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EU consultation

Review of the Merger Guidelines

22 submissions from 22 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission lists 134 submissions on this file. Shown here: the 22 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.

Who showed up

19 submissions from industry — companies and their trade associations — against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 9.5 industry submissions for every one from civil society.

Industry 19Civil society 2Public authorities, academia, other 1

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.

What the room declares

14 of 22
in the EU Register
66
full-time lobbying staff
€7.5M+
declared costs a year
70
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 3 Sept 2025 — it ran from 8 May 2025.

Where it stands
Awaiting adoption
Adoption expected
31 Dec 2027 · in 488 days

How it got here

  1. Call for evidence3 Sept 2025
  2. Public consultation3 Sept 2025

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Communication.

22 positions

FD

France Digitale

· · filed 3 Sept 2025 · source

PDF

France Digitale welcomes the European Commissions initiative to revise the EU Merger Guidelines and views it as an important step toward ensuring that Europe remains a strong and competitive player in the global market.

LinkedInX
N

NetChoice

· · filed 3 Sept 2025 · source

PDF

NetChoice welcomes the European Commissions Review of its Merger Guidelines and supports the Commission's stated objective to ensure merger guidelines are "fit for today's fast-changing economy" while providing predictability for businesses. NetChoice is a trade association of leading internet businesses that promotes the value, convenience, and choice that online business models provide to American consumers.

LinkedInX
TN

TDC NET

· · filed 3 Sept 2025 · source

PDF

TDC NET fully supports the initiative to review the Merger Guidelines as mandated in the Mission Letter to Executive Vice President Ribera and outlined in the Commissions Competitiveness Compass. While other global regions are innovating and scaling, Europe is falling behind. European operators are constrained by fragmentation and overregulation, which hinder investments.

LinkedInX
ER

European Round Table for Industry

· · filed 3 Sept 2025 · source

PDF

ERT is convinced that effective competition law enforcement is critical to ensure open markets, deliver consumer benefits and maintain a fair level-playing field between companies. As the most sophisticated and impactful antitrust enforcer globally, that is seen as the role model for agencies around the world, the European Commissions Directorate General for Competition (DG COMP), is a critical enabler and guardian…

LinkedInX
FD

Fédération française des télécoms

· · filed 3 Sept 2025 · source

PDF

FFTélécoms welcomes the opportunity to respond to the public consultation on the evaluation and impact assessment on merger guidelines. Obviously, EU competition and internal market rules have a direct impact on the competitiveness of the telecommunications sector which is highly strategic at both the EU and national level.

LinkedInX
AF

Allied For Startups

· · filed 3 Sept 2025 · source

PDF

The revision of the EU Merger Guidelines is a unique chance to align competition policy with Europes innovation and competitiveness agenda. Startups, central to building global tech leaders, depend on predictable M&A pathways to scale, recycle capital, and attract investment. Yet Europes shallow exit markets and unpredictable merger control risk pushing founders abroad, draining jobs and IP.

LinkedInX
TD

The Danish Chamber of Commerce

· · filed 3 Sept 2025 · source

PDF

The Danish Chamber of Commerce (Dansk Erhverv) supports the initiative to review the Merger Guidelines as mandated in the Mission Letter to Executive Vice-President Ribera and outlined in the Commissions Competitiveness Compass and Clean Industrial Deal.

LinkedInX
VG

Vodafone Group

· · filed 3 Sept 2025 · source

We welcome the ECs efforts to review its competition framework. Europe needs a shift in competition policy that enables European companies to innovate, invest, scale up and improve competitiveness (as per Draghi and the Competitiveness Compass). But the guidelines review is not enough. A comprehensive review of the merger framework is needed, including the Merger Regulation and Remedies Notice.

LinkedInX
DT

Deutsche Telekom AG

· · filed 3 Sept 2025 · source

On a general note, Deutsche Telekom welcomes the revision of the Guidelines as a step in the right direction towards modernising the EU Merger Control Framework. However, this is insufficient to meet President von der Leyen´s prospect of new approach to competition policy, better geared to our common goals and more supportive of companies scaling up as set out in her Political Guidelines.

