Market studies and other market analysis tools for competition authorities

3. Market Investigations

In general, market studies provide a means for competition authorities to identify competition problems within a sector, but other than initiating further investigations, they do not provide the ability to rectify them. Instead, addressing underlying competition issues often relies on others accepting the recommendations and taking action. This section discusses market investigations, an extension of market studies with remedial powers.

Such an extension marks a departure from the principles of many competition law regimes, where the possibility to impose remedies depends on the conduct of relevant parties. Deciding to expand competition law in such a way is therefore not a step to be taken lightly and may not be appropriate given the context in a jurisdiction.

3.1. What are market investigations?

3.1.1. Definition of market investigations

As with market studies, the term market investigation can have different connotations to different audiences, with alternative names used for similar tools. In defining the term market investigation for this paper, the goal is to clarify what is being discussed rather than propose a strict definition.

Broadly, the main distinguishing feature of market investigations is that they provide powers for competition authorities to impose remedies on firms after finding a competition issue in a sector. This could include the ability to place behavioural restrictions on firms, and even potentially the ordering of structural remedies through divestment.

Put another way, for the purposes of this paper the main difference between market studies and market investigations is having some form of power to impose remedies on firms at the end. Note however that within this definition, market investigations do not necessarily need a full suite of remedial powers, with any level of power being sufficient to warrant a distinction from market studies.1 The section below summarises some examples of such powers.

Similar remedial powers may exist in other forms. For example, in Israel firms classified as monopolies may be subject to a set of remedial instructions when there is evidence of demonstrable harm to market competition or the public.2 In the sense that remedies can be implemented to improve competition absent a specific finding of wrongdoing, this shares some similarities with market investigations. Nonetheless, this paper only considers tools that apply to markets as a whole as market investigation powers.

3.1.2. Examples of market investigation powers

Most jurisdictions within and outside of the OECD do not have market investigation powers as defined above. However, while these powers were once reserved for only a handful of authorities, there appears to be a growing number of jurisdictions that have some form of market investigation powers. Table 2 summarises examples of jurisdictions that possess market investigation powers, including when they were enacted, the scope of the powers, as well as their timeframes and how they can be initiated.

Table 2. Summarised examples of market investigation powers

Country	Date introduced	Scope of remedial powers	How initiated?
UK	2002	Broad*	After market study reference
Greece	2005	Broad	Self-initiated or per request of the Ministry of Economy, Competitiveness and Shipping
Iceland	2011	Broad	Self-initiated
Mexico	2013	Broad	Self-initiated or per request of the Executive Branch
South Africa	2018	Broad (divestitures required order by Competition Tribunal)	Self-initiated or per request of the Minister
Germany	2023	Broad (stricter rules for structural remedies)	Self-initiated
Italy	2023	Broad	Self-initiated
Denmark	2024	Only behavioural remedies	Self-initiated
Norway	2025	Broad (stricter rules for structural remedies)	Self-initiated

Note: * Broad remedial powers refer to the ability to order a range of different measures, including the divestiture of assets.

Sources: CMA (2013), “Guidelines for market investigations: their role, procedures, assessment and remedies”, Available at CC3 (Revised), Guidelines for market investigations: Their role, procedures, assessment and remedies (publishing.service.gov.uk); Article 11 of Greek Competition Law, Law 3959/2011; Lianos I. (2005), “The Greek Parliament votes the reform of the competition Act (Law, 2 August 2005)”, e-Competitions News Issue, Concurrences, p. 7; Fletcher, A.(2021), 'Market Investigations for Digital Platforms: Panacea or Complement?', Journal of European Competition Law & Practice, Vol. 12, p. 44–55; Mena-Labarthe C., (2016), “Market Investigations as a New Tool for Competition Agencies: The Mexican Experience”, OECD (2020), “GFC: Using market studies to tackle emerging competition issues – Contribution from Mexico”; CPI Antitrust Chronicle; Whish, R. (2020), “New Competition Tool: Legal comparative study of existing competition tools aimed at addressing structural competition problems with a particular focus on the UK’s market investigation tool”, Directorate-General for Competition Expert Study; Icelandic Competition Authority, Rules on Market Investigations Carried Out by the Competition Authority, https://en.samkeppni.is/competition-rules/legislation/rules-on-market-investigations/; Competition Commission of South Africa, South African Competition Act 1998, https://www.compcom.co.za/wp-content/uploads/2021/03/Competition-Act-A6.pdf ; Bonakele T., Das Nair R., Roberts S., (2022), “Market Inquiries in South Africa : Meeting Big Expectation?” in: Motta M, Peitz M, Schweitzer H, eds. Market Investigations: A New Competition Tool for Europe?. Cambridge University Press; p. 291 – 319; Lesofe I., Tetani S., (2023), “Using market inquiries: A sharper tool for competition authorities?”, South African Mercantile Law Journal, Volume 35 Issue 3, 2023, p. 327 – 369; Bundeskartellamt, Sector Inquiries and Remedies, https://www.bundeskartellamt.de/EN/Tasks/Sector_inquiries/Sector_inquiries_node.html#frage1; OECD (2023), Annual Report on Competition Policy Developments in Italy, p. 6; Danish Competition Authority (2024) English Translation of Danish Competition Act, https://en.kfst.dk/media/s4ybfdap/the-danish-competition-act-1150-af-03112024.pdf; Norwegian Competition Authority Press Release, Market investigation comes into effect today, 01/07/2025, https://konkurransetilsynet.no/market-investigation-comes-into-effect-today/?lang=en#:~:text=As%20of%20today%2C%20the%20Norwegian,violation%20of%20the%20Competition%20Act.

