Introduction

In May 2025, the Competition Commission (the “Commission”) submitted its annual report (the “Report”) to the Legislative Council Panel on Economic Development, outlining its enforcement activities, investigative progress, and strategic priorities for the year ahead. This newsletter highlights key developments from the 2024-25 reporting period and offers insights into the Commission’s outlook for 2025-26 and beyond.

Key developments and highlights

Investigations

Between May 2024 and April 2025, the Commission received 318 complaints and enquiries, bringing the cumulative total to over 3,100 since the Competition Ordinance (Chapter 619 of the Laws of Hong Kong) (the “Ordinance”) came into force. Seven matters proceeded to initial assessment, and one advancing to full investigation. These cases focused on, among others, construction and infrastructure, information technology, and real estate and property management.

In August 2024, the Commission and the Independent Commission Against Corruption (“ICAC”) conducted their second joint operation, together, they conducted investigation on renovation projects of 38 residential and industrial buildings in Hong Kong Island, Kowloon and the New Territories with the value of the relevant renovation contracts totalled over HK$1 billion. This marked a significant step in tackling misconduct that spans both anti-competitive and corrupt practices. We expect that the 2 agencies will have more co-operation and work closely together in the coming future. The Commission and the ICAC signed a Memorandum of Understanding on 18 December 2024 that covers aspects such as joint investigations, exchange and use of information, and referral of cases, among other matters.

Enforcement

On the enforcement front, the Commission concluded six cases before the Competition Tribunal, with two resulting in rulings in favour of the Commission and four other judgments pending. This included Hong Kong’s first cartel case regarding a government subsidy scheme, where three undertakings and an individual who had settled with the Commission were ordered to pay pecuniary penalties totalling HK$1.31 million, mirroring the investigation efforts of the Commission in searching for suspected anti-competitive conduct involving the Pilot Subsidy Scheme for Third-party Logistics Service Providers in November 2024. The Competition Tribunal also handed down judgment in a cleansing service cartel case in February 2025, resulting in HK$22.29 million of penalties in total and director disqualification orders against the three individuals for a period of two years.

Other than litigation, the Commission has explored and adopted non-litigation remedies in six cases, including accepting commitments in accordance with Section 60 of the Ordinance and issuing infringement notices under Section 67 of the Ordinance as enforcement outcomes. The Commission also continued to strengthen cooperation with other enforcement agencies, including but not limited to the ICAC. It is anticipated that with the strengthened cooperation between the two, the overall effectiveness in combating illegal activities that involve both anti-competitive and corruption elements can be enhanced.

Outlook

Looking ahead, as the Ordinance nears its tenth anniversary, the Commission continues to evolve as both a regulator and policy advisor—strengthening its enforcement record while deepening its engagement with public bodies and market stakeholders. Beyond enforcement, the Commission shall continue to give priority to investigations and enforcement actions that would result in the greatest overall benefit to competition and consumers in Hong Kong, with a continued focus on three particular areas: anti-competitive conduct concerning livelihood issues, cartels that aim to exploit government or public funding, and anti-competitive conduct affecting digital markets. The Commission shall continue to advise government bureaux and public bodies on competition-sensitive policy design, covering areas such as estate management, tyre safety regulation, and public procurement.

Takeaways

The Report reflects the Commission maturation into a strategically active enforcement body with a growing policy footprint. As the Ordinance enters its second decade, businesses should expect more assertive investigations, broader outreach, and a stronger push for competition-conscious policymaking. Proactive compliance and early legal engagement remain key to navigating this evolving landscape.