Dawn Raid Analysis Quarterly: 2026 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 2026 at a glance

In the second quarter of 2026, European competition authorities conducted a total of 15 dawn raids, four fewer than in the previous quarter (Q1 2026).

The most active competition authority in Q2 2026 was the Polish competition authority conducting four dawn raids, followed by the Romanian competition authority conducting three dawn raids. Consumer goods was the most targeted sector this quarter, with competition authorities conducting four dawn raids in Q2 2026.

Key Q2 2026 legal developments

Below is a selection of key developments in Q2 2026:

• The General Court draws the line on lawyers' fee cost recovery during a dawn raid
• Antitrust enforcement without borders? The case that could reshape European Commission's investigative powers
• No-poach and wage-fixing in the spotlight in Poland: Polish competition authority conducts three dawn raids in two weeks

The General Court draws the line on lawyers' fee cost recovery during a dawn raid

On 22 April 2026, General Court (the Court) delivered a judgment concerning a demand for a reimbursement of costs arising from a dawn raid. In March 2023, the European Commission (the Commission) ordered an inspection at Red Bull's premises in Austria, France, and the Netherlands, as part of an investigation into potential anticompetitive agreements and abuse of dominant position in the energy drinks sector. After the on-site inspection at Red Bull's premises concluded on 24 March 2023, the Commission moved the inspection to its own premises in Brussels. This continuation took place over two periods: 14-20 June 2023 and 29 August-29 September 2023.

Red Bull subsequently submitted a reimbursement request covering travel and accommodation expenses, daily subsistence allowances, and the entirety of its lawyers' fees — including fees from a second law firm instructed specifically for the Brussels phase. The Commission agreed to reimburse travel, accommodation, and subsistence costs but refused to reimburse the lawyers' fees.

The central issue of the dispute was what constitutes additional costs and could be therefore reimbursable. The Court held that reimbursable costs are the costs that qualify as "additional costs":

• Costs must be over and above those that would have been incurred had the inspection continued at the undertaking's own premises, and
•  there must be an exclusive causal link between the costs and the fact that the inspection continued at the Commission's premises.

The Court held that lawyers' fees do not generally qualify as additional costs where the undertaking had already chosen to be assisted by lawyers during the on-site phase, because the legal services would, in principle, have been the same regardless of location. Given that Red Bull had engaged lawyers on a continuous basis throughout the on-site inspection at its premises in March 2023, no exclusive causal connection could be established between the decision to continue the inspection in Brussels and the legal fees arising from that continued phase.

The Court acknowledged that the Commission has not entirely excluded the prospect that some lawyers' fees may amount to "additional costs"; however, it is for a company to show that the particular legal services to which those fees relate would not have been rendered had the inspection taken place at its own premises. As regards the fees charged by the law firm based in Brussels that Red Bull had instructed, the Court declined to grant reimbursement, observing that Red Bull had at no point supplied the itemised breakdown of its lawyers' fees that the Commission had specifically asked for, and had instead consistently taken the position that it was entitled to full reimbursement.

Practical implications 

• Understand what qualifies as "additional costs". The Court has reiterated that reimbursable costs must satisfy the two-part test set out above. Travel, accommodation, and subsistence costs for staff and lawyers travelling to Brussels for the continuation of the inspection will typically qualify. Lawyers' fees, however, will generally not, particularly where a company was already using lawyers during the on-site phase unless a company can prove that the fees were genuinely incurred as a result of the change of location.
• Document everything meticulously from the outset. The Commission may request detailed evidence — including names of lawyers, hours worked, hourly rates, descriptions of advice provided, and reasons why that advice was provided solely for the purpose of the continued inspection. Companies should maintain granular records from day one of the inspection and be prepared to substantiate every cost item.

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Antitrust enforcement without borders? The case that could reshape European Commission's investigative powers

On 6 May 2026, a US-headquarter chip and software companies group (the Group) filed an appeal before the EU General Court challenging the Commission's request for information (RFI) issued by way of a decision ordering the Group to produce documents located outside the EU, including documents containing legal advice from non-EU qualified lawyers on non-EU law matters. 

The lawsuit follows complaints emerging from users and trade associations alleging that, amongst others, the Group had imposed unfair licensing practises that harmed European cloud providers. In response, the Commission opened an investigation into potential antitrust abuse.

The core of the dispute relates to the correspondence containing legal advice given by the company's US-based in-house lawyers on matters of US law that are also located outside of the EU. Under US law, these documents are protected by legal professional privilege. However, EU law on legal professional privilege does not extend to communications with in-house lawyers. This is because in-house lawyers are viewed as employees who are not necessarily independent from their company employer. Only advice from external lawyers benefits from protection under EU law.

Specifically, the key grounds of appeal are: 

• The Commission unlawfully interferes with the Group's privileged communications with non-EU lawyers on non-EU law, infringing its fundamental rights.
• The Commission lacks enforcement jurisdiction to compel a non-EU based company to produce documents located outside the EU, including those containing non-EU advice in violation of the principle of territoriality under public international law.
• The decision breaches the principle of comity, which requires the Commission to exercise restraint and defer to non-EU privilege rules where enforcement would adversely affect the essential interests of those jurisdictions.
• The Commission cannot circumvent these jurisdictional limits by directing enforcement measures at the Group's EU-domiciled subsidiary which lacks access to or control over the documents at issue.

Practical implications

The appeal has the potential to redefine the boundaries of the Commission's investigative reach, particularly regarding the treatment of foreign legal privilege during both formal information requests and dawn raids, and could set an important precedent for all non-EU headquartered companies subject to EU antitrust enforcement.

• First test of non-EU privilege before EU courts: This is the first time that the Court will be called upon to determine whether legal advice on non-EU law matters is protected from disclosure to EU investigators. The settled EU law only addresses the status of EU-based in-house lawyers at an EU company. This case extends the debate into an entirely new dimension involving cross-border privilege.
• Implications for dawn raids and beyond: The outcome of this case could have profound consequences for how the Commission conducts dawn raids at companies with global operations. If the Court rules that non-EU privileged documents must be respected, it could impose new constraints on what Commission inspectors can seize or demand during dawn raids at EU subsidiaries of non-EU parent companies. This issue also arises in other types of proceedings or investigations such as in relation to merger control, or Foreign Subsidies Regulation (FSR).
• Extraterritorial enforcement limits: The case squarely raises the question of whether the Commission can effectively reach beyond EU borders by compelling an EU subsidiary to produce documents held by its non-EU parent, particularly when those documents are privileged under the parent's home jurisdiction. This has direct relevance to dawn raids, where inspectors may encounter documents on shared servers or in global document management systems that contain advice from lawyers in multiple jurisdictions.
• Practical impact on multinational compliance: For multinational companies operating in the EU, the case will clarify whether they need to segregate privileged non-EU legal advice from documents accessible to EU subsidiaries — a significant operational and compliance consideration that would affect how companies prepare for and respond to dawn raids.

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No-poach and wage-fixing in the spotlight in Poland: Polish competition authority conducts three dawn raids in two weeks

Over a two week period spanning late May and early June of this year, the Polish Competition Authority (UOKiK) conducted three separate dawn raids targeting suspected no-poach and wage-fixing agreements in the retail/logistics, automotive components and pharmaceutical packaging sectors. The UOKiK has made clear that these dawn raids form part of a broader and ongoing programme of labour market enforcement. Given the pace and breadth of these investigations, there is no doubt that labour market collusion now sits amongst priority enforcement areas.

The three matters cover distinct but overlapping dynamics. On 25 May 2026, UOKiK raided Lidl (supermarket chain) and four transport companies, suspecting that carriers serving Lidl's distribution centers agreed not to recruit each other's drivers, with Lidl allegedly operating an access-control mechanism that entrenched the arrangement. On 2 June 2026, UOKiK  opened formal antitrust proceedings against Dino Polska (also a supermarket chain), four carriers, and five individual managers, alleging a three-month "quarantine period" during which drivers could not move between carriers in the Dino network, with Dino Polska suspected of being the scheme's initiator and enforcer. On 8 June 2026, UOKiK raided automotive components manufacturers (including Toyota Boshoku) and pharmaceutical packaging producers, investigating suspected wage-fixing (including coordination of salaries and employee benefits) alongside mutual no-poach agreements amongst companies active across inter alia industrial manufacturing, pharmaceuticals, logistics, and automotive supply.

Three sets of dawn raids across three separate matters within two weeks indicate a sustained, proactive programme of enforcement – not isolated incidents. Given the wide range of sectors in which UOKiK conducts dawn raids, this enforcement could target any sector. Even companies that do not compete directly compete in any downstream product could still be at risk of enforcement if they recruit from the same regional workforce pool and infringe the rules. Businesses active in Poland should proactively review HR policies, contractor access protocols, inter-company recruitment arrangements, and any salary benchmarking coordination before UOKiK's investigative focus widens further.

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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 2026 One dawn raid Sector: Road signage and street furniture 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 2026 One dawn raid Sector: IT equipment 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 2026 Five dawn raids Sectors: Construction; health facilities; IT; household and garden goods; information technology 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 2026 One dawn raid Sector: Electric vehicle charging 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 2026 Four dawn raids Sectors: Private passenger transport sector; audit and certification; food supplements and dermo cosmetics products; landscaping services 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 2026 One dawn raid Sector: Radiopharmaceuticals 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 2026 One dawn raid Sector: Solar panels 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 2026 Two dawn raids Sectors: Meal vouchers; multiple sclerosis medication  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 2026 One dawn raid Sector: Food retail 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 2026 Two dawn raids Sectors: Labour markets; suppliers to institutions in the public sector 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 2026 One dawn raid Sector: Digital platforms 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 2026 Five dawn raids Sectors: E-commerce platform; electronic equipment; pharmaceutical packaging; automotive components; logistic services for retail  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 2026 Five dawn raids Sectors: Railway infrastructure; waste services; electric minibuses for student transport; security services; healthcare and medical equipment 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 2026 Two dawn raids Sectors: Optical networks; advertising and marketing services  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 2026 One dawn raid Sector: Household appliances  2024 One dawn raid Sector: IT suppliers 2023 None reported 2022 None reported 2021 One dawn raid Sectors: Driver training   Spain 2026 Five dawn raids Sectors: Insurance; engineering consultancies; aerial services; hospital serums and parenteral nutrition products; mortgage brokerage 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 2026 One dawn raid Sector: Chocolate confectionery  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.

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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.}

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