Competition Law Update - April 2026

Welcome to the latest edition of our newsletter, which explores recent competition law developments across the UK and EU.

One of the key developments in the UK in recent weeks was the confirmation of Doug Gurr as permanent CMA Chair. In this edition, we explore what this appointment – alongside the CMA’s first digital markets interventions in relation to Apple and Google – indicates about the CMA’s enforcement priorities and direction of travel.  

Turning to the EU, we examine the CJEU’s judgments on various points of appeal in the long-running Air Freight cartel saga, and the Commission’s evolving decisional practice under the Foreign Subsidies Regulation, in view of its recent conditional clearance in ADNOC/Covestro.

We also look at upcoming changes to the UK’s national security screening regime, and consider what the CMA’s recent informal guidance on a sustainable agriculture initiative tells us about the application of its Green Agreements ”open door” policy.

Confirmation of CMA permanent Chair highlights the political tightrope it is currently walking

Doug Gurr was recently confirmed as the permanent Chair of the CMA, for a five-year term. This followed a report from and hearing before the House of Commons Business and Trade Committee, which expressed reservations about the appointment and the CMA’s approach to enforcement. We consider the extent to which those concerns were warranted, and the implications for the CMA’s enforcement policy.
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The CMA’s SMS investigations into Apple and Google: where do we stand?

After considerable delay, the CMA has finally started to exercise its new digital markets regulatory powers. The initial measures announced by the CMA were a procedural mixed bag, comprising both the expected (draft Conduct Requirements) and the unexpected (voluntary commitments from Apple and Google). 
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Final boarding call: the CJEU brings the Air Freight cartel proceedings to a close

On 26 February 2026, the EU Court of Justice largely dismissed the appeals of 13 airlines in the long-running Air Freight cartel proceedings, upholding a series of 2022 rulings by the General Court. We pick out the key points from the various rulings.
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The Foreign Subsidies Regulation in action part two: learnings from the ADNOC/Covestro decision

The European Commission recently published the non-confidential version of its decision to conditionally approve Abu Dhabi National Oil Company’s acquisition of Covestro AG. The decision sheds further light on the Commission’s approach to enforcing the merger component of the Foreign Subsidies Regulation. 
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What's caught and what's not? The Government's proposed changes to the NSIA's notifiable sectors 

Four years on from the entry into force of the National Security and Investment Act 2021, the UK Government is set to implement its first update to the mandatory notification categories. The proposed changes provide further clarity in some areas (including AI), and are forecast to slightly increase the overall number of mandatory notifications. 
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Narrowing the LENs: latest CMA informal guidance a missed opportunity for sustainability agreements?

The CMA recently published its fourth piece of informal guidance under its Green Agreements “open door” policy, on the 3Keel LENs 2.0 scheme. We examine the guidance and consider its implications for parties seeking comfort on their environmental sustainability cooperation agreements.
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This edition was edited by Senior Associate, Matthew Jones. 

If you have any questions about the articles in this newsletter, do not hesitate to reach out to Matthew, or any of your usual contacts: Cameron Firth, Malcolm Walton, Christophe Humpe, Caja Griesenbach, Foad Hoseinian and Fiona Beattie.