Dawn Raid Analysis Quarterly

White & Case Dawn Raid Analysis Quarterly (DRAQ) is an information resource on surprise on-the-spot inspections (dawn raids) across Europe. Here we will guide you through the latest updates and legal developments.

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The White & Case Dawn Raid Analysis Quarterly (DRAQ) is an information and discussion resource regarding surprise on-the-spot inspections by antitrust authorities (dawn raids) across Europe. DRAQ provides updates on recent case law, enforcement activity and trends.

Q4 2023 at a glance

In Q4 2023, European competition regulators carried out a total of 18 dawn raids, which is six more than in Q3. The most active regulators in Q4 were the Spanish CNMC with four dawn raids, followed by the EC, French, Italian and Slovakian competition authorities with two dawn raids each.

The most targeted sectors in Q4 2023 were the health and safety, and construction sectors (three dawn raids per sector) carried out by the EC and Slovakian, Greek, Swiss and UK competition authorities. More than half of the dawn raids in the health and safety sectors were carried out in Q4 (three out of five), and all the dawn raids in the construction sector in 2023 were carried out in Q4 alone.

Noteworthy for Q4: In October 2023, the EC carried out dawn raids of construction chemical companies in cooperation with the UK, Turkish and US competition authorities. This is the second coordinated dawn raid in 2023, following the EC's dawn raid on fragrances manufacturers coordinated with the UK, US and Swiss competition authorities in March 2023. This evidences that cross-border enforcement is very much alive.

Comparing 2023 and 2022 numbers, the number of dawn raids carried out in 2023 and 2022 are broadly in line. European competition authorities carried out 62 dawn raids in 2023, which is just two fewer than in 2022 (64 dawn raids).

Outlook for 2024: There was an increase of dawn raids in consumer industries in 2023 in comparison to 20221, and we expect this trend to continue in 2024. Throughout 2023, the EC has been promising an "increased focus on cases that are relevant for the cost-of-living crisis." The 2023 data suggests that these promises were not empty, as regulators have indeed been targeting consumer industries, likely in recognition of the cost-of-living crisis. One of the causes for the cost-of-living crisis has been spikes in inflation. The ECB expects inflation to reach a target of 2 per cent only at the end of 2025, which can be an indicator that dawn raids will continue in 2024.

We provide more statistics below on the number of raids and the sectors impacted, including a country-by-country list, available through our Interactive Dawn Raid map.