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The French Competition Authority, Autorité de la concurrence has published its third study on the leniency programme, drawing on interviews with lawyers specialised in competition law, with a view to assessing the programme's application over the past decade and identifying possible areas for improvement. The Authority noted that, following similar studies conducted in 2014 and 2018, this latest edition provides a clearer picture of practitioners experiences and sheds light on the factors influencing decisions to apply for leniency. In this context, the Authority observed that the number of leniency applications has increased in recent years and that certain factors, such as the growing number of damages actions, have become more significant in companies strategic considerations.
Nevertheless, the Authority found that the core drivers of leniency applications remain unchanged, namely the prospect of obtaining a substantial reduction in fines and the fact that dawn raids have already been carried out. The study further highlighted the emergence of new factors that were not present in 2014, in particular the ability to collect reports from whistleblowers, which are beginning to play a more prominent role and are expected to have a lasting impact on the functioning and attractiveness of the leniency programme.
(Autorité de la concurrence – 09.01.2026)
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