The French Competition Authority (FCA) and businesses have welcomed the introduction of new thresholds. The reform is expected to reduce the number of merger notifications by 20–30%.

The case for reform

France's current merger control notification thresholds date back to 2004 (and to 2008 for retail-specific thresholds). Absent any adjustment for inflation, an increasing number of transactions have been subject to FCA review since then. For example, the FCA issued 192 merger control decisions in 2015 compared with 328 in 2025, representing an increase of 70%.

This increase has placed growing pressure on the FCA's already limited resources as well as unnecessary burdens on companies. More than 90% of notified transactions are eligible for the simplified procedure and unlikely to raise competition concerns because of, e.g., limited overlaps or a limited market position of the parties.

The FCA has sought to adapt its approach to cope with this increased workload. For instance, in July 2024, the newly appointed head of the FCA merger unit launched a so-called pacte de confiance setting out a principle of exemption from customary pre-notification discussions for concentrations eligible for the simplified procedure, so that the 25-business-day Phase I review period could start immediately. However, although this has streamlined the review process, this had no impact on the number of reportable transactions and only the legislator has the power to change the thresholds and thus reduce the number of reviewable deals.

New thresholds

The legislator has now increased the merger thresholds based on the cumulative growth rate of France’s nominal GDP between 2004 and 2023 (and between 2008 and 2023 for retail-specific thresholds). The following new thresholds will apply to formal notifications submitted from 1 September 2026:

• General thresholds: parties must have €250 million of aggregate global turnover (previously €150 million), and at least two parties must generate €80 million in French turnover (previously €50 million).
• Retail-specific thresholds: parties must have €100 million in aggregate global turnover (previously €75 million) and at least two parties must generate €20 million in French turnover (previously €15 million).

Thresholds for overseas territories remain unchanged. This reflects the French legislator's intention to capture more transactions in these territories characterised by high sector concentration and elevated costs of living.

Expected consequences 

By reducing the number of notifications, the reform is expected to benefit both the FCA, by allowing it to focus its resources on transactions that raise more significant competition concerns, and businesses, by easing the notification burden for mid-sized deals.

This is not, however, a sign of weaker enforcement. Indeed, the FCA, as well as other European competition authorities, are currently focusing on capturing below-threshold transactions that may raise competition concerns.

In November 2025, the FCA applied for the first time the CJEU Towercast judgment (see our briefing for further detail) and sanctioned Doctolib for the predatory acquisition of a rival medical appointment platform as an abuse of dominance – even though the deal was not subject to merger control.

In addition, the FCA is currently seeking the introduction of a call-in power that would enable it to review below-threshold transactions likely to harm competition, subject to triggering conditions that are yet to be determined.