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ARTICLE · 10 NOVEMBER 2025

CMA Updates Cartels Leniency Guidance

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The UK's Competition and Markets Authority ("CMA") has updated its guidance on leniency and no-action applications in cartel investigations. The new guidance came into force on 28 October 2025, following a public...

United StatesAntitrust/Competition Law
Dina Jubrail
Dina Jubrail
Matthew Levitt
Matthew Levitt
Kassia Pletscher
Kassia Pletscher

1. Summary

The UK's Competition and Markets Authority ("CMA") has updated its guidance on leniency and no-action applications in cartel investigations. The new guidance came into force on 28 October 2025, following a public consultation earlier in the year.

The changes are intended to bring the guidance into line with relevant legislation, as well as reflecting developments in the CMA's policy, experience and processes. These include delaying the requirement for a leniency applicant to admit their participation in cartel activity, removal of upfront immunity for corporate Type B1 applicants and of automatic immunity for director disqualification for directors of corporate Type B and Type C leniency applicants, and clarification regarding the range of discounts available for Type B and Type C applicants.

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