United Kingdom: Digital Markets, Competition and Consumers Bill including unilateral conduct regulation entered into force

On 1 January 2025, the unilateral conduct provisions of the Merger Control and Antitrust Rules in the Digital Markets, Competition and Consumers Act 2024 entered into effect, enabled by Statutory Instrument 2024 No. 1226 (C. 78). In particular, the Bill introduces an ex-ante regulatory regime for companies with "strategic market status" in digital markets. The Competition and Markets Authority can designate companies with a global turnover of over GBP 25 billion or a UK turnover of over GBP 1 billion as having "strategic market status" if they hold substantial market power or have strategic influence. Designated firms are subject to conduct requirements and dedicated codes of conduct. In addition, the CMA can impose behavioural and structural remedies if an investigation concludes that a designated company can exert an adverse effect on competition.