Information sharing in competition policy

2. The economics of information sharing: Benefits, risks and context

Information sharing between competitors can take many forms and occur through various channels. For competition policy, the economic significance of such conduct lies not in the fact that information is shared, but in the extent to which the information sharing is likely to alter firms’ incentives and behaviour in ways that soften rivalry and facilitate co‑ordination, and whether, in the market context concerned, any such restrictive effects are likely to be outweighed by countervailing efficiency benefits (OECD, 2011[2]). Economics therefore matters because it helps identify which features of information sharing are most relevant to competitive assessment. In particular, the likely effects depend on the nature of the information, the timing, frequency and format of disclosure, the market context, and the role of any intermediaries. These factors interact, and different combinations can have materially different implications for both efficiency benefits and competitive harm.

To inform the legal and enforcement discussion that follows, this section begins by discussing the circumstances in which information sharing may give rise to efficiency benefits. This reflects the need to explain why firms and policymakers sometimes view information sharing as beneficial, and in which circumstances such claims may have economic substance. The section then turns to the mechanisms through which information sharing can harm competition. The analysis subsequently considers how the characteristics of the information, the channel of disclosure and the market context shape the overall assessment, before concluding with a discussion of how recent technological developments affect the economic analysis of information sharing.

2.1. Where benefits and efficiencies can arise

Competition authorities are regularly presented with arguments that information sharing can improve market outcomes by addressing uncertainty, supporting investment or facilitating the functioning of markets. In assessing such arguments, it is useful to consider the economic mechanisms through which information sharing may, in certain circumstances, generate efficiency benefits. This section sets out the principal efficiency rationales identified in the economic literature. These benefits are not unconditional, and whether they arise in each case depends on factors such as the characteristics of the information, the structure of the market and the design of the disclosure, issues examined further in Section ‎2.3 . The purpose of this discussion is to provide economic context for the legal and enforcement analysis that follows, not to anticipate how any particular arrangement would be assessed under competition law.

When considering the potential benefits of information sharing, it is useful to distinguish between two broad settings. In some cases, information sharing takes the form of broad disclosure or transparency, where information is made available to consumers, investors or other market participants outside the group of competing firms. In other cases, information sharing is more narrowly targeted and takes place primarily or exclusively between competitors themselves. These two settings differ in both their economic rationale and their competitive implications. As a general matter, efficiency benefits are more likely to arise where information reaches actors outside the competitive relationship between firms, while more targeted exchanges between competitors often have less clear-cut efficiency benefits.

In relation to broader information sharing such as mandated disclosure, the information is typically directed at a specific audience such as consumers or investors, but once released it is available to rivals as well. Therefore, such public disclosure may also function as a co-ordination device and is worth considering the benefits and risks. Information disclosure to consumers for example through product labelling, price comparison requirements, nutritional information, energy ratings and similar regimes, can lead to benefits due to the reduction in information asymmetries between sellers and buyers. This improves consumer decision making and intensifies the competitive pressure on suppliers to compete on price and quality, particularly in markets where product characteristics would otherwise be difficult for consumers to verify (Dranove and Jin, 2010[3]). Disclosure to investors, including financial reporting requirements, improves capital allocation by allowing markets to price risk more accurately and identify underperforming firms (Diamond and Verrecchia, 1991[4]).

The efficiency benefits of narrowing information sharing between firms fall into four broad categories: (i) improved decisions and allocative efficiency under uncertainty; (ii) reduced barriers to irreversible investment; (iii) stability benefits in structurally interdependent sectors; and (iv) temporary co-operation in acute disruptions. These are taken in turn.

First, information sharing can affect firms’ decisions under uncertainty by improving the information on which they individually base output or investment choices. For example, sharing information about aggregate demand conditions may allow firms to form more accurate expectations about market demand. In quantity‑setting environments, where firms compete primarily by choosing how much to supply (such as some commodity or electricity generation markets), each firm may then adjust its own output decision accordingly. In that sense, information sharing can lead firms to adjust their output to different extents, not through any joint decision, but because they respond individually to better information about market conditions (Vives, 1984[5]). Sharing information about costs can operate in a similar way by reducing uncertainty about market conditions and rivals’ behaviour. When firms have better information about cost shocks, they can adjust their own output decisions more accurately in response to realised conditions. In oligopoly models with cost uncertainty, this typically reduces the variability of aggregate output and prices, as firms respond in a more aligned way to similar information.

