SGIs in Europe’.

2.6.3.

The amendment of the de minimis Regulation for agriculture, which includes a significant increase in the aid ceilings – raising the de minimis ceiling per business over three years from EUR 25 000 to EUR 50 000 and increasing the maximum amount of cumulative de minimis aid allowed per Member State from 1,5 % to 2 % of the value of the agricultural output of the Member State – constitutes a significant adjustment, greater than that in other sectors. However, this increase appears justified by the high degree of vulnerability of the agri-food sector to market volatility and by the disproportionate impact of rising energy prices on key inputs such as fertilisers. The EESC therefore recognises the importance of providing more flexibility to support farmers and agricultural businesses in dealing with these challenges.

2.6.4.

The amendment of the Guidelines on Regional State aid (RAG) in May 2024 to support strategic technological projects is a positive development. Here, the EESC takes the opportunity to reiterate the importance of preserving social and economic cohesion across the EU. This objective should be pursued through a balanced use of different instruments, including a well-calibrated State aid policy and proper funding under the new MFF.

2.6.5.

The EESC stresses the importance of the IPCEIs when it comes to State aid, encouraging the Commission to strengthen its close cooperation with the Member States in the JEF-IPCEI and IPCEI Design Hub. This collaboration is essential for improving and speeding up the design and assessment processes for new IPCEIs, thus facilitating the pooling of resources by Member States in strategic sectors and technologies of common interest. Smoothening procedures and increasing transparency might be key to effectively boost IPCEI.

2.6.6.

Coordinated efforts in State aid measures and schemes are particularly important in areas where market dynamics alone cannot deliver the desired results (market failure), and thus help to maintain the EU’s competitiveness and innovation on the global stage. This is in line both with the Draghi report’s proposal to reform the IPCEIs to cover a broader concept of innovation and with the innovative and ambitious suggestion in the Letta report to develop, in the future, a mechanism for combining European and national funds that do not fall under the State aid rules, aimed at financing strategic pan-European projects.

2.7. State aid – Temporary frameworks and CISAF

2.7.1.

The EESC recognises that the temporary State aid frameworks introduced in response to the COVID-19 pandemic and the Russian invasion of Ukraine have been key to supporting the European economy at a time of unprecedented crises. The EESC takes note of the European Commission’s observation that, while there are significant differences between the nominal aid amounts disbursed by Member States under these schemes, ‘the picture becomes more nuanced when looking at relative State aid expenditure compared to GDP’. Nevertheless, the EESC believes that the significant disparities between Member States in terms of their financial resources and their administrative capacity to deploy those resources may risk undermining the consolidation of the internal market if not properly regulated.

2.7.2.

Looking at the new CISAF regime as a stable replacement for the past temporary frameworks, the EESC emphasises that achieving the objectives of the Clean Industrial Deal will require unprecedented levels of investment. Neither public funding nor private funding on their own will be sufficient to deliver what is needed. Here, State aid will continue to play a crucial role in incentivising the necessary investments, but the following elements will also be essential: i) implementing reforms aimed at cutting red tape while promoting social and labour standards; ii) facilitating the completion of the single market and of the Banking Union and Capital Markets Union, as pointed out in the recent Letta and Draghi reports; and iii) coordinating efforts at national and EU level through additional instruments, such as the proposed Competitiveness Fund and a reinforced multiannual financial framework (4).

2.7.3.

The EESC deems that, in order to address fragmentation concerns related to the progressive relaxation of state aid control, the Commission should consider introducing provisions to encourage broad participation of more Member States in relevant IPCEIs, thus creating spillover effects across borders in aid schemes. For example, the focus could go to enhancing and strengthening cross-border value chains by allowing for higher aid intensities in cases with clear spillover effects.

2.8. Digital Markets Act (DMA)

2.8.1.

The EESC supports the increasing enforcement of the DMA by the Commission as a valuable tool that complements the existing competition rules in order to make the digital sector in the EU more contestable, and curb unfair practices by companies acting as gatekeepers in the online platform economy. Although the DMA has only recently come into force, it already seems capable of: i) curbing undue ‘self-preferencing’; ii) enabling interoperability with smaller competitors; and iii) removing artificial barriers to competition.

2.8.2.

At the same time, the EESC points out that the increasing relevance and effectiveness of the DMA has triggered the need, for digital companies and stakeholders, to have reliable guidance and more predictability about the priorities and technicalities of enforcing the DMA.

2.9. Foreign Subsidies Regulation (FSR)

2.9.1.

Finally, the EESC welcomes the fact that the Commission rigorously enforced the FSR in 2024 to protect the integrity of the EU single market from competition-distorting subsidies granted by non-EU countries to companies operating in the EU, in particular with respect to mergers and public procurement procedures. This enforcement activity – which should keep the administrative burden proportionate in the interest of both the Commission and the enterprises concerned – is essential for achieving a twofold and relevant objective: keeping the EU single market open to trade and investment from third countries, while preventing unfair competition especially in strategic sectors, which can be detrimental not only to European companies but also to European workers.

Brussels, 3 December 2025.

The President

of the European Economic and Social Committee

Séamus BOLAND

(1) https://competition-policy.ec.europa.eu/about/reaching-out/protecting-competition-changing-world_en.

(2) See also the FOOD DELIVERY SERVICES CASE AT.40795, June 2025.

(3) Commission document Topic G: Public policy, security and labour market considerations, consulted on 24 September 2025.

(4) Opinion of the European Economic and Social Committee – Framework for State aid measures to support the Clean Industrial Deal (COM(2025) 7600 final) (OJ C, C/2026/68, 30.1.2026, ELI: http://data.europa.eu/eli/C/2026/68/oj).

ELI: http://data.europa.eu/eli/C/2026/872/oj

ISSN 1977-091X (electronic edition)

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