As the table demonstrates, over half of the countries with some form of market investigation power have been granted it within the last seven years, with three countries receiving in since 2023. Part of this interest may be driven by a view that competition issues in digital markets may require additional tools to remedy.

Nonetheless, with the exception of the UK, Greece, Iceland and Mexico, market investigations are still relatively new and experience is therefore likely to be fairly light. The UK has had the power for over 20 years and has the most experience with market investigations, with others generally having had significantly less experience with them. In general, other than the UK, Mexico and Greece appear to have carried out the next highest amount of market investigations, but seem to have each completed closer to ten and five respectively in total (European Commission, 2020[14]). Usage of the tool may increase as time proceeds since those who recently acquired the power begin to use it.3

In addition, there have been discussions regarding the potential introduction of market investigations in several other countries, including some competition authorities arguing that they needed these powers. Some of these discussions have resulted in decisions not to proceed, and it is not clear that all interest will result in powers being enacted. Nonetheless, it further emphasises the increasing relevance of market investigation tools. Box 4 summarises some recent developments in this regard.

Box 4. Competition authorities and potential market investigation powers

Several jurisdictions have expressed the desire to enhance their investigation powers through the adoption of new tools for competition, or actively considered whether to do so.

Czechia

In 2024, the Czech Competition Authority (CCA) suggested deploying a “new competition tool” within the update of the Czech Competition Act. Currently, the CCA can run sectoral investigations to monitor markets, but cannot impose remedies without initiating a formal investigation of an anticompetitive agreement or an abuse of dominance. This is where the CCA believes it may need other powers, for instance by being able to make companies adhere to transparency standards, publish information or, in extreme cases, amending aspects of the business.

Sweden

A conference organised by the Swedish Competition Authority in 2024 considered the potential value of market investigation tools. After this, a study by the Swedish Government considering new legislation to strengthen competition was published in March 2025, concluding that there were certain competition issues in Swedish markets that could not be effectively tackled under current legislative frameworks. To remedy this problem, it proposed the introduction of a new tool that would allow the Swedish Competition Authority to impose structural or behavioural remedies, but only after meeting some transparency conditions with the parties involved.

The Netherlands

In October 2024, the Minister of Economic Affairs issued a letter addressed to the Speaker of the House of Representatives, stating the necessity for a new competition tool to conduct market investigations to address competition issues encountered in some sectors, including increase in concentration or lock-in issues. In particular, he mentioned the introduction of a research and remedial authority, citing other countries and the Draghi report. The ministry is therefore studying different options for structuring such remedial powers.

European Union (EU)

In June 2020, an initial public consultation was launched on the potential need for a change in competition rules to allow for enforcement action preserving the competitiveness of markets, namely through a New Competition Tool (NCT). However, significant pushback was raised by business representatives, regarding concerns over the tool’s extensive scope and the potential uncertainty this would cause. Based on this feedback and wider analysis, the EC decided to incorporate some elements into the Digital Markets Act (DMA), abandoning at that time the idea of an NCT. Following recommendations by the Draghi report in 2024, the idea of an NCT in the EU has once again been raised as a point of discussion.