These mechanisms can have ambiguous welfare effects for consumers. In some settings, improved information can benefit consumers by allowing firms to match supply more closely to underlying market conditions, leading to fewer shortages, lower price spikes and improved allocative efficiency. In other settings, however, consumers gain disproportionately from episodes of intense competition associated with firms choosing higher output levels when making decisions under demand or cost uncertainty. By reducing uncertainty and aligning firms’ expectations, information sharing can dampen such competitive fluctuations. As a result, greater informational precision can reduce consumer surplus in some settings, even when it improves firms’ decisions or industry‑level efficiency (Shapiro, 1986[6]). The welfare implications are therefore context-specific and depend on the competitive variable, the source of uncertainty, and the information structure of the market (Raith, 1996[7]). This context‑dependence is explained further in Section ‎2.3.

Second, where entry, capacity expansion or other irreversible investment requires sunk costs, uncertainty about future market conditions is itself a barrier to commitment: firms delay or forgo investment they would otherwise make. Information that reduces this uncertainty, for example aggregated data on demand trends or capacity utilisation, can lower effective barriers to entry and expansion and support investment that benefits consumers over time (Pindyck, 2009[8]).

Third, in sectors where firms are highly interdependent, information sharing can produce system-wide stability benefits that individual firms may not fully internalise when acting alone. In financial services, for example sharing operational and risk-related data supports financial stability for the system as a whole (Van Dijk, Jenkinson and Pham, 2024[9]; Cho, 2021[10]).

Fourth, efficiency rationales can also arise in acute disruptions, where limited and temporary co-operation may be necessary to ensure continuity of supply. The COVID-19 pandemic provided a prominent example: major supply-chain disruptions prompted discussion of limited, temporary co-operation or information sharing where necessary to ensure the provision of essential goods and services, with competition authorities setting out the conditions under which such arrangements would not attract enforcement. The OECD's work during the pandemic reviewed the broader shortage literature and the related question of crisis cartels, underlining that these frameworks are time‑limited and do not alter the standing treatment of information sharing outside acute disruption (OECD, 2020[11]).

The benefits set out in this section, from improved allocative efficiency to consumer and investor disclosure, share a common feature: each arises because information reduces uncertainty, and each can therefore also reduce the strategic uncertainty that sustains competition.

2.2. How information sharing can harm competition

Although information sharing can generate efficiencies, it can also harm competition. In the case of information sharing between competitors, the principal concern is typically its potential to facilitate co-ordinated conduct. Information disclosure may also be relevant in other contexts, including the use of selective disclosure for exclusionary conduct, but the discussion below focusses on co-ordination.

Co-ordinated conduct typically requires that firms reach a common understanding, monitor adherence to it, and punish deviations credibly (Stigler, 1964[12]). Each condition is harder to satisfy in the absence of reliable information about rivals’ conduct. This three-part framework is the central organising principle for assessing the collusion risk of any information-sharing arrangement: the central question is whether a specific disclosure makes one or more of these conditions easier to satisfy (OECD, 2011[2]).

Information sharing can facilitate co-ordination by affecting each of these conditions directly:

• On common understanding: making rival strategies observable reduces ambiguity about the terms on which co-ordination might occur, making it easier for competitors to reach alignment (Kühn and Vives, 1994[13]).

• On monitoring: where firms interact repeatedly, collusion is self-sustaining only if deviations can be detected reliably. Information sharing enables firms to distinguish deliberate price-cutting from demand shocks (Stigler, 1964[12]; Green and Porter, 1984[14]).

• On punishment credibility: faster and more accurate detection reduces the lag before retaliation, strengthening the deterrent effect that keeps collusion stable (Abreu, Pearce and Stacchetti, 1990[15]; Green and Porter, 1984[14]).

These mechanisms are not merely theoretical. Where co-ordination is achieved, the consequence is typically elevated prices, restricted output, lower quality and a transfer of surplus from consumers to firms, which the empirical literature on cartel overcharges suggests is substantial (Connor, 2024[16]). Increased transparency and structured information flows can also raise prices and support co-ordinated outcomes in concentrated markets, where no explicit cartel is operating. Box 1 provides a concrete illustration through a public disclosure initiative.

Box 1. Empirical illustration on the competitive impact of information sharing

The example below shows that increased transparency can, in some concentrated markets, have unintended competitive effects even where there is no allegation of an explicit cartel.

