Cullen International's latest Global Trends benchmark compares policy approaches to addressing potential issues related to the market power of online platforms in 14 major jurisdictions.

Key takeaways:

All monitored jurisdictions use competition law to address the market power of online platforms, but they do so in different ways. For example, China strengthened its rules through law changes, guidelines, and active enforcement, while South Africa used market inquiries to obtain remedies and voluntary commitments. In merger control, half of the monitored jurisdictions have introduced rules to deal with killer acquisitions.

Only the EU, the UK, and Japan directly address the market power of online platforms through new ex ante regulations that work alongside competition law and allow authorities to impose specific obligations on designated companies. Australia, Brazil, India, and Thailand are considering or proposing new regulatory frameworks.

Most jurisdictions addressed anticompetitive conduct and mergers involving online platforms on a case-by-case basis under competition law. Of the few ex ante regulatory frameworks in place, only the EU started enforcement under the Digital Markets Act, while Japan and the UK only recently introduced their rules and are still at an early stage.

The research covers:

• competition law rules and guidance specific to online platforms;
• regulation that allows authorities to address the market power of online platforms ex ante, even in the absence of a competition law infringement; and
• recent landmark cases in each jurisdiction.

Scope
Region: Global
Jurisdictions: 14 (Australia, Brazil, China, the EU, India, Japan, Korea, Malaysia, Nigeria, Singapore, South Africa, Thailand, the UK and the US)
Policy area: Competition
Last updated: January 2026

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