Dawn Raid Analysis Quarterly: 2025 Q2

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.

Q2 2025 at a glance

In the second quarter of 2025, European competition authorities conducted a total of 20 dawn raids, the same number as in Q2 2024. The Spanish and Romanian authorities were the most active, with each conducting three dawn raids. The Spanish authority conducted dawn raids in the transport, pharmaceutical and construction sectors. The Romanian competition authority carried out dawn raids in the automotive, transport, and health and safety sectors. The top three targeted sectors in Q2 2025 were construction (four dawn raids), transport (four dawn raids) and consumer goods (three dawn raids).

Key Q2 2025 legal developments

Below is a selection of key developments in Q2 2025:

• Successful challenge of inspection decision on grounds of temporal scope
• What level of detail is required for an inspection decision in an ex officio investigation?
• Regulation 1/2003 reform
• New Czech whistleblowing tool – more raids?
• Lawfulness of the joint dawn raid by the Italian and Irish competition authorities in the Ryanair case – TAR ruling

Successful challenge of inspection decision on grounds of temporal scope

On 9 July 2025, the General Court partially annulled the European Commission’s (EC) inspection decision of Michelin (Case T-188/24), which the EC had used to dawn raid Michelin in 2024 on the alleged grounds that Michelin may have infringed Article 101 TFEU by using earnings calls to signal pricing strategies to competitors. The Court upheld the inspection decision for the more recent period but annulled the part of the inspection decision referring to earlier years on the basis that the EC had not supported its suspicions for this earlier period with sufficiently serious indicia of anti-competitive conduct.

The dawn raid arose as a result of an ex officio investigation by the EC which involved the algorithmic screening of hundreds of thousands of earnings calls. The Court considered there was no contemporaneous evidence for the part of the decision referring to the earlier years, and that references in later earnings calls to past behaviour were not sufficient evidence.

The Court rejected Michelin’s arguments that the use of the words “and/or” in describing the form of the suspected co-ordination as an agreement or concerted practice was too imprecise.  The Court considered that the exact legal characterisation of the suspected co-ordination depended on an assessment which could not be required at the time the inspection decision was drafted and that the characterisation did not alter the scope of Michelin’s duty to co-operate or the extent of Michelin’s rights of defence during the inspection. The use of the word “including” to describe the EC’s suspicions did not make the decision excessively vague but allowed Michelin to understand sufficiently the EC’s suspicions.  

What level of detail is required for an inspection decision in an ex officio investigation?

On 30 April 2025 (Symrise v Commission, Case T-263/23), the General Court rejected a challenge to a dawn raid in an ex officio investigation where the EC had launched the inspection on the basis of its own market enquiries (several requests for information from third parties and an open source intelligence report), rather than information supplied by an immunity applicant.

The GC confirmed that there is a low bar for launching dawn raids in ex officio investigations. The GC held that the EC is not required in the inspection decision to:

• Set out all the information at its disposal concerning the presumed infringements
• Make a precise legal analysis or set out the exact legal nature of the presumed infringements
• Define precisely the relevant market
• Indicate the period during which the presumed infringements were committed
• Insert an end date in an inspection decision (although the inspection must end within a reasonable time which does not create a disproportionate interference with the fundamental right of privacy of the company concerned)

However, the EC must indicate the subject matter and purpose of the inspection, the presumed facts which it intends to investigate, the market thought to be affected, the nature of the suspected restrictions of competition, and the supposed degree of involvement in the infringement of the business concerned, as well as the powers of the EC inspectors.

The GC rejected arguments that the insertion of the words “inter alia” before the listing of the categories of suspected conduct rendered the reasoning in the inspection decision vague and imprecise.

Regulation 1/2003 reform 

On 10 July 2025, the EC  launched a 12-week public consultation (until 2 October 2025)  gathering views on policy options for revision of Regulation 1/2003. With respect to dawn raids, the EC is considering the following three options:

• Introducing an independent and self-standing power for the EC to adopt decisions ordering the preservation of digital and physical information; and/or
• Adapting the existing EC inspection power so that it is independent from the power to enter physical premises and means of transport (in other words creating a power to conduct fully remote inspections) and adapting the power to conduct inspections so that it covers all business records, regardless of the storage location of the data; and/or
• Enabling the EC to summon persons and ask them questions.  

New Czech whistleblowing tool – more raids?

The Czech Competition Authority has launched a new anonymous and confidential system for reporting suspected competition law infringements via a website. The new tool may result in more raids being conducted by the Authority. It will complement the tools that the Authority is already using, most importantly complaints, leniency applications and information provided by the police or other public authorities.