Denmark (ready-mixed concrete): A public transparency initiative led to the publication of firm-specific transaction prices for ready-mixed concrete in three Danish regions. Following publication, average prices of the reported grades rose by 15‑20% within a year. The subsequent academic analysis concluded that the additional transparency likely reduced the intensity of price competition, contrary to the initiative’s intended pro-competitive objective. Denmark later removed the requirement.

Sources: Albæk, Møllgaard & Overgaard (1997[17]), Government‐Assisted Oligopoly Coordination?, A Concrete Case https://onlinelibrary.wiley.com/doi/full/10.1111/1467-6451.00057.

2.3. How circumstances shape risk

Both the likelihood of efficiencies and the risk of harm to competition depend on the circumstances of the information-sharing arrangement. The discussion below begins with the market conditions that determine whether information is likely to alter firms’ expectations and incentives and then turns to the characteristics of the information itself, including its subject matter and timing, and the form and channel through which it is shared.

2.3.1. Market structure and context

The competitive effects of information sharing depend in part on market structure and conditions, which determine whether increased transparency is likely to influence expectations and sustain co‑ordinated outcomes (OECD, 2011[2]; Motta, 2004[18]). These factors are discussed in turn below.

Concentration affects the probability that shared information has a competitive impact. Where a few firms account for a large share of supply, each firm places greater weight on predictions of rivals’ behaviour, and information that reduces uncertainty can have larger effects on competitive outcomes. In more fragmented markets, individual firms have limited ability to influence overall market conditions, and the same information is less likely to materially alter strategic behaviour.

Product homogeneity or similarity also affects the risk associated with information sharing. Where firms offer highly similar products or services, disclosures about prices, output, or capacity are more likely to be strategically relevant to rivals and more readily translated into a common understanding of market conditions. By contrast, greater product differentiation can weaken the link between a rival’s disclosure and a firm’s own optimal response, making aligned conduct harder to establish and sustain (Thomadsen and Rhee, 2007[19]).

Stability of demand and cost conditions also affects the informativeness of disclosures. When market conditions change slowly and external shocks are limited, even historical or aggregated data can enable firms to infer competitors likely behaviour with reasonable accuracy. Economic research confirms that greater signal precision, including signals derived from aggregated or historical data, can increase the scope for detecting deviations and anticipating rivals’ conduct, expanding the conditions under which co-ordinated outcomes are sustainable (Awaya and Krishna, 2020[20]).

Barriers to entry shape the durability of any competitive harm from information sharing. In markets where entry is slow or costly, the effects of co-ordination are less likely to be eroded by new competition, increasing the impact of any arrangement that softens rivalry. Where entry is easy, the competitive significance of information sharing is lower because co-ordinated outcomes are less sustainable.

Baseline market transparency is a further contextual factor. In markets where prices, output levels, or capacity utilisation are already observable, additional disclosures may have limited incremental effect. In markets where underlying conduct is opaque, equivalent disclosures can materially reduce uncertainty and alter strategic incentives (OECD, 2011[2]). The interaction between pre-existing transparency and additional disclosure is therefore relevant to the overall assessment.

Table 1. Market context risk factors

Dimension	Lower Risk	Higher Risk
Concentration	Fragmented (many competitors)	Oligopoly (few symmetric firms)
Market homogeneity	Highly differentiated markets	Highly homogeneous markets
Demand stability	Volatile, unpredictable demand	Stable, predictable demand
Barriers to entry	Low barriers (easy entry)	High barriers (slow/costly entry)
Baseline transparency	Already a transparent market	Opaque market (exchange adds most)

Sources: Motta (2004[18]), Competition Policy: Theory and Practice; Thomadsen and Rhee (2007[19]) Costly Collusion in Differentiated Industries; OECD (2011[2]), Information Exchanges between Competitors under Competition Law; Awaya and Krishna (2020[20]), Information exchange in cartels.

These structural factors do not determine competitive effects in isolation, but they shape the extent to which different types of information and levels of detail influence firms' expectations and incentives, other factors that shape the competitive impact are considered below.

2.3.2. Characteristics of the information

Having considered the market conditions that shape whether information sharing is likely to affect firms’ expectations and incentives, the analysis turns to the characteristics of the information itself. Established analysis treats several characteristics as central to competitive risk: the subject matter of the information, its timing or age, its level of detail or aggregation, the frequency or pattern of disclosure, and whether it is genuinely public and readily accessible in practice (OECD, 2011[2]). Subsequent economic research has refined rather than displaced this framework, as highlighted in Box 2.

