Financial Services Antitrust Bulletin
18 December 2025
Since Q3 2025, competition authorities across the world have continued to closely scrutinise the financial services sector. This edition of the Clifford Chance Financial Services Antitrust Bulletin charts the following key themes derived from developments in Europe, North America, the Asia-Pacific region and North Africa:
M&A on the rise
Merger activity in financial services remains robust, with authorities closely scrutinising both domestic and cross-border transactions. The unconditional clearances of transactions in the insurance and financial services sectors across the EU, France, Italy and the UK highlight a pragmatic approach to consolidation in respect of mergers that do not raise significant competition concerns.
Collective redress and consumer compensation gain support
There is a continued emphasis on ensuring effective enforcement of competition and consumer protection laws and delivering tangible outcomes for consumers, with authorities and courts facilitating significant compensation schemes. The UK’s CAT approval of a GBP 200 million collective settlement in the Mastercard litigation, Poland’s landmark commitment decision requiring Bank Pekao to pay record compensation for complaint-handling failures, and US settlements in private antitrust actions against major financial institutions (Schwab/TD Ameritrade, Visa, Mastercard) reflect this trend.
Modernisation of digital assets and financial infrastructure
Regulators are moving to modernise frameworks for digital assets and financial infrastructure. Australia’s introduction of a licensing regime for digital asset platforms aims to close regulatory gaps, enhance governance and align with international standards, while also prompting industry consolidation. In parallel, authorities are considering the competitive implications of open banking regimes, with Australia also consulting on exemptions for small lenders.