Sources: Office for the Protection of Competition, Opening remarks of the Chairman of the Office for the Protection of Competition Petr Mlsna delivered at the International Chamber of Commerce Czech the Antitrust Conference in Prague on 24 April 2025, https://uohs.gov.cz/en/information-centre/press-releases/competition/4195-new-competition-tools-the-way-to-more-efficient-competition-law-enforcement.html; . Swedish Competition Authority (2024) The Pros and Cons of New Tools, https://www.konkurrensverket.se/en/knowledge-and-research/the-pros-and-cons/the-pros-and-cons-of-new-tools/; Sveriges Riksdag (2025), Improved Competition in Public and Private Activities, https://www.riksdagen.se/sv/dokument-och-lagar/dokument/statens-offentliga-utredningar/forbattrad-konkurrens-i-offentlig-och-privat_hdb322/html/; Authority for Consumers and Markets Press Release, “Speech Martijn Snoep: De New Competition Tool, het waarom en het hoe”, 10/02/2025, https://www.acm.nl/nl/publicaties/speech-martijn-snoep-de-new-competition-tool-het-waarom-en-het-hoe ; European Commission, Single Market – new complementary tool to strengthen competition enforcement, https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12416-New-competition-tool_en; European Commission (2024) The Draghi report on EU Competitiveness, https://commission.europa.eu/topics/eu-competitiveness/draghi-report_en.

3.1.3. Approaches to market investigations

A key consideration in the design of market investigation tools is when remedial powers are triggered. Two elements are relevant for this. First, when and how a market investigation can be launched. Second, the requisite bar to surpass in order for remedy provisions to be triggered.

In most circumstances, competition authorities with market investigation powers appear able to launch one at their own initiative. For authorities that possess both market study and market investigation powers, a decision may be required on which tool will be the most appropriate in the circumstances. Another model, for example used in the UK, is a two-phase system. Under the UK model, a market investigation is a possible outcome of a market study, if it concludes that there are competition issues and makes a referral to a second stage market investigation.4 The market study could be completed by the CMA or by a concurrent competition regulator in the UK, such as the Financial Conduct Authority or the Office of Communications (Ofcom).5

The second element is the legal test for when, and which, remedies can be applied. This is a noticeable difference between market studies and market investigations. While in market studies, authorities will inevitably follow a process in deciding when to recommend remedies, with a market investigation a legal threshold will be required. These legal tests, like other areas of competition law, typically start in legislation and then evolve over time through the courts. There are usually two aspects to the legal test. First, it is necessary to establish that there is a sufficient competition issue that requires a remedy. For example, this could be the finding of an adverse effect on competition, as in the UK.6 The second aspect is whether the proposed remedy is necessary and proportionate given that finding, and includes that less intrusive remedies would not lead to as effective an outcome.

3.1.4. Due process and appeals

Broadly, the steps for a market investigation will be similar as for a market study, although there will likely need to be additional procedures to ensure ample consultation with potentially affected firms. For example, in Iceland, the law specifies that parties subject to a market investigation enjoy the same rights as they would during an enforcement investigation (European Commission, 2020[14]).

As administrative decisions that can have major implications for affected firms, the decisions of market investigations will generally be subject to appeal. Appeals might challenge the legality of the findings, such as challenging that a significant competition problem exists, or that the remedies enacted are appropriate. Appeals may result in decisions being annulled or remitted to the competition authority to reconsider. For example, in the case of the market investigation into private healthcare in the UK, following an appeal in relation to the London market, the Competition Appeals Tribunal set aside some of the CMA’s findings and remitted the case back to the CMA to reconsider.7

There are also a range of time limits for market investigations. Some authorities are provided with clear timeframes under which, barring limited or exceptional circumstances, a market investigation must be completed.8 As with market studies, there may be limited provisions to extend deadlines in certain pre‑defined circumstances. Others do not appear to have similar constraints, in some cases market investigation powers appearing more open-ended. For regimes that possess both market study and market investigation powers, there may be a need to decide at the launch of an inquiry which route will be followed.

Given the impact of the findings and outcomes on markets, market investigations typically have stronger requirements to consult with stakeholders prior to being finalised. For example, in Greece, there is a requirement for the Hellenic Competition Commission (HCC) to “publish its opinion in an adequate and appropriate manner and open it to public consultations.”9 Consultations should be based on both the expected findings and the proposed remedies.

There are also likely to be requirements on competition authorities to publish clearly at the beginning of an investigation the fact that it is being launched and its expected scope. For example, in Mexico, at the beginning of a market investigation, it must publish a notice in the Federal Official Gazette clearly stating the market being analysed (European Commission, 2020[14]).

