Jurisdiction(s):
United Kingdom

Competitor information exchange: CMA guidance on data sharing, algorithms and platforms, UK case law and compliance under the Chapter I prohibition

Published by a LexisNexis Competition expert

Practice notes

Information sharing is a common commercial practice that can enhance transparency around pricing and other commercially sensitive data and, in some cases, deliver efficiencies. Nonetheless, information exchange is increasingly pursued as an anti-competitive behaviour. Simultaneously, it remains one of the most difficult areas for the application of competition law.

Illustrative conduct includes alleged price signalling, exchanging information and bid-rigging, unilateral disclosure of pricing intentions, indirect exchanges, sharing via an intermediary, information exchange in initial public offerings and share placings, or exchanges between merging parties. This Practice Note examines how the Competition and Markets Authority (CMA), alongside sectoral regulators, applies the Chapter I prohibition of the Competition Act 1998 (CA 1998) to agreements and concerted practices involving information exchange. For an EU competition law perspective, see Practice Note: Information exchange under EU competition law.

Framework for the assessment of information exchanges

In order to find an infringement of the Chapter I prohibition of CA 1998, the CMA must establish that:

the parties entered into an agreement or engaged in a decision or concerted practice
which...

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Web page updated on 21/05/2026

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