The service is accessible via a web interface at https://uohs.integrityline.com, which provides a quick and simple reporting system comprising a set of questions for the user to complete. Users can also upload documents and images, or leave voice mails (with automatic voice modification to hide the identity of the speaker). Whistleblowers may choose to remain anonymous or provide contact information for further communication. The Authority has declared that they guarantee strict confidentiality and anonymity in relation to any reports made through the system. The Authority recommends that users create a secure mailbox for follow-up communication which requires a chosen password and a randomly generated report number to log in. 

Lawfulness of the joint dawn raid by the Italian and Irish competition authorities in the Ryanair case – TAR ruling

In June 2025, the Regional Administrative Court of Lazio (“TAR”) upheld the legality of the joint dawn raid conducted by the Italian Competition Authority (“AGCM”) and the Irish Competition Authority (“CCPC”) at Ryanair’s premises in Dublin, Ireland. The judgment marks the last chapter in the litigation that began in March 2024 when Ryanair challenged the search warrant issued by the Dublin District Court before the Irish courts whilst simultaneously initiating proceedings before the Italian TAR, seeking interim measures. The 2025 TAR judgment confirmed the position of Italian law regarding the legality of a dawn raid conducted abroad jointly by the AGCM and a foreign competition authority, in accordance with the co-operation mechanism outlined in Article 22 of Regulation 1/2003.

Background 

In September 2023, the AGCM opened a proceeding against Ryanair for an alleged abuse of dominant position. In March 2024, the AGCM requested the assistance of the CCPC to carry out an inspection at Ryanair’s Dublin headquarters on the basis of Article 22 of Regulation 1/2003. Article 22 allows national competition authorities to assist each other with investigations. It states that, upon request, national competition authorities can undertake investigations, including inspections on behalf of another national competition authority within the European Union. 

At the beginning of the inspection, Ryanair personnel were informed about the Irish search warrant but not about the connected AGCM documents upon which the search warrant was based. Furthermore, at the end of the inspection, the inspectors did not prepare minutes of the inspection nor did they provide Ryanair with a copy of the seized documents. 

In May 2024, the Irish High Court found that the case fell outside of the jurisdiction of the Irish courts on the basis of AGCM’s actions being regarded as within the public law powers of investigation – for more details see here. In parallel, Ryanair also brought proceedings before the Italian TAR, seeking interim relief and the annulment of the inspection on the grounds that: (i) the inspection had not been duly authorised by the Board of the AGCM as required by Article 10(1) of the Regulation on the Proceedings of the Italian Competition Authority (Presidential Decree No. 217 of 1998); and (ii) the officials did not inform Ryanair about  the AGCM documents upon which the Irish search warrant was based. 

In May 2024, the TAR granted interim relief, preventing AGCM from using the documents seized during the inspection for the purposes of its investigation. It also ordered the AGCM to hand over the documents based on which the Italian competition authority requested the assistance from the Irish regulator. The AGCM appealed the interim relief before the Italian Council of State, the highest Italian administrative court. In light of the pending appeal, the TAR decided to stay the proceedings, noting that the outcome of the Council of State’s ruling on the interim measures would also affect other substantive aspects of the case.

The co-operation mechanism pursuant to Article 22 of Regulation 1/2003 under Italian law – Key takeaways

The 2025 TAR judgment (judgment No. 8507, 2 May 2025) fully endorsed the interpretation of Article 22 of Regulation 1/2003 provided by the Italian Council of State judgment issued in November 2024. 

• The Italian Council of State held that Article 22 of Regulation 1/2003, which served as the legal basis for the AGCM’s request for collaboration addressed to the CCPC, provides a sufficient foundation for initiating an investigation and does not require implementation through Italian domestic law to be effective.
• The absence of a formal decision by the AGCM’s Board under Article 10 of Presidential Decree No. 217 of 1998 does not invalidate the inspection carried out abroad, as that inspection was lawfully conducted under the co-operation mechanism established by Article 22 of Regulation 1/2003. In fact, the AGCM’s Board had adopted a resolution authorising the request for co-operation, explicitly stating that it sought assistance for an investigation. However, the Board could not formally authorise the investigation itself, as the execution of the inspection was necessarily subject to the authorisation of the competent foreign authority – in this case, the Irish court.
• Therefore, the absence of a formal decision under Article 10 of Presidential Decree No. 217 of 1998 authorising the investigation does not invalidate the inspection carried out abroad, as the latter was lawfully conducted under the co-operation mechanism established by Article 22 of Regulation 1/2003. The lawfulness of the inspection must be assessed with reference to the legal act authorising it within the jurisdiction where it took place – namely, the search warrant issued by the Irish authorities.
• The Council of State clarified that the authorisation of the AGCM’s Board is not a prerequisite for invoking Article 22 of Regulation 1/2003. Accordingly, any challenge to the validity or legality of the Irish search warrant must be brought before the Irish courts.
• At most, the Italian courts may assess whether the AGCM’s request for co-operation complied with the requirements of Article 22 of Regulation 1/2003. However, they may not review the lawfulness of investigative measures taken in another Member State, such as any alleged infringement of the rights of the undertaking under investigation.
• At the time of writing, no appeal has been lodged by either party, and the deadline for bringing an appeal has expired. The judgment is therefore final and binding.

