REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Report on Competition Policy 2024
Date: 2025-04-25
Institutions: Directorate-General for Competition, European Commission
Subjects: EU competition policy, EU financial instrument, State aid, anti-trust legislation, competitiveness, control of restrictive practices, merger control, restriction on competition, single market, twin transition

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 25.4.2025  COM(2025) 181 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Report on Competition Policy 2024 {SWD(2025) 102 final}  
 
 
Contents 
1. 

Introduction .................................................................................................................................... 2 

2.  Modernising  and  simplifying  competition  rules  to  contribute  to  the  EU’s  competitiveness,  the 
green and digital transitions, and the strengthening of the Single Market ............................................. 3 

2.1. Evaluating and revising antitrust and merger rules ..................................................................... 3 

2.2. Evaluating and revising State aid rules and guidance ................................................................. 5 

2.3. State aid policy as a key to resilience in times of crisis .............................................................. 7 

The  Temporary  Crisis  and  Transition  Framework  to  support  transition  towards  a  net-zero 
economy ......................................................................................................................................... 7 

Implementing the Recovery and Resilience Facility ..................................................................... 8 

3. Effective competition enforcement contributed to the EU’s green and digital transitions and to the 
strengthening of the Single Market ........................................................................................................ 8 

3.1. Keeping markets fair and contestable and strengthening the Single Market .............................. 8 

Antitrust enforcement .................................................................................................................... 8 

Merger control ............................................................................................................................. 13 

State aid control ........................................................................................................................... 16 

3.2 Supporting the green transition .................................................................................................. 18 

Antitrust enforcement .................................................................................................................. 19 

Merger control ............................................................................................................................. 19 

State aid control ........................................................................................................................... 20 

3.3. Supporting an economy that works for people ......................................................................... 23 

Financial services sector .............................................................................................................. 23 

Taxation ....................................................................................................................................... 25 

4. Effective enforcement of the Digital Market Act and the Foreign Subsidies Regulation ............... 26 

4.1. Addressing the challenges and dynamics of digital markets by enforcing the DMA ............... 26 

4.2. Protecting the Single Market from distortive foreign subsidies by enforcing the FSR ............ 28 

5. Impact of competition policy and enforcement ............................................................................... 29 

5.1. Benefits from competition enforcement for consumers and citizens ........................................ 29 

5.2. Protecting competition in a changing world ............................................................................. 30 

5.3. Impact of State aid policy on the Single Market ....................................................................... 31 

6. Communication and advocacy support competition policy ............................................................. 36 

7. Relations with other EU institutions ................................................................................................ 37 

8. Competition policy in a European and global context ..................................................................... 37 

8.1. Promoting a European competition culture through the European Competition Network ....... 37 

 
 
8.2. Helping Member States to reform through the Technical Support Instrument ......................... 38 

8.3. International relations ............................................................................................................... 38 

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1.  Introduction 

Since the very beginning of the European project, competition policy has played a fundamental role 
in shaping the Single Market. Competition policy allows companies of all sizes to compete and grow 
on the merits in the EU, while also fostering innovation and growth, as well as contributing to the 
overall competitiveness and resilience of the EU economy.  

EU  competition  policy  along  with  effective  competition  enforcement  keep  prices  down,  increase 
product  quality,  and  speed  up  innovation,  generally  enhancing  the  welfare  of  consumers  and 
businesses.  The  objective  of  EU  competition  policy  is  to  keep  markets  open  and  contestable,  in 
particular  by  removing  and  sanctioning  practices  that  distort  the  competitive  process,  and  by 
allowing only the least distortive State aid.  

In 2024, two reports were published by Enrico Letta1 and Mario Draghi2. Mr Letta’s report contains 
recommendations on how to improve the Single Market, and Mr Draghi’s report includes proposals 
on how to increase the EU’s competitiveness. Both reports emphasise the Single Market as the EU’s 
best  asset  for  a  competitive,  clean,  and  digital  future,  and  the  fact  that  effectively  enforcing 
competition  rules  is  a  fundamental  source  of  productivity  growth  and  competitiveness  in  the  EU. 
Effective competition is a core feature of well-functioning markets. 

Against  this  background,  in  2024,  the  European  Commission  (Commission)  and  its  Directorate-
General for Competition continued to develop EU competition policy to achieve the objectives of a 
green,  digital,  and  resilient  European  economy,  as  well  as  to  actively  enforce  competition  rules. 
Effective  competition  is  a  core  feature  of  well-functioning  markets.  Competition  policy  does  not, 
however,  operate  in  a  vacuum.  Sector-specific  regulations  and  competition  enforcement  work 
together and reinforce each other.  

The  Report  on  Competition  Policy  of  2024  is  addressed  by  the  Commission  to  the  European 
Parliament, the Council of the European Union, the European Economic and Social Committee and 
the European Committee of the Regions. The Report describes key developments in EU competition 
policy  and  enforcement  during  2024.  A  more  comprehensive  account  of  policy  developments, 
enforcement  actions  and  important  case-law  is  included  in  the  Staff  Working  Document  (SWD) 
which accompanies the Report. 

1Much More than a Market - Speed, Security, Solidarity - Empowering the Single Market to deliver a sustainable future and prosperity for all EU 
Citizens, Enrico Letta, 10.4.2024. 
2 The future of European competitiveness – A competitiveness strategy for Europe, Mario Draghi, 9.9.2024.  

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2.  Modernising  and  simplifying  competition  rules  to  contribute  to  the  EU’s 
competitiveness, the green and digital transitions, and the strengthening of the 
Single Market 

Much  work  was  done  in  2024  to  ensure  that  all  competition  enforcement  instruments  (merger 
control,  antitrust  and  State  aid  control)  remain  fit  for  purpose  to  protect  fair  competition  and  are 
aligned with the objectives of a green, digital, and resilient EU economy.   

2.1. Evaluating and revising antitrust and merger rules  

In February 2024, the Commission adopted the revised Market Definition Notice (MDN) updating 
how markets are defined with a view to reflect new market realities and developments in decisional 
practice and case law3. Market definition requires identifying the boundaries of competition between 
companies when assessing mergers and most antitrust cases.  The MDN increases  transparency and 
legal certainty for businesses, facilitates compliance and contributes to a more efficient competition 
enforcement.  The  revised  MDN  provides  up-to-date  and  more  accessible  guidance.  It  describes 
general principles and emphasises the importance of non-price parameters for market definition, such 
as innovation, quality, reliable supply, and sustainability. In addition, the MDN includes guidance on 
market  definition  concepts  in  specific  circumstances,  for  example  in  digital  markets,  innovation-
intensive industries, and markets undergoing structural transition. The MDN also covers quantitative 
techniques used when defining markets and calculating market shares. 

The evaluation of the antitrust procedural framework was completed in 2024. Regulation 1/20034 
and its implementing act, Regulation 773/20045 establish a procedural framework aimed at ensuring 
the  effective and  uniform  application  of  Articles  101  and  102  TFEU.  After extensive  collection  of 
evidence, a public consultation and a survey, the Commission published in September 2024 a  Staff 
Working Document6 presenting the results of the evaluation. Throughout the evaluation process, the 
Commission services liaised with the national competition authorities of the Member States (NCAs). 
The  Commission  staff  concluded  that,  in  general,  the  evaluated  regulations  had  performed  well  in 
attaining  their  objectives of  effective  and  uniform application  of  Articles  101  and  102 TFEU,  both 
through the changes it brought to the Commission’s enforcement powers and by empowering NCAs 
to enforce EU competition rules. The evaluation also identified areas for further reflection, to ensure 
that competition enforcement keeps up with digitalisation and to ensure coherent and swift antitrust 
enforcement. 

Exclusionary abuses of dominance harm both businesses and consumers. They lead to higher prices, 
less  innovation  and  poorer  quality  of  goods  and  services.  In  2024,  the  Commission  continued 

3 Communication from the Commission - Commission Notice on the definition of the relevant market for the purposes of Union competition law 
OJ C, C/2024/1645, 22.2.2024, p. 1. 
4 Council Regulation (EC) No 1/2003 of 16.12.2002 on the implementation of the rules on competition laid down in Articles 81 and 82 of  the 
Treaty, OJ L, 4.1.2003, p. 1. 
5 Commission Regulation (EC) No 773/2004 of 7.4.2004 relating to the conduct of proceedings by the Commission pursuant to Articles 81 and 
82 of the EC Treaty, OJ L 123, 27.4.2004, p. 18. 
6Commission Staff Working Document – Evaluation of Regulations 1/2003 and 773/2004 (SWD (2024) 217 final), 5.9.2024.  

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preparing new Guidelines on exclusionary abuses of dominance. The purpose of the exercise is to 
systematise the case-law on exclusionary conduct under Article 102 TFEU with a view to ensuring 
legal certainty and predictability, and providing operational guidance for companies. The Guidelines 
are  also  meant  to  promote  a  workable  effects-based  approach,  in  line  with  economic  thinking  and 
conductive  to  effective  enforcement  of  Article  102  TFEU.  The  Commission  published  the  draft 
Guidelines  on  exclusionary  abuses  of  dominance  for  comments  in  August  20247.  The  European 
Competition Network (ECN) subsequently endorsed the draft Guidelines in a joint statement issued 
in September 20248.  

In January 2024, the Commission launched the evaluation of the Motor Vehicle Block Exemption 
Regulation (MVBER). The purpose of this evaluation is to assess the extent to which the MVBER is 
still fit for purpose. In April 2023, the Commission had prolonged the MVBER for five years until 31 
May 20289. This limited prolongation allowed the Commission more time to assess emerging trends, 
such as those resulting from the expanding use of digital features in new vehicles. The Commission 
also updated the Supplementary Guidelines for the sector10 with the same period of validity.  

The  evaluation  of  the  rules  on  technology  transfer  agreements  was  finalised.  The  Technology 
Transfer  Block  Exemption  Regulation  (TTBER)11  exempts  certain  categories  of  agreements  and 
practices from the application of EU competition rules. The current TTBER will expire on 30 April 
2026 and was subject to evaluation (including the accompanying guidelines)12 to assess how the rules 
have  worked  in  practice,  to  help  decide  whether the  Commission  should  let the  Regulation expire, 
prolong it, or prepare a revised Regulation and related guidelines. In November 2024, the results of 
the  evaluation  were  published13.  The  evaluation  showed  that  the  TTBER  and  the  Guidelines  on 
Technology Transfer Agreements had been largely successful in ensuring the effective, efficient, and 
uniform  application  of  EU  competition  rules  to  technology  transfer  agreements,  and  that  their 
objectives remain relevant. The evaluation also demonstrated that the TTBER and the accompanying 
Guidelines  could  be  improved  and  simplified  to  enhance  legal  certainty  and  reflect  recent  market 
developments.  The  Commission  will  revise  the  Technology  Transfer  framework  to  ensure  that 
companies  have  clear,  simple  and  up-to-date  rules  for  procompetitive  technology  licensing 

7 Communication from the Commission – Guidelines on the application of Article 102 of the Treaty on the Functioning of the European Union to 
abusive exclusionary conduct by dominant undertakings. 
8  Joint  statement  by  the  European  Competition  Network  (ECN)  on  the  European  Commission’s  initiative  to  adopt  Guidelines  on  abusive 
exclusionary conduct by dominant undertakings of 2.9. 2024. 
9  Commission  Regulation  (EU)  No  461/2010  of  27  May  2010  on  the  application  of  Article  101(3)  of  the  Treaty  on  the  Functioning  of  the 
European Union to categories of vertical agreements and concerted practices in the motor vehicle sector, OJ L 129, 28.5.2010, p. 52 as amended 
by Commission Regulation (EU) 2023/822 of 17 April 2023 on amending Regulation (EU) No 461/2010 as regards its period of application, OJ 
L 102I, 17.4.2023, p. 1. 
10  Commission  Notice:  Supplementary  guidelines  on  vertical  restraints  in  agreements  for  the  sale  and  repair  of  motor  vehicles  and  for  the 
distribution of spare parts for motor vehicles, OJ C 138, 28.5.2010, p. 16 as amended by Communication from the Commission Amendments to 
the  Commission  Notice  –  Supplementary  guidelines  on  vertical  restraints  in  agreements  for  the  sale  and  repair  of  motor  vehicles  and  for  the 
distribution of spare parts for motor vehicles 2023/C 133 I/01, OJ C 133I , 17.4.2023, p. 1. 
11 Commission Regulation (EU) No 316/2014 of 21 March 2014 on the application of Article 101(3) TFEU to categories of technology transfer 
agreements, OJ L 93, 28.3.2014, p. 17. 
12  Communication  from  the  Commission  –  Guidelines  on  the  application  of  Article  101  TFEU  to  technology  transfer  agreements,  OJ  C  89, 
28.3.2014, p. 3. 
13  Commission  Staff  Working  Document  –  Evaluation of Commission Regulation  (EU)  No 316/2014 of 21 March 2014 on  the  application  of 
Article 101(3) of the Treaty on the Functioning of the European Union to categories of technology transfer agreements (SWD (2024) 269 final), 
22.11.2024.  

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agreements, thereby facilitating technology dissemination, incentivising initial R&D, and promoting 
innovation. 

In  November  2024,  the  Commission  published an  ex-post  evaluation  study  commissioned  by  DG 
Competition  covering  ‘killer  acquisitions’  in  the  pharmaceutical  sector14. For  the  purposes  of  the 
study,  killer  acquisitions  were  defined  as  the  acquisitions  of  innovative  pharmaceutical  pipeline 
products which have as their object or effect to discontinue one of overlapping R&D projects. There 
is  a  significant  risk  that  such  killer  acquisitions  reduce  innovation  competition  involved  in  the 
transaction  and  ultimately  in  the  entire  market.  The  study  assessed  not  only  M&A  deals,  but  also 
other types of transactions including licensing deals and R&D co-operation agreements15. According 
to the study, between 2014 and 2018, on average 48 transactions per year involved the acquisition of 
narrowly  overlapping  R&D  projects  at  the  level  of  clinical  trials.  In  a  significant  number  of  these, 
one  of  the  R&D  projects  of  the  parties  was  subsequently  abandoned.  Without  access  to  internal 
documents,  the  study  was  not  able  to  identify  specific  examples  of  deals  that  were  confirmed 
(’proven’)  to  be  killer  acquisitions,  but  18  transactions  per  year  were  found  to  ‘deserve  further 
scrutiny’,  meaning  that  there  was  no  clearly  identifiable  technical  or  safety  reason  explaining  the 
discontinuation  in  question.  The  study  assessed  the  Commission’s  past  enforcement  addressing 
potential  killer  acquisitions  and  the  legal  framework  guiding  the  Commission’s  actions  in  this 
respect.  It  found  that  the  Commission  had  correctly  assessed  the  theories  of  harm  in  five  merger 
cases  involving  killer  acquisitions16.  Moreover,  the  study  included  suggestions  for  improving  the 
design of remedies. Finally, the study analysed the suitability of the merger and antitrust tools used to 
deal with killer acquisitions where the Commission does not have jurisdiction17. 