3.1.5. Types of remedies

As the main distinguishing feature of market investigations, it is worth briefly considering the range of remedies that may be available within them. A lot of prominence is given to the potential for market investigations to lead to structural remedies, such as a forced divestiture of a set of assets by a firm. However, even in the context of relatively limited experience of market investigations across the world, structural remedies are very rare.

That said, some examples of structural remedies from market investigations exist, most of which are from the UK, which appears to have ordered divestitures relatively few times, with the order appearing to have been carried out at least twice (in another case a revised order following remittal removed the need for divestiture). Box 5 summarises examples of remedies that have been implemented after market investigations, including past examples of divestitures.

Beyond divestitures, a range of other remedies are possible which may have the potential to boost competition. These can include orders that restrict firm behaviour or place them under certain obligations. This could even extend to price regulation in some circumstances, or require customers to market their businesses more widely. While market investigations extend the powers of competition authorities to some extent, this is not without limitations. Market investigation powers do not generally, for example, extend to provide competition authorities with the ability to create or alter legislation. In this regard, recommendations can be made to propose changes, much as is the case for market studies.

The existence of market investigation powers does not mean that remedies will necessarily need to be imposed. For example, in a recent market investigation by the CMA into cloud computing services competition issues were identified, but rather than impose remedies, the CMA decided to consider the issues in more detail under the Digital Markets, Competition and Consumer Act.10

Box 5. Examples of market investigation divestiture and price control remedies from the UK

Despite conducting many market investigations since acquiring the power, the UK competition authorities have used structural remedies in relatively few occasions.

In 2009, following a market investigation into airports owned by BAA, the Competition Commission (CC), one of the predecessor bodies to the Competition and Markets Authority (CMA), found that the common ownership of airports in south-east England and lowland Scotland gave rise to adverse effects on competition (AEC). To effectively remedy this, the CC ordered the divestiture of several airports by BAA, namely both Stansted and Gatwick airports in south-east England, and either Edinburgh or Glasgow airport in lowland Scotland. After several appeals, the three airports were sold to new owners in the following years, Gatwick in 2009, Edinburgh in 2012 and Stansted in 2013.

Further, following a market investigation into aggregates, cement and ready-mix concrete in January 2014, the CC released its final report, identifying several AECs and noting that a mix of remedies were required, including two structural remedies. This included the divestiture of a cement plant by Lafarge and a ground granulated blast furnace slag plant by Hanson. Both parties appealed the decision. In parallel, as part of the remedy process for the merger between Lafarge and Holcim, Lafarge divested most of its UK cement business, hence complying with the market investigation order. Following an unsuccessful appeal, Hanson completed the sale of its GGBS plant in Scunthorpe in July 2015.

Market investigations can also result in price controls, for example in situations where the prospect of improving competition sufficiently to protect consumers from high prices in the short-term is particularly low. Such controls are undertaken rarely due to their potential to distort markets and the competitive process, but have been used in limited circumstances in the past. One example can be seen from the CMA’s final report in 2016 as part of the energy market investigation, where the CMA ordered the introduction of a price-cap for a category of energy consumers that received supply through prepayment meters.

Source: Competition Commission (2009) BAA airports market investigation, A report on the supply of airport services by BAA in the UK, https://webarchive.nationalarchives.gov.uk/ukgwa/20140402170726mp_/http://www.competition-commission.org.uk/assets/competitioncommission/docs/pdf/non-inquiry/rep_pub/reports/2009/fulltext/545.pdf; CMA (2016) BAA airports: Evaluation of the Competition Commission’s 2009 market investigation remedies, https://assets.publishing.service.gov.uk/media/57399d43ed915d152d00000b/evaluation_of_baa__market_investigation_remedies.pdf; Press release, CMA welcomes the sale of cement and GGBS plants, 05/08/2015,CMA website, https://www.gov.uk/government/news/cma-welcomes-the-sale-of-cement-and-ggbs-plants; Press release, Slot allocation at Keflavik Airport disrupts competition in the air transport market, 11/08/2013, Iceland Competition Authority website, Slot allocation at Keflavik Airport disrupts competition in the air transport market | News | The Icelandic Competition Authority

3.2. Overview of considerations for market investigations

In considering the appropriateness of market investigation tools within a jurisdiction, many factors will be relevant, including the specific national and legal context, as well as other legal tools. Further, even if the tool exists in a jurisdiction, authorities will likely carefully consider when it is appropriate to use. This section discusses some of the possible benefits of using market investigations, as well as some of the challenges.