Box 2. Recent economic literature refining the analysis of information sharing

Recent economic research has refined rather than displaced the classic framework for assessing information sharing. Four of the most relevant developments are highlighted below:

Aggregate data may still be risky. Awaya and Krishna (2020[20]) show, in a repeated-oligopoly model with secret price cuts, that even aggregate sales disclosures can support near-perfect collusion when firms can infer rivals’ conduct from the shared data. The test is not whether data are labelled “aggregated” but whether they still permit sufficiently precise inference.

List prices and surcharges can be collusive focal points. Harrington and Ye (2019[21]) show that firms can collude by co‑ordinating on list prices or surcharges even where final transaction prices are negotiated. These announcements affect buyer behaviour and can raise transaction prices indirectly, making them economically significant despite not being the prices customers ultimately pay.

Private exchanges of prices can raise prices even without a classic cartel mechanism. Harrington (2022[22]) shows that a private exchange of prices, including non-transaction prices such as list prices and surcharges, can raise consumer prices under certain conditions without requiring the monitoring-and-retaliation mechanism of standard cartel models.

Unverifiable communication (“cheap talk”) can still facilitate collusion. Spector (2022[23]) shows that in markets where reliable sales data become publicly verifiable only with a delay, the early exchange of self-reported sales figures between competitors can support collusion even if those reports are unverifiable “cheap talk”. By allowing firms to detect market-share imbalances sooner and reallocate market shares without resorting to price wars, such communication reduces the window in which a deviation remains profitable.

Reducing information access asymmetrically can soften competition. Byrne et al. (2025[24]) exploit a natural experiment in Australian retail gasoline in which one firm lost access to a high-frequency price-sharing platform used by its rivals. Counter-intuitively, the shift from symmetric to asymmetric information sharing softened competition and raised margins, because the firm's strategic ignorance functioned as a commitment to higher pricing. The finding is a cautionary note for remedy design: restricting information sharing asymmetrically can have effects opposite to those intended.

Sources: Awaya, Y., & Krishna, V. (2020[20]) Information exchange in cartels. RAND Journal of Economics https://onlinelibrary.wiley.com/doi/full/10.1111/1756-2171.12320; Byrne, D. P., de Roos, N., Lewis, M. S., Marx, L. M., & Wu, X. (2025[24]) Asymmetric information sharing in oligopoly: A natural experiment in retail gasoline. Journal of Political Economy, https://www.journals.uchicago.edu/doi/10.1086/734872; Harrington, J. E., Jr., & Ye, L. (2019[21]) Collusion through coordination of announcements, The Journal of Industrial Economics, 67(2), 209–241, https://onlinelibrary.wiley.com/doi/full/10.1111/joie.12199; Harrington, J. E., Jr. (2022[22]) The anticompetitiveness of a private information exchange of prices, International Journal of Industrial Organization, 85, 102793, https://www.sciencedirect.com/science/article/pii/S0167718721000850?via%3Dihub.

Established analysis and the more recent work highlighted in Box 2 point to the same underlying question: does the information shared reduce strategic uncertainty between firms in ways that make co-ordination easier to sustain? Five characteristics of the information itself bear most directly on this question: its subject matter, its timing or age, the frequency with which it is disclosed, its level of detail or aggregation, and whether it is genuinely public in practice. These factors do not operate independently. As Box 2 illustrates, information that appears low-risk on one dimension, for example because it is aggregated, may still be competitively significant if it is disclosed frequently enough, or with sufficient structure, to permit inference about individual firms' conduct. The discussion below addresses each factor in turn, considering its likely effects all else equal, before Section ‎2.3.3 turns to the form and channel through which information is communicated.

Subject matter: Co-ordination is most likely where the shared information is one in which firms may have an incentive to align their conduct or monitor deviations from a co‑ordinated outcome. Information that bears directly on firms’ commercial conduct or intentions is therefore generally the most competitively sensitive (Kühn and Vives, 1994[13]). In price-setting markets, price-related information typically presents the greatest risk because it directly reveals how rivals are likely to behave. In quantity or capacity-setting environments, information on output, sales, capacity utilisation, market shares, or customer allocation may be equally or more important because it helps firms monitor deviations from output restraint or quota-like understandings. In negotiated-price markets, non-transaction prices such as list prices and surcharges may also be competitively significant (Harrington and Ye, 2019[21]). Information about costs or demand conditions may also facilitate co-ordination, particularly where it helps firms distinguish genuine shocks from opportunistic undercutting, but its effects are often more context dependent. Operational or technical information (for example, logistics, safety, or standards) is generally lower risk where not connected to the strategic factors on which co-ordination typically relies, although the assessment remains context-specific (OECD, 2011[2]).

