On 14 July 2026 the CCPC published its 2025 Annual Report. Irish merger control trends were a key feature.
The CCPC issued 91 merger determinations during 2025, securing commitments to address competition concerns in five cases and completed five full Phase II Investigations. Of the 90 notifications submitted in 2025, eight of which were media mergers. Merger notifications increased by almost 10% since 2024 and, following CCPC advocacy, increased merger notification thresholds came into effect on 1 July 2026.
Increase in the CCPC’s Turnover Thresholds:
From 1 July 2026, the Irish mandatory merger notification thresholds have increased.
Previously ‘mergers or acquisitions’ were mandatorily notifiable to the CCPC, if, in their most recent financial year the turnover in the Republic of Ireland:
- of all undertakings involved in a ‘merger or acquisition’ was at least €60 million, and
- of each of at least two undertakings involved was at least €10 million;
Since 1 July 2026, deals are mandatorily notifiable if the turnover in the Republic of Ireland:
- of all undertakings involved in a ‘merger or acquisition’ is at least €100 million, and
- of each of at least two undertakings involved is at least €15 million.
Beware - Below-threshold deals still carry risk:
The CCPC has a statutory power, to ‘call-in power’, enabling it require notification of below-threshold transactions where it considers that the deal may “have an effect on competition in markets for goods or services” in Ireland. That ‘call-in power’ has been in force since September 2023 and has already been used (see Uniphar/Touchstore).
This means parties should assess not only turnover, but also whether the transaction involves factors likely to attract scrutiny, including:
- horizontal overlaps;
- vertical links;
- concentrated markets;
- valuable data, technology or strategic assets; and
- a real prospect of complaints from customers, suppliers or competitors.
Where ‘call-in’ risk appears material, early engagement and careful transaction planning will be important and in some cases, parties may also wish to consider making a voluntary notification to ensure deal certainty.
Proposed changes to the media merger regime:
Only eight media mergers were notified in 2025, a similar figure to 2024. However, dealmakers should remain aware of a potential broadening of scope of the Irish media merger regime under proposed legislation:
If enacted, the proposed legislation is expected to broaden the definition of a media business, transfer responsibility for media merger assessment to Ireland’s media regulator Coimisiún na Meán, introduce a ‘call-in power’ for certain non-notifiable media transactions and create a new ‘gun-jumping’ offence.
These changes could bring a wider range of media sector deals into scope and increase regulatory scrutiny in Ireland.
It is worth remembering that currently ‘media mergers’ involving a merger or acquisition where:
(i) two or more of the undertakings involved carry on a media business in the State; or
(ii) one or more of the undertakings involved carries on a media business in the State and one or more of the undertakings involved carries on a media business elsewhere
is designated as a special class of merger or acquisition, having been specified in an order by the Minister for Enterprise, Tourism and Employment, that requires notification on a mandatory basis, irrespective of the turnover of the undertakings involved.
Practical takeaways for dealmakers:
Transaction teams should:
- Check early whether their thresholds are mandatorily notifiable under Irish merger control rules (and indeed under Irish FDI Screening rules)
- Carry out a substantive Irish competition assessment for deals that fall below the CCPC’s thresholds for mandatory notification, given there may nevertheless be a ‘call-in’ risk;
- Review transaction documents to ensure they address possible CCPC engagement, including conditions precedent, long-stop dates and risk allocation; and
- Continue to assess filing requirements and referral risk in other relevant jurisdictions.
