The German Federal Cartel Office ("FCO") has published its 2025 review, which shows another high‑intensity enforcement year. 

1. Key Antitrust Developments in 2025 at a glance

The FCO imposed around EUR 10 million in cartel fines, drew on 600 whistleblower reports and conducted ten dawn raids, reflecting its continued focus on cartel detection supported by increasingly sophisticated digital investigative tools. 

In the digital sector, the FCO advanced major cases, including a market test for Apple’s ATTF remedies and commitments closing Google’s Automotive Services and Maps investigations. The FCO emphasised that AI‑driven business models could amplify platform power, reinforcing the need for continued vigilance.

In the energy sector, the FCO concluded its review of energy‑price relief measures, returning approximately EUR 200 million to the federal budget and confirming largely compliant supplier behaviour. Following its mineral‑oil sector inquiry, it launched a Section 32f GWB proceeding—an instrument enabling structural market intervention even without a proven infringement that was introduced with the 11^th Amendment to the ARC back in 2023—focused on structural concerns in the wholesale fuels market. 

Abuse of dominance proceedings also shaped the year, with active cases in district heating, food retail (Coca‑Cola, Edeka), e‑commerce (Temu) and telecoms (Vodafone/Vantage Towers).

Merger control remained busy with around 900 filings, including the prohibition of Tönnies/Vion and the imposition of a far‑reaching three‑year pre‑notification obligation on the Rethmann/Remondis group, covering even below‑threshold acquisitions. Public‑procurement oversight remained strong, and the Competition Register continued to be used intensively, with roughly 700 daily queries.

2. Outlook to 2026

For 2026, German antitrust enforcement is expected to be shaped less by legislative change and more by the practical application of the powerful new instruments already enacted. Companies active in Germany should prepare for continued assertiveness in digital markets, closer scrutiny of structurally concentrated sectors and further development of the FCO’s post‑sector‑inquiry intervention powers.

In the digital space, the FCO will continue to prioritize oversight of large platforms under Section 19a GWB, while deepening cooperation with the European Commission on the enforcement of the Digital Markets Act. The authority has also indicated a growing interest in competition issues related to cloud services and the use of artificial intelligence, suggesting these may become early-stage areas of exploration in 2026.

The next antitrust year starts with the year’s most significant platform for policy direction—the FCO's 23rd International Competition Conference (IKK) which will be taking place in Berlin from 11–13 March 2026. It is expected to offer an early indication of how the FCO intends to balance enforcement intensity with the new regulatory landscape.