Timing: Forward-looking information, including intended prices, planned capacity adjustments, or future commercial strategies, is generally the most sensitive because it reduces uncertainty about rivals’ future behaviour most directly. Recent work further illustrates this point by showing that disclosures of future price intentions can raise transaction prices even in the absence of any monitoring mechanism or reciprocal communication, by influencing firms’ expectations about future offers (Harrington, 2022[22]). Current information may also be competitively significant because it can affect rivals’ pricing or output choices directly and enable firms to monitor adherence to a co‑ordinated outcome by detecting deviations in real time or with only a short lag. Historical information generally raises fewer concerns the older it is at time of disclosure, because it becomes less helpful for firms monitoring deviations from co‑ordinated outcomes.

Frequency: Frequency of disclosure is closely related to timing because it affects how quickly information can be used. Frequent disclosures make it easier for firms to update their beliefs about rivals’ current positions, distinguish genuine market shocks from opportunistic deviations, and react before the gains from cheating dissipate. For the same reason, a systematic exchange repeated over months or years is generally more concerning than a one-off disclosure of equivalent content, because it provides an ongoing monitoring device rather than a single snapshot (OECD, 2011[2]).

Granularity: The level of detail or aggregation of the information also matters. Firm-specific or highly disaggregated data are generally more useful for co-ordination and monitoring than genuinely aggregated information, because they make it easier to identify or infer rivals’ conduct. However, the relevant question is not only whether data are nominally aggregated, but whether the aggregation is sufficient to make inference about individual firms difficult in practice. Recent economic research qualifies the older presumption that aggregate data are relatively low risk by showing that even aggregate sales disclosures may sustain near-perfect collusion where they allow firms to infer rivals’ behaviour with sufficient precision (Awaya and Krishna, 2020[20]; OECD, 2011[2]).

Publicly available: Whether information is genuinely public and readily accessible in practice is a further determinant of competitive risk. Information that is already observable to competitors and customers at low cost will generally raise fewer concerns, because its exchange is less likely to confer a private informational advantage or materially reduce strategic uncertainty beyond what the market already reveals. By contrast, information that is only nominally public may still be competitively significant where it is costly to collect, difficult to reconstruct, or sufficiently structured to reveal firm-specific conduct in practice.

2.3.3. How information is transmitted and processed

Beyond the characteristics of the information itself, the way information is disclosed also affects competitive risk. There can be differences in effect depending on the degree to which disclosure is targeted or broadly observable, one-way or iterative, direct or mediated through an intermediary, and merely transmitted or further processed into recommendations or other guidance. These features affect whether disclosures act as signals, monitoring devices, or inputs into rapid adjustment by rivals.

A first relevant dimension is the degree to which disclosure is targeted rather than broadly observable. This should be distinguished from the question, addressed in Section ‎2.3.2, whether information is already genuinely public and readily accessible in practice. Economically, private disclosure will often be more competitively significant because it gives rivals a targeted informational advantage that is not equally available to customers or other market participants. More broadly observable disclosure may nevertheless also soften competition where it is sufficiently detailed, regular, or forward-looking to shape rivals’ expectations and create focal points for alignment. Recent work shows, for example, that disclosures of future price-related information can influence transaction prices even without reciprocal communication or a classic monitoring mechanism (Harrington, 2022[22]; Harrington and Ye, 2019[21]).

A second dimension is the extent to which disclosure allows reciprocal feedback rather than remaining essentially one-way. Reciprocal sharing of information can reduce ambiguity more quickly by allowing firms to clarify, confirm, or update one another’s expectations, and may therefore be especially effective in supporting common understanding or monitoring. One-way disclosure may still be strategically significant, however, where it operates as signalling or a commitment device, particularly in concentrated markets where rivals can readily interpret and react to it (Harrington, 2022[22]; Kühn and Vives, 1994[13]). This connects the economics of information exchange to a broader literature on communication and collusion, which shows that firms may use both explicit and more indirect messages to co‑ordinate expectations, even though the latter are typically less effective in sustaining collusive outcomes (Andres, Bruttel and Friedrichsen, 2023[25]).