2.2. Evaluating and revising State aid rules and guidance 

In  May  2024,  the  Commission  amended  the  Guidelines  on  Regional  State  aid  (RAG)18.  The 
possibility  for  Member  States  to  grant  aid  under  the  RAG  is  an  important  instrument  to  support 
investments in the less advantaged regions of Europe and to enhance social and economic cohesion. 
The  amendment  to  the  RAG19  enabled  Member  States  to  amend  their  regional  aid  maps  to  grant 
higher  amounts  of  regional  aid  for  investment  projects  covered  by  the  Strategic  Technologies  for 
Europe Platform (STEP)20 by up to 10 percentage points in the regions eligible for aid under Article 
107(3)(a)  TFEU  (so-called  ‘a’  areas),  and  5  percentage  points  in  the  regions  eligible  for  aid  under 
Article  107(3)(c)  TFEU  (so-called  ‘c’  areas).  The  aim  of  STEP  is  to  support  the  development  and 

14  Without  access  to  internal  documents  the  authors  were  unable  to  confirm  (‘prove’)  specific  examples  of  killer  acquisitions,  The order  of 
magnitude of the findings in the study is comparable to what other researchers using different methods and datasets have found.  
15 Buccirossi, P., Marrazzo, A. et al. (2024), Ex-post evaluation: EU competition enforcement and acquisitions of innovative competitors in the 
pharma  sector  leading  to  the  discontinuation  of  overlapping  drug  research  and  development  projects,  Final  report  prepared  by  Lear  for  the 
European Commission, November 2024. See https://competition-policy.ec.europa.eu/publications/ex-post-economic-evaluations_en. For a more 
extensive description of the outcome, see the accompanying Staff Working Document, section 7.4.  
16 The five cases were selected for the purposes of the study and do not indicate the total number of cases involving potential killer acquisitions. 
17 As regards killer acquisitions, please also refer to the summary in section 3.1 below of the Court of Justice judgment in the Illumina/Grail case    
18 Communication from the Commission Guidelines on regional State aid, OJ C 153, 29.4.2021, p. 1. 
19  Communication  from  the  Commission  supplementing  the  Guidelines  on  regional  State  aid  with  regard  to  the  Strategic  Technologies  for 
Europe.  
20 Regulation (EU) 2024/795 of the European Parliament and of the Council establishing the Strategic Technologies for Europe Platform (STEP) 
and  amending  Directive  2003/87/EC  and  Regulations  (EU)  2021/1058,  (EU)  2021/1056,  (EU)  2021/1057,  (EU)  No  1303/2013,  (EU)  No 
223/2014, (EU) 2021/1060, (EU) 2021/523, (EU) 2021/695, (EU) 2021/697 and (EU) 2021/241, 29.2.2024. 

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manufacturing  of  critical  technologies  relevant  to  the  green  and  digital  transitions,  as  well  as  the 
strategic sovereignty of the EU. 

Risk  finance  plays  a  crucial  role  in  funding  the  economy,  especially  for  start-ups,  SMEs  and  mid-
caps. In January 2024, the Commission provided Member States with practical guidance on how to 
assess  the  existence  of  aid  for  risk  finance  measures  when  considering  whether  or  not  public 
measures to facilitate companies’ access to finance constitute State aid21.  

On  1  January  2024,  two  revised  de  minimis  regulations  entered  into  force.  A  third  de  minimis 
regulation was adopted in December 2024.  

The revised general de minimis Regulation22 will apply until 31 December 2030. It exempts small 
aid amounts from EU State aid control because they are deemed to have no effect on trade between 
Member  States  and  not  to  distort  or  threaten  to  distort  competition.  The  exemption  ceiling  was 
increased from EUR 200 000 to EUR 300 000 per company over a period of three years.  Member 
States will be obliged to register de minimis aid in a central register set at national or EU level. This 
obligation will apply as of 1 January 2026.  

The revised Services of General Economic Interest (SGEI) de minimis Regulation23 also entered 
into  force  on  1  January  2024.  The  exemption  ceiling  for  de  minimis  aid  for  SGEIs  was  increased 
from  EUR  500  000  to  EUR  750  000  per  company  over  a  period  of  three  years.  Just  as  under  the 
general de minimis Regulation, Member States will be obliged to register SGEI de minimis aid in a 
central register set at national or EU level. This obligation will apply as of 1 January 2026.  

In  December  2024,  the  Commission  adopted  an  amendment  of  the  Agricultural  de  minimis 
Regulation24.  With  the  amended  rules,  Member  States  can  to  a  larger  extent  support  farmers  in  a 
simple, fast, direct and efficient manner. The main changes introduced with the amendment are: (1) a 
raise  of  the  maximum  de  minimis  ceiling  per  company  over  three  years,  from  EUR 25 000  to 
EUR 50 000, (2) an increase of the ‘national cap’ (maximum amount of cumulative  de minimis aid 
allowed per Member State) from 1.5% to 2% of the value of agricultural output of the Member State 
concerned, (3) the deletion of the ‘sectorial cap’ (upper limit of measures per Member State targeting 
only  one  product market),  (4)  the  introduction  of a  mandatory  central  register  of  de  minimis  aid at 
national  or  European  level  and  (5)  the  extension  of  the  validity  of  the  revised  Regulation  until  31 
December 2032.  

The  raising  of  the  de  minimis  ceiling  and  the  central  register  for  de  minimis  aid  in  the  three 
regulations  significantly  simplify  the  applicable  rules.  The  raised  ceilings  allow  Member  States  to 

21 Practical guidance for Member States: The Market Economy Operator Test for Risk Finance Measures, 26.1.2024. 
22 Commission Regulation (EU) 2023/2831 of 13 December 2023 on the application of Articles 107 and 108 of the Treaty on the Functioning of 
the European Union to de minimis aid, OJ L, 2023/2831, 15.12.2023. 
23 Commission Regulation (EU) 2023/2832 of 13 December 2023 on the application of Articles 107 and 108 of the Treaty on the Functioning of 
the European Union to de minimis aid granted to undertakings providing services of general economic interest, OJ L, 2023/2832, 15.12.2023.  
24 Commission Regulation (EU) No 1408/2013 of 18 December 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning 
of the European Union to de minimis aid in the agriculture sector, OJ L 352 24.12.2013, p. 9. 

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deliver  more  support  faster  and  simpler  and  the  central  registers  reduce  reporting  obligations  for 
stakeholders.    

Moreover, in June 2024, the Commission published for consultation its new draft rules for land and 
multimodal  transport,  the  Land  and  Multimodal  Transport  Guidelines  (LMTG)  and  the 
Transport  Block-Exemption  Regulation  (TBER).  The  TBER  intends  to  exempt  from  prior 
notification certain categories of aid in the rail, inland waterways, and multimodal transport sector. It 
will  complement  the  LMTG,  which  will  replace  the  current  Railway  Guidelines25,  and  set  out  the 
conditions to assess the compatibility with the Single Market of aid to sustainable land transport that 
is not block-exempted. These two sets of rules will form a comprehensive and up-to-date rulebook 
for aid to sustainable land transport. The review process of these two instruments is ongoing. 

2.3. State aid policy as a key to resilience in times of crisis  

The  State  aid  rules  ensure  that  aid  is  targeted  at  market  failures,  avoids  overcompensation,  the 
crowding out of private financing and other types of competition distortion in the Single Market. In 
recent  years,  State  aid  policy  has  helped  the  EU  economy  to  cope  with  successive  crises  and  to 
emerge more resilient from them.  

The Temporary Crisis and Transition Framework to support transition towards a net-zero economy  

In  2024,  the  Commission  continued  to  apply  the  Temporary  Crisis  and  Transition  Framework 
(TCTF)26 to support the EU economy following Russia’s war of aggression against Ukraine and 
to further support sectors key for the transition to a net-zero economy.  

The  possibility  to  accelerate  the  roll-out  of  schemes  for  renewable  energy,  energy  storage  and 
decarbonisation  of  industrial  production  processes  (sections  2.5  and  2.6  TCTF)  and  to  adopt 
measures further accelerating investments supporting transition towards a net-zero economy (section 
2.8)  remain  in  force  until  the  end  of  2025.  The  sections  enabling  Member  States  to  grant  limited 
amounts of aid (section 2.1 TCTF) and aid to compensate for high energy prices (section 2.4 TCTF) 
remained applicable until 30 June 2024. On 2 May 2024, following a consultation of Member States, 
the  Commission  amended  the  TCTF  in  light  of  the  specific  situation  of  undertakings  active  in  the 
primary  production  of  agricultural  products  as  well  as  in  the  fishery  and  aquaculture  sectors.  The 
Commission adopted a limited prolongation of the provisions enabling Member States to continue to 
grant limited amounts of aid (section 2.1 TCTF) until 31 December 2024 for undertakings in those 
sectors27.  

In 2024, the Commission adopted 127 decisions (of which 55 amendment decisions) under the TCTF 
or based on its principles, approving 77 national measures notified by 24 Member States. The overall 

25 Communication from the Commission — Community guidelines on State aid for railway undertakings, OJ C 184, 22.7.2008, p. 13–31. 
26 Communication from the Commission Temporary Crisis and Transition Framework for State Aid measures to support the economy following 
the aggression against Ukraine by Russia, OJ C 101, 17.3.2023, p. 3. 
27  Communication  from  the  Commission  –  Second  amendment  to  the  Temporary  Crisis  and  Transition  Framework  for  State  Aid  measures  to 
support the economy following the aggression against Ukraine by Russia, OJ C, C/2024/3113, 2.5.2024. 

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budget that Member States notified to the Commission under such State aid measures amounted to 
EUR 68.03 billion. 

Implementing the Recovery and Resilience Facility 

Implementation by the Commission of the national recovery and resilience plans adopted under the 
Recovery and Resilience Facility (RRF)28 – the centrepiece of the NextGenerationEU initiative29 – 
continued in 2024. The RRF, next to and on top of cohesion policy,  promotes cohesion among the 
Member  States  by  mitigating  the  social  and  economic  fallout  of  the  COVID-19  pandemic  and  by 
supporting  the  green  and  digital  transitions.  Most  measures  financed  by  the  RRF  do  not  constitute 
State  aid.  Of  those  that  qualify  as  State  aid,  the  majority  could  be  implemented  directly  by  the 
Member  States,  either  under  a  block-exemption  regulation30  or  under  a  de  minimis  regulation31. 
However,  certain  RRF-financed  State  aid  measures  must  be  notified  to  the  Commission  for  prior 
authorisation. During 2024, the Commission adopted at least 40 State aid decisions authorising RRF-
funded  measures.  Some  of  these  decisions  concerned  Important  Projects  of  Common  European 
Interest (IPCEIs), because in certain cases RRF funds were used to co-finance such projects. 

3.  Effective  competition  enforcement  contributed  to  the  EU’s  green  and  digital 
transitions and to the strengthening of the Single Market 

Enforcing  the  competition  rules  contributes  to  the  removal  of  barriers  to  entry  and  barriers  to 
expansion in the Single Market. In a market economy, there is no competitiveness without effective 
competition. By making markets work better and preserving market discipline, competition rules lead 
to  more  innovation,  investment  and  more  diversified  supply  chains.  This  contributes  to  the  digital 
and green transformations, as well as to the economic resilience of the EU economy, and supports the 
EU industrial policy.  

3.1. Keeping markets fair and contestable and strengthening the Single Market 

Antitrust enforcement  

In  antitrust,  the  Commission  continued  in  2024  to  pursue  several  cases  in  digital  markets  against 
large  digital  companies  and  thus  ensuring  that  these  companies  do  not  abuse  their  market  power. 
Digital  markets  have  specific  features  and  pose  concrete  challenges  due  to  the  prevailing  business 
models  and  usual  market  dynamics.  For  instance,  companies  may  acquire  data  or  technology  to 
increase barriers to entry or use rivals’ data for their own benefit (for example platforms with a dual 
function, namely intermediary and also competitor). 

28  See:  https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131  and  https://ec.europa.eu/economy_finance/recovery-and-resilience-
scoreboard/index.html?lang=en. 
29 https://next-generation-eu.europa.eu/index_en  
30 Mainly Commission Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories of aid compatible with the internal market in 
application of Articles 107 and 108 of the Treaty, OJ L 187, 26.6.2014, p. 1, as last amended by Commission Regulation (EU) 2021/1237, OJ L 
270, 29.7.2021, p. 1. 
31 Mainly Commission Regulation (EU) 2023/2831 of 13.12.2023 on the application of Articles 107 and 108 of the Treaty on the Functioning of 
the European Union to de minimis aid, OJ L, 2023/2831, 15.12.2023, p.1. 

8 

 
 
In March 2024, the Commission fined Apple over EUR 1.8 billion for abusing its dominant position 
on the market for the distribution of music streaming apps  used by iPhone and iPad users (together 
iOS  users)  through  its  App  Store32.  In  particular,  the  Commission  found  that  Apple  applied 
restrictions  on  app  developers  preventing  them  from  informing  iOS  users  about  alternative  and 
cheaper music subscription services available outside of the app (anti-steering provisions). 

In  November  2024,  the  Commission  fined  Meta EUR  797.72  million  for  abusing  its  dominant 
position33.  Meta’s  prime  product  is  its  personal  social  network  Facebook.  In  addition,  Facebook 
offers ‘Facebook Marketplace’, an online classified ads service where users can buy and sell goods. 
The Commission concluded that Meta infringed EU antitrust rules by tying Facebook Marketplace to 
its  personal  social  network  Facebook.  Since  all  Facebook  users  have  access  to  and  get  exposed  to 
Facebook  Marketplace  whether  they  want  it  or  not,  this  gives  Facebook  Marketplace  substantial 
advantages which competitors cannot match. Moreover, Facebook unilaterally imposes unfair trading 
conditions  on  other  advertisers  on  Meta’s  platforms,  in  particular  Facebook  and  Instagram.  This 
allows  Meta  to  use  ad-related  data  generated  by  other  advertisers  for  the  sole  benefit  of  Facebook 
Marketplace.  

In June 2024, the Commission informed Microsoft of its preliminary view that the company infringed 
Article  102  TFEU  by  tying  its  communication  and  collaboration  product  Teams  to  its  popular 
productivity applications included in its Office 365 and Microsoft 365 suites for businesses34. 

In addition to investigations  into the market behaviour of  large digital companies, the Commission 
acted against anti-competitive practices in a number of other sectors, for example mobile phones and 
clothing. 

In November 2024, the Commission opened a formal investigation into whether Corning – a major 
producer  of  break-resistant  glass  for  handheld  electronic  devices  -  may  have  abused  its  dominant 
position  in  the  worldwide  market  for  such  devices35. The  Commission  is  investigating  whether 
Corning concluded  anti-competitive exclusive supply agreements with mobile phone manufacturers 
and with companies that process raw glass for this purpose. The Commission  is concerned that the 
agreements  that  Corning  put  in  place  with  mobile  phone  producers  and  raw  glass  processors  may 
have  excluded  rivals  from  large  segments  of  the  market,  thereby  reducing  customer  choice, 
increasing prices, and stifling innovation to the detriment of consumers. 

