Dawn Raid Analysis Quarterly: 2025 Q3

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.

Q3 2025 at a glance

In the third quarter of 2025, European competition authorities conducted a total of 11 dawn raids - two more than in the same period last year (Q3 2024).

The Danish Competition and Consumer Authority was the most active regulator in Q3, carrying out three dawn raids in the consumer goods, financial services, and transport sectors. Notably, this coincides with the Danish regulator's October announcement of adopting a new press policy: proactively disclosing dawn raids shortly after they are conducted, rather than at a later stage (if at all), as was previously the case.

Ambitious start to Q4: October marked a very busy beginning to Q4. In just a month, European competition authorities conducted seven dawn raids. The European Commission targeted flu vaccine and ski equipment makers for possible anticompetitive behaviour—adding a seasonal touch.

Key Q3 2025 legal developments

Below is a selection of key developments in Q3 2025:

• AG Medina distinguishes business from personal: Guidance on business email seizures during antitrust dawn raids
• General Court endorses European Commission’s dawn raid powers in Red Bull legal challenge
• European Commission imposes first ever fine for incomplete reply to information request

AG Medina distinguishes business from personal: Guidance on business email seizures during antitrust dawn raids

On 23 October 2025, Advocate General Medina delivered her second opinion in an ongoing dawn raid case. The CJEU is seeking to answer the question of whether a competition authority needs a prior judicial authorisation to seize business emails.

The case arises from requests for a preliminary ruling submitted by a Portuguese court and concerns three parallel antitrust investigations of medical imagery, medical testing and payment provider companies. The companies claimed that for the Portuguese competition authority to seize the communication, it needed a prior authorization from a judge as opposed to just from a public prosecutor. They argued that this is because the work emails contained personal data which benefit from protection under the Article 8 of the European Charter of Fundamental Rights. AG Medina already delivered her first opinion in the case last year (for more details, see here).  The CJEU decided to reopen the oral procedure, and convene the  Grand Chamber to take into account the Landeck ruling that was delivered in the meantime. In Landeck, the judges held that when police seize personal mobile phone of a private individual from their home during a criminal investigation, they must comply with strict requirements, including obtaining a judicial authorization.

AG Medina argued that circumstances in Landeck are not comparable to the case at hand. In particular, she distinguished it from Landeck based on the following two key aspects:

• Access to business emails v access to personal mobile phone: In Landeck, the police took a suspect’s personal mobile phone from their private residence, gaining complete and unrestricted access to all its information. Such access could reveal highly detailed insights into the data subject’s private life, such as their daily routines, places they live or visit, movements, activities, social connections, and locations they frequent. In contrast, the collection of business emails generally does not enable authorities to draw such detailed conclusions about an individual’s private life. Additionally, any personal data obtained from business emails is typically gathered only incidentally and in small amounts, making it unlikely for authorities to build a comprehensive or in-depth profile of someone’s private affairs.
• Antitrust dawn raids target businesses, while a criminal investigation targets individuals: Therefore antitrust dawn raids do not justify the same level of protection as when an authority targets an individual. 

On this basis,  AG Medina concluded that a competition authority does not need a judicial authorization when conducting dawn raids at business premises (unless a Member State explicitly imposes such requirement) provided:

• Sufficient legal safeguards are in place: A competition authority must:
  • ensure the inspection decision is well-reasoned and precise;
  • limit data collection to what is strictly necessary;
  • ensure the collection and access to data is carried out in the presence of representatives of the business;
  • unform individuals of any processing of their personal data and of their rights;
  • use rigorously defined keywords for digital searches;
  • anonymise irrelevant personal data;
  • ensure that personal data is stored in a secure environment, only for as long as strictly necessary;
  • ensure that access to personal data is restricted to as few people as possible, who are subject to confidentiality obligations and are prohibited from using the data for purposes other than the investigation;
  • secure deletion of personal data (either because it is irrelevant to the purpose of the investigation or because the acceptable period of retention has expired) by means of a general cleansing mechanism that prevents its subsequent recovery;
  • have a data protection officer who examines “independently” whether the rules concerning personal data have been correctly applied.
• Ex post facto judicial review of the conduct of the inspection is available, both during and at the end of the investigation.  