3.2.1. Potential benefits

Significant competition issues can arise due to market features or behaviour not captured by traditional competition law (Peitz and Motta, 2020[3]). The promise of market investigation tools is the ability to improve competition holistically, without relying on evidence of individual breaches of competition law (Van Den Boom et al., 2023[15]). Such a tool may be particularly relevant for consideration in the context of digital markets, where underlying issues may reduce the effectiveness of competition, even beyond potential breaches of competition (Fletcher, 2021[16]).

Market investigations provide the independent power for competition authorities to impose structural or conduct remedies to resolve competition issues in a flexible manner, without needing to rely on further legislative or regulatory efforts (Fletcher, 2021[16]). While market studies also study competition, beyond conducting enforcement action where appropriate and possible, they must rely on adoption of recommendations by policy makers, which may not have an instrument other than primary legislation through which to enact them.11 Irrespective of the merits of the recommendations proposed, there may be reasons that these do not get implemented, such as administrative costs for public servants that are not competition experts to assess the proposals, multiple competing priorities for limited attention/capacity, as well as the risk of broader political considerations having effect. Even taking aside the question of whether the recommendations are considered at a government level, there are clear cost and time implications.

Focussed competition remedies made by teams with in-depth knowledge of the sector, following an investigation, but also potentially allowing the supplementation of knowledge from previous work, could deliver substantial benefits in terms of improved competition, in a way unlikely to be addressed through other tools due to the factors noted above. For example, the CMA’s evaluation of its predecessor body’s market investigation into airports, described above in Box 5 and which resulted in the divestment by BAA of three airports, estimated that benefits to UK consumers were likely to be at least GBP 870 million between 2009 and 2020.12

Another potential benefit of such a power residing within a specialist competition authority is that it provides one agency with the potential to consider how to promote competition with a full set of tools (Van Den Boom et al., 2023[15]). While a lot of discussion around market investigation tools focusses on the potential for divestments, as noted above, in practice these are rare. There are also a range of other remedies that have the potential to boost competition holistically. Evidence-based decisions made by an independent competition authority also reduce the risk of political interference or lobbying, compared to decisions made through a broader political process.

While a potential negative is the costs that companies may incur as part of an investigation or probe, appropriate processes should ensure they have the ability to appeal through the court system.

3.2.2. Potential drawbacks

In some jurisdictions, market investigations could see a shift in the nature of competition authorities, allowing remedial action absent competition law breaches. That said, many of the considerations in the section above on the limitations of market studies will also apply to market investigations. For example, despite their remedial powers, market investigations may not be suitable substitutes for enforcement action in many situations. Without the ability to impose penalties, market investigations may not be able to generate a sufficient level of deterrence, notwithstanding the potentially large costs of remedies that could be imposed. Further, as noted above, if the underlying competition issues are driven by issues with existing regulations, the additional powers are unlikely to lead to different outcomes compared to market studies.

Market investigations, by their nature, are typically long and costly exercises for competition authorities. Appeals are likely when significant remedies are imposed, likely furthering cost implications. While costs can be high, perhaps one of the largest issues is the length of time required for actual changes to be made. Given the fact that costs may be incurred on parties absent evidence of wrongdoing, robust checks and balances are required to ensure due process (European Commission, 2020[14]). This means however that market investigation tools may not be the solution for pressing or urgent issues.

Market investigations also have the potential to impose significant costs for firms participating in them, much as with market studies. In addition, however, there could be significant costs if remedies are implemented and this could affect firms independently of any illegal activity. While the relationship between competition and innovation can be complicated (OECD, 2023[17]), legal uncertainty can reduce firm investment incentives. This could be the case for example if the prospect of having to divest assets in the event of a market investigation became a reality. While the existence of market investigation powers could create this possibility and therefore lead to increased legal uncertainty, as divestments appear rare, it is not clear that in themselves this would lead to a significant increase in legal uncertainty just because an authority was granted the power.

Remedies may pose potentially complex and complicated trade-offs with policy areas other than competition, requiring judgements which competition authorities may not be best placed to make. It is worth noting that, while there are risks of political interference in market investigations, this may not always be inherently negative. While there are risks of short-termism and distortions based on lobbying, decision making should generally follow the outcome of democratic political processes. In this sense, market investigations do not truly create new possibilities, just allocate powers differently and, some will argue, inappropriately. There may also be interesting policy trade-offs when remedies interact with regulations or are within the remit of other regulators, and may require additional protocols and co-operation mechanisms.13 This weakens the potential remedial power of market investigations. Further, such powers have the potential to put strain on authorities’ political independence, as government may see such powers as an opportunity to enact changes at arm’s length.