A third dimension is the use of intermediaries and whether their design facilitates the exchange or monitoring of the information. Intermediaries such as trade associations, benchmarking services, data pools,1 or common platforms can increase the competitive significance of information by standardising, regularising, and widening its dissemination, thereby making rival conduct easier to compare over time. The economic concern is therefore not the presence of an intermediary as such, but whether the intermediaries’ design makes information more useful for inference or monitoring. This helps explain why apparently lower-risk information may still facilitate collusion where the structure of disclosure allows firms to reconstruct rivals’ conduct with sufficient precision.

A final distinction concerns whether information is merely transmitted or also processed. Algorithmic systems and data-driven platforms do not simply convey market information; they may combine, interpret, and react to it at speed, or convert it into pricing recommendations and other strategic guidance. The implications of technology such as algorithmic facilitation for competition are discussed further below.

2.4. How new technologies fit in the economic framework of information sharing

The economic theory set out in the preceding sections was developed originally with traditional forms of information exchange in mind: periodic disclosures, trade-association statistics, and bilateral contacts between firms. Several technological developments have since changed the practical conditions under which information is shared, observed and acted upon, without displacing the underlying economic logic. This section considers three such developments: pricing algorithms that learn to co‑ordinate without explicit communication, common intermediaries through which information flows between rivals indirectly, and automated tools that have changed what counts as "publicly available" information.

First, pricing algorithms can now leave rivals as well-informed about each other's conduct as if they had exchanged information directly, using only prices that firms already post publicly. Computer experiments in which rival firms are represented by reinforcement-learning algorithms show that the algorithms consistently settle on prices above the competitive level, holding those prices through patterns of reward and retaliation similar to those that sustain classic cartels (Calvano et al., 2020[26]). Evidence from Germany's retail gasoline market points in the same direction: the adoption of pricing algorithms raised margins, but only in local markets where more than one competing station had adopted such algorithms (Assad et al., 2024[27]). Algorithmic interaction can therefore substitute for some of the functions that explicit communication or direct information exchange would otherwise serve, especially rapid monitoring of rivals and credible retaliation against deviations.

Second, common intermediaries that provide algorithmic pricing recommendations or benchmarking tools to multiple competing firms differ from ordinary algorithmic interaction because they centralise and standardise rival-relevant information. Instead of each firm observing public outcomes and reacting independently, a single intermediary processes information within a common framework and returns firm-specific guidance or benchmarks. In economic terms, this resembles a hub-and-spoke arrangement, and recent theoretical work shows that such structures can generate supra-competitive outcomes, with the intermediary’s efficiency itself facilitating collusion (Harrington, 2026[28]). Even non-binding recommendations can influence pricing behaviour, with outcomes depending on how deviations are treated (Hunold and Werner, 2025[29]). This reinforces the view that the competitive significance of information sharing depends not only on the data disclosed but on how it is processed, standardised and disseminated through shared infrastructure.

Third, automated price monitoring and web scraping have reduced the cost of observing rivals’ publicly posted prices to near zero, and the competitive implications cut both ways. Where rivals can already observe a firm's conduct continuously, the marginal contribution of additional disclosure is smaller. But the traditional presumption that genuinely public information is low risk rested on the assumption that some public information was not practically useful for real-time monitoring. Automation has weakened that assumption, so the competitive significance of public information may be closer to that of actively shared information than the traditional framework implies (OECD, 2024[30]).

These developments do not necessarily call for new theories of competitive harm. The mechanisms already used to assess information sharing, the formation of common expectations, the ability to monitor rivals, and the credible threat of retaliation, continue to explain when information sharing facilitates co-ordination. What has changed is the range of channels through which those mechanisms operate. For practitioners, this adjusts the dimensions in Section ‎2.3.2: the effective frequency of disclosure is now continuous rather than periodic, the age of information at the point of response has collapsed to minutes, firm-specific inferences can be drawn from data that appears aggregated or public, and the gap between technically accessible and practically useful information has narrowed.

Looking forward, foundation models and large language models are likely to extend this dynamic further, reducing the cost of converting unstructured public sources, such as regulatory filings, earnings calls and trade press, into actionable competitive intelligence. Agentic AI may cut the other way, allowing consumers to search, compare and negotiate bilaterally in ways that reduce firms' ability to observe each other's offers (CMA, 2026[31]; OECD, 2026[32]). These forward-looking effects remain emerging questions for further research.

Note

← 1.  Data pooling services are arrangements through which a third party collects data from multiple firms, standardises or aggregates them, and redistributes the resulting information often as benchmarks, market statistics, or comparative reports to participating firms or subscribers.