Dawn Raid Analysis Quarterly: 2026 Q1
White & Case Dawn Raid Analysis Quarterly (DRAQ) is an information resource on surprise on-the-spot inspections (dawn raids) across Europe. Here, we guide you through the latest updates and legal developments for 2026 Q1.
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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.
Q1 2026 at a glance
In the first quarter of 2026, European competition authorities conducted a total of 19 dawn raids – two more than in the corresponding period of the previous year (Q1 2025).
Among the competition authorities most active in conducting dawn raids, the Spanish and Czech competition authorities led with three dawn raids each, making them the two most active authorities in the Q1 period. The French and Polish competition authorities followed with two dawn raids each. In terms of the most targeted sectors, transport was the most investigated, featuring in four raids covering the sectors of private passenger transport, engineering consultancies, railway infrastructure, and road signage. Consumer goods was the second most targeted sector, with three raids spanning food retail, electronic equipment, and e-commerce platforms. ICT and financial services were the third most targeted sectors, each appearing in two raids.
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.
Key Q1 2026 legal developments
Below is a selection of key developments in Q1 2026:
- The Rise of AI in Antitrust Enforcement: More dawn raids on the horizon?
- Green light for dawn raids without judicial authorisation in Turkey
- Legal Professional Privilege under EU Law in the Age of AI
The Rise of AI in Antitrust Enforcement: More dawn raids on the horizon?
Competition law enforcement has traditionally relied on information derived from leniency programmes, whistleblowers or complainants. However, a fundamental shift is now underway. Competition authorities are increasingly adopting AI technology, moving the nature of enforcement from reactive to proactive. With the help of AI tools, competition authorities can scan public communications and market data in sophisticated ways, enabling them to detect potential anti-competitive conduct and generate sufficient indications to justify a dawn raid. As a result, ex-officio investigations — and consequently dawn raids, which may mark the starting point of such investigations — are likely to become more frequent, even in the absence of a complaint or insider information.
A number of competition authorities are deploying AI capabilities in antitrust enforcement to gather market intelligence, detect anti-competitive conduct or analyse vast amount of data. The European Commission’s investigation into the tyre manufacturers represents the most high-profile known instance of AI-assisted antitrust enforcement triggering a dawn raid in 2024 (Michelin v European Commission (T-188/241). The European Commission used AI to assist in analysing hundreds of thousands of public statements and earnings calls involving the communications of the companies’ financial results and projections, which led to sufficient indications to justify a dawn raid.2 This demonstrates that public statements of companies are now a direct source of enforcement exposure, as companies face a heightened likelihood of triggering dawn raids based on patterns identified algorithmically rather than through traditional means.
The Spanish competition authority’s deployment of the BRAVA (Bid Rigging Algorithm for Vigilance in Antitrust) system represents one of the most prominent examples of AI-driven bid rigging detection capabilities. BRAVA relies on machine learning and big data techniques, primarily trained on datasets drawn from public tenders within Spain, and is designed to flag potentially collusive tenders — this may generate the type of actionable intelligence capable of justifying the initiation of dawn raids against suspected cartel participants in public procurement. Notably, in February 2026, the Spanish competition authority reported that the system had already detected collusive conduct which led to the imposition of fines, and that it had been providing training to the US Department of Justice in the use of similar tools. Other regulators, including in the UK, Australia and Lithuania, have reportedly been developing comparable detection capabilities.
Practical implications
- Companies’ public statements may be dawn raid triggers: The EU tyre manufacturers case is a clear warning.
- Companies should review public disclosure practices: Assess whether public communications — particularly on pricing and other strategically sensitive matters — go beyond what is required by law.
- Public procurement is a key risk area: AI bid rigging detection tools are proliferating across jurisdictions, increasing the risk of coordinated dawn raids for companies active in public tenders.
Green light for dawn raids without judicial authorisation in Turkey
The Turkish top court has given the green light for the country's competition regulator — the Turkish Competition Authority (TCA) — to conduct dawn raids without needing to obtain a court order first. In a closely watched November 2025 ruling, the court upheld the legality of dawn raids without a prior judicial approval, cfonfirming the continued legality of the TCA’s long-standing dawn raid model. The decision brings much-needed certainty for ongoing investigations that had been thrown into doubt by an earlier ruling, which suggested such unannounced inspections might infringe on companies' rights. For the full picture, read the analysis here.
Legal Professional Privilege under EU Law in the Age of AI
During unannounced inspections, every legal professional privilege claim counts — yet businesses may be inadvertently putting those claims at risk through everyday AI use. As companies increasingly rely on AI tools to handle legal and business matters, there is a risk that privilege over sensitive documents and communications may be compromised — potentially exposing them to disclosure during antitrust investigations. Our article explores when legal professional privilege may be maintained and when it may be lost under existing EU law principles when using AI chatbots, and sets out practical safeguards to help businesses protect their privilege before a dawn raid occurs.
1 Michelin v European Commission (T-188/24), paragraph 116 et seq, 138. The Court held that the reasons put forward by the Commission constituted sufficient grounds for ordering an inspection, at least for the main time period. The outcome of the Commission’s quantitative and qualitative analysis of the earning calls constituted sufficient indicia to substantiate the suspicion of price coordination.
2 Michelin v European Commission, paragraph 92 et seq.
Interactive Dawn Raid map
Hover over the highlighted countries to get a closer look at the enforcement activity of the respective National Competition Authorities since 2021.
Austria2024
2023
2022
2021
Belgium2026
2025
2024
2023
2022
2021
Bulgaria2026
2025
2024
2023
2022
2021
Croatia2025
2024
2023
2022
2021
Cyprus2023
2022
2021
Czech Republic2026
2025
2024
2023
2022
2021
Denmark2026
2025
2023
2022
2021
Estonia
Finland2025
2024
2023
2022
2021
France2026
2025
2024
2023
2022
2021
Germany2024
2023
2022
2021
Greece2026
2025
2024
2023
2022
2021
Hungary2025
2023
2022
2021
Ireland2025
2024
2023
2022
2021
Italy2026
2025
2024
2023
2022
2021
Latvia2026
2025
No dawn raids for the period 2021 – 2023 Lithuania
Luxembourg2025
2024
2023
2022
2021
Netherlands2026
2025
2023
2022
2021
Norway2026
2025
2023
2022
2021
Poland2026
2025
2024
2023
2022
2021
Portugal2024
2023
2022
2021
Romania2026
2025
2024
2023
2022
2021
Slovakia2026
2025
2024
2023
2022
2021
Slovenia2026
2024
2023
2022
2021
Spain2026
2025
2024
2023
2022
2021
Sweden2023
2022
2021
Switzerland2025
2024
2023
2022
2021
United Kingdom2023
2022
2021
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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 – 2026 (Q1) (PDF)
View full image: Dawn raid leader board (PDF)
View full image: Number of dawn raids tracker per year and during 2018 – 2026 (Q1) in the EU plus Switzerland and the UK (PDF)
View full image: Dawn raids tracker by sector: EU plus Switzerland and the UK, 2018 – 2026 (Q1) (PDF)
View full image: Dawn raids tracker by sector: EU plus Switzerland and the UK, 2025 and 2026 (Q1) (PDF)
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This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.