Competition Quarterly Milestones – Regulatory and Advocacy (October-December 2025)

On 6 October 2025, the CCI released a report on the market study on “Artificial Intelligence and Competition” (Report).¹

The CCI conducts market studies to understand the competitive dynamics of a sector. While these findings are non-binding, they offer insight into the CCI’s evolving enforcement priorities.

Principal findings

This Report suggests that businesses deploying AI technologies should consider potential competition law implications from the outset with an early-stage assessment. Key components of this assessment include training technical teams on competition law principles, documentation and evaluation of training data sets for potential bias and building safeguards against collusion directly into the algorithm design. The Report signals that CCI expects competition law considerations to form an integral and constant part of AI development, deployment, and commercial strategy as the sector evolves.

The CCI issued a ‘first of its kind’ order clarifying the scope of one of the key exemptions, i.e., Rule 3 of the Competition (Criteria of Exemption of Combination) Rules, 2024 (Exemption Rules).² Rule 3 exempts incremental acquisitions from being notified to the CCI provided certain conditions regarding shareholding and rights of the acquirer are fulfilled.

The combination notice pertained to two intra-group transactions involving the acquisition of certain shareholding in Lenskart Solutions Limited and Care Health Insurance Limited by Kedaara group entities from other Kedaara group entities in the respective targets. The combination notice was filed as a matter of technical compliance to seek clarity on whether Rule 3 of the Exemption Rules applied to instances where the transaction did not result in an increase in the group’s overall shareholding in the target i.e., the transaction is merely an intra-group restructuring.

Upon review, the CCI clarified that a strict interpretation of acquisition of “additional shares” would be against the spirit and scheme of the Exemption Rules. Accordingly, the CCI ruled that although the acquiring Kedaara group entity may not be acquiring any “additional” shares in Lenskart and Care Health Insurance, since all other requirements of Rule 3 of the Exemption Rules were being met, the transaction is exempted from notification to the CCI.

The Exemption Rules were introduced relatively recently in 2024, and issues in their interpretation and implementation continue to be addressed. As the provisions offer exemption from notification, the present case offers additional clarity on the scope of Rule 3 and its applicability to intra-group restructurings.

In a significant step to ensure that the digital competition framework is based on market data and analysis, the Ministry of Corporate Affairs has released a request for proposal to appoint an agency to conduct a market study to review and evaluate the following aspects of the draft Digital Competition Bill, 2024 (DCB):³

The study aims to provide evidence-based analysis of the provisions in the draft DCB, recognizing that any framework adopted will have significant implications.

Over the course of time, we can anticipate firms to increasingly prioritize and implement compliance measures for their AI and digital systems.