In  November  2024, the  Commission  fined the  fashion  house  Pierre  Cardin  and  its  largest  licensee 
Ahlers  EUR  5.7  million  for  infringing  EU  competition  law36.  The  Commission  found  that  Pierre 
Cardin  and  Ahlers  had  infringed  Article  101  TFEU  by  restricting  passive  sales  of  Pierre  Cardin-
licensed  products  within  the  EU  and  by  restricting  the  customers  to  whom  such  products  could  be 

32 Case AT.40437 – Apple – App Store Practices (music streaming). 
33 Case AT.40684 – Facebook Marketplace. 
34 Case AT.40721 – Microsoft Teams, and AT.40873 – Microsoft Teams II. 
35 Case AT.40728 – Corning. 
36 Case AT.40642 – Pierre Cardin/Ahlers. 

9 

 
 
sold.  By  preventing  consumers  from  shopping  around  for  a  better  deal  and  from  benefiting  from 
greater choice, Pierre Cardin’s and Ahlers’ behaviour illegally fragmented the Single Market.  

In  2024,  the  Commission  continued  to  investigate  the  food  sector,  which  is  of  key  concern  to  EU 
citizens. The rising price of groceries - accelerated by inflation - is an important contributor to the 
increasing cost-of-living in the EU.  

In May 2024, the Commission imposed a EUR 337.5 million fine on Mondelez for obstructing cross-
border trade of chocolate, biscuits, and coffee products37. Mondelez had concluded 22 agreements in 
breach  of  Article  101 TFEU,  as  well  as  had abused  its  dominant  position  in  breach  of  Article  102 
TFEU.  

In  January  2024,  the  Commission  adopted  a  statement  of  objections  concerning  an  alleged 
Norwegian  salmon  cartel38.  Norway  accounts  for  over  half  of  the  worldwide  production  of  farmed 
Atlantic  salmon  and  EU  companies  are  its  main  customers.  The  Commission  suspects  that 
Norwegian  salmon  producers  may  have  infringed  EU  antitrust  rules  by  colluding  to  distort 
competition in the EU market for spot sales of Norwegian farmed Atlantic salmon.  

Further,  the  Commission  continued  its  efforts  to  keep  pharmaceutical  products  affordable  for 
everyone. By preserving and widening the choice of treatment and by stimulating innovation leading 
to the development of new and better medicines, the Commission’s enforcement of the competition 
rules  benefitted  national  healthcare  systems,  pharmacies,  patients  and  ultimately  consumers  in 
general.  

To  this  end,  in  July  2024,  the  Commission  made  legally  binding  commitments  offered  by  Vifor  to 
address  the  alleged  disparagement  of  its  closest  competing  intravenous  iron  treatment  in  the  EU, 
Pharmacosmos’ medicine Monofer39. Vifor has undertaken to carry out a comprehensive and multi-
channel  communication  campaign  to  rectify  and  undo  the  effects  of  the  potentially  misleading 
messages  previously  disseminated  regarding  the  safety  of  Monofer.  Vifor  also  promised  not  to 
engage  in  external  promotional  and  medical  communications  disparaging  Monofer’s  safety  for  a 
period of 10 years.   

In October 2024, the Commission fined global pharmaceutical company Teva EUR 462.6 million for 
abusing  its  dominant  position  by  delaying  competition  against  Copaxone  (glatiramer  acetate),  the 
company’s  ‘blockbuster’  medicine  for  the  treatment  of  multiple  sclerosis40.  Teva  had  held  a  basic 
patent  for  glatiramer  acetate  until  2015.  The  Commission  found  that  Teva  artificially  extended  the 
patent  protection  of  glatiramer  acetate  by  creating  a  web  of  secondary  patents  regarding  the 
manufacturing  process  and  dosing  regimen  and  subsequently  enforcing  them  against  competitors, 
resulting  in  prolonged  legal  battles  and  hindering  entry  of  competing  medicines.  Moreover,  Teva 

37 Case AT.40632 – Mondelez – Trade restrictions. 
38 Case AT.40606 – Farmed Atlantic Salmon. 
39 Case AT.40577 – Vifor – IV iron products. 
40 Case AT.40588 – TEVA – Copaxone. 

10 

 
 
systematically  spread  misleading  information  about  the  competing  product’s  safety,  efficacy,  and 
therapeutic equivalence with Copaxone, in order to hinder the competing product’s market entry and 
uptake. Teva abused its dominant position in the markets for glatiramer acetate in Belgium, Czechia, 
Germany,  Italy,  the  Netherlands,  Poland,  and  Spain.  The  grave  effects  of  Teva’s  anticompetitive 
behaviour are borne out by the fact that once the rival product entered the market, the list prices for 
glatiramer acetate fell by up to 80%.  

Source: European Commission 

Regulation  No  1/2003  empowers  the  Commission  to  conduct  unannounced  inspections  at  the 
premises  of  companies  suspected  of  infringing  EU  competition  rules.  In  2024,  the  Commission 
carried out unannounced inspections in several sectors, for example tyres (on two occasions)41, data 
centre  construction42  and  financial  services43.  In  June  2024,  the  Commission  fined  International 
Flavors  &  Fragrances  Inc.  and  International  Flavors  &  Fragrances  IFF  France  SAS  EUR  15.9 
million  for  obstructing  a  Commission  investigation  by  deleting  data  on  a  mobile  phone  during  an 
inspection44.  

In 2024, the Court of Justice and the General Court rendered several important judgments relating to 
the  Commission’s  antitrust  enforcement  activities,  confirming  some  of  the  most  consequential 
decisions the Commission adopted in recent years:  

41 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_561 and https://ec.europa.eu/commission/presscorner/detail/en/ip_24_3365  
42 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5926  
43 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_4832 
44 Case AT.40882 – IFF – Deletion of data. 

11 

 
 
 
The General Court largely upheld the fine imposed on Qualcomm by the Commission 
In  2019,  the  Commission  adopted  a  decision  concluding  that  Qualcomm,  a  company  active  in  the 
its  dominant  position  by  supplying  Universal  Mobile 
production  of  chipsets,  had  abused 
Telecommunications  System  (UMTS)  chipsets  to  two  of  its  key  customers,  Huawei  and  ZTE,  below 
cost, with the intention of eliminating its competitor Icera. The Commission defined the relevant market 
as slim and integrated baseband chipsets compliant with the UMTS standard. The Commission found that 
Qualcomm  held  a  worldwide  dominant  position  on  that  market,  at  least  from  1  January  2009  to  31 
December  2011,  and  imposed  a  fine  on  the  company  of  EUR  242  042 000.  In  its  appeal,  Qualcomm 
requested the General Court to annul the Commission’s decision in its entirety or reduce substantially the 
amount  of  the  fine.  In  its  judgment  of  18  September  2024,  the  General  Court  dismissed  Qualcomm’s 
challenge, with the exception of a plea concerning the calculation of the fine. The Court found that the 
Commission  departed,  without  justification,  from  the  methodology  laid  down  in  its  2006  fining 
guidelines. Therefore, the General Court reduced the fine imposed on Qualcomm to EUR 238 732 65945.  

The Court of Justice upheld the Commission’s decision in the Google Shopping case 
In a 2017 decision, the Commission found that Google had given preference, on its general search results 
pages,  to  the  results  of  its  own  comparison-shopping  service  over  those  of  competing  comparison- 
shopping services. Google promoted its own results in a primary position in ‘boxes’ with accompanying 
image and text information. By contrast, the search results for competing comparison-shopping services 
appeared  as  simple  generic  results  displayed  as  blue  links.  Google  engaged  in  this  behaviour  in  13 
countries  in  the  European  Economic  Area.  The  Commission  concluded  that  Google  had  abused  its 
dominant position by engaging in exclusionary behaviour on the markets for online general searches and 
for  specialised  product  searches  and  imposed  a  fine  of  EUR  2  424  495 000.  Google  and  its  parent 
company  Alphabet  appealed  the  Commission’s  decision  before  the  General  Court.  In  a  judgment  of 
November  2021,  the  General  Court  largely  dismissed  the  challenge  and  upheld  the  fine.  Following 
Google’s  and  Alphabet’s  appeal  of  that  judgment,  the  Court  of  Justice  also  upheld  the  Commission’s 
decision46.  The  Court  of  Justice  stated  that,  in  principle,  the  fact  that  a  dominant  firm  treats  its  own 
products or services more favourably than it treats those of its competitors cannot be regarded as in itself 
abusive. However, the Court of Justice found that, in the light of the characteristics of the market and the 
specific  circumstances  of  the  case,  Google’s  conduct  was  discriminatory  and  did  not  constitute 
competition on the merits. The Court of Justice upheld the fine imposed by the Commission.  

The General Court annulled the Commission’s decision in Google AdSense 
On 18 September 2024, the General Court annulled the Commission’s decision in Google AdSense47. The 
Commission  found  in  its  decision  that  Google  had  abused  its  dominant  position  through  the  use  of  an 
exclusivity clause, a placement clause, and a prior authorisation clause in the services agreement which 
Google used for its advertising platform AdSense, in order to restrict or prohibit the display of ads from 
competing services. Google subsequently removed or amended the clauses in question. While the General 
Court upheld the majority of the Commission’s findings, it annulled the Commission’s decision to impose 
on Google a fine of almost EUR 1.5 billion because the Commission had failed to take into consideration 
all the relevant circumstances when  assessing the scope and duration of the three clauses. Accordingly, 

45 Judgment of the General Court of 18.9.2024 in case T-671/19, Qualcomm v Commission.  
46  Judgment  of  the  Court  of  Justice  of  10.9.2024  in  case  C-48/22 P,  Google  and  Alphabet  v  Commission  (Google  Shopping), 
ECLI:EU:C:2024:726.   
47  Judgment  of  the  General  Court  of  18.9.2024  in  case  T-334/19,  Google  and  Alphabet  v  Commission  (Google  AdSense  for  Search), 
ECLI:EU:T:2024:634. 

12 

 
 
 
 
the  General  Court concluded  that  the  Commission  had  failed to establish  that  each  clause  constituted  a 
self-standing  abuse  of  a  dominant  position,  and  that  they  together  constituted  a  single  and  continuous 
infringement of Article 102 TFEU. 

Merger control 

In  2024,  the  Commission  continued  to  enforce  merger  control  rules  to  protect  businesses  and 
consumers  from  price  increases,  but  also  from  a  deterioration  of  other  important  parameters  of 
competition  such  as  quality,  choice,  and  innovation  in  many  important  areas  of  the  EU  economy. 
Merger control prevents the creation of excessive market power, foreclosures, and the elimination of 
market entrants, thereby supporting the Commission’s priorities.  

In  2024,  the  Commission’s  merger  control  activities  remained  at  a  high  level.  The  Commission 
adopted 398 merger decisions in various sectors, as compared to 333 in 2023. The vast majority of 
concentrations  (351)  were  approved  by  simplified  procedure.  The  Commission  intervened48  in  10 
proposed acquisitions, of which 8 were approved subject to conditions. There was no prohibition in 
2024, but two notified mergers were abandoned by the parties and withdrawn in Phase II49. The cases 
resulting in a clearance decision subject to commitments are summarised below, beginning with the 
three cases concluded after in-depth investigations. 

In  February  2024,  the  Commission  approved  the  proposed  acquisition  by  Korean  Air  of  Asiana 
Airlines,  subject  to  conditions50.  The  Commission  was  concerned  that  the  transaction  would  harm 
competition  in  the  markets  for  air  cargo  transport  services  between  the  EU  and  South  Korea,  and 
passenger air transport service on four routes between Seoul and certain EU destinations. To address 
the Commission’s competitive concerns, Korean Air offered to divest Asiana’s global cargo freighter 
business, and to make available to rival airline T'Way the necessary assets to enable it to start flight 
operations on the four overlapping routes. 

In  July  2024,  the  Commission  authorised  the  proposed  acquisition  of  joint  control  of  ITA  by 
Lufthansa  and  the  Italian  Ministry  of  Economy  and  Finance  (MEF),  subject  to  conditions51.  To 
address  the  Commission’s  competitive  concerns,  Lufthansa  and  the  MEF  proposed  (i)  to  make 
available  to  one  or  two  rival  airlines  the  necessary  assets  to  enable  them  to  start  non-stop  flights 
between Rome or Milan and certain airports in Central Europe, as well as ensure that one of these 
airlines  will  have  access  to  ITA’s  domestic  network  to  offer  indirect  connections  between  certain 
airports  in  Central  Europe  and  certain  Italian  cities  other  than  Rome  and  Milan,  (ii)  to  enter  into 
agreements  with  rivals  to  improve  their  competitiveness  on  the  long-haul  routes  of  concern,  for 
instance through interlining agreements or slot swaps, and (iii) to transfer take-off and landing slots 
at Linate airport (Milan) to the remedy takers for short-haul routes connecting Italy with countries in 
central Europe. 

48 Interventions in merger cases include prohibition decisions, mergers cleared subject to remedies as well as withdrawals in Phase II. 
49 Case M.10920 – Amazon/iRobot and Case M.11109 – IAG/AIR EUROPA. 
50 Case M.10149 – Korean Airlines/Asiana Airlines. 
51 Case M.11071 – Deutsche Lufthansa/MEF/ITA. 

13 

 
 
 
In  February  2024,  the  Commission  approved  the  proposed  creation  of  a  joint  venture  in  Spain 
between  Orange  and  MásMóvil,  subject  to  conditions52.  The  companies  offered  to  divest  mobile 
spectrum held by MásMóvil to competitor Digi across three frequency spectrum bands (two medium 
frequency bands and one high frequency band). This will help Digi build its own network and ensure 
strong  competitive  constraints  on  the  joint  venture.  Additionally,  the  companies  will  enter  into  an 
optional national roaming agreement. Digi can then decide whether or not the company wishes to use 
the optional roaming agreement. 

Source: European Commission 

Five cases were concluded after an initial investigation in which the Commission made its clearance 
decision  conditional  on  commitments  by  the  notifying  parties.  In  February  2024,  the  Commission 
conditionally  approved  the  proposed  acquisition  of  Bolloré  Logistics  by  CMA  CGM53.  Both 
companies play substantial roles within the global logistics and transport sectors. The parties offered 
to  divest  all  of  Bolloré  Logistics'  activities  in  Guadeloupe,  Martinique,  Saint  Martin,  and  French 
Guiana, as well as a number of assets in metropolitan France linked to the divested activities. These 
remedies were designed to address competition concerns primarily related to the logistics market in 
the French overseas territories and metropolitan France. 

