In a report published in September last year, Mario Draghi argued for a “new approach to competition policy supporting a new Industrial Deal”, noting that “competition policy should continue to adapt to changes in the economy so that it does not become a barrier to Europe’s goals.” This call for action echoed the Political Guidelines for the current Commission of President von der Leyen (published in July last year), which emphasised the need for a competition policy that is “better geared to our common goals and more supportive of companies scaling up in global markets”.

In his report, Draghi put forward a number of proposals to “revamp” EU competition policy. However, as any business executive will know, plans are one thing, execution is another. The challenging task of figuring out how to implement the high-level political strategy takes time and rests on the shoulders of DG COMP.

A year on, where do we stand? The table below gives an overview of where we are at with some of Draghi’s key proposals, and whether or not they were addressed in President von der Leyen's mission Letter to Commissioner Teresa Ribera.

 

The key takeaways

• The EC has taken steps towards implementing Draghi’s recommendations, with more actions being taken in competition law than any other area (a report by the European Policy Innovation Council found that 19% of the recommendations relating to competition, regulatory and mergers had been acted on, compared to 11% across all Draghi recommendations and 0% for energy).
• Mario Draghi’s hoped-for revolution has not yet occurred, and some recommendations seem to have fallen off the radar. While no one expected change to happen overnight (as the former head of DG COMP pointed out, reform is an “evolution, not a revolution”), more needs to be done.
• More progress can be expected: particular areas to watch out for in the coming months (and years) will be the revised merger guidelines, the revised Antitrust Procedural Framework (expected at the end of 2026) and the planned Competitiveness Coordination Tool.
• At present, the implementation of the Draghi Report is mainly case-specific, making it less visible, concrete and predictable. This dynamic is likely to continue to prevail in the near term. This should not, however, deter companies from bringing projects or concerns to the EC’s attention when these are linked to the EC’s broader strategic agenda.

Where are we now? A deep-dive

We discuss the status each of the concrete proposals in depth, below.

1. Allow the creation of EU champions in strategic sectors

Status: In progress, but the EC is playing the long game

What did the Report recommend?

The Draghi Report called for an overhaul of competition rules to give EU companies the scale to compete with Chinese and US companies. Draghi noted that: “There is a question about whether vigorous competition policy conflicts with European companies’ need for sufficient scale to compete with Chinese and American superstar companies”.

What has the EC done so far?

This recommendation has been a focal point in the EC’s review of the EU merger guidelines, which focus on growth, scale and investment . Where the EC will land on this (incl. for example the introduction of an “innovation defence”) is however far from certain. Until then, any impact observed will be at case level. For more details, have a look at our separate blog on the review of the merger guidelines.

2. Include security and resilience considerations in merger reviews

Status: In progress, but the outcome is uncertain

What did the Report recommend?

The Draghi Report advocates for the inclusion of a security and resilience criteria in merger control assessments, stating that they should “be used as an input for DG COMP as an additional public interest criterion”. The idea behind this is that enhancing resilience is considered a merger benefit, and to ensure that a merger does not weaken economic resilience in a market (for example, by leading to reliance on a single source of raw materials).

What has the EC done so far?

Security and resilience are coming into focus in the review of the EU merger guidelines, so we may see the EC taking security and resilience into consideration in future merger assessments. However, the extent to which these factors will be considered is not yet clear, and whether it will apply to all mergers or just those related to key sectors remains to be seen.

3. Introduce post-merger monitoring and use more behavioural remedies

Status: No current proposals, but this is a space to watch

What did the Report recommend?

The Draghi Report advocates for the ex-post (i.e. post-closing) evaluation of mergers, including by obliging merging parties to provide regular information on their merged business.

What has the EC done so far?

There are no current proposals to change the EC’s approach to remedies. However, the CMA’s acceptance of behavioural remedies in Vodafone/Three could lead the EC to closely consider behavioural remedies in telecoms mergers (and other similar industries where investment is underpinned by achieving scale). This is especially as the Draghi Report backs monitoring post-merger behaviour over forced divestments – an approach seen as vital for strategic sectors competing on a global scale. This will be an area to watch in the coming year.

4. Speed up decision-making for merger review

Status: In progress, but limited change is expected

What did the Report recommend?

The Draghi Report suggests that decision-making processes need to be accelerated. In her Mission Letter, President von der Leyen also called on Ribera to speed up enforcement of competition rules.

What has the EC done so far?

The EC has promised changes to simplify and reduce the reporting burden, and cut the ‘red tape’ across legislation, with the Competitiveness Compass noting that revised guidelines for assessing mergers need to be simplified and provide for faster enforcement. The EC’s ongoing review of the EU merger guidelines can be expected to reflect these aims, with the papers published as part of this review noting that “[a] fast-paced merger control system that approves the vast majority of cases under the simplified and super-simplified procedures helps firms in the EU to gain scale when they do not attain market power”. However, for mergers that do not raise competition concerns, a lot of this work seems to have been done already as 80% of all cases now benefit from a simplified review and the scope for simplification in complex cases seems to be limited. For more complicated cases, change will have to come from procedural best practices.

5. Speed up antitrust enforcement

Status: In progress, but outcome is uncertain

What did the Report recommend?

The Draghi Report suggests that decision-making processes need to be accelerated. In her Mission Letter, President von der Leyen also called on Ribera to speed up enforcement of competition rules.

What has the EC done so far?

This call to action has been reflected in the ongoing evaluation of the Antitrust Procedural Framework. The EC’s request for feedback on the Framework notes its objective of enhancing “effective and speedy antitrust enforcement”, with one of the first policy points noted as improving the speed of decision-making. We therefore expect speed and efficiency to be a key focus point as the EC reviews the Framework this year. However, as with the EU merger guidelines, it will be some time before we understand the impact of the revisions to the Framework, with a revised Framework expected in Q3 of 2026.

