The Commission for the Protection of Competition (CPC) has recently unveiled a draft bill aimed at a comprehensive overhaul of the Control of Concentrations Between Undertakings Law. These proposed amendments represent the most significant update to the Cyprus merger regime since 2014, reflecting the needs of a digital and globalised economy.
1. Significant Revision of Turnover Thresholds
One of the most critical changes for legal practitioners and investors involves the “recalibration” of jurisdictional thresholds.
- Individual Turnover Requirement: The draft bill proposes that at least two participating undertakings must each have a turnover of at least €200,000 in Cyprus.
- The Impact: This shift aims to capture “killer acquisitions” and smaller, strategically significant transactions that may have previously escaped regulatory scrutiny under the older, broader aggregate thresholds.
2. Introduction of Digital & Electronic Filings
In a move toward administrative efficiency, the CPC is proposing the formalisation of electronic and digital submissions.
- Efficiency: This will significantly reduce the “paper-heavy” burden on notifying parties.
- Predictability: Digital timestamps will provide clearer evidence of filing dates, helping streamline Phase I review initiation timelines.
3. Alignment with EU Digital & Subsidy Regulations
The proposed law seeks to harmonise Cyprus’s local regime with recent European Union frameworks, specifically:
- Digital Markets Act (DMA): Integrating concepts to address concentrations in the digital sector.
- Foreign Subsidies Regulation (FSR): Ensuring the CPC has the tools to assess the impact of foreign state aid on local competition.
4. Stronger Protections for Confidential Information
Recognising the sensitive nature of M&A data, the amendments introduce refined definitions for:
- Business Secrets
- Confidential Information
- Personal Data (aligned with GDPR)
5. Enhanced Enforcement & Judicial Oversight
The draft bill clarifies the CPC’s power regarding administrative fines. Notably, the Administrative Court will be explicitly empowered to adjust (increase or decrease) fines, thereby providing a more robust mechanism for judicial review and legal certainty.
Comparison: Current Law vs. 2025 Proposed Amendments
| Feature | Current Law (83(I)/2014) | Proposed Amendment (2025) |
| Notification Method | Primarily Paper-based | Full Digital/Electronic Filing |
| Local Turnover Threshold | €3.5m aggregate in Cyprus | €200,000 per undertaking (at least two) |
| EU Regulation Sync | Basic EU alignment | Integrated DMA & FSR principles |
| Whistleblower Support | Limited | Aligned with Law No. 6(I)/2022 |
FAQ: What You Need to Know
When will these changes take effect?
The draft bill is currently undergoing final legal vetting following the public consultation period. It is expected to be submitted to the House of Representatives for a vote in late 2025 or early 2026.
Will smaller mergers be affected?
Yes. Due to the proposed lower individual turnover thresholds, smaller transactions that impact the Cyprus market will likely require mandatory notification to the CPC.
Can I still submit paper notifications?
While the law introduces digital filings, it aims to supplement and modernise the process rather than immediately eliminate traditional methods, though digital is the clear priority for the future.
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