However, the AG emphasised that, in line with the already existing EU law, prior judicial authorization is required in two specific situations: (i) when emails are seized at an individual’s private residence, or (ii) when the seizure is intended to incriminate an individual under criminal law.

The CJEU follows AG opinions in majority of the cases. If this is the case here, the opinion serves as a useful checklist for authorities as well as businesses, in particular in relation to preservation of privacy rights.

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General Court endorses European Commission’s dawn raid powers in Red Bull legal challenge

On 15 October 2025, Red Bull lost its legal challenge against the European Commission’s (EC) decision to conduct a dawn raid at its business premises. This General Court (GC) judgment provides important clarifications on the balance between the EC’s investigatory powers in antitrust investigations and the procedural safeguards available to companies subject to inspections. Notably, the case is part of a recent trend, including the Symrise and Michelin challenges, where companies have challenged the EC’s dawn raid powers, as discussed in our previous quarterly edition.

In May 2023, Red Bull contested the EC’s decision to inspect its business premises, following a raid conducted in March 2023. The investigation was prompted by a competitor’s complaint alleging that Red Bull engaged in anticompetitive practices. After the initial raid, EC inspectors continued their review at the EC’s own premises. In July 2023, Red Bull also sought interim relief to suspend the execution of the dawn raid decision, but the GC dismissed this application, finding that privacy rights were sufficiently protected – for more details see here.

In its appeal, Red Bull argued (i) that the EC’s inspection decision authorising the dawn raid was insufficiently clear about the purpose and object of the inspection, (ii) the EC did not have sufficient evidence to justify the dawn raid, and (iii) the dawn raid was disproportionate as the EC could have sent a request for information (RFI) instead which would be less restrictive. Additionally, Red Bull also argued that the decision to continue the inspection at its premises was disproportionate. It also raised issues with the behaviour of inspectors during the dawn raid.

The GC rejected all of Red Bull’s arguments. In particular, the Court found that:

• The inspection decision was sufficiently clear: The decision was adequately reasoned, enabling Red Bull to understand the scope of the inspection and its duty to cooperate. The GC noted that the decision clearly described the relevant sectors, geographic market, and the nature of the suspected anticompetitive conduct. It  dismissed the argument that the inclusion of terms such as “in particular” or “potential” created uncertainty regarding the scope of the inspection or hindered Red Bull’s ability to comprehend the subject matter.
• The EC had sufficiently serious evidence: The EC had serious indications of a potential infringement, based on complaints from both a competitor and third parties. The GC emphasized that the EC is not required to verify every detail or contact every third party at this preliminary stage, as this could compromise the investigation and the “element of surprise essential to any inspection.”
• The EC was entitled to choose a dawn raid over an RFI: The GC confirmed that the EC may opt for a dawn raid instead of less intrusive measures, such as an RFI, if it considers this necessary for an effective investigation—especially where voluntary cooperation is unlikely to yield incriminating evidence.
• Conduct during the inspection is irrelevant to the legality of the dawn raid decision: Complaints about alleged aggressive behaviour of EC inspectors, handling of electronic data, or the continuation of the inspection at the EC’s premises were deemed irrelevant to the legality of the inspection decision itself. The GC noted settled case law according to which the legality of an act must be assessed based on the legal and factual circumstances at the time the act was adopted. Subsequent events cannot affect its validity, and any issues with the conduct of the inspection must be challenged separately.

