India's Competition Commission Adopts New Merger Thresholds, Capturing More Deals

Revised Merger Control Framework

India's Competition Commission (CCI) implemented revised merger control thresholds in 2025, significantly expanding the number of transactions requiring mandatory notification. The reforms represent a major evolution in India's competition enforcement architecture, bringing the country's merger control regime closer to international standards observed in the European Union and other advanced jurisdictions. The changes reflect the CCI's determination to ensure that potentially anti-competitive transactions do not escape regulatory scrutiny simply because the target entity generates limited revenues within India.

Introduction of the Deal Value Threshold

The revised framework introduces a deal value threshold of INR 2,000 crore (approximately $240 million), capturing transactions where the target may have limited revenues but commands a high acquisition price due to its data, technology, or user base. This new threshold directly addresses "killer acquisition" concerns -- situations where a dominant company acquires a nascent competitor not for its current revenues but to eliminate a potential future competitive threat. By focusing on the value the acquirer is willing to pay rather than the target's existing financial metrics, the CCI has created a mechanism to review transactions that would previously have fallen below traditional turnover-based thresholds.

Relevance to India's Technology Sector

The deal value threshold is particularly relevant for India's booming technology sector, where startups and digital platforms frequently command valuations far in excess of their current revenue generation. Acquisitions of fintech companies, e-commerce platforms, health-tech startups, and data-driven businesses will now more frequently trigger mandatory notification requirements. This has significant implications for both domestic conglomerates and international technology companies that have been active acquirers in the Indian digital economy. Transaction parties must now assess not only whether traditional asset and turnover thresholds are met but also whether the total deal consideration crosses the new value-based threshold.

Accelerated Phase I Review and Expanded Phase II Powers

Alongside the new thresholds, the CCI has reduced Phase I review time from 30 to 20 working days, providing a faster initial assessment period for transactions that do not raise substantive competition concerns. This acceleration is intended to offset the increased filing burden created by the lower thresholds, ensuring that clearly benign transactions are processed efficiently. At the same time, the CCI has expanded its Phase II investigative powers, equipping the regulator with enhanced tools to conduct in-depth reviews of transactions that present genuine competition issues. These expanded powers include broader information-gathering authority and the ability to impose more tailored remedies.

Implications for M&A Practitioners

For M&A practitioners operating in India, the new thresholds necessitate careful deal planning to ensure timely filing and to avoid the risk of gun-jumping violations. Legal and compliance teams must incorporate the deal value assessment into their early-stage transaction analysis, particularly for acquisitions in the technology, pharmaceutical, and digital services sectors where target valuations may significantly exceed revenues. Building sufficient time into deal timetables for CCI review, and preparing comprehensive filing packages that address potential competition concerns proactively, has become an essential component of transaction execution in the Indian market.