In June 2024, after a Phase I investigation, the Commission approved the proposed acquisition of the 
European pharmaceutical over-the-counter business of Viatris by Cooper54, subject to conditions. To 
address the Commission's competition concerns, the parties committed to divest the rights, title, and 
interests  in  the  infant  laxative  medicine  Bebegel,  as  well  as  those  relating  to  the  earwax  removal 
product  Otowaxol.  The  Commission  concluded  that  the  divestments  fully  address  the  competition 
concerns by creating opportunities for new competitors to enter and expand as viable competitors in 
the markets for these products. 

52 Case M.10896 – Orange/MásMóvil/JV. 
53 Case M.11143 – Bolloré Logistics/CMA CGM. 
54 Case M.11383 – Viatris/Cooper. 

14 

 
 
 
In August 2024, the Commission conditionally approved  Bunge’s acquisition of  Viterra55. The two 
companies  are  global  agribusinesses  active  across  the  agricultural  value  chain,  from  the  upstream 
origination  of  crops  to  the  downstream  supply  of  food,  feed  and  fuel  products.  The  Commission’s 
investigation showed that Bunge and Viterra exert significant market power on upstream farmers as 
well as on customers throughout the value chains of rapeseed and sunflower seeds in Central Europe. 
The Commission’s clearance is conditional upon the divestment of Viterra’s origination, processing 
and refining assets and personnel in Hungary and Poland. 

In October 2024, the Commission conditionally approved  the acquisition of Courir by JD Sports56. 
Both  companies  are  multi-brand  sports  goods  retailers,  more  specifically  retailers  of  leisure  sports 
footwear and apparel in several EEA countries. The Commission found that the merger would give 
rise to high combined market shares in several local markets in France and Portugal, leading to less 
competition, higher prices and less choice for consumers in these local markets. The Commission’s 
clearance was conditional upon the divestment of all Courir stores in Portugal and several stores in 
certain local markets in France to Snipes, a direct competitor of the parties. 

In  October  2024,  the  Commission  approved  the  acquisition  of  EQOS  by  Eiffage,  subject  to 
conditions.57 EQOS and Eiffage, respectively headquartered in Germany and France, are active in the 
installation and maintenance of catenaries and overhead contact lines for long distance railway lines, 
including  in  Belgium.  The  Commission  found  that  the  merger  would  lead  to  higher  prices,  lower 
quality  and  less  innovation,  to  the  detriment  of  the  railway  infrastructure  management  in  Belgium 
and  ultimately  of  consumers.  The  decision  is  conditional  upon  the  divestment  of  EQOS  Belgium. 
This  will  enable  an  independent  player  to  act  as  a  new  competitive  constraint  on  the  market. In 
December 2024, the Commission approved Stadsbader, a Belgian company active in the railway 
infrastructure sector, as the purchaser of EQOS Belgium.  

The General Court upheld the Commission decision authorising Vodafone’s acquisition of Liberty 
Global’s telecommunications activities in Germany, the Czech Republic, Hungary, and Romania 
In  July  2019,  the  Commission  approved  Vodafone’s  acquisition  of  Liberty  Global,  subject  to 
commitments. In Germany, the transaction consisted of the acquisition of  sole control  of Unitymedia, a 
company  providing  television  and  broadband  internet  services.  Three  German  companies  -  Deutsche 
Telekom,  Tele  Columbus  and  NetCologne  -  appealed  the  Commission  decision.  The  General  Court 
dismissed the appeal. In its decision, the Commission had found that prior to the transaction, the merging 
firms  were  neither  actual,  nor  potential  competitors  in  the  markets  for  the  retail  supply  of  TV  signal 
transmission  services  in  Germany.  The  General  Court  confirmed  that  finding  and,  accordingly,  the 
Commission could legitimately find that there was no significant impediment to effective competition as a 
result of the concentration. 

The Court of Justice annulled the Commission’s jurisdiction decisions in lllumina/GRAIL  

55 Case M.11204, Bunge/Viterra. 
56 Case M.11159, JD Sports / Groupe Courir. 
57 Case M.11577, Eiffage/Eqos. 

15 

 
 
 
By setting aside the judgment of the General Court, the Court of Justice annulled – in its judgment of 3 
September 202458 - the Commission's decisions59 to examine the acquisition of GRAIL by Illumina under 
Article 22(3) of the EU Merger Regulation (EUMR)60. In view of the principle of good administration, 
the Commission subsequently withdrew all decisions adopted under the premise that it had jurisdiction to 
scrutinise the Illumina/GRAIL merger.61 In September 2022, the Commission had blocked the proposed 
transaction  over  concerns  that  it  would  have  significant  anticompetitive  effects,  stifling  innovation  and 
reducing choice in the market for blood-based early cancer detection tests. 
The  Court  of  Justice  held  that  ‘The  Commission  is  not  authorised  to  encourage  or  accept  referrals  of 
proposed  concentrations  without  a  European  dimension  from  national  competition  authorities  where 
those authorities are not competent to examine those proposed concentrations under their own national 
law.’  
In  line  with  the  judgment,  the  Commission  withdrew  its  2021  guidance  on  Article  22  of  the  EUMR, 
which encouraged Member States to refer certain types of cases even if they did not meet the turnover 
thresholds  for  EU  merger  control.    Moreover,  the  Commission  stated  that  it  would  continue  to  accept 
referrals made under Article 22 Merger Regulation by Member States only where they are competent to 
review  a  concentration  under  their  national  rules  or  do  not  have  a  merger  control  regime  at  all.  The 
Commission also stated that it would consider further steps to ensure that it is able to review cases where 
a proposed merger could have a negative impact on competition in the EU but does not otherwise meet 
the EUMR notification thresholds62. 

State aid control  

Investments in digital infrastructure, technologies and services are key drivers of economic growth, 
not only in the digital sector but in the  whole economy. Such investments are necessary to achieve 
the  policy  objectives  set  out  in  the  Digital  Decade  Policy  Programme63.  State  support  for  risky 
investments  in  the  digital  sphere  can  be  necessary  to  address  market  failures  (that  is  to  say  when 
relying on private initiatives only would result in investment levels that are too low from  a societal 
point of view). 

In April 2024, Slovakia’s plans to compensate digital terrestrial television (DTT) network operator 
Towercom  for  its  direct  costs  incurred  for  the  release  of  the  700  MHz  band  were  approved  by  the 
Commission64. Towercom will receive a compensation of EUR 11.7 million. This follows a Decision 
of the European Parliament and the Council pursuing the release of the 700 MHz band in favour of 

58  Judgment  of  the  Court  of  Justice  of  3.9.2024  in  joined  cases  C-611/22  P  and  C-625/22,  Illumina  and  Grail  v  Commission, 
ECLI:EU:C:2024:677.  
59 In March 2021, the French Competition Authority sought to refer to the Commission Illumina’s proposed acquisition of GRAIL under Article 
22 Merger Regulation. On 19 April 2022, the Commission accepted the Article 22 referral. The referral request was subsequently joined by the 
national competition authorities in the Netherlands, Belgium, Greece, Iceland, and Norway.  
60 Case M.10188 – Illumina/GRAIL. 
61 Namely: (i) the decision adopted on 22.7.2021 opening a phase II investigation into the proposed acquisition of GRAIL by Illumina (M.10188), 
(ii)  the  decision  adopted  on  6.9.2022  prohibiting  the  acquisition  of  GRAIL  by  Illumina  (M.10188),  (iii)  two  decisions  concerning  interim 
measures adopted on 29.10.2021 (M.10493) and on 28.10.2022 (M.10938), (iv) the decision adopted on 12.10.2023 ordering restorative measures 
requiring  Illumina to  unwind  its acquisition of  GRAIL  (M.10939),  and  (v)  the  decision  adopted  on 12.7.2023  fining  Illumina  and  GRAIL  for 
implementing their merger before approval by the Commission (M.10483).  
62 Statement by Executive Vice-President Vestager of 3.9.2024. https://ec.europa.eu/commission/presscorner/detail/en/statement_24_4525. 
63  Decision  (EU)  2022/2481  of  the  European  Parliament  and  of  the  Council  of  14  December  2022  establishing  the  Digital  Decade  Policy 
Programme 2030. 
64 Case SA.55953 – Slovakia – Compensation to Towercom for the costs resulting from the release of the 700 MHz band. 

16 

 
 
mobile  communications  by  June  202065  and  allowing  adequate  compensation  of  DTT  operators  in 
accordance with State aid rules. 

In  May  2024,  the  Commission  approved  a  EUR  2  billion  Italian  State  aid  measure  to  support 
STMicroelectronics in the construction and operation of an integrated chip manufacturing plant for 
silicon carbide power devices in Catania, Sicily66. The project builds on technologies that have been 
and  will  be  developed  as  part  of  Important  Projects  of  Common  European  Interest  (IPCEIs)  for 
research  and  innovation  in  microelectronics67.  The  measure  will  strengthen  the  EU's  security  of 
supply, resilience, and digital sovereignty in semiconductor technologies, in line with the objectives 
set out in the European Chips Act Communication68. 

In  some  instances,  the  Commission  concluded  that  the  support  measures  were  not  in  line  with  EU 
State aid rules.  

For instance, in 2024, the Commission assessed the restructuring plan implemented by Romania for 
Blue  Air.  The  Romanian  airline  Blue  Air  had  been  in  financial  difficulty  since  2019.  In  2020, 
Romania  granted  a  public  guarantee  to  compensate  the  airline  for  damage  directly  caused  by  the 
coronavirus and a public guarantee on a rescue loan. Public support for companies in difficulty must 
be backed up by viable plans to ensure long-term viability of the aid recipient. In February 2024, the 
Commission concluded that the restructuring plan implemented for Blue Air were not in line with EU 
State aid rules69. 

In June 2024, the Commission concluded that  Hungary’s plan to support the construction of a new 
automotive  components  plant  in  Észak  Magyarország  was  not  in  line  with  EU  State  aid  rules70. 
Regional aid must incentivise a company to carry out an additional activity in a disadvantaged area 
and this requirement was not fulfilled in this case. The Commission concluded that Hungary failed to 
prove that the aid was decisive for the beneficiary to locate its investment in Hungary.  

In April 2024, the Commission concluded that Czechia's investment support granted to certain large 
Czech agricultural companies in 2017 and 2018  was not in line with EU State aid rules71. Czechia 
must  recover  the  incompatible  State  aid.  The  aid  was  based  on  the  former  Agricultural  Block 
Exemption  Regulation,72  under  which  the  aid  can  only  be  granted  to  SMEs.  The  Czech authorities 
erroneously qualified some of the beneficiaries as SMEs, while they were in fact large enterprises. 

65 Decision (EU) 2017/899 of the European Parliament and of the Council of 17 May 2017 on the use of the 470-790 MHz frequency band in the 
Union, L 138/131. 
66 Case SA.107594 – Italy – Catania Campus – STMicroelectronics S.r.l. 
67 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_18_6862, and https://ec.europa.eu/commission/presscorner/detail/en/IP_23_3087  
68 Regulation (EU) 2023/1781 of the European Parliament and of the Council of 13 September 2023 establishing a framework of measures for 
strengthening Europe’s semiconductor ecosystem and amending Regulation (EU) 2021/694 (Chips Act), OJ L 229, 18.9.2023, p. 1. 
69 Case SA.62829 – Romania – Blue Air.  
70 Case SA.63470 – Hungary – LIP – Regional investment aid to Rubin NewCo 2021 Kft. 
71 Cases SA.50787 and SA.50837 – Czechia – Aid for restructuring of orchards and aid for the construction of drip irrigation in orchards, hop 
fields, vineyards and nurseries. 
72 Commission Regulation (EU) No 702/2014 of 25 June 2014 declaring certain categories of aid in the agricultural and forestry sectors and in 
rural areas compatible with the internal market in application of Articles 107 and 108 of the Treaty on the Functioning of the European Union, OJ 
L 193, 1.7.2014, p. 1–75. 

17 

 
 
One of the principal drivers of competitiveness is innovation. State aid rules allow Member States to 
support  the  development  of  state-of-the-art  technologies  with  public  funding.  IPCEIs  serve  this 
purpose. They enable Member States to pool State resources in strategic sectors and technologies of 
common EU interest, especially in sectors where markets alone do not deliver the desired outcome. 

The  Commission  closely  cooperated  with  Member  States  in  the  Joint  European  Forum  for  IPCEIs 
(JEF-IPCEI), to improve and speed up the design and assessment process of new IPCEIs73.   

IPCEIs in health and pharmaceuticals 
In  May  2024,  the  Commission  approved  the  first  IPCEI  to  support  research,  innovation  and  the  first 
industrial  deployment  of  healthcare  products,  as  well  as  innovative  production  processes  of 
pharmaceuticals  (IPCEI  Med4Cure)74.  This  IPCEI  will  contribute  to  the  European  Health  Union's 
objectives by addressing diseases for which there are no satisfactory means of prevention or treatment. It 
will also increase the EU's preparedness for emerging health threats. The project was jointly notified by 
six  Member  States.  The  Member  States  will  provide  up  to  EUR  1  billion  in  public  funding,  which  is 
expected to unlock additional EUR 5.9 billion in private investments. Thirteen companies, including nine 
SMEs, will carry out projects as part of the IPCEI Med4Cure.  

Source: European Commission 

3.2 Supporting the green transition  

Competition policy contributes to the EU’s environmental objectives and climate targets, for example 
the decarbonisation of the EU economy and the shift from fossil fuels to alternative fuels in transport. 

73 See: https://competition-policy.ec.europa.eu/state-aid/ipcei/joint-european-forum-ipcei_en  
74 Cases SA.105088 – Belgium; SA.104974 – France; SA.105126 – Hungary; SA.105085 – Italy; SA.105097 – Slovakia; SA.105098 – Spain, 
RRF – Important Project of Common European Interest on health (IPCEI-Med4Cure). 

18 

 
 
 
 
Competition law enforcement contributes to the European Green Deal75 by keeping markets efficient, 
fair, and innovative.  

Antitrust enforcement  

In  2024,  the  Commission  continued  to  fight  anticompetitive  market  behaviour  hindering  the  green 
transition.  A  shift  from  road  transport  to  environment-friendlier  modes  of  transport  is  crucial.  Rail 
transport in particular reduces the carbon footprint. This shift  cannot be achieved without effective 
competitive, and attractive rail transport services.  

In  October  2024,  the  Czech  and  Austrian  rail  incumbents  -  České  dráhy  (ČD)  and  Österreichische 
Bundesbahnen (ÖBB) - were fined EUR 48.7 million for infringing EU competition rules76. ČD and 
ÖBB  provide  rail  passenger  transport  services  in  Czechia  and  Austria.  ČD  and  ÖBB  colluded  to 
prevent a new entrant, RegioJet, from acquiring used wagons from ÖBB, on which RegioJet largely 
relied  to  compete.  In  order  to  exclude  RegioJet  from  the  market,  ČD  and  ÖBB  exchanged 
confidential  information  about  sales  procedures,  bids  and  the  degree  of  interest  of  other  bidders, 
thereby rigging the sales of rolling stock so that ČD could buy the used wagons instead of RegioJet. 