Practical takeaways

• Inspection decisions must clearly state the object and purpose of the inspection, but need not provide exhaustive detail or disclose all evidence at the preliminary stage. However, the GC is prepared to scrutinise the sufficiency of the evidence in the EC’s file used as a basis to launch an inspection.
• The EC is not required to use the least intrusive means if an inspection is justified by the needs of the investigation; inspections are appropriate where voluntary disclosure is unlikely.
• Challenges to the conduct of an inspection must be raised separately from challenges to the legality of the inspection decision itself. The legality of the decision is assessed based on the circumstances at the time of adoption, not on subsequent events

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European Commission imposes first ever fine for incomplete reply to information request

On 8 September 2025, the European Commission (EC) imposed a fine of €172,000 on Eurofield SAS (Eurofield) and its then-parent company for providing incomplete information in response to requests for information (RFI) during an ongoing antitrust investigation in the synthetic turf sector. This marks the first time the EC has fined a company for an incomplete RFI reply in an antitrust case. The decision sends a clear message: companies must take RFIs very seriously. For more details, see our alert. 

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Interactive Dawn Raid map

EU Austria 2024 One dawn raid Sector: Vehicle repair 2023 One dawn raid Sector: Refrigeration and freezing equipment  2022 Three dawn raids Sectors: Wood-pellets; waste management 2021 One dawn raid Sector: 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 Sector: Wheat 2022 None reported 2021 None reported Cyprus 2023 None reported 2022 One dawn raid Sector: Bricks 2021 None reported Czech Republic 2025 Four dawn raids Sectors: Post services; engineering; land construction; household and garden equipment 2024 Nine dawn raids Sectors: Domestic appliances; lorries; roads and motorways; web portal and search engines; unknown 2023 Eight 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 Five dawn raids Sectors: Sports equipment; passenger transport; accounting services; robotic lawnmowers; maritime freight transport  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 Sectors: Rail transport; graphic cards; 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 Four dawn raids Sectors: Maritime and private tutoring services; provision of passenger transport services; electricity generation and wholesale supply; transport by public passenger vehicles  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; aluminum; 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 Sectors: 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 Sectors: Airlines; home alarms 2023 One dawn raid Sector: Publicly funded transport 2022 None reported 2021 None reported Italy 2025 Seven dawn raids Sectors: Transportation; jewellery and watches; application communication services; ski passes; civil drones; watches; civil drones 2024 Three dawn raids Sectors: 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 Two dawn raids Sectors: Software; civil and hydraulic engineering, road construction 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 Sectors: Agricultural machinery; processing and wholesale trade of raspberries; household appliances, 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 Sectors: 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 Sectors: Console gaming; sunflower oil, butter and sugar; voucher services related to employee benefits; banking 2022 One dawn raid Sector: 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 Three dawn raids Sectors: Air conditioning, cooling and heat pump services; air conditioning, refrigeration and heat pumps; bakery products 2024 Three dawn raids Sectors: Photovoltaics; provision of institutional healthcare; medical devices suppliers 2023 Three dawn raids Sectors: 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 Sector: IT suppliers 2023 None reported 2022 None reported 2021 One dawn raid Sectors: Driver training   Spain 2025 Nine dawn raids Sectors: Generic medicine; civil engineering construction; leasing of facilities intended for the activity of FBO at airports; public transport; international movers; recycling and decontamination of end-of-life vehicles; private healthcare and healthcare consultancy; international moving; public transport 2024 Four dawn raids Sectors: 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 Sectors: 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 Two dawn raids Sectors: Steel products; building and civil engineering  2024 One dawn raid Sector: Civil engineering and construction 2023  Four dawn raids Sectors: 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 Sectors: End-of-life vehicle manufacturing; immigration facilities; sports TV broadcasting  2021 None reported EU 2025 Five dawn raids Sectors: Non-alcoholic drinks; ski equipment; vaccines; e-commerce platform (FSR dawn raid); ski equipment  2024 Four dawn raids; one FSR dawn raid Sectors: 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 (Q3 + October) (PDF)

View full image: Dawn raid leader board (PDF)

View full image: Number of dawn raids tracker per year and during 2018 – 2025 (Q3 + October) in the EU, plus Switzerland and the

View full image: Dawn raid tracker by sector: EU plus Switzerland and the UK, 2018 – 2025 (Q3 + October) (PDF)

View full image: Dawn raids tracker by sector: EU plus Switzerland and the UK, 2024 and 2025 (Q3 + October) (PDF)

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