Dear Friends,
Happy New Year!
We share here our fourth quarter of 2025 updates on competition and consumer protection enforcement across Southeast Asia. You will see agencies pairing active casework with policy modernisation in digital and traditional sectors alike. Enforcement activity remained pronounced in areas such as price-fixing and procurement collusion, while consumer protection probes have increased across all sectors and safety standards. In parallel, merger control reviews and measures continue across many diverse sectors in the region. Legislative and policy initiatives focused on strengthening cross‑border cooperation, refining penalties and procedures, and addressing competition and consumer risks arising from artificial intelligence (“AI“), platform governance, and the wider digital economy.
Merger control
Merger control clearances is an important area of the work that we do. A review of the cases reflects how busy the regulators are and consequently how seriously the area is taken. In Singapore, the Competition and Consumer Commission of Singapore (“CCS“) cleared the acquisition of a healthcare business after concluding the transaction would not substantially lessen competition in the relevant markets. CCS also consulted on streamlining its Guidelines on Merger Procedure, proposing a more efficient assessment approach – having had a case of ours used as the trial was an honour. In Vietnam, the National Competition Commission (“VCC“) issued conditional approvals in the gypsum board and loan markets. Vietnam has also proposed revising the sanctions framework for economic concentrations, reflecting a move toward more calibrated and practical enforcement. In Indonesia, the Indonesia Competition Commission (“KPPU“) reported sustained merger notification volumes in 2025 despite changes in thresholds, and continued to enforce against procedural breaches, highlighting the risk of sanctions for late filings and entity‑specific notification failures.
Anti‑competitive agreements and unfair consumer practices
Activities involving cartels, collusion, vertical restrictions, abuse of dominance, and consumer‑facing misconduct have seen more intense enforcement. In Malaysia, the Malaysia Competition Commission (“MyCC“) issued proposed decisions against alleged cartels in childcare pricing and prison procurement tenders, and accepted undertakings from speedboat operators to cease coordinated fare announcements. A number of cases have gone up on appeal to the Malaysian courts. Recently, the High Court upheld an abuse of dominance decision by MyCC, clarified that prior MyCC infringement findings are not a prerequisite for private actions (which is different from the position in Singapore), and granted a stay of substantial fines in a poultry feed cartel matter. In Indonesia, KPPU fined companies for bid‑rigging, advanced probes into alleged collusion in online loan interest rate setting, and prepared a vertical exclusion case in the air-conditioner market for hearing. The Philippines Competition Commission referred alleged bid‑rigging in flood control projects to the Department of Justice and formalised an inter‑agency coordination to bolster detection and case development in public procurement.
On consumer protection, in Singapore, CCS acted against misleading online practices, issued safety warnings after market surveillance found non‑compliant children’s products online, and provided guidance to improve market transparency and consumer understanding. In Vietnam, VCC fined companies for misleading claims aimed at diverting customers and issued directives to safeguard consumer rights on digital platforms and in media services. In Thailand, the Trade Competition Commission (“TCCT“) sanctioned abuse of superior bargaining power in a franchise context.
Legislation and policy
Policy reform and regional cooperation progressed apace, with authorities refining tools to address digital economy issues and cross‑border challenges. In Singapore, consultations have been conducted on harmonising the treatment of market competition issues across the telecommunication and media sectors, as well as streamlining merger and settlement procedures. In Vietnam, the new Law on E‑Commerce has been adopted, positioning Vietnam as a regional forerunner in platform governance. In Thailand, TCCT advanced competition policy priorities around AI, the green economy, and global trade, and deepened inter-agency collaboration to better regulate digital platforms. TCCT has also introduced regulatory amendments to raise the threshold for determinant market dominance. In Indonesia, KPPU pushed legislative reform proposals to introduce pre‑merger notification, leniency, search and seizure powers, and expanded market and dominance definitions. Regionally, Cambodia and Hong Kong signed a Memorandum of Understanding to strengthen cooperation, while the Philippines endorsed the ASEAN Framework Agreement on Competition and signed a Memorandum of Understanding with Malaysia, reinforcing cross‑border enforcement, capacity‑building, and sustainable competition governance.
Compliance reminder
In light of these developments, businesses really need to proactively review and strengthen their competition and consumer protection compliance frameworks, prioritising high‑risk areas such as information exchanges, procurement engagement, platform and marketplace conduct, digital marketing and claims, AI‑enabled tools, and merger filing protocols. Practical steps include conducting targeted audits of online practices, refreshing staff training on dos and don’ts, and validating notification triggers and timelines across relevant jurisdictions.
Our regional team stands ready to assist with rapid risk triage, merger strategy, investigations response, and programme enhancements tailored to local enforcement priorities.
The Rajah & Tann Asia Competition & Antitrust Team is committed to staying ahead of the rapid developments in competition law across the region and stands ready to assist. Please reach out to us if you wish to further discuss these developments.
For more information, click here to read the full Legal Update.
Disclaimer
Rajah & Tann Asia is a network of member firms with local legal practices in Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. Our Asian network also includes our regional office in China as well as regional desks focused on Brunei, Japan and South Asia. Member firms are independently constituted and regulated in accordance with relevant local requirements.
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Please note also that whilst the information in this publication is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as legal advice or a substitute for specific professional advice for any particular course of action as such information may not suit your specific business and operational requirements. You should seek legal advice for your specific situation. In addition, the information in this publication does not create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on the information in this publication.