Outlook

There may be two important consequences from this ruling. 

First, the case reveals a jurisdictional gap: the Irish courts declined to assert jurisdiction over the case on the basis of the exercise of public authority by another Member State – namely, the AGCM’s involvement in the inspection – whilst the Italian courts held that it was for the Irish judiciary to assess the legality of the search warrant and the underlying documents, including the AGCM’s request for co-operation.

Second, from a procedural standpoint, the ruling confirms that inspection decisions are treated differently under Italian law depending on whether the inspection is carried out domestically or abroad. Inspections conducted on Italian territory must comply with the procedural safeguards laid down in Article 10 of Presidential Decree No. 217/1998, including, as in the case at hand, a formal decision by the AGCM’s Board authorising the inspection.

By contrast, inspections carried out abroad pursuant to the co-operation mechanism under Article 22 of Regulation (EC) No 1/2003 are not subject to the same internal procedural requirements. In such cases, it is sufficient for the AGCM’s Board to approve the request for co-operation. The responsibility for assessing the legality of the inspection, including any potential violation of the rights of defence, lies with the courts of the Member State where the inspection takes place This includes review of both the request for co-operation and the supporting documentation provided by the AGCM.

Interactive Dawn Raid map

EU Austria 2024 One dawn raid Sectors: Vehicle repair 2023 One dawn raid  Sector: Refrigeration and freezing equipment  2022 Three dawn raids Sectors: Wood-pellets; waste management 2021 One dawn raid Sectors: Waste management. Belgium 2025 One dawn raid Sector: Personal care and retail  2024 One dawn raid Sector: Bus and coach passenger transport 2023 One dawn raid Sector: IT manufacturers 2022 Two dawn raids Sectors: Bovine meat; Press publisher and distribution 2021 None reported Bulgaria 2025 One dawn raid Sector: Construction machinery  2024 One dawn raid Sectors: Traders of construction machinery and equipments 2023 One dawn raid Sector: Food and beverage 2022 One dawn raid Sectors: Toners and other printing consumables 2021 None reported Croatia 2025 One dawn raid Sector : Low and medium voltage  2024 Two dawn raids Sectors: Management, constructions, and maintenance of state roads; sports and recreation packages for employees 2023 One dawn raid Sectors: Wheat 2022 None reported 2021 None reported Cyprus 2023 None reported 2022 One dawn raid Sectors: Bricks 2021 None reported Czech Republic 2025 4 dawn raids Sector: Post services; engineering; land construction; household and garden equipment 2024 9 dawn raids Sectors: Domestic appliances; lorries; roads and motorways; web portal and search engines; unknown 2023 8 dawn raids Sectors: Domestic appliances; consumer electronics; unknown 2022 14 dawn raids Sectors: Consumer electronics; smelters; unknown 2021 16 dawn raids Sectors: Pet food and pet accessories; railways; electronic appliances Denmark 2025 Four dawn raids Sectors: Sports equipment; passenger transport; accounting services; robotic lawnmowers 2023 None reported 2022 None reported 2021 One dawn raid Sector: Auto repair services Estonia No dawn raids for the period 2021 – 2023 Finland  2025 One dawn raid Sector: Asphalt 2024 One dawn raid Sector: Elder care homes 2023 None reported 2022 None reported 2021 None reported France 2025 Two dawn raids Sectors: Glass bottles; cancer treatment 2024 Four dawn raids Sectors: Medical biology; energy cable distribution; manufacture and distribution of explosives for civil uses; agricultural inputs 2023 Four dawn raids Sector: Rail transport; graphic cards; production and marketing of food and non-food product sectors; production and marketing of food and non-food products 2022 Four dawn raids Sectors: Cow's milk; leather goods; agricultural supplies; cash register services for newsagents and tobacconists 2021 Two dawn raids Sectors: Food retail; pharmacy data collection Germany 2024 Three dawn raids Sectors: Tyre retail; unknown; toilet paper; paper towels and tissues 2023 11 dawn raids 2022 12 dawn raids Sectors: Power-cable manufacturer As stated in the Bundeskartellamt (BKa) annual report of 2022, in 2022 the BKa carried out a total of 12 dawn raids and provided official assistance for another six 2021 Two dawn raids As stated in the BKa annual report of 2021, in 2021 the BKa conducted two dawn raids Greece 2025 Three dawn raids Sector: Maritime and Private