Every February, the ACM announces its agenda for the coming year. For 2025, the ACM focuses on three overarching themes: the digital economy, the energy transition and sustainability.
Digital economy
The focus on market power and deception in the digital economy is part of a broader development in Europe with a large amount of (relatively) new legislation and regulation in the digital field, including the Digital Services Act, the Digital Markets Act and the Data Act. The ACM believes it is especially important that people (especially people in vulnerable positions and minors) and businesses can confidently be part of the digital society.
The ACM will focus its efforts this year on protecting these groups from manipulation, abuse, disinformation and deception by acting with other market regulators. Moreover, the authority will investigate computerised and personalised pricing and provide information on the rights and obligations arising from key new laws and regulations. The ACM wants to act against companies that abuse customers' dependence on their software or platform.
Energy transition
The ACM wants to accelerate the energy transition by facilitating necessary changes and innovations in the energy system. In doing so, the authority says it will maintain a focus on affordability, security of supply and fair distribution of costs.
A key problem in the field of energy is grid congestion, which the ACM wants to reduce by introducing measures for flexible grid use. In addition, the authority plans to draft an input tariff and a regulatory method for gas and electricity grid operators. Moreover, the ACM will provide information on new possibilities from the new Energy Act. The ACM has further elaborated on these points in a focus document Energy.
Sustainability
Sustainability is also high on the ACM's agenda. The ACM focuses on the reliability of sustainability claims made by companies, specifically in the food sector, and the competition law implications of sustainability agreements. For instance, it provides advice on the possibilities and limits of the competition law framework within which parties can cooperate to promote sustainability and innovation. It will also examine to what extent and in what ways cooperation in the agro-nutri sector and the international comparison of labels can facilitate sustainability in agriculture. Finally, this focus area will be fleshed out by preparing for supervision of new European rules on international corporate responsibility by large companies.
Besides focusing on these three themes, the ACM also announced five more general market studies on specific markets in 2025. In 2024, the ACM published the results of one such investigation into the savings market. The ACM stresses that these investigations do not necessarily mean that competition or consumer laws have been violated by companies operating in these markets. General market investigations are aimed at uncovering the causes of a market's malfunctioning, without directly imposing sanctions on companies unless the market investigation gives concrete grounds for further investigation. The five specific markets targeted by the ACM in 2025 are the following: veterinarians; (digital) learning resources; computerised consumer pricing; fixed internet budget segment; and hydrogen.
Furthermore, the ACM has recently been advocating for a so-called "New Competition Tool". Such a tool is intended to enable the ACM to immediately follow up general market investigations with concrete measures that can be imposed in a general sense on an entire market sector. Here, the ACM draws inspiration in particular from the UK, where a similar tool has been applied for some time. The tool resembles the ACM’s powers in regulated markets such as the postal and telecoms markets. It should enable the ACM to act more quickly in rapidly changing markets, where repressive supervision (i.e. fines for displayed market behaviour of specific companies) seems to work less well. Whether the legislator will actually proceed to introduce such an instrument for the ACM remains to be seen. The Ministry of Economic Affairs is currently still looking into the feasibility and desirability of this instrument as well as the need for a reform of merger supervision that we reported on earlier. The results of those studies are expected in spring 2025.
