Irish Merger Control in 2025:

Given the potential impact on transaction timetable and in some cases on deal certainty, it is important that businesses consider merger control (and indeed foreign investment controls which came into effect just over a year ago) early in any given transaction. Understanding the potential impact of these regimes is essential for any company, investor or stakeholder planning transactions in 2026.

1. Record Activity

In 2025, the CCPC received 90 merger notifications, representing a 9.8% increase on the previous year and a 32% rise since 2023. This growth demonstrates a strong and resilient M&A market in Ireland, where businesses continued to pursue strategic acquisitions despite global uncertainty. M&A activity was driven by mid-market transactions, cross-border investment and private equity interest, with notable consolidation across Professional Services, Manufacturing, and Construction sectors. Media mergers also doubled, highlighting the breadth of activity and the growing complexity of transactions. The increase in merger control notifications highlights the importance of Ireland’s merger control regime to the M&A market and signals that businesses are operating in an environment where regulatory scrutiny is active but efficient.

2. Faster Reviews

The CCPC issued 91 determinations during the year, including 12 carried over from 2024. Whilst the majority of transactions were cleared quickly, the data shows a nuanced picture. Over two-thirds of determinations were made under the SMNP, with these cases cleared in an average of 12.5 working days. Phase 1 reviews averaged 17 days in the absence of an RFI or 28 days to issue a standard Phase 1 decision, but Phase 2 investigations extended to nearly 200 working days.

Compared to the European Commission, which clears over 90% of notified mergers at Phase I, often via its simplified procedure, Ireland’s 70% SMNP clearance rate demonstrates a similar commitment to efficiency whilst maintaining rigorous oversight where necessary. This alignment with EU trends reinforces confidence that Ireland’s merger control regime supports deal-making whilst safeguarding competition.

3. Remedies and Phase 2 Investigations

Although most mergers in 2025 were cleared without conditions, a small number required extended reviews and commitments to address competition concerns. The CCPC progressed six Phase 2 investigations during the year, and several Phase 1 cases also involved remedies. These commitments typically fell into two categories, namely,:

1. Structural Remedies: The CCPC required some divestments of assets or businesses to maintain competitive market structures. This included selling sites, facilities or customer accounts to approved third parties to prevent market concentration in local or national markets.

2. Behavioural Remedies: Historically, competition authorities have been reluctant to accept behavioural remedies due to concerns around monitoring, enforceability and effectiveness. However, in recent years both the European Commission and the UK’s Competition and Markets Authority have shown greater openness to such commitments. The CCPC’s acceptance of behavioural remedies in 2025 reflects this trend. For example, in M/24/075 - Dalata Hotel Group / CG Hotels (Radisson Blu Hotel Dublin Airport), the parties agreed to operate the Maldron Hotel independently for a defined period, preserving competitive choice. Similarly, in M/25/045 - BWG Foods / Perry’s Cash and Carry, the CCPC required strict information-sharing firewalls to prevent anti-competitive coordination. These developments signal a shift towards more flexible solutions, aligning the CCPC with broader international practice.

All remedies were subject to legally binding conditions, with independent monitoring trustees appointed to oversee implementation and ensure compliance with the CCPC’s requirements. For stakeholders, this underscores the importance of early engagement and proactive planning to secure timely clearance.

4. Regulatory Developments

2025 was also a year of structural and policy change in Ireland. The CCPC reorganised its competition functions, creating a dedicated Mergers Division separate from Antitrust enforcement. This move reflects the growing complexity of merger control.

Looking ahead, stakeholders should prepare for changes to the financial thresholds for mandatory notification as the CCPC has recommended an increase to such thresholds to enable better focus on the transactions with the greatest competitive impact (which would be  a welcome outcome for the M&A market). In addition, draft revised Merger Guidelines are expected in 2026, which will set out best practice and address emerging issues such as digital markets, innovation and dynamic competition.

5. Media & Digital

Media mergers were a particular focus in 2025, with eight notifications compared to three notifications in 2024. The forthcoming Media Regulation Bill, which will implement the European Media Freedom Act, will expand the definition of media businesses to include online platforms and introduce new thresholds for notification. At the same time, the CCPC continues to engage actively at EU level, co-chairing the European Competition Network’s Mergers Working Group and contributing to the European Commission’s review of its Horizontal and Non-Horizontal Merger Guidelines. These developments signal a future where digital and sustainability considerations will play an increasingly central role in merger control analysis.

6. Below Threshold Deals

When the CCPC was granted the power to ‘call in’ transactions below the notification thresholds, it generated significant discussion among practitioners. However, the 2025 Report confirms that this power has not yet been exercised by the CCPC, albeit the CCPC noted that it did examine several cases closely and refined their internal processes.

7. Takeaways

The 2025 Report makes clear that merger control in Ireland is evolving rapidly.  While the vast majority of Transaction are cleared relatively quickly, where substantive issues arise this can add significant time to overall transaction timelines.  Early engagement with the CCPC and careful planning of remedies can make the difference between a smooth clearance and a prolonged review. Businesses should also anticipate regulatory changes in 2026, including higher notification thresholds and updated guidelines that reflect the realities of digital markets and innovation-driven competition.

Contact Us

At Eversheds Sutherland (Ireland) LLP, our dedicated Competition, Trade and Foreign Investment team, led by Claire Morgan, combines deep regulatory insight with practical, commercial advice. Working together with our experienced Corporate M&A team, we guide clients through every stage of the merger control process in addition to broader competition compliance challenges.