In January 2024, the Commission made legally binding commitments by Renfe, thereby opening up 
competition  in  online  rail  ticketing  in  Spain77.  The  Commission  concluded  that  the  commitments 
offered  by  Renfe  addressed  its  preliminary  concerns  that  Renfe  may  have  infringed  Article  102 
TFEU by refusing to supply all its content and real-time data (RTD) to third-party ticketing platforms 
(TPTPs). Renfe’s commitments open up competition in online rail ticketing in Spain, contributing to 
more affordable rail services and promoting environmentally friendly means of transport.   

Merger control  

In  2024,  the  Commission  investigated  and  examined  multiple  mergers  and  acquisitions  relating  to 
green technologies and sustainability efforts, in sectors such as renewable energy78, electric vehicle 
charging stations79 and biofuels80.  

In August 2024, the Commission approved the creation of two joint ventures by three French-based 
companies, Eramet, Suez RV France and TFIN81. The three parent companies are active respectively 
in the extraction and recovery of metals, in water and waste management services, and in closed-loop 
recycling solutions at each stage of a vehicle’s life. The transaction mainly  concerned the recycling 
of lithium-ion batteries from electric vehicles and residues from their production.  

75  Communication  from  the  Commission  to  the  European  Parliament,  the  European  Council,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions, the European Green Deal, COM(2019) 640 final. 
76 Case AT.40401 – Second-hand Rolling Stock. 
77 Case AT.40735 – Renfe – Online rail ticket distribution in Spain. 
78 Case M.11632 – Alten/Worldgrid. 
79 Case M.11745 – Die Schweizerische Post/Fenaco/PowerUp JV. 
80 Case M.11639 – Enilive/LG Chem/JV. 
81 Case M.11371 – Eramet/Suez RV/TFIN/JV. 

19 

 
 
In  October  2024,  the  Commission  unconditionally  approved  the  proposed  acquisition  of  Terna,  a 
Greek  renewable  energy  company  listed  on  the  Athens  Stock  Exchange,  by  Masdar  of  the  United 
Arab  Emirates  (UAE)82.  Masdar  is  a  renewable  energy  and  sustainability  company  that  advances 
solutions in energy, water, urban development, and clean technologies around the world. 

State aid control  

Considerable  funds  will  need  to  be  mobilised  to  support  the  greening  of  the  EU  economy,  mainly 
from  private  sources,  but,  where  necessary,  incentivised  and/or  complemented  by  public  funds. 
Existing  state  aid  control  rules  offer  multiple  possibilities  for  Member  States  to  finance  initiatives 
that contribute to the decarbonisation and greening of the economy. 

In 2024, the Commission approved 51 State aid measures83 aimed at accelerating the green transition 
across  various  sectors.  These  measures  include  substantial  support  for  renewable  energy  projects, 
industrial  decarbonization  efforts,  and  clean  mobility  initiatives.  For  example,  approved  State  aid 
measures have supported the expansion of renewable energy sources such as wind and solar power, 
the adoption of low-carbon technologies in industrial production, and the development of sustainable 
transport  solutions,  including  electric  vehicle  infrastructure  and  hydrogen-powered  mobility.  These 
initiatives  not  only  contribute  to  climate  neutrality  but  also  promote  economic  resilience  and 
competitiveness within the EU. 

In  November  2024,  the  Commission  decided  that  a  German  EUR  1.9  billion  State  aid  measure 
supporting DB Cargo84 was in line with EU State aid rules as assessed under the EU Guidelines on 
rescue  and  restructuring  aid85.  DB  Cargo is  the  biggest  EU  rail  freight  operator  by  size  and 
turnover and a fully owned subsidiary of State-owned Deutsche Bahn (DB). In the assessment of the 
compatibility  of  the  aid,  the  Commission  took  into  account  the  paramount  importance  of  rail 
freight as a sustainable lower-emissions alternative to road transport and its role as indispensable 
solution to the ecological transformation of logistics circuits.  

IPCEIs  may  be  designed  to  stimulate  innovation  in  clean  technologies  and  increase  energy  and 
resource efficiency. To this end, the IPCEI Hy2Infra was approved by the Commission. 

IPCEI in hydrogen infrastructure  
In  February  2024,  the  Commission  approved  an  IPCEI  which  supports  hydrogen  infrastructure  (IPCEI 
Hy2Infra)86.  Seven  Member  States  will  provide  up  to  EUR  6.9  billion  in  public  funding,  which  is 
expected  to  unlock  EUR  5.4  billion  in  private  investments.  As  part  of  this  IPCEI,  32  companies  with 
activities  in  one  or  more  Member  States,  including  SMEs,  will  participate  in  33  projects.  The  IPCEI 

82 Case M.11634 – Masdar/Terna. 
83 This number does not include aid granted under the GBER. 
84 Case SA.50952 – Germany – Alleged State aid measures in favour of DB Cargo. 
85 Communication from the Commission – Guidelines on State aid for rescuing and restructuring non-financial undertakings in difficulty,  
OJ C 249, 31.7.2014, p. 1–28. 
86 Cases SA.102821 – France; SA.102825 – Germany; SA.102815 – Italy; SA.102807 – The Netherlands; SA.102810 – Poland; SA.103494 – 
Portugal; SA.102811 – Slovakia, RRF – Important Project of Common European Interest on Hydrogen Infrastructure (IPCEI Hy2Infra). 

20 

 
 
Hy2Infra will boost the supply of renewable hydrogen, reducing dependency on natural gas. Doing so, the 
IPCEI will help to achieve the objectives of the European Green Deal as well as the REPowerEU Plan. 

Source: European Commission  

IPCEIs in the hydrogen value chain  
In May 2024, the Commission approved an IPCEI to support research, innovation and the first industrial 
deployment  in  the  hydrogen  value  chain  (IPCEI  Hy2Move)87.  Seven  Member  States  will  provide  up  to 
EUR  1.4  billion  in  public  funding,  which  is  expected  to  unlock  additional  EUR  3.3  billion  in  private 
investments. As part of this IPCEI, 11 companies with activities in one or more Member States, including 
SMEs and start-ups, will carry out 13 projects. The project contributes to the EU's target of 90% reduction 
of emissions from the mobility and transport sectors, to allow the EU to become climate-neutral by 2050. 

87 Cases SA.104442 – Estonia; SA.104668  – France; SA.104676 – Germany; SA.104453 – Italy; SA.104440 – The Netherlands; SA.104434 – 
Slovakia; SA.104435 – Spain, RRF – Important Project of Common European Interest on Hydrogen on Mobility & Transport (IPCEI Hy2Move). 

21 

 
 
 
 
 
 
Source: European Commission 

In February 2024, a EUR 1.3 billion German State aid measure88 was approved by the Commission 
under  the  Guidelines  on  State  aid  for  climate,  environmental  protection,  and  energy  (CEEAG)89. 
Partially financed via the RRF, it supports ArcelorMittal in decarbonising part of its steel production 
processes. The State aid scheme contributes to the targets set up in the EU Hydrogen Strategy, the 
European  Green  Deal,  and  the  Green  Deal  Industrial  Plan.  Moreover,  the  measure  reduces 
dependence  on  Russian  fossil  fuels  and  will  fast-forward  the  green  transition,  in  line  with  the 
REPowerEU Plan. 

Also,  under  the  CEEAG,  in  June  2024  the  Commission  approved  a  EUR  265  million  Swedish 
measure  partially  financed  through  the  RRF.  The  measure  will  support  H2GS  AB  in  setting  up  a 
large-scale green steel plant90. In addition, in October 2024, the Commission approved a  EUR 128 
million  Swedish  measure  to  support  SSAB  in  decarbonising  its  steel  production.  The  measure  is 
designed to accelerate the SSAB’s transition to electrified steelmaking at its steel plants in Sweden 
and contribute  to  the  greening  of  the  steel  value  chain91.  This  State aid  measure  is in line  with the 
EU’s target of climate neutrality by 2050.  

In  April  2024,  under  the  RAG,  the  Commission  approved  a  Slovak  State  aid  measure  that  will 
contribute  to  job  creation,  regional  development,  and  the  European  Green  Deal.  The  State  aid 
amounted to EUR 267 million92. The investment aid will support the establishment of a new electric 
passenger vehicles production plant in Valaliky, Eastern Slovakia.  

88 Case SA.104898 – Germany – RRF – ArcelorMittal (Bremen & Eisenhuttenstadt). 
89 Communication from the Commission – Guidelines on State aid for climate, environmental protection and energy 2022 (OJ C 80, 18.2.2022, 
pp. 1–89). 
90 Case SA.110031 – Sweden – Sweden setting up a large-scale green steel plant. 
91 Case SA.109640 – Sweden – Support to SSAB Luleå for the transition to carbon-neutral production of slabs. 
92 Case SA.103740 – Slovakia – Regional investment aid to Volvo Car Slovakia s. r. o. 

22 

 
 
 
The  Commission  approved,  under  the  State  aid  framework  for  research  and  development  and 
innovation93,  in  April  2024  a  French  State  aid  measure  with  a  budget  of  EUR  300  million94.  It 
supports  Electricité  de  France  subsidiary  Nuward  in  researching  and  developing  small  modular 
nuclear reactors.  

In  July  2024,  the  Commission  approved  a  French  State  aid  scheme  under  the  TCTF,  which  will 
support for 20 years the deployment of offshore wind energy, contributing to the transition towards a 
net-zero economy. The budget of the scheme is EUR 10.82 billion95. 

In 2024 the Commission approved under the TCTF EUR 902 million in investment aid to Northvolt, 
for the construction of an electric vehicle battery plant96. Without the aid, the company would have 
invested in the United States and not in the EU. 

In  May  2024,  a  EUR  3.2  billion  Czech  scheme  was  approved  by  the  Commission  under  the 
CEEAG97,  which  will  support  the  electricity  generation  from  new  and  modernised  high-efficiency 
combined  heat  and  power  plants.  The  scheme  will  contribute  to  the  implementation  of  Czechia's 
National Energy and Climate Plan, the European Green Deal and EU's energy efficiency targets. 

3.3. Supporting an economy that works for people 

Financial services sector  

In  2022,  the  Commission  had  provisionally  found  that  Apple  restricted  competition  by  abusing  its 
dominant position in the market for mobile wallets98 used on iOS devices by limiting access to such 
functionality  on  iPhones  for  in-store  payments  (‘tap  and  go’),  thereby  reserving  access  to  Apple 
Pay99.  In  July  2024,  the  Commission  found  that  the  commitments  offered  by  Apple  addressed  its 
preliminary concerns and made them legally binding. Apple committed to allow rivals to access the 
‘tap and go’ technology of iPhones (or Near Field Communication)100, allowing iPhone users to have 
a wider range of safe and innovative mobile wallets to choose from101. 

93 Communication from the Commission - Framework for State aid for research and development and innovation (OJ C 414, 28.10.2022, pp. 1–
38). 
94 Case SA.106964 – France – Soutien à la phase APD du projet Nuward. 
95 Case SA.109161 – France – TCTF FR Régime de soutien à Deux parcs éoliens en mer posés, l'un en Sud Atlantique et l'autre au large de la 
Normandie dans la zone Centre Manche 2. 
96 Case SA.107936 Germany– TCTF – Aid to Northvolt Germany GmbH. 
97 Case SA.108368 – Czechia – Support for electricity from high-efficiency combined heat and power generation. 
98 A mobile wallet is a digital way to store credit, debit, ID, and gift cards so that purchases can be made using a mobile smart device rather than a 
physical card. 
99 Case AT.40452 – Apple - Mobile Payments.  
100  Near-field  communication  (NFC)  is a  set  of  communication  protocols that  enables  communication  between  two  electronic  devices  over  a 
distance of 4 cm. 
101 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_3706  

23 

 
 
Source: European Commission 

In 2024, the Commission examined several mergers in the financial services sector. For example, 
in  March  2024,  the  Commission  approved  the  creation  of  a  joint  venture  by  Worldline  and  Crédit 
Agricole,  both  based  in  France102.  The  joint  venture  is  targeting  the  market  for  the  provision  of 
acquiring  and acceptance services103  to  French  and  foreign  merchants  in  France.  In  June  2024,  the 
Commission approved the acquisition of sole control of  Alpha Bank Romania by UniCredit104. The 
transaction related to various banking and financial services in Romania, such as retail and corporate 
banking, and financial market services. 

In 2024, the Commission authorised the prolongations and reintroductions of certain existing State 
aid schemes enabling Member States to provide aid for the restructuring of or orderly market 
exit of financial firms in distress. For example, in September 2024, the Commission authorised the 
reintroduction  of  a  Polish  scheme  for  the  liquidation  of  credit  unions,  in  place  since  2014105. 
Moreover,  in  April  and  December  2024,  the  Commission  approved  a  Cypriot  reintroduction  and 
amendment  of  the  scheme  for  the  management  of  loans  granted  under  Government  Housing  Plans 
(OIKIA  scheme)  providing  grants  in  the  form  of  partial  debt  write-offs  to  borrowers  encountering 
difficulties  in  repaying  their  loans  under  a  government  housing  plan106.  In  December  2024,  the 
Commission agreed to another extension of the Hercules asset protection scheme in Greece. Hercules 

102 Case M.11120 – Worldine/Crédit Agricole/JV. 
103 Acquiring is a set of services that enables merchants to accept payment cards (for example when a customer puts the card on the payment 
terminal and the terminal approves the payment – the services that enable this approval are the acquiring services). Acceptance is a service that 
allows  a  merchant to optimise  its  connection to  multiple acquirers  (those  providing  acquiring  services). This  is  mainly  for big  merchants  (for 
example a supermarket) to whom hundreds / thousands of payments are made each day and who would usually be connected to multiple acquirers 
to optimise these payments. 
104 Case M.11546 – Unicredit/Alpha Bank Romania. 
105 Case SA.114922 – Poland – Reintroduction of the Credit Unions Orderly Liquidation Scheme. 
106  Case  SA.112704  –  Cyprus  –  Scheme  for  the  management  of  loans  granted  under  Government  Housing  Plans  (OIKIA  scheme)  and  Case 
SA.116563 - Cyprus - Amendment of the scheme for the management of loans granted under Government Housing Plans (OIKIA scheme) 

24 

 
 
 
assists  banks  in  the  securitisation  and  offloading  of  non-performing  loans  from  their  balance 
sheets107.  

Taxation 

In February 2024, the Commission closed the State aid investigation into Danish108 and Swedish109 
public financing of the Øresund fixed rail-road link. The Commission concluded that neither the 
guarantee granted by Denmark and Sweden, nor the construction constituted new State aid. However, 
a part of the tax support granted and implemented by Denmark was deemed to constitute new State 
aid  that  was  disproportionate  and  therefore  incompatible  with  State  aid  rules.  Denmark  had  to 
recover the incompatible aid. 