tutoring services; provision of passenger transport services 2024 Seven dawn raids Sectors: IT and technology sector and related services; organisation of educational trips for public and private schools; smart water meter systems; ferry services; waste management; pet food; coffee, chocolate and infant nutrition 2023 Seven dawn raids Sectors: Pharmaceuticals; alcoholic beverages; food processing; poultry; electricity grid; baby products; medical equipment 2022 12 dawn raids Sectors: Children's toys; aluminium; PVC and iron processing; import and distribution of white goods; transport; electricity; catering; medical products; 2 x construction; eyewear; cosmetics and personal care; breast pumps and accessories 2021 13 dawn raids Sectors: Sunflower; cotton and maize seeds; cadastral survey services; production and supply of pharmaceutical products; refining; wholesale and retail trade of petrol and diesel; 2x supply and retail trade of supermarket products; school bags; kids’ lunch bags and pencil cases; IT systems; catering services; public tenders for natural gas works; import; wholesale and retail markets of power-driven hard tools and garden tools; wholesale and retail markets of telecommunications and teleconferencing equipment; lighting systems Hungary 2025 Two dawn raids Sector: Domestic soft drinks manufacturer; vitamins and dietary supplements 2023 Three dawn raids Sectors: Food and beverages; soft drinks; online accommodation booking 2022 None reported 2021 Two dawn raids Sectors: Timber; gravel market Ireland 2025 One dawn raid Sector: Betting 2024 Two dawn raids Sector: Airlines; home alarms 2023 One dawn raid Sector: Publicly funded transport 2022 None reported 2021 None reported Italy 2025 Five dawn raids Sector: Transportation; jewellery and watches; application communication services; ski passes; civil drones   2024 Three dawn raids Sector: Online travel agencies; potato chips; vehicle repair 2023 Seven dawn raids Sectors: Oil; electric recharging stations; organization of sporting competitions; automotive fuels; anti-lock breaking systems; organization of competitive motor sports events; wine glass bottles 2022 Two dawn raids Sectors: Tolled motorways; catering services for penitential institutions 2021 None reported Latvia 2025 Two dawn raids Sectors: Coffee machines; funeral services    No dawn raids for the period 2021 – 2023 Lithuania No dawn raids for the period 2021 – 2023 Luxembourg 2025 One dawn raid Sector: Insurance 2024 One dawn raid Sectors: Pharmaceutical and parapharmaceutical 2023 None reported 2022 None reported 2021 None reported Netherlands 2025 One dawn raid Sectors: Software 2023 None reported 2022 None reported 2021 One dawn raid Sector: Food processing sector Norway 2025 One dawn raid Sector: veterinary clinics 2023 None reported 2022 Two dawn raids Sectors: Finance; construction 2021 Two dawn raids Sectors: Pharmaceuticals; relocation services Poland 2025 Two dawn raids Sectors: Waste management; drivers 2024 Seven dawn raids Sectors: Consumer electronics; digital distribution platform for video games; technologies related to electric and robotic systems; flooring panels; sale of drones; home appliance retailer; power production, trading and distribution  2023 Four dawn raids Sector: Agricultural machinery; processing and wholesale trade of raspberries; household applicances, grain storage 2022 Three dawn raids Sectors: Gas meters; grain trade and shipments; coffee machines 2021 Five dawn raids Sectors: Monitoring equipment; cleaning devices; hospital IT systems; KIA car dealerships; pork wholesale Portugal 2024 Three dawn raids Sectors: Unknown 2023 Three dawn raids Sectors: Supermarket retailing; condominium administration 2022 Six dawn raids Sectors: Wood-chip; wholesale of pharmaceutical goods; IT consulting; health & pharmaceutical; pharmaceutical and para pharmaceutical 2021 Two dawn raids Sectors: Procurement of military equipment; commercialized subscription databases with business information Romania 2025 Seven dawn raids Sector: Housing and construction design; dentistry; LPG port operating services; vehicle maintenance and repair services; road sign products; medical products and equipment; crop seeds 2024 Six dawn raids Sectors: Archival services for pensions; electricity meter reading services; ICT equipment; medical oxygen; dietary supplements; hydrological data 2023 Four dawn raids Sector: Console gaming; Sunflower oil, butter and sugar; voucher services related to employee benefits; banking 2022 One dawn raid Sectors: Motor vehicles 2021 12 dawn raids Sectors: Telecommunications; direct oral