Ireland CCPC Annual Report 2024: Competition Law Trends and Takeaways
Paul Henty, Beale & Co.
Dublin and London
Introduction
The Irish Competition and Consumer Protection Commission (CCPC) recently published its Annual Report for 2024, marking its tenth year as Ireland’s competition regulator. The report reveals a notable increase in enforcement activity, continuing trends seen in 2023.
This article reviews key developments in merger control, cartel enforcement, abuse of dominance, and gun-jumping, comparing them to the 2023 report. It also considers how the CCPC’s level of activity compares to other European competition authorities, and what these developments mean for in-house counsel and business leaders regarding strategic planning, risk management, and transaction structuring.
Merger Control: Rising Notifications and a Landmark Prohibition
Merger activity in Ireland accelerated in 2024. The CCPC handled 82 merger notifications, representing a 21 percent increase from 2023. Despite this heavier caseload, the authority improved its turnaround times through wider use of the Simplified Merger Notification Procedure (SMNP). Approximately 71 percent of merger determinations were cleared under the SMNP, compared to around half in 2023. SMNP cases were completed in an average of 13.3 working days, while standard Phase 1 reviews averaged 16.3 days (both improvements on the prior year).
The most significant development in 2024 was the CCPC’s prohibition of Dublin Airport Authority’s proposed acquisition of QuickPark, the principal independent long-term car park at Dublin Airport. The transaction would have given the airport operator control of more than 90 percent of long-term airport parking, creating a near-monopoly likely to reduce consumer choice and increase prices. This was the first outright prohibition in several years and signals a more assertive merger control stance.
In total, eight Phase 2 investigations were opened in 2024, of which three were cleared unconditionally, one with remedies, and three carried forward into 2025. Eleven notifications required extended Phase 1 reviews, comparable to the previous year. The trend suggests a maturing merger regime: the CCPC is prepared to dig deeper where overlaps arise, while processing straightforward cases efficiently.
The authority also launched a consultation on revised Merger Guidelines in late 2024 and signalled potential future ‘call-in’ powers for non-notifiable transactions. These developments suggest that early competition law assessment will become increasingly critical, even for mid-sized transactions.
Cartel Enforcement: Raids, Prosecutions and International Cooperation
The CCPC increased its anti-cartel enforcement activity in 2024, opening five new investigations, two of which involve suspected collusion. Dawn raids were conducted at business premises as part of ongoing cartel inquiries, marking a further normalisation of unannounced inspections as an enforcement tool. This follows a revival of criminal cartel enforcement activity seen in 2023, including dawn raids at multiple premises linked to bid-rigging allegations in the transport sector.
A notable case progressing towards trial concerns alleged bid-rigging in public school transport services. This case involves multiple operators and will be one of the first criminal cartel prosecutions in Ireland in many years. The CCPC also assisted the Italian Competition Authority in a Dublin-based search at Ryanair’s headquarters as part of an abuse of dominance investigation, underscoring greater cross-border cooperation.
The Competition (Amendment) Act 2022, which implements the EU ECN+ Directive, has fundamentally reshaped Irish enforcement. The CCPC now has the power to impose administrative fines through in-house adjudication, issue formal fining guidelines, and offer settlements for leniency applicants. These new tools allow the authority to pursue civil enforcement routes alongside traditional criminal prosecution, accelerating outcomes and increasing deterrence.
Abuse of Dominance: Renewed Interest in Market Power
Two of the five new competition investigations opened in 2024 relate to alleged abuse of dominance. This marks a shift towards greater scrutiny of unilateral conduct, an area where Irish enforcement has historically been limited.
The first investigation related to healthcare software company (Clanwilliam) and the provision of Electronic Patient Record (EPR) software and related services such as electronic referrals and text messaging services. The second investigation related to Dublin Port Company and the provision of port infrastructure at Dublin Port and/or the provision of port towage services at Dublin Port.
The 2022 reforms empower the CCPC to impose administrative fines of up to 10 percent of turnover for dominance abuses, aligning Ireland more closely with European practice. The establishment of a dedicated adjudication unit is expected to make dominance enforcement more practical and responsive. Companies with strong market positions should therefore review pricing, rebate, and exclusivity policies for potential competition risks.
