IT for Change submitted a response to the public consultation to assess the EU's Horizontal and Non-Horizontal Merger Guidelines on 3 September 2025. We provided targeted inputs to the 'digitalisation' chapter to highlight the novel concerns emerging from the platform economy that remain largely unaddressed in the current iteration of the guidelines.
Digital ecosystems, as a result of their porous boundaries, network effects, and use of data as a critical resource, bring new competitive dynamics. The Guidelines, for instance, do not address killer acquisitions and other measures undertaken by Big Tech to stifle competition or the amplification of intelligence value through data. We also highlighted the dangerous trend of dilution of workers' rights and dignity with the rise of digital labour platforms. For instance, vertical integration across enterprises allows incumbents to exercise control and supervise smaller players, resulting in the rise of extractive labor practices down the value chain.
Read the full response here.