Our Expert in Australia
No results available
Australia’s mandatory merger control regime represents the most significant change to the nation’s competition law framework in decades, replacing the long-standing voluntary notification system with a compulsory, suspensory process administered by the Australian Competition and Consumer Commission (ACCC). Since 1 January 2026, every acquisition of shares or assets that meets prescribed control and monetary thresholds must be notified to the ACCC before completion, and closing is prohibited until clearance or a waiver is granted. This guide provides M&A practitioners with a single, actionable resource covering who must notify, the timelines that now shape deal execution, the remedies and waiver process, and the personal liability exposure that directors and officers face under the reformed regime.
For over four decades, Australia operated an informal, voluntary merger clearance process. The ACCC could review transactions brought to its attention, but there was no legal obligation to notify and no mechanism to prevent completion before the regulator had finished its assessment. The Australian Government’s 2023 Competition Review identified this as a critical gap, noting that voluntary notification left the ACCC reliant on parties’ willingness to engage and limited its ability to prevent anti-competitive transactions before they occurred.
The Treasury-led reform process culminated in amendments to the Competition and Consumer Act 2010 (Cth), establishing mandatory merger control in Australia through a phased rollout designed to give the market time to adjust.
| Date | Change / Instrument | Practical Effect |
|---|---|---|
| 1 July 2025 | Voluntary notification pilot commences | Parties could use the new ACCC notification forms and process on an opt-in basis, receiving early guidance and feedback on the regime’s operation |
| 1 January 2026 | Mandatory and suspensory regime enters full force | Notification is compulsory for all transactions meeting the prescribed control and monetary thresholds; completion is prohibited until ACCC clearance or waiver |
| 26 March 2026 | Penalty framework updated | Maximum penalties for contraventions of the merger notification and gun-jumping provisions increased, expanding both corporate and personal liability exposure |
The ACCC has stated that Australia’s mandatory merger control regime aims to identify and prevent anti-competitive acquisitions while providing a clear, efficient process that supports legitimate deal activity. The regime brings Australia into line with most comparable economies, including the EU, United Kingdom, United States, Canada, and Japan, which already operate mandatory or semi-mandatory notification systems. For deal teams accustomed to the informality of the old process, the shift requires fundamental changes to transaction planning, SPA drafting, board governance, and completion mechanics.
The new regime casts a wide net. All acquisitions of shares or assets, including legal or equitable interests, must be notified to the ACCC where the control threshold and the monetary thresholds are met. Understanding exactly when notification is triggered is the first compliance decision every deal team must make.
Notification is required where the acquirer would, as a result of the transaction, gain the ability to directly or indirectly control or exert material influence over the target’s operations. This is deliberately broad and covers:
Alongside the control test, the transaction must meet monetary thresholds based on the turnover of the parties in Australia. In practical terms, these thresholds are designed to capture economically significant transactions while exempting very small deals. According to the ACCC’s published guidance, the notification obligation applies where the combined Australian turnover of the merger parties, or the turnover of the target business in Australia, exceeds the prescribed levels. Deal teams must calculate turnover using the ACCC’s published methodology, which includes rules on aggregation across related entities and attribution of revenue from associated businesses.
A critical practical issue for multinational groups is that the monetary thresholds are assessed on a consolidated group basis. Revenue from all Australian subsidiaries, joint ventures (where control exists), and related bodies corporate is attributed to the acquirer. This means that an overseas parent with multiple Australian portfolio companies may trigger notification even where the individual acquiring entity’s turnover is modest. Early threshold analysis, run at the term-sheet or due-diligence stage, is essential to avoid surprises at signing.
For in-house counsel and deal project managers, the following step-by-step framework offers a reliable initial screen. Industry observers suggest running this analysis as soon as a transaction reaches heads-of-terms stage.
The practical answer is: earlier than you think. Preparing for ACCC merger review involves assembling market share data, identifying competitive overlaps, and drafting the notification, all of which require lead time. Competition counsel should be briefed at the same time as corporate and finance advisors, not after the SPA is finalised. Board papers authorising the transaction should explicitly record that ACCC notification requirements have been assessed and that the proposed deal timeline accommodates the regulatory process.