Another limitation of the process is that the nature of a market investigation can create dynamics where remedies are to some extent “one-shot”, as typically the power to impose remedies is tied to the legal instrument. In practice this usually means that they are imposed at the end of the study. This may limit the ability to make remedies robust to changing circumstances. There may also be challenges in devising complex remedies within defined timeframes. Depending on the instruments available, there may be some ability to reduce this risk by allowing clauses in orders or, as longstanding practice, prefer remedies with definitive timeframes, such as structural remedies. On the other hand, remedies that do endure over time may require significant resources from authorities to monitor or adapt (Fletcher, 2021[16]).

More generally, there is debate on the scale of the gap between practices covered by traditional enforcement and other competition issues (Colangelo, 2024[18]). This gap is further brought into question in the context of ex-ante competition regulation, that has been adopted and is being considered in some jurisdictions in relation to digital markets (OECD, 2021[19]). The smaller the gap, the lower the potential benefits of market investigations would be.

Given the significance of imposing remedies that may entail substantial costs on businesses independently of a finding that their conduct has breached the law, as discussed above, due process and robust procedures are required to ensure affected parties are able to provide evidence to contradict findings and propose alternative solutions (Fletcher, 2021[16]).

Notes

← 1.  For example, powers to impose divestment remedies are not needed in order for a tool to be considered a market investigation, as long as other forms of remedy can be imposed on firms.

← 2.  Unlike broader market investigation powers however, these powers rely on a market share of 50%, or a finding of being a monopoly, and relate only to those specific firms rather than markets as a whole. See OECD (2011), Competition Law and Policy in Israel 2011, pages 32-34, https://doi.org/10.1787/9789264097667-en..

← 3.  Recently for example, the Budeskartellamt announced the first use of its new tool, see Bundeskartellamt Press Release, Bundeskartellamt examines significant malfunctioning of competition in the wholesale of fuels – first proceeding based on new competition tool, 06/03/2025, https://www.bundeskartellamt.de/SharedDocs/Meldung/EN/Pressemitteilungen/2025/03_06_2025_Proceeding_32f.html. In addition, the Italian competition authority launched an investigation into pricing by airlines where it noted it could use its new powers, see Autorità Garante della Concorrenza e del Mercato Press Release, IC56 - Italian Competition Authority: launch of a sector inquiry on pricing algorithms for air passengers on routes to and from Sicily and Sardinia,16/11/2023, https://en.agcm.it/en/media/press-releases/2023/11/IC56.

← 4.  For more information on the UK market study and market investigation regime, see CMA (2013) Market Investigation Guidelines: CC3, https://www.gov.uk/government/publications/market-investigations-guidelines.

← 5.  The recent cloud market investigation, for example, followed a referral to a market investigation following a market study by Ofcom, see: CMA, Cloud Services Market Investigation, https://www.gov.uk/cma-cases/cloud-services-market-investigation.

← 6.  CMA (2013) Market Investigation Guidelines: CC3, https://www.gov.uk/government/publications/market-investigations-guidelines.

← 7.  See CMA, Private Healthcare Market Investigation, https://www.gov.uk/cma-cases/private-healthcare-market-investigation#timetable-1.

← 8.  For example, in the UK there is an 18 month timeframe for market investigations, while in Mexico, the investigation phase is limited to no more than 120 days, after which a preliminary report must be issued within 60 days (European Commission, 2020[14]).

← 9.  Article 11(2) of the Greek Competition Act, https://www.epant.gr/en/legislation/protection-of-free-competition.html.

← 10.  CMA (2025) Cloud Services Market Investigation, https://www.gov.uk/cma-cases/cloud-services-market-investigation.

← 11.  In cases where secondary legislation can be amended to address problems, this will still require action from the relevant part of government.

← 12.  Competition Commission (2009), BAA airports market investigation, A report on the supply of airport services by BAA in the UK, https://webarchive.nationalarchives.gov.uk/ukgwa /20140402170726mp_/http://www.competition-commission.org.uk/assets/competitioncommission /docs/pdf/non-inquiry/rep_pub/reports/2009/fulltext/545.pdf.

← 13.  It may also be unclear which would take precedence in the event that there are contradictions between market investigation remedies and sector regulator decisions.