Gun-Jumping: Enforcement of Standstill Obligations
For the first time in several years, the CCPC opened an investigation into suspected gun-jumping in 2024. This reflects a growing willingness to enforce standstill obligations against companies that close transactions prior to obtaining clearance. The Competition (Amendment) Act 2022 strengthened the CCPC’s powers to prosecute gun-jumping and increase penalties, bringing Ireland in line with other active EU jurisdictions such as France and Spain.
Businesses should ensure that Irish thresholds are properly assessed in multi-jurisdictional transactions, and that no integration steps occur before clearance is received. The CCPC’s focus on procedural compliance demonstrates that even technical breaches may now attract enforcement attention.
Comparison with European Peers
Relative to its size, the CCPC is now one of the more active national competition authorities in Europe. The authority’s increasing use of administrative powers mirrors trends in countries like the Netherlands and Denmark, where hybrid civil-criminal models have enhanced deterrence. Its prohibition of QuickPark places Ireland within the mainstream of EU merger enforcement practice, moving beyond a purely remedial approach.
Implications for M&A: No shortcuts in Deal Closing
For M&A practitioners and businesses, there are the following take-aways:
- Notification Threshold Assessment: Always evaluate if a transaction triggers the Irish merger thresholds (based on parties’ turnover in Ireland). This includes share acquisitions, joint ventures, and asset acquisitions that might not look like full mergers. If in doubt, err on the side of notifying or seek informal guidance; the cost of a filing is far lower than a potential gun-jumping fine or void transaction.
- Standstill Obligations: Once a notifiable deal is signed and submitted, do not implement any integration steps until CCPC (and any other required authorities) give the green light. That means no transfer of business control, no joint management, and caution in exchanging competitively sensitive information. The CCPC’s active enforcement means even soft gun-jumping (such as coordinating market strategies or pricing with your future subsidiary before clearance) could be scrutinised.
- Internal Coordination: Ensure the deal teams, both legal and commercial, understand the importance of the standstill period. Integrations planning is fine, but it must remain clean-team based and conditional. Sales or supply chain teams should not start acting as one company prematurely. If the CCPC is investigating a gun-jumping case now, it likely wants to set a precedent; do not become the example.
- Global Transactions: If your transaction requires approvals in multiple countries, remember Ireland is one of them when thresholds apply. It can be easy to focus on larger jurisdictions and overlook Irish filing needs, but the CCPC will notice if a global deal quietly closes its Irish leg without notification. The CCPC’s increasing cooperation within the ECN means they share intelligence with European counterparts.
In addition to competition-law considerations, transactions involving foreign investment now also fall under the Irish FDI screening regime. The Screening of Third Country Transactions Act 2023 introduces a mandatory notification and review system for certain transactions by non-EU/EEA investors that pose risks to security or public order. The regime came into force on 6 January 2025, and covers transactions meeting criteria such as a third-country investor acquiring control of an asset or undertaking in Ireland, a value threshold (currently €2 million), and involvement in specified critical sectors.
Deal documentation must now reflect the possibility of Irish FDI review as well as competition clearance, with timing, warranties and condition precedent provisions structured accordingly. Transactions should no longer treat Ireland only as a competition-clearance jurisdiction but must reflect both merger control and FDI screening obligations. Non-notification under the new FDI law can result in a fine not exceeding €4 million and/or up to 5 years imprisonment. The Act also gives the Minister power to “call-in” past transactions (completed in certain windows) that should have been notified or give rise to security/public order concerns, even if they fell outside the mandatory notification criteria.
Conclusion
The 2024 Annual Report confirms that the CCPC has evolved into a confident and assertive competition authority. It is faster at clearing unproblematic mergers, tougher on problematic ones, more coordinated internationally, and increasingly willing to use its new administrative powers. For businesses, this means that competition law risk is now integral to transaction planning, pricing strategies, and internal compliance frameworks. Ireland’s enforcement environment has matured, and companies should adjust their governance and deal processes accordingly.