In  June  2024,  the  Commission  adopted  two  decisions  regarding  Germany110.  The  Commission 
concluded that Germany’s special tax scheme for public casino operators was not in line with the 
EU State aid rules. Therefore, the incompatible State aid had to be  recovered, and the tax schemes 
abolished. 

The  Court  of  Justice  confirmed  the  Commission’s  decision  that  Ireland  granted  Apple  unlawful 
State aid 
In a 2016 decision, the Commission concluded that companies belonging to the Apple Group had - from 
1991  to  2014  -  received  tax  advantages  granted  by  Ireland  that  constituted  unlawful  State  aid.  The  aid 
concerned profits generated by Apple outside the U.S. Ireland had issued two tax rulings favouring two 
companies in the Apple Group. Both companies were incorporated in Ireland but not tax resident there. In 
its  decision,  the  Commission  found  that  by  excluding  from  the  tax  base  profits  generated  by  the  two 
companies on the ground that the head offices of those companies were located outside Ireland, the tax 
rulings had conferred on those companies unlawful State aid incompatible with the EU internal market. 
The  Commission  therefore  ordered  Ireland  to  recover  aid  estimated  at  EUR  13  billion.  In  2020,  the 
General  Court  annulled  the  Commission’s  decision,  holding  that  the  Commission  had  not  sufficiently 
established that the Apple Group companies enjoyed a selective advantage. On 10 September 2024, the 
Court of Justice set aside the General Court’s judgment and confirmed the Commission’s decision111. The 
Commission  welcomed  the  judgment  by  the  Court  of  Justice  and  drew  the  following  conclusions. 
Member  States  have  the  exclusive  competence to  define their  corporate  taxation  system.  This  does  not 
mean  that  tax  rulings  escape  EU  State  aid  control.  The  Commission  can  exercise  control  to  avoid  that 
companies receive unfair tax advantages through rulings that derogate from national law, domestic case 
law or administrative practice. It is crucial that the tax administration abides by its own rules. But it is the 
Commission that must prove that Member States deviated from their own tax rules112. 

107 Case SA. 116229 - Greece - Prolongation and amendment of the reintroduced Hercules Scheme 
108 Case SA.52162 – Denmark – State aid in favour of the Oresund Bridge Consortium. 
109 Case SA.52617 – Sweden – State aid in favour of the Oresund Bridge Consortium. 
110 Cases SA.44944 and SA.53552 – Germany – Tax treatment of public casinos operators in Germany. 
111 Judgment of the Court of 10.09.2024 in Case C-465/20 P, Commission v Ireland and Others. 
112 See: https://ec.europa.eu/commission/presscorner/detail/en/speech_24_4624 

25 

 
 
4.  Effective  enforcement  of  the  Digital  Market  Act  and  the  Foreign  Subsidies 
Regulation  

4.1. Addressing the challenges and dynamics of digital markets by enforcing the DMA 

The DMA113 is a Single Market regulatory instrument that aims to make the digital sector in the EU 
more  contestable  and  put  an  end  to  unfair  practices  by  companies  acting  as  ‘gatekeepers’  in  the 
online platform economy. Companies formally designated as gatekeepers must comply with a set of 
obligations set out in the DMA114. 

The first six designated gatekeepers115 submitted their DMA compliance reports in March 2024116 . 
Later  in  the  same  month  the  Commission  opened  formal  non-compliance  investigations  against 
Alphabet, Apple and Meta. These investigations concerned: Alphabet’s and Apple’s rules on steering, 
in their respective app stores (i.e. Google Play; App Store); Alphabet’s self-preferencing on Google 
Search; Apple’s user choice obligations, including the web browser choice screen, uninstallation and 
defaults;  and  Meta’s  ‘pay  or  consent’  advertising  model.  The  Commission  suspected  that  the 
compliance measures put in place by these gatekeepers fell short of effective compliance and did not 
provide companies operating in the EU as well as EU citizens with the wide range of opportunities 
provided for by the DMA. 

For core platform services, the Commission carried out five in-depth market investigations following 
rebuttals  of  respective  companies  of  their  presumed  gatekeeper  status,  carefully  reviewing  a  wide 
range  of  market  players’  as  well  as  the  gatekeepers’  views.  As  a  result,  the  Commission  decided, 
first,  in  February  2024  that,  despite  meeting  the  thresholds,  some  of  Microsoft’s  core  platform 
services – namely Microsoft’s online search engine Bing, web browser Edge and online advertising 
service  Microsoft  Advertising  –  and  Apple’s  messaging  service  iMessage,  do  not  qualify  as 
gatekeeper services. Second, in addition to deciding not to designate X Ads and TikTok Ads as core 
platform  services  in  May  2024,  the  Commission  concluded  in  October  2024  its  fifth  market 
investigation by deciding that the online social networking service X should not be designated as a 
core  platform  service,  as  it  does  not  constitute  under  the  DMA  an  important  gateway  for  business 
users to reach end users117. In total, the Commission adopted six non-designation decisions in 2024. 

113 Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital 
sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828 (Digital Markets Act), OJ L 265, 12.10.2022, p. 1. 
114 For example, companies designated as gatekeepers for one or more core platform services under the DMA must allow third parties to inter-
operate  with  the  gatekeeper’s  own  services  in  certain  specific  situations;  allow  their  business  users  to  access  the  data  they  generate  when 
operating  the  platform;  provide  platform  advertisers  with  the  tools  and  information  necessary  for  verifying  advertisements  hosted  by  the 
gatekeeper;  allow  business users  to promote their offers  and  conclude  contracts  with customers outside the gatekeeper’s  platform.  Designated 
gatekeepers  are,  for  example,  prohibited  from  treating  their  own  products  and  services  more  favourably  in  ranking  than  similar  products  and 
services  or  products  offered  by  third  parties;  they  can  no  longer  prevent  consumers  from  linking  up  to  businesses  outside  its  platforms;  they 
cannot prevent users from un-installing any pre-installed software or app or track end users outside the core platform service for the purpose of 
targeted advertising without consent. 
115 In September 2023, the Commission designated six gatekeepers under the DMA – Alphabet, Amazon, Apple, ByteDance, Meta, and Microsoft  
in relation to 22 core platform services provided by these gatekeepers. 
116 Public versions of these reports have been published. See: https://digital-markets-act-cases.ec.europa.eu/reports/compliance-reports.  
117The non-confidential version of the decision will be published on the Commission's website dedicated to the DMA. 

26 

 
 
In  June  2024  the  Commission  informed  Apple  of  its  preliminary  view  that  its  App  Store  steering 
rules are in breach of the DMA because they prevent app developers from freely steering consumers 
to alternative channels for offers and content. In addition, in the same month the Commission opened 
a new non-compliance procedure against Apple regarding its contractual requirements for third-party 
app developers and app stores, including Apple's new ‘Core Technology Fee’.  

In  July  2024,  the  Commission  informed  Meta  of  its  preliminary  findings  that  its  ‘pay  or  consent’ 
advertising  model  did  not  comply  with  the  DMA  by  opening  non-compliance  proceedings.  In  the 
Commission's preliminary view, this binary choice forces users to consent to the combination of their 
personal  data  and  fails  to  provide  them  with  an  equivalent  version  of  Meta's  social  networks  with 
fewer personalised ads. 

Moreover,  in  April  2024,  the  Commission  designated  Apple  as  a  gatekeeper  with  respect  to  its 
operating system iPadOS for use in the  company’s tablets (iPads), which unlocks the opportunities 
set forth in the DMA to all companies operating in the EU. In May 2024, the Commission designated 
Booking as a gatekeeper under the DMA for its online intermediation service Booking.com. It had six 
months, until 14 November 2024 to ensure full compliance with DMA obligations for this service. 
On 13 November 2024, Booking published a compliance report detailing the measures it has taken 
for Booking.com to comply with the DMA.118  

In  September  2024,  the  Commission  initiated  two  specification  proceedings119  to  assist  Apple  in 
complying with its obligations under the DMA to provide, to third party developers and businesses, 
free  and  effective  interoperability  with  hardware  and  software  features  controlled  by  Apple's 
operating  systems  iOS  and  iPadOS,  designated  under  the  DMA.  On  18  December  2024,  the 
Commission sent preliminary findings to Apple in both specification proceedings. These preliminary 
findings proposed measures, taking account of Apple’s and third parties’ input, for Apple to ensure 
interoperability of connected devices with iPhones and to make interoperability by third parties more 
predictable and transparent, as required by the DMA. 

In  July  2024,  the  General  Court  issued  its  judgment  concerning  Bytedance’s  challenge  of  being 
designated as a gatekeeper under the DMA. The General Court dismissed the appeal. 

The DMA calls for close cooperation between the Commission as the sole enforcer of the Act, NCAs 
and other concerned parties. To this end, a High-Level Group was created120. The main objectives of 
the High-Level Group are to support a coherent and effective implementation of the DMA and other 
sector-specific regulations applicable to gatekeepers. In 2024, the High-Level Group met eight times. 

118 See: https://digital-markets-act-cases.ec.europa.eu/reports/compliance-reports. 
119 Pursuant to Article 8(2) of the DMA, the Commission may, on its own initiative, adopt a decision specifying the measures a gatekeeper has to 
implement to ensure effective compliance with substantive DMA obligations, such as the interoperability obligation of Article 6(7) DMA. 
120  The  High-level  group  is  composed  of  30  representatives  nominated  from  the Body  of  the  European  Regulators  for  Electronic 
Communications (BEREC),  the European  Data  Protection  Supervisor (EDPS)  and European  Data  Protection  Board,  the European  Competition 
Network (ECN),  the Consumer  Protection  Cooperation  Network (CPC  Network),  and  the European  Regulatory  Group  of  Audiovisual  Media 
Regulators (ERGA). 

27 

 
 
More information on how the Commission enforces the DMA is available in the DMA annual report. 

4.2. Protecting the Single Market from distortive foreign subsidies by enforcing the FSR 

In  2024,  the  Commission  rigorously  enforced  the  FSR121  to  protect  the  Single  Market  from 
competition-distortive  subsidies  granted  by  non-EU  countries  to  companies  operating  in  the  Single 
Market.  The  FSR  provides  a  framework  for  addressing  distortion  caused  in  the  Single  market  by 
foreign subsidies with a view to ensuring a level playing field. Such distortions can arise with respect 
to any economic activity, and in particular in concentrations and public procurement procedures. At 
the  same  time,  the  FSR  ensures  that  the  EU  Single  Market  remains  open  to  trade  and  investment 
from third countries122. 

In  2024,  the  Commission  received  102  concentration  notifications  under  the  FSR.  In  2024,  the 
Commission opened a preliminary review in the field of security equipment for airports and ports. As 
a part of this investigation, the Commission carried out unannounced inspections under the FSR at 
the Dutch and Polish premises of Nuctech, a Chinese company active in the production and sale of 
security equipment in the EU. The Commission had indications that the inspected company may have 
received  foreign  subsidies  that  could  distort  competition  in  the  Single  Market123.  Furthermore,  the 
Commission opened a preliminary review in the field of wind energy. 

Amongst  the  102  concentration  notifications  received  under  the  FSR,  the  Commission  opened  one 
in-depth investigation, concerning the acquisition by Emirates Telecommunications Group Company 
PJSC (e&) of sole control of PPF Telecom Group B.V. (PPF), excluding its Czech business124. The 
Commission  conditionally  approved  this  transaction  in  September  2024,  subject  to  the  full 
compliance with the commitments offered by the parties. e& is a telecommunications operator based 
in the UAE and controlled by the sovereign wealth fund Emirates Investment Authority (EIA). PPF, 
headquartered  in  the  Netherlands,  is  a  telecommunications  operator  active  in  Czechia,  Bulgaria, 
Hungary, Serbia, and Slovakia. The Commission found that e& and EIA received foreign subsidies 
from the UAE, notably in the form of an unlimited State guarantee to e&, as well as grants, loans, 
and other debt instruments. Under the FSR, unlimited State guarantees are considered as ‘most likely 
to distort the internal market’. Using these subsidies, the merged entity could have made investments 
distorting  competition  in  the  Single  Market.  To  address  the  Commission's  concerns,  e&  and  EIA 
committed  that  e&’s  articles  of  association  do  not  deviate  from  ordinary  UAE  bankruptcy  law, 
thereby removing the unlimited State guarantee. In addition, any financing from the EIA and e& to 
PPF  was  prohibited  for  the  merged  entity’s  activities  in  the  Single  Market.  The  parties  committed 

121 Regulation (EU) 2022/2560 of the European Parliament and of the Council of 14 December 2022 on foreign subsidies distorting the internal 
market,  OJ  L  330,  23.12.2022,  p.  1.  DG  Competition  is  responsible  for  enforcing  the  FSR  rules  on  concentrations  and  to  start  ex  officio 
procedures outside public procurement procedures, while DG Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) is  responsible 
for enforcing the FSR in public procurement. 
122 The FSR closes a regulatory gap in the Single Market where subsidies granted by Member States are subject to close scrutiny under EU State 
aid  rules,  while  subsidies  granted  by  non-EU  governments  go  largely  unchecked.  Under  the  FSR,  companies  have  to  notify  financial 
contributions received from non-EU public authorities in the last three years, before implementing a concentration (that is to say a merger, an 
acquisition, or a joint venture) or the award of a contract in a public procurement procedure in the EU above given notification thresholds. The 
FSR allows the Commission to conduct ex officio reviews if information indicates the existence of a foreign subsidy distorting the Single Market. 
123 https://ec.europa.eu/commission/presscorner/detail/en/mex_24_2247  
124 Case FS.100011 – Emirates Telecommunications Group / PPF Telecommunication Group. 

28 

 
 
that other transactions between the companies take place on market terms and undertook to inform 
the Commission of future acquisitions not notifiable under the FSR. 

5. Impact of competition policy and enforcement 

5.1. Benefits from competition enforcement for consumers and citizens  

The  Commission’s  antitrust  and  mergers  enforcement  generate  direct  benefits  for  citizens.  DG 
Competition  measures  their  impact  in  several  ways.  An  important  measure  is  direct  customer 
savings, that is to say direct price effects benefitting customers after the Commission intervened in 
mergers and antitrust cases (including cartels and unilateral conduct). Based on a method adopted by 
the  Organization  for  Economic  Cooperation  and  Development  (OECD)125,  DG  Competition 
estimates  that  between  2012  and  2023,  direct  customer  savings  generated  by  the  Commission’s 
antitrust and merger enforcement amounted to EUR 12 billion to EUR 21 billion per year126. 

Customer savings (midpoints – i.e. middle of each range) 2013-2023  

Source: European Commission 

The  Commission  is  not  the  sole  enforcer  of  the  EU  competition  rules.  NCAs  are  also  heavily 
involved.  In  2024,  DG  Competition  started  to  measure  and  estimate  the  direct  additional  customer 
savings generated by the enforcement of EU NCAs. In the period 2020-2022, total direct customer 
savings  from  all  the  13  participating  NCAs  can  be  estimated  to  an  amount  in  a  range  of  EUR  7 
billion to EUR 11 billion per year.  If all customer savings are combined, that is to say the savings 
generated by the Commission and the participating  NCAs, they add up to an amount ranging from 
EUR 23 billion to EUR 38 billion in the period 2020-2022. These calculations provide a preliminary 

125 The OECD Guide for helping competition authorities assess the expected impact of their activities, OECD, 15.4.2014. 
126 The EUR 12 billion amount is the average of the lower bounds 2012-2023 and the EUR 21 billion is the average of the upper bounds for the 
same period. 

