On 9 September 2025, the Czech ICC Commission on Competition held a meeting with representatives of the Czech Competition Authority, chairman Petr Mlsna and vice-chairman for competition Kamil Nejezchleb. The discussion provided a clearer picture of the upcoming legislative changes, enforcement priorities, and new tools that will significantly influence competition law in the Czech Republic.
We both attended the meeting. We expected plenty, but the scope of the planned reforms—and the strengthening of the Czech Competition Authority – took us by surprise. Of course, the legislative process will not begin until next year, but it is already useful to know what the Czech Competition Authority intends to achieve. Let’s take a closer look at what lies ahead.
Amendment to the Competition Act and the New Competition Tool (NCT)
The Czech Competition Authority plans to reintroduce the long-awaited New Competition Tool (NCT). This instrument, currently missing from the authority’s toolbox, would allow the Czech Competition Authority to intervene even in markets where it does not find any legal infringement (such as a cartel or abuse of dominance). Compared to the original draft, the tool is meant to be faster (intervention within one year instead of four) and to include not only behavioural remedies but also structural ones (for example, ordering a divestment). Structural measures, however, would be used only if behavioural remedies failed. The scope would now also extend to regulated sectors such as telecoms, energy, and banking. The legislative process should begin in early 2026.
Individual Liability and Procedural Changes
The Czech Competition Authority confirmed its plan to introduce personal liability for individuals involved in hardcore cartel agreements, with possible penalties of up to CZK 10 million or a ban on activity of up to five years. The declared aim is not primarily to punish individuals, but to use them as a source of evidence against companies. Other changes include faster settlements, more efficient dawn raids (with part of the review carried out on the Czech Competition Authority’s premises), clearer obligations on companies during inspections (e.g., bringing in a computer from home if required), and stricter sanctions for non-cooperation (up to 5% of turnover).
Enforcement Priorities
The Czech Competition Authority’s main priority remains cartels, especially bid rigging, due to their impact on public procurement. The authority is also paying more attention to abuse of dominance and is conducting sector inquiries (currently in non-alcoholic beverages, waste, and EV charging). Another focus is tackling territorial supply restrictions, where the Czech Competition Authority is pushing for legislative changes at the EU level. Increasingly, the Czech Competition Authority is also focusing on labour market agreements (no-poach and wage-fixing).
Inspections and Court Case Law
Divergent case law in recent years has led the Czech Competition Authority to adjust its practices, with a stronger focus on clear procedural steps, cooperation obligations, and proportionality. The authority is also considering the use of AI tools for market monitoring and evidence gathering – provided funding is available for developing tailored solutions.
Labor Market Agreements
The Czech Competition Authority stressed that no-poaching, non-solicitation, and wage-fixing agreements are hardcore restrictions. Until now, the authority has mainly taken a preventive and awareness-raising approach. That “grace period,” however, is ending – violations will now be fined. Priority sectors include sports and highly skilled professions, though the focus could expand to other labor markets. The Czech Competition Authority is also considering what baseline to use for calculating fines.
Merger Control: Call-In Model and Higher Notification Thresholds
The newly proposed call-in model will allow the Czech Competition Authority to review transactions that do not meet the mandatory notification thresholds, provided the combined turnover in the Czech Republic exceeds CZK 2.5 billion – even if the target company has only minimal turnover (e.g., start-ups). At the same time, the thresholds for ordinary notifications will be raised, reducing the number of routine, unproblematic mergers (the combined turnover threshold will increase from CZK 1.5 billion to CZK 2.5 billion, and the turnover of at least two parties will increase from CZK 250 million to CZK 350 million). This change is expected to eliminate 20-30% of mandatory filings. The approach is designed to capture potentially harmful “killer acquisitions” while easing the burden on both businesses and the authority. That said, the impact on legal certainty for businesses will be considerable.
Conclusion
We cannot recall such an “intense” meeting with the Czech Competition Authority. While it was expected that the authority would push for reforms in the next Chamber of Deputies of the Czech Parliament, few anticipated that the proposals would be far more ambitious than the original draft. Overall, the meeting demonstrated the Czech Competition Authority’s determination to expand its powers, strengthen enforcement, and address new challenges – from digital platforms to labor markets. Businesses operating in the Czech Republic should prepare for stricter scrutiny, higher compliance expectations, and greater personal accountability in the years to come.
That is our initial summary. We ourselves need some time to digest all the information we received. In the coming weeks, we will return to each topic in dedicated blog posts – bringing more detail and our commentary. So stay tuned to the competition section of our blog to make sure you don’t miss anything.