anticoagulants; paints and decorative coatings; book distribution; archiving of documents; tenders for an electronic services project; poultry; electricity; labour protection equipment; retail of electronic products; technical site permit services; street signage   Slovakia 2025 Two dawn raids Sector: Air conditioning, cooling and heat pump services; air conditioning, refrigeration and heat pumps 2024 Three dawn raids Sector: Photovoltaics; provision of institutional healthcare; medical devices suppliers 2023 Three dawn raid Sector: Healthcare waste management; laboratory medical diagnostics; medicines and medical devices 2022 Four dawn raids Sectors: IT; forestry; cables; sale and repair of robotised workplaces 2021 None reported Slovenia 2024 One dawn raid Sectors: IT suppliers 2023 None reported 2022 None reported 2021 One dawn raid Sectors: Driver training   Spain 2025 Five dawn raids Sector: Generic medicine; civil engineering construction; leasing of facilities intended for the activity of FBO at airports; public transport; international movers 2024 Four dawn raids Sector: Provision of consulting and technical assistance services; leasing of facilities intended for the activity of FBOs at airports; agriculture machinery; consultancy and technical assistance services 2023 Eight dawn raids Sector: Travel agencies; haircare products; low-voltage electricity networks and electricity trading; agricultural machinery; rail transport; pharmaceutical digital logistics tool; electricity and gas; drugs and medications 2022 Four dawn raids Sectors: Energy; food; security and surveillances services 2021 Two dawn raids Sectors: Plastic and metal recycling; database marketing   Sweden 2023 None reported 2022 One dawn raid Sectors: Bread 2021 Four dawn raids Sectors: Waste management and treatment; plumbing products and installations; bread; PCR tests   Switzerland 2025 One dawn raid Sector: Steel products 2024 One dawn raid Sector: Civil engineering and construction 2023  Four dawn raids Sector: Fragrances; printer accessories and office equipment; civil engineering and construction; steel products 2022 Two dawn raids Sectors: Dermatological medication; road maintenance 2021 Two dawn raids Sectors: Transport of waste collection and waste disposal; unknown   United Kingdom 2023 One dawn raid Sector: Fragrances 2022 Three dawn raids Sector: End-of-life vehicle manufacturing; immigration facilities; sports TV broadcasting  2021 None reported EU 2025 Three dawn raids Sector: Non-alcoholic drinks, ski equipment, vaccines 2024 Four dawn raids; one FSR dawn raid Sector: Tyre manufacturers; consultancy for tyre manufacturers; security equipment; financial derivatives; data contruction centre 2023 Seven dawn raids Sectors: Energy drinks; fragrances; fashion; synthetic turf manufacturing; medical devices for cardio-vascular applications; Chemical additives for cement and chemical admixtures for concrete and mortar; online ordering and delivery of food, groceries and other consumer goods 2022 Four dawn raids Sectors: Fashion; online food delivery; water infrastructure; ELV vehicles 2021 Four dawn raids Sectors: Defence; animal health; wood pulp; manufacturing and distribution of garments Back to Map

A look at the statistics

The information below has been sourced from LexisPSL, and is based on dawn raids that have been publicly announced by competition authorities. The LexisPSL information was supplemented from selected public sources in jurisdictions where further information was available. Since not all competition authorities announce every dawn raid, the data below likely underestimate the number of raids. The sector charts reflect dawn raids in which the sectors were identified by the competent authorities. In some jurisdictions (e.g., Germany or Czech Republic), the authority publishes the number of raids without identifying the sector. As a result, the statistics in the charts below may underestimate the actual number of dawn raids by sector and country. The statistics displayed for the Czech Republic are available only as of 2021.

View full image: Number of dawn raids per year in the EU, Switzerland and the UK, 2018 – 2025 (Q2) (PDF)

View full image: Dawn raid leader board (PDF)

View full image: Number of dawn raids tracker per year and during 2018 – 2025 (Q2) in the EU, plus Switzerland and the UK (PDF)

View full image: Dawn raid tracker by sector: EU plus Switzerland and the UK, 2018 – 2025 (Q2) (PDF)

View full image: Dawn raids tracker by sector: EU plus Switzerland and the UK, 2024 and 2025 (Q2) (PDF)

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