29 

 
 
 
 
 
insight  of  the  magnitude  of  the  direct  savings  generated  by  competition  enforcement  by  the 
Commission and the 13 participating NCAs127. 

Indirect  deterrent  effects  of  enforcement  and  their  positive  effects  on  innovation  and  quality are 
also significant. Indirect effects are more difficult to estimate than direct effects, but they are likely to 
be of greater significance than direct customer savings. Late 2023, the Commission commissioned a 
survey  study  on  deterrent  effects  of  competition  enforcement  to  better  understand  how  companies 
take them into consideration in their business decisions. The project continued in 2024 and will be 
concluded in the first half of 2025. 

5.2. Protecting competition in a changing world 

In  June  2024,  DG  Competition  published  a  Staff  Report  entitled  ‘Protecting  competition  in  a 
changing world - Evidence on the evolution of competition in the EU during the past 25 years’128. A 
related  conference  and  an  expert  workshop  were  also  held  in  2024.  The  Staff  Report  draws  on 
contributions from the OECD, insights of a researchers’ consortium, and from research done by DG 
Competition  itself.  The  purpose  of  the  report  was  to  study  how  and  why  the  conditions  of 
competition  have  evolved  in  the  EU  over  the  past  20-25  years,  and  to  determine  how  and  why 
effective  competition  matters  for  broader  economic  outcomes  (such  as  prices,  productivity, 
competitiveness, and growth).  

Research presented in the first part of the present report suggests that, on average and in a wide range 
of sectors in the EU over the past 25 years, (i) concentration at both industry and market level has 
increased,  (ii)  markups  and  profits  in  particular  at  the  top  of  the  distribution  chain  have  increased, 
(iii) the gap between industry leaders and followers as regards markups, profits and productivity has 
increased, and (iv) business dynamism has declined, as measured by indicators such as market share 
volatility  between  leading  firms,  or  entry  and  exit  rates.  An  important  driver  of  the  developments 
observed  over  the  past  25  years  seems  to  be  that,  across  many  sectors,  large  first-mover  firms  can 
reap  most  of  the  benefits  (‘winner  takes  most’  dynamics),  largely  due  to  long-term  structural 
economic  shifts:  (i)  rise  of  the  share  of    investments  in  proprietary  IT  solutions  and  data  or  other 
intangibles (for example R & D, patents, and brands), (ii) globalisation, and (iii) rising mergers and 
acquisitions activities, though the latter possibly to a more limited extent. Regulatory barriers to entry 
and exit may also have contributed to these trends.  

While the trends and the mix of contributing factors will vary by sector, on average, the intensity of 
competition seems to be weaker and the market power of firms at the top of the markup and profit 
distribution seems to be more pronounced than in the past. 

Additional  research  presented  in  the  second  part  of  the  report  confirms  and  supplements  prior 
research that effective (or weak) competition can have significant positive (or negative) effects, not 

127 The estimated range does not cover all EU NCAs, so the amount must be regarded as a rough estimate. In addition, it is worth noting that this 
initial exercise covered three years during which enforcement was likely affected by the Covid pandemic. 
128 See: https://op.europa.eu/en/publication-detail/-/publication/c03374f1-3833-11ef-b441-01aa75ed71a1  

30 

 
 
only  on  prices  and  thus  on  the  purchasing  power  of  consumers,  but  also  on  the  productivity  and 
competitiveness of EU firms and thus on overall economic growth129. These results are borne out by 
a study analysing the relationship between price and market concentration in six sectors where prices 
vary significantly between Member States, by a survey of EU-based exporting firms on the relevance 
of effective domestic competition within the EU Single Market and by a study on the macroeconomic 
effects of effective competition. 

5.3. Impact of State aid policy on the Single Market  

To protect the fairness and proper functioning of the Single Market, the TFEU prohibits State aid that 
distorts  or  threatens  to  distort  competition.  State  aid  control  ensures  that  competition  between 
companies takes place on the merits and is not based on the level of government support received by 
each firm. In this manner, subsidy races favouring companies supported by Member States with the 
‘deepest  pockets’  can  be  avoided.  However,  in  certain  situations  government  intervention  may  be 
necessary  to  safeguard  the  functioning  and  fairness  of  the  economy.  For  this  reason,  the  TFEU 
provides the possibility for Member States to grant State aid to support certain, clearly defined policy 
objectives. State aid can be granted provided that it is necessary, proportionate, and appropriate for 
achieving the identified objectives and without unduly distorting competition in the Single Market. 
The outcome of effective State aid control is State support that is better targeted, legitimate, effective 
and avoids overcompensation. In this way, State aid control helps maximising the utility of limited 
public resources. 

To  monitor  the  impact  of  State  aid,  the  Commission  regularly  collects  data  measuring  how  the 
Member States implement their State aid measures. This is done in several ways, most importantly:  

(i)  The  State  aid  Scoreboard,  published  every  year,  is  based  on  data  compiled  by  the  Member 
States130  on  actual  expenditure  (that  is  to  say  the  disbursed  amounts)  under  each  approved  aid 
measure,  including  the  aid  elements,  that  is  to  say  the  advantage  granted  by  the  aid131.  The  most 
recent State Aid Scoreboard data covers 2023. 

(ii) Periodical surveys collecting information about public aid granted and disbursed by the Member 
States  during  the  recent  crises  (the  COVID-19  pandemic  and  Russia’s  war  of  aggression  against 
Ukraine). These surveys were carried out on an exceptional basis in order to capture the impact of the 
very  large  aid  amounts  approved  in  response  to  Russia’s  invasion  of  Ukraine  and  to  support 
economic  sectors  key  to the transition  to  a  net-zero  economy. To  do  so,  the  Commission collected 
information on State aid that was actually granted in accordance with the approved crisis measures, 
that is to say funds to which companies had received legal entitlement during the period covered by 
each survey. The most recent survey covers support given until the end of June 2024. 

129 For a summary of the outcome, see the accompanying Staff Working Document, section 7.3.  
130    The  data  contained  in  the  State  aid  Scoreboard  is  based  on  annual  reporting  made  by  Member  States  in  accordance  with  Article  6(1)  of 
Commission Regulation (EC) 794/2004. The Member States remain responsible for the data provided. 
131  The aid element depends on the form of the aid. For grants, the advantage passed on to the beneficiary normally corresponds to the budgetary 
expenditure.  For other  aid instruments,  the advantage to  the beneficiary  and  the cost to government  may  differ.  In  the  case of guarantees,  for 
example,  the  beneficiary  avoids  the  risk  associated  with  the  guarantee,  since  it  is  carried  by  the  State.  Such  risk-carrying  by  the  State  should 
normally be remunerated by an appropriate premium. Where the State forgoes all or part of such a premium, this represents the aid element. 

31 

 
 
 
Disbursement of crisis and non-crisis State aid in 2023 

The figures discussed below exclusively refer to disbursements under support measures qualifying as 
State  aid.  Member  States  may  have  granted  significant  support  to  their  economies  and  households 
through other means which do not qualify as State aid. 

According  to  the  most  recent  annual  reports  submitted  by  Member  States  (covering  2023),  they 
disbursed  EUR  186.77  billion  (corresponding  to  1.09%  of  EU  GDP)  on  support  for  non-crisis  and 
crisis measures.  

Total expenditure was significantly reduced compared to previous years. In nominal terms, the 2023 
expenditure almost halved when compared to the years 2020 and 2021 (that is to say the peak of the 
COVID-19  crisis).  When  adjusted  for  inflation  (compared  to  the  annual  rate  of  inflation  in  2022) 
total State aid expenditure decreased by approximately 23%.  

Figure  1:  Total  State  aid  expenditure,  aid  elements  in  percentage  of  GDP,  breakdown  between 
COVID-19 related State aid, TC(T)F132 related State aid and non-crisis State aid measures 

For the following reasons, the reduced expenditure observed during 2022 and 2023 is consistent with 
a significant reduction of aid related to crisis measures133:  

(i) Expenditure on COVID-19 measures amounted to EUR 10.55 billion in 2023, which corresponds 
to  around  0.06%  of  EU  GDP  and  less  than  6%  of  total  State  aid  expenditure.  Compared  to  the 
expenditure on COVID-19 measures in 2022 - which amounted to EUR 77.70 billion in 2023 prices -   
it  represents a  reduction of  86%.  This  decrease  was  to  be  expected  in  light  of the  phase-out of  the 
COVID-19 Temporary Framework completed at the end of December 2023. 

(ii)  The  expenditures  reported  for  crisis  measures  were  predominantly  based  on  the  TC(T)F, 
including its  sections to  support  the transition to  a net-zero economy.  State aid measures  that  were 
approved  under  the  TCTF  or  were  approved  based  on  TCTF  principles,  decreased  to  EUR  39.45 
billion in 2023. This amounts approximately 0.23% of total EU GDP and 21% of the total State aid 

132 TC(T)F refers to Temporary Crisis (and Transition) Framework. 
133  While  in  2022,  COVID-related  aid  represented  around  0.45  %  of  the  EU  GDP,  it  decreased  to  0.06%  of  EU  GDP  in  2023.  Also  aid 
expenditure in response to the disturbance of the economy provoked by Russia’s war of aggression against Ukraine decreased from 0.27% of EU 
GDP in 2022 to 0.23% of the EU GDP in 2023.  

32 

 
 
 
expenditure in 2023. Compared to the 2022 expenditure of EUR 45.59 billion in constant prices, the 
total aid expenditure in 2023 decreased by 13%.   

In 2023, State aid for non-crisis objectives increased to around EUR 136.78 billion, a 14% increase 
compared to the 2022 expenditure of EUR 119.98 billion (in constant prices). In nominal terms, the 
total amount disbursed for non-crisis aid increased in 19 Member States, in comparison to 2022134. 
The increase in non-crisis State aid appears to have been mainly driven by increased disbursement of 
aid for environmental protection (including energy savings).  This type of aid increased from around 
EUR  45.99  billion  in  2022  to  EUR  55.32  billion  in  2023.  Similarly,  the  State  aid  expenditure  for 
research,  development  and  innovation  increased  from  EUR  11.99  billion  in  2022  to  EUR  15.95 
billion  in  2023.  Non-crisis  State  aid  disbursed  for  sectoral  development  increased  from  EUR  9.37 
billion in 2022 to EUR 13.02 billion in 2023. Finally, State aid dedicated to IPCEIs almost doubled, 
from EUR 1.25 billion in 2022 to EUR 2.22 billion in 2023. 

Despite  the  increase,  non-crisis  aid  amount  for  2023  remains  well  below  the  expenditure  for  non-
crisis  measures  calculated  at  the  peak  of  the  COVID-19  pandemic.  In  constant  prices,  this 
expenditure  amounted  to  EUR  157.46  billion  in  2020  and  EUR  157.23  billion  in  2021.  Moreover, 
2023  non-crisis  aid  expenditure  remains  below  pre-crisis  expenditure,  which  amounted  to  EUR 
153.34 billion in 2019 and EUR 145.43 billion in 2018 in constant prices.  

Figure 2: State Aid expenditure excluding crisis aid between 2018 and 2023, aid elements in EUR 
billion in constant prices, breakdown by objective of the aid 

134 Malta (+0.91 percentage points), Croatia (+0.47 p.p.), Greece (+0.33 p.p.), Poland (+0.32 p.p.), Lithuania (+0.27 p.p.), Slovenia (+0.22 p.p.), 
Luxembourg (+0.21 p.p.), Germany (+0.19 p.p.), Latvia (+0.16 p.p.), Italy (+0.13 p.p.), Denmark (+0.12 p.p.), Spain, Slovakia and Austria (+0.09 
p.p.),  Finland  (+0.08  p.p.),  Ireland  (+0.07  p.p.),  France  and  Cyprus  (+0.04  p.p.),  and  Estonia  (+0.02  p.p.).  While  it  remained  stable  in  the 
Netherlands, in  seven other  Member  States  the levels  of non-crisis  aid  reduced:  Portugal  (-0.44 p.p.), Czechia  (0.23 p.p.)  and  Bulgaria  (-0.11 
p.p.), Sweden (-0.09 p.p.), Belgium (-0.07 p.p.), Bulgaria (-0.04 p.p.) and Romania (-0.02 p.p.). 

33 

 
 
 
 
Looking at the distribution of crisis aid and non-crisis State aid expenditure among the Member 
States  as  a  share  of  national  GDP,  there  is  a  significant  dispersion  of  spending135.  In  conclusion, 
while there are significant differences between the nominal aid amounts disbursed by Member States, 
the picture becomes more nuanced when looking at relative State aid expenditure compared to GDP. 

Finally,  the  figures  indicated  above  exclusively  refer  to  disbursements  under  support  measures 
qualifying as State aid. Member States may have granted significant support to their economies and 
households through other non-State aid means.     

Figure  3:  Total  State  aid  expenditure  by  Member  State  in  2023,  aid  elements  in  EUR  billion, 
breakdown between non-crisis State aid measures, COVID-19 related State aid, and TC(T)F related 
State aid. 

Figure  4:  Total  State  aid  expenditure  by  Member  State,  as  %  of  2023  national  GDP,  breakdown 
between non-crisis State aid measures, COVID-19 related State aid, and TC(T)F related State aid. 

135 Hungary spent the most in relation to its 2023 GDP (around 2.91%). The second largest spender relative to GDP  was Croatia (around 1.86%). 
The Member States with the smallest expenditure in 2023  - Ireland, Cyprus, and Bulgaria  - spent 0.39% to 0.51% of their respective national 
GDPs.  More  information  can  be  found  on  the  State  aid  Scoreboard  published  on  the  Commission  website:  https://competition-
policy.ec.europa.eu/state-aid/scoreboard_en 

34 

 
 
 
 
 
State aid to boost industrial innovation and technological leadership  

Although a state may play an important role when trying to boost competitiveness in an economy, 
many types of support do not entail State aid in the sense of Article 107(1) TFEU.  Still, the State aid 
rules  offer  multiple  possibilities  for  the  Member  States  to  support  a  well-functioning  and  fair 
economy, as well to address market failures. The TCTF ‘transition sections’ are intended to boost the 
green  and  digital  transitions.  Until  31  December  2025,  Member  States  may  grant  aid  to  foster  the 
transition to a net-zero economy136.  