Once notification is mandatory, the ACCC process becomes the critical path for deal completion. Understanding the mechanics, and their interaction with SPA conditionality, is essential for managing timetable risk.
The ACCC requires a structured notification containing:
Quality of the initial filing directly affects review time. Incomplete or unclear notifications are likely to prompt information requests, extending the ACCC clearance timeline and delaying completion.
The regime establishes statutory timeframes for the ACCC’s initial review, with the ability to extend into a more detailed Phase 2 investigation for complex or contentious matters. Early indications suggest that straightforward, non-contentious transactions are being cleared within the initial review window, while transactions involving horizontal overlaps or concentrated markets are proceeding to extended review.
The suspensory effect is the single most important practical consequence for deal teams. Once a notification is lodged for a mandatory transaction, the parties are legally prohibited from completing the acquisition until the ACCC has either cleared the transaction, accepted enforceable undertakings, or granted a waiver. There is no “deemed clearance”, silence does not equal approval. Completing before clearance (known as gun-jumping) is a contravention that attracts serious penalties.
| Deal Milestone | ACCC Action / Filing Requirement | SPA Drafting Tip |
|---|---|---|
| Signing / Exchange | Lodge ACCC notification (or waiver application) promptly after signing | Include a condition precedent requiring ACCC clearance or waiver; specify a long-stop date that accommodates extended review |
| Pre-completion / Interim Period | ACCC conducts review; may issue information requests or commence Phase 2 | Include interim operating covenants (ordinary course obligations); restrict integration planning that could constitute gun-jumping |
| Completion | ACCC clearance or waiver received; or undertakings accepted | Include a termination right if ACCC clearance is not obtained by the long-stop date; consider reverse break-fee provisions to allocate regulatory risk |
Not every notified transaction will proceed through a full review. The ACCC has established three primary pathways to resolution, and deal teams should understand each when preparing their notification strategy.
The ACCC’s waiver process is designed for transactions that clearly do not raise competition concerns, for example, acquisitions in unrelated markets, or where the target’s Australian operations are de minimis. A waiver application is typically shorter than a full notification and is assessed on an expedited basis. According to early commentary, the ACCC has been granting waivers for clearly benign transactions within relatively short timeframes, providing an important safety valve for deal flow.
Key points for waiver applications include demonstrating that the merger parties do not compete in any relevant market, that there are no vertical or conglomerate relationships of competitive significance, and that the transaction does not raise public interest concerns flagged by the ACCC.
Where the ACCC identifies competition concerns but does not seek to block the transaction outright, it may accept court-enforceable undertakings. These typically involve structural remedies, divestiture of overlapping business units or assets, although behavioural undertakings may be accepted in limited circumstances. Negotiating undertakings extends the review timeline, and deal teams should build this possibility into their long-stop date calculations. The likely practical effect will be that parties need to identify potential divestiture packages early and have them ready as a fallback position during the ACCC review.
The enforcement framework underpinning the new regime carries real consequences for both corporations and individuals. The penalty increases that took effect on 26 March 2026 significantly raised the stakes for non-compliance, making this a governance issue, not merely a transaction-management issue.
Competition law penalties in Australia for merger-related contraventions, including failure to notify, gun-jumping, and provision of false or misleading information in a notification, can be substantial. Corporate penalties are calculated based on the greater of a fixed maximum amount, a multiple of the benefit obtained from the contravention, or a percentage of the corporation’s annual Australian turnover.
Directors and officers have a duty to ensure that the corporation complies with the law, and a failure to implement adequate compliance processes for ACCC notification can attract personal civil liability. The following governance actions are recommended:
D&O insurance policies should be reviewed to confirm coverage for competition law contraventions, including civil pecuniary penalties. Deal-specific indemnities in the SPA should address the allocation of liability for any failure to comply with the notification regime, particularly in cross-border transactions where the overseas parent may bear ultimate responsibility for ACCC notification compliance.
| Entity / Actor | Notification Obligation | Potential Exposure |
|---|---|---|
| Acquiring corporation (or Australian target) | Must notify ACCC if control and monetary thresholds met; suspensