Indian Merger Control Key Trends (2024–2025)

India’s merger control regime has entered a new phase. With 128 combination filings in 2024 alone, the Competition Commission of India (“CCI”) has signaled a more expansive, faster, and sharper enforcement framework which is reshaping how deals must be structured, assessed, and timed.  

The Competition (Amendment) Act, 2023 and the new Combination Rules mark a shift to “Merger Control 2.0.” The introduction of the Deal Value Threshold (“DVT”) of ₹2,000 crore with “substantial business operations in India” has widened the CCI’s jurisdiction beyond traditional asset and turnover tests, capturing a broader range of transactions across sectors, not just digital or tech deals.  

Another major development is the adoption of the “material influence” standard for control. This lowers the threshold for notifiability, meaning even minority acquisitions, private equity investments, can trigger CCI approval requirements. 

While revised de minimis exemptions reduce compliance burdens for genuinely small targets, transactions triggering the DVT cannot rely on these exemptions. At the same time, the green channel route, which offers deemed approval, faces stricter scrutiny, with penalties imposed for inaccurate overlap disclosures and gun‑jumping.  

Timelines have been shortened significantly: the overall merger review period has been reduced from 210 to 150 calendar days, and the CCI now averages approvals in under 16 days. However, frequent information requests and clock‑stops mean early and accurate filings are more critical than ever.  

India’s merger control regime is faster, broader, and more exacting. Dealmakers must plan earlier, assess control and overlaps more rigorously, and treat competition compliance as a core transaction risk, not a post‑signing formality. 

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