In  2023,  the  total  amount  of  industrial  aid137  -  including  support  based  on  State  aid  guidelines  - 
amounted to EUR 126.97 billion, corresponding to approximately 0.74% of EU GDP. Out of the total 
amount  of  industrial  aid,  environmental  protection  aid  (including  energy  savings)  was  the  main 
policy objective during the last ten years. It amounted to EUR 55.32 billion in 2023, accounting for 
44% of total industrial aid, that is to say approximately 0.32% of total EU GDP. State aid disbursed 
for  the  benefit  of  IPCEIs  amounted  to  EUR  2.22  billion  in  2023.  Investment  aid  disbursed  in 
accordance  with  the  Regional  Aid  Guidelines  to  support  the  production  of  batteries,  battery 
components, solar panels, and electric vehicles amounted to EUR 138 million in 2023.   

Beyond 2023, according to the most recent data collected through a survey of aid granted under the 
TCTF until the end of June 2024138, 11 Member States139 have started implementing measures under 
the  ‘transition  sections’  of  the  framework:  around  EUR  2.38  billion  were  granted  for  measures 
approved under Sections 2.5, 2.6. and 2.8 TCTF.140  

When  focusing  exclusively  on  aid  granted  to  foster  the  transition  to  a  net-zero  economy  by  each 
Member  State,  calculated  as  a  percentage  of  national  GDP,  Portugal  was  the  largest  aid  provider, 
followed by Slovakia. 

136 Aid may be granted to (i) accelerate the roll-out of renewable energy, storage and renewable heat relevant for REPowerEU (measures under 
Section 2.5) and (ii) decarbonise industrial production processes (measures under Section 2.6). Member States may also grant aid to accelerate 
investments  in  key  sectors  for  the  transition  towards  a  net-zero  economy,  enabling  investment  support  for  the  manufacturing  of  strategic 
equipment,  namely  batteries,  solar  panels,  wind  turbines,  heat-pumps,  electrolysers  and  carbon  capture  usage  and  storage  as  well  as  for 
production of key components and for production and recycling of related critical raw materials (measures under Section 2.8). 
137  Industrial  aid  refers  to  State  aid  expenditure,  in  aid  element,  in  2023  as  reported  in  annual  reports,  excluding  State  aid  with  the  following 
policy  objectives:  ‘Culture’,  ‘Heritage  conservation’,  and  ‘Compensation  of  damages  caused  by  natural  disasters’.  The  analysis  also  excludes 
crisis  aid,  i.e.,  State  aid  expenditure  provided  in  the  context  of  the  COVID-19  crisis  and  State  aid  expenditure  in  response  to  Russia’  war  of 
aggression against Ukraine. 
138 A more complete presentation of the aid granted from March 2022 until June 2024 under the Temporary Crisis (and Transition) Framework is 
available in the Competition State aid brief: Competition policy briefs - European Commission 
139 Portugal, Slovakia, Hungary, Croatia, Spain, Germany, Italy, Belgium, France, Austria, and Denmark. 
140 Out of those EUR 2.38 billion, EUR 150 million have been granted under section 2.5 TCTF  – Aid for accelerating the rollout of renewable 
energy,  storage,  and  renewable  heat  relevant  for  REPowerEU;  EUR  240  million  under  section  2.6  –  Aid  for  the  decarbonisation  of  industrial 
production  processes  through  electrification  and/or  the  use  of  renewable  and  electricity-based  hydrogen  fulfilling  certain  conditions  and  for 
energy  efficiency  measures  and  EUR  1.99  billion  under  section  2.8  –  Aid  for  accelerated  investments  in  sectors  strategic  for  the  transition 
towards a net-zero economy.   

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Figure 5: Transition State aid granted in 2023 and 2024 (until 30 June 2024) under TCTF measures 
(in absolute values and as percentage of national GDP) 

6. Communication and advocacy support competition policy 

In 2024, the Commission continued with its competition policy advocacy and outreach activities at 
multiple  levels  to  support  the  effectiveness  of  EU  competition  policy,  most  prominently  with  the 
Executive Vice-President responsible for Competition participating in events and press conferences. 
Supported  by  the  Commission’s  Representations,  senior  managers  at  DG  Competition  also 
participated  in  outreach  activities  in  the  Member  States.  These  activities  complement  DG 
Competition’s  external  communication  initiatives  such  as  press  releases,  policy  briefs,  newsletters, 
and social media. 

In 2024, the Commission continued ‘The Markets for People’ itinerant debate series. Entitled ‘This is 
why  we  need  competition  policy’,  the  fifth  and  last  debate  was  held  in  Aarhus,  Denmark  in  May 
2024. In addition, DG Competition continued its ‘Let’s Talk Competition’ series of webcast debates. 
In the webcasts, experts debated key policy and enforcement developments in competition policy141. 

Important communication efforts were also undertaken at the occasion of the publication of the DG 
Competition staff report ‘Protecting competition in a changing world. Evidence on the evolution of 
competition in the EU during the past 25 years’, with a launch conference on 27 June 2024142 and an 
expert workshop on 15 October 2024.143  

141 See: https://competition-policy.ec.europa.eu/about/reaching-out/lets-talk-competition_en. 
142 See: https://competition-policy.ec.europa.eu/about/reaching-out/protecting-competition-changing-world_en  
143 See: https://competition-policy.ec.europa.eu/about/reaching-out/protecting-competition-changing-world-public-workshop_en.  

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7. Relations with other EU institutions 

The  European  Parliament,  the  Council,  the  European  Economic  and  Social  Committee  and  the 
European Committee of the Regions are key partners to the Commission in the continuing dialogues 
on competition policy. In the European Parliament, Executive Vice-President Vestager participated 
in  2024  in  several  exchanges  of  views  or  structured  dialogues,  including  with  the  Economic  and 
Monetary  Affairs  Committee,  the  Internal  Market  and  Consumer  Protection  Committee,  the 
Subcommittee on Tax Matters and the Budgetary  Control Committee. In addition, Executive Vice-
President Vestager participated in plenary debates on competition policy.  

In  the  Council,  Executive  Vice-President  Vestager  participated  in  2024  in  exchanges  of  views  and 
debates on competition policy matters as well as on competitiveness, the green transition and State 
aid tools in the context of Russia’s war of aggression against Ukraine.  

The  Commission  also  engaged  directly  with  other  EU  bodies.  For  example,  DG  Competition  staff 
were present at meetings convened by the rapporteur responsible for drafting the European Economic 
and Social Committee’s Opinion on the Commission’s Report on Competition policy 2023, adopted 
in  October  2024144.  At  such  meetings  of  the  drafting  group  and  the  section  responsible  for 
competition policy (Single Market, Production and Consumption), DG Competition provided advice 
and responded to factual questions.  

8. Competition policy in a European and global context 

8.1. Promoting a European competition culture through the European Competition Network 

In the EU, NCAs enforce competition rules within their national jurisdictions while the Commission 
focuses  on cases  with a  Single  Market  dimension.  Multilateral  cooperation  between  NCAs  and  the 
Commission – especially in antitrust – is done through the European Competition Network (ECN)145. 
The  objective  is  ensuring  that  EU  antitrust  rules  are  applied  in  an  effective  and  consistent  manner 
across the EU, in particular in investigations into behaviours that restrict competition and are liable to 
affect  trade  between  EU  Member  States.  Joint  enforcement  of  the  antitrust  rules  through  the  ECN 
framework reinforces the relevance and credibility of competition policy across the EU.    

In 2024, the Commission continued to safeguard effective and consistent application of Articles 101 
and 102 TFEU across the EU. First, NCAs inform the Commission about any new investigation at 
the  stage  of  the  first  formal  investigative  measure.  Second,  NCAs  consult  the  Commission  before 
adopting  certain  types  of  decisions.  In  2024,  191  new  investigations  were  launched  within  the 
network  and  66  envisaged  decisions  were  submitted  to  the  Commission  by  NCAs.  The  ECN 
members meet frequently to discuss cases, policy issues and matters of strategic importance. In 2024, 

144 European Economic and Social Committee - Opinion on the Commission’s Report on Competition policy 2023, 21.10.2024, (COM(2024) 115 
final), https://www.eesc.europa.eu/en/our-work/opinions-information-reports/opinions/report-competition-policy-2023. 
145 Commission Notice on cooperation within the Network of Competition Authorities, OJ C 101, 27.4.2004, p. 43 and OJ C 374, 13.10.2016, p. 
1. 

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37  ECN  meetings  took  place.  The  Working  group  for  digital  investigations  and  AI  promotes  the 
pooling of data scientists within the ECN. The pooled resources are used to work together on projects 
of common interest for the NCAs, for example detecting bid rigging by analysing large data sets.   

8.2. Helping Member States to reform through the Technical Support Instrument 

The Technical Support Instrument (TSI) is the Commission’s instrument for assisting Member States 
in designing and implementing reforms146. The support does not require co-financing from Member 
States. The support can take the form of, for example, strategic and legal advice, studies, training and 
expert visits on the ground. It can cover any phase in the reform process. The TSI is managed by the 
Commission’s  Reform  and  Investment  Task  Force  (SG  REFORM).  Each  year,  the  TSI  identifies 
flagship technical support projects that address common needs across Member States and  align with 
key EU priorities. 

For the 2024 cycle, DG COMP supported funding for the following projects: 

Fighting  Bid-Rigging  in  Public  Procurement  -  Improving  Compliance  and  Competition  for 
Public  Contracts147:  Designed  and  organised  by  the  OECD,  this  project  aims  at  helping Austria, 
Bulgaria,  Croatia,  Cyprus,  Greece,  and  Romania  to  improve  bid-rigging  prevention  and  detection 
through  a  series  of  workshops.  In  addition,  the  project  promotes  capacity  building,  good  practices 
and cooperation between competition authorities and contracting authorities and other public bodies. 

Competition  Market  Study  –  Digital  Sector148:  The  aim  of  this  project  is  to  identify  possible 
competition  issues  in  digital  markets  in  Poland,  Latvia  and  Lithuania  and  the  suitability  of  current 
national and EU legislative frameworks to effectively address such issues.  

8.3. International relations 

Multilateral relations 

In  2024,  the  Commission  continued  to engage  in international competition-related  fora  such  as  the 
OECD  Competition  Committee,  the  International  Competition  Network  (ICN),  and  the  United 
Nations Conference on Trade and Development (UNCTAD). 

As one of the co-chairs of the ICN Merger Working Group, the Commission contributed to the work 
on recommended practices for merger analysis, notably by leading the work revising the chapters on 
unilateral  and  coordinated  effects  in  horizontal  mergers.  In  addition,  the  Commission  co-organised 
the ICN Merger Workshop, which took place in Taiwan in November 2024.  

The  Commission  participated  in  several  OECD  Roundtable  discussions  and  contributed  to  the 
drafting  of  the  revised  OECD  Merger  Recommendation,  which  is  a  guidance  document  covering 

146https://commission.europa.eu/funding-tenders/find-funding/eu-funding-programmes/technical-support-instrument/technical-support-
instrument-tsi_en. 
147https://www.oecd.org/en/about/projects/fighting-bid-rigging-in-public-procurement-in-austria-bulgaria-croatia-cyprus-greece-and-
romania.html 
148 https://www.oecd.org/en/about/projects/oecd-competition-market-study-digital-sector-in-poland-latvia-and-lithuania.html 

38 

 
 
procedural aspects of merger control. Finally, the Commission participated in the work on a revised 
version of an OECD document covering substantive aspects of merger control.  

Bilateral relations 

In 2024, the Commission continued negotiations for concluding Fair Trade Agreements with India, 
Indonesia, Philippines, Thailand and ESA5149.  

In  April  2024,  the  Commission  and  the  U.S.  competition  authorities  held  the  fourth  high-level 
meeting of the Joint Technology Competition Policy Dialogue150, to continue cooperation in ensuring 
and  promoting  fair  competition  in  the  digital  economy.  The  dialogue  focused  on  the  evolving 
business  strategies  of  Big  Tech  companies,  including  recent  investments  and  partnerships  between 
major cloud providers and AI providers, as well as their implications for competition enforcement. 

In  2024,  the  Commission  continued  its  work  on  bilateral  cooperation  with  the  United  Kingdom  as 
foreseen in the EU/UK Trade Cooperation Agreement151 as well as in the Withdrawal Agreement152. 
In  October,  the  Commission  and  the  UK  finalised  technical  discussions  on  a  Competition 
Cooperation Agreement153. The future agreement would be a 'supplementing agreement' to the EU-
UK  TCA,  which  foresees  the  possibility  to  enter  into  a  separate  agreement  on  competition 
cooperation. The agreement would not only allow the Commission, but also the NCAs enforcing EU 
competition law, to cooperate with the UK competition authority.  

In  2024,  the  Commission  also  started  negotiations with  Switzerland  on  eight  issues  relevant  to  the 
bilateral relations between the EU and Switzerland. One of the issues covered is State aid.  

The Commission continued in 2024 its cooperation on competition policy with the Korea Fair Trade 
Commission  and  the  Japan  Fair  Trade  Commission.  The  Commission  also  continued  negotiations 
with  Canada  to  ensure  that  the  provisions  on  data  protection  in  the  EU-Canada  Competition 
Cooperation Agreement align with the standards established by the Opinion of the Court of Justice 
on the 2014 EU Canada Passenger Name Record Agreement154. Moreover, the Commission engaged 
in  2024  with  several  African  national  and  regional  authorities  to  further  cooperation  in  the 
competition field155.  

As  regards EU enlargement  policy,  the  Commission’s  main  objective in the competition  field is  to 
assist the candidate countries156 and potential candidates157, in creating, maintaining and developing 

149 Five Eastern and Southern Countries: Comoros, Madagascar, Mauritius, Seychelles and Zimbabwe. 
150 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1952 
151 Trade and cooperation agreement between the European Union and the European Atomic Energy Community, of the one part, and the United 
Kingdom of Great Britain and Northern Ireland, of the other part, OJ L 444, 31.12.2020, p. 14. 
152  Agreement  on  the  withdrawal  of  the  United  Kingdom  of  Great  Britain  and  Northern  Ireland  from  the  European  Union  and  the  European 
Atomic Energy Community, OJ C 384I, 12.11.2019, p. 1–177. 
153 See: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5468 
154 Opinion of the Court of Justice (Grand Chamber) of 26.7.2017, Opinion 1/15,  Draft agreement between Canada and the EU — Transfer of 
Passenger Name Record data from the EU to Canada, EU:C:2016:656. 
155 See: https://africa.competitioncooperation.eu/ 
156 Countries granted candidate country status by the European Council on the basis of a recommendation by the European Commission: Albania, 
Bosnia and Herzegovina, Georgia, Moldova, Montenegro, North Macedonia, Serbia, Türkiye and Ukraine. 

39 

 
 
legislative  frameworks  and  assist  well-functioning  and  operationally  independent  competition  and 
State  aid  authorities,  and  to  help  such  authorities  to  build  up  solid  enforcement  records.  The 
Commission is also working on the implementation of support facilities for Ukraine and Moldova to 
assist the legal, administrative but also economic integration of these countries with the EU  Single 
Market. 

157 Potential candidate for EU membership: Kosovo. 

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41