6. Create more room for collaboration on R&D

Status: Some progress for targeted areas

What did the Report recommend?

The Draghi Report suggests reforms to create a simplified process for R&D collaboration, commenting that there needs to be a ‘simple, streamlined’ process for companies to follow to ‘reach scale’ when it would benefit consumers. When making this suggestion, Draghi proposes for DG Comp to “provide some clear guidance, templates” with specific illustrations for critical areas.

What has the EC done so far?

The EC recently revised the R&D Block Exemption Regulation and Horizontal Guidelines, both of which provide illustrations and guidance for R&D collaboration. Therefore, it is not surprising that significant further work hasn’t been completed by the EC on this recommendation on a broader level. However, the EC has still taken this recommendation on board in other more specific areas, noting in the Competitive Compass that it would review the Technology Transfer framework to ensure that companies have clear, simple and up-to-date rules for procompetitive technology licensing agreements to facilitate technology dissemination, incentivise R&D, and promote innovation. Public consultation on the revised TTBER has begun, and with the existing TTBER set to expire in April 2026, an updated TTBER can be expected soon.

7. Vigorously and effectively enforce the DMA and FSR

Status: In progress for the FSR, but the EC is treading carefully when it comes to the DMA

What did the Report recommend?

The Draghi Report calls for existing rules on the distortive effects of foreign subsidies (FSR) and compliance of tech platforms (the DMA) to be applied effectively.

What has the EC done so far?

While enforcement of the FSR has continued at pace, with the EC launching a number of investigations and carrying out dawn raids, it has been an increasingly political flash-point where the DMA is concerned – at least since February 2025.

DMA enforcement has received push-back from the US and Trump administration, with Congress writing to Ribera in February this year to raise concerns that the DMA’s enforcement targeted American companies. Although Ribera subsequently defended the EU’s digital legislation, anecdotally DMA enforcement seems to have slowed since April 2025.

Commenting on the EC’s recent adoption of the Google Adtech decision, Ribera was careful to state that the United States Federal Court recently upheld the main claims of a DOJ complaint against Google which closely mirrored the complaints addressed in the EC’s decision – perhaps seeking to ensure that this most recent tech enforcement did not (again) draw the ire of Congress. Despite assurances that the EC will continue to apply its rules ‘firmly and fairly’ there is no doubt that DMA enforcement (and antitrust enforcement against tech companies more broadly) has become politicised, and this is likely to dampen enforcement for the foreseeable future.

8. Reform the State aid framework to support EU-wide strategic projects

Status: Early indications of change, but sweeping reforms remain some way off

What did the Report recommend?

The Draghi report advocates for the modernisation of the EU State aid regime, urging the EC to move away from a patchwork of national schemes towards a more strategic, coordinated approach at EU level, and calling for greater emphasis on innovation and resiliency in State aid decisions. Draghi also calls for the State aid framework to actively foster pan-European projects of strategic importance, particularly by expanding the Important Projects of Common European Interest (IPCEIs) instrument to better focus on innovation and resiliency, and to speed up administrative processes.

What has the EC done so far?

The EC has already introduced some reforms to State aid rules to boost European competitiveness, particularly in the clean tech industry and to support the green transition. The main development is the adoption of the Clean Industrial Deal State Aid Framework (CISAF), which provides Member States with tools to support clean energy, industrial decarbonisation and the manufacturing of critical clean technologies while ensuring cohesion and preventing excessive State aid.

The EC has not revised the IPCEI instrument since the updated instrument came into force in January 2022, nor has it started consultations on a review of the IPCEI instrument. It is unclear whether a revised framework focusing on innovation and resiliency is something the EC plans to take forward.

And while the EC indicated in its Competitiveness Compass, that it planned to streamline the IPCEI approval process by leveraging a new “Competitiveness Coordination Tool”, nothing has officially been announced yet. This will be a space to watch.

9. Introduce a new competition tool

Status: No current proposals

What did the Report recommend?

The Draghi Report recommends introducing a new competition tool that allows the EC to carry out market studies, and later a market investigation to determine a solution with firms. This would be used: (i) in areas of tacit collusion, (ii) where consumer protection is more likely, (iii) in markets where economic resilience is weak (i.e. where it relies on a single source of raw material), and (iv) where past enforcement shows commitments aren’t working.

What has the EC done so far?

Ribera commented in her response that the proposal “merit[ed] an in-depth reflection”. However, it was not mentioned in the Competitiveness Compass and (so far) it does not appear that the recommendation has been actioned by the EC.

10. Closing the skills gap with labour mobility

Status: Enforcement ramping up, but no proposed reforms

What did the Report recommend?

The Draghi Report suggests moves to address practices that limit labour mobility, like non-competes and no-poach agreements. The concern underlying this recommendation is that the EU needs people with knowledge and skills for green and digital transitions, and low labour mobility is a barrier to achieving this.

What has the EC done so far?

Investigations relating to no-poach agreements have taken place in at least fourteen Member States. While most cases are expected to be dealt with by national competition authorities – with France being the latest competition authority to sanction labour arrangements – the EC has been actively investigating cases in this sector. After launching its second dawn raid in relation to labour related arrangements in November last year, the EC reached its first cartel finding in the labour market, imposing hefty fines on Delivery Hero and Glovo for (among other things) a broad no-poach agreement. However, there are no proposed EU-wide rules / reforms relating to non-competes and no-poach agreements.