LinkedInX
DE

DigitalTrade4.EU

· · filed 3 Sept 2025 · source

PDF

The document is a comprehensive feedback to the European Commissions Call for Evidence on the Review of the Merger Guidelines. It advocates for modernizing the EUs merger control framework to align with the green and digital transitions, emphasizing the integration of data-driven competition, sustainability, and resilience into merger assessments.

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C

Cigref

· · filed 3 Sept 2025 · source

PDF

Position OF CIGREF ON THE REVISION of EU DIRECTRICES LIGNES ON HORIZONTALS AND NON-HORIZONTAL CONCENTRATIONS CIGREF, a network of 160 large French companies and public administrations, has the task of strengthening the digital capacities of its members. As dutilisers of digital solutions and services, we would like to share our reflections on the revision of the Merger Control Guidelines.

Filed in French · English published by the European Commission

LinkedInX
IB

International Bar Association

· · filed 3 Sept 2025 · source

PDF

The Mergers Working Group of the Antitrust Section of the International Bar Association (Working Group) welcomes the European Commissions effort to refresh the EU Horizontal and Non-Horizontal Merger Guidelines (the 'EU merger guidelines') where they appear to be patently out-of-date.

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CO

Chamber of Progress

· · filed 3 Sept 2025 · source

PDF

On behalf of Chamber of Progress a tech industry association supporting public policies to build a more inclusive society in which all people benefit from technological advancements please find our response to the European Commission (EC) Call for Evidence on the Merger Guidelines attached.

LinkedInX
BT

BREKO - The German Broadband Association

· · filed 3 Sept 2025 · source

PDF

BREKO welcomes the opportunity to contribute to the ongoing debate on the evolution of the merger control guidelines in the EU telecommunications markets. In the German telecommunications market, mergers have not played a significant role in driving fibre deployment or in strengthening competition.

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G

GSMA

· · filed 3 Sept 2025 · source

PDF

The GSMA and Connect Europe welcome the opportunity to comment on the revision of the EU Merger Guidelines. We recognise that the revision represents a step in the right direction towards modernising the EU Merger Control Framework and bringing it in line with the objectives of the Mission Letter and the current geopolitical and market trends, subject to adopting a revolutionary rather than an evolutionary approach.

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CE

Connect Europe

· · filed 3 Sept 2025 · source

PDF

Connect Europe and GSMA welcome the opportunity to comment on the revision of the EU Merger Guidelines. We recognise that the revision represents a step in the right direction towards modernising the EU Merger Control Framework and bringing it in line with the objectives of the Mission Letter and the current geopolitical and market trends, subject to adopting a revolutionary rather than an evolutionary approach.

LinkedInX
SI

Swedish Incubators & Science Parks

· · filed 3 Sept 2025 · source

PDF

Swedish Incubators & Science Parks (SISP), the national association for Swedens incubators, science parks, and innovation hubs, welcomes the Commissions review of the Horizontal and Non-Horizontal Merger Guidelines.

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BC

British Chamber of Commerce EU & Belgium

· · filed 2 Sept 2025 · source

PDF

BritCham welcomes the opportunity to contribute to the Commissions review of the Merger Guidelines and strongly supports the Commissions ambition to ensure that EU merger control promotes competitiveness, innovation, and resilience.

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S

SMEunited

· · filed 2 Sept 2025 · source

The upcoming revision of the EU merger guidelines should take into account the specific characteristics of SMEs in European markets. Unlike large multinational corporations, SMEs often lack the financial and legal resources and therefore might face aggressive consolidation trends that reduce market. In particular, some acquisitions can remove innovative SMEs from the market.

LinkedInX
AN

Asociación Española de Startups

· · filed 1 Sept 2025 · source

The revision of the Horizontal and Non-Horizontal Merger Guidelines must be modernized to reflect current market dynamics, particularly in digital and technological sectors, fostering innovation, European competitiveness, and startup growth.

LinkedInX
AT

ACT | The App Association

· · filed 1 Sept 2025 · source

PDF

The App Association is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry.

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IE

industriall Europe

· · filed 29 Aug 2025 · source

PDF

Competition policies have a significant impact on employment levels, wages and working conditions. Adverse consequences may arise whenever a narrow assessment of the consumer interest and strict economic efficiency tests are insufficiently balanced with social considerations. Merger controls focus narrowly on economic efficiency and consumer welfare and leave little room for the promotion of social dialogue.

LinkedInX
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.