Antitrust Enforcement Around The World

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Most discussions of antitrust enforcement focus on the US and the European Union, but laws about enforcing competition have been spreading around the world. The October 2025 issue of the Review of Industrial Organization includes articles on the history and experience of the enforcement of competition policy in Brazil, China, Egypt, India, and five countries of Central and Eastern Europe. Russell Pittman offers some broader perspective in his “Editor’s Introduction to the Special Issue on Competition Law Enforcement in Developing Countries.” Pittman writes (citations omitted):

There are at least 125 countries and jurisdictions in the world with competition laws—
perhaps more. Some readers may not be aware of the relatively recent nature of this
state of affairs: There were only 12 competition law regimes worldwide in 1970, and
two of these—the Japanese and German—were forced upon the losers by the victors
in World War II. Countries with market economies gradually adopted competition
laws in the post-war period, to the point that there were about 40 competition laws
by the time of the fall of the Berlin Wall (1989). Over the 20 years that followed, the number exploded, to at least 110 by 2010; and, according to one authoritative source,
there are 135 today: 129 countries and 6 regional organizations.

What accounts for this explosion? In the most economically advanced of the Central and Eastern European (CEE) countries, reformers had included competition laws
in their legal and regulatory agendas from the beginning. In other CEE countries, the desire for an invitation to membership in the European Community clearly played more of a role … More broadly, many developing countries found that loans from the World Bank or the International Monetary Fund, as well as bilateral and multilateral trade agreements with wealthier countries, were conditioned on the writing and implementation of competition laws.

On the side of carrots—as opposed to sticks—developing countries around the
world have received technical assistance in writing and enforcing competition laws
and training agency staffs from sources as diverse as the U.S. Department of Justice,
Antitrust Division, and U.S. Federal Trade Commission, the European Commission,
OECD, UNCTAD, the World Bank, and successful younger competition agencies
such as the Hungarian Competition Authority, the Japanese Fair Trade Commission, and the Korea Fair Trade Commission.

The experience of competition law varies widely across countries. In Brazil, the laws don’t seem to have had much effect. In China, when antitrust authories took action against big platform firms like Alibaba, there were strong effect on the stock prices of firms in the same industry–that is, investors in Chinese stocks saw government antitrust as having considerable power. In India, the enforcement authorities have sometimes imposed fines for improper pre-merger notification, but have almost never blocked an actual merger. In my own reading, the evidence suggests that antitrust authorities in these countries do not seem to have much independent power. They rarely confront powerful incumbent firms, although in some cases (China), competition authority can be used as a club by the central government.


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