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Mergers, acquisitions and joint ventures can need clearance from competition authorities before or after completion. Getting the analysis wrong can mean fines, delay or an order to unwind the deal. PAD International Group helps businesses assess whether a transaction needs to be notified in the UK, the EU or Iran, and how to manage the process.
United Kingdom
UK merger control is run by the Competition and Markets Authority (CMA) under the Enterprise Act 2002. Notification is voluntary and the regime is non-suspensory, but the CMA can investigate deals that were not notified, impose hold-separate orders and, in serious cases, require them to be unwound. Since 1 January 2025, after the Digital Markets, Competition and Consumers Act 2024, the CMA can review a merger where:
- the target has UK turnover above £100 million; or
- the parties together supply at least 25% of goods or services of a particular description in the UK and the deal increases that share; or
- one party has at least a 33% share of supply and UK turnover above £350 million, and the other has a UK nexus (a new “hybrid” test).
A small-merger safe harbour applies where each party has UK turnover below £10 million.
European Union
Under the EU Merger Regulation, deals that meet the turnover thresholds must be notified to the European Commission and cannot close until cleared. Many EU member states also run their own national regimes, and foreign direct investment screening may apply alongside competition review.
Iran
Iran’s competition rules are set out in the Law on the Implementation of the General Policies of Article 44 of the Constitution, enforced by the Competition Council. Mergers and acquisitions that may restrict competition can fall within its review powers, so transactions involving Iranian businesses should be checked against these rules early.
What our analysis covers
- Whether filing thresholds are met in each relevant country.
- Market definition and the parties’ combined shares.
- Likely concerns and possible remedies.
- Deal timetable, conditions precedent and gun-jumping risks.
- Coordination with foreign investment screening and local counsel.
Planning a transaction? Ask a question or book a consultation, or return to competition law services.
General information only, current as of November 2026. It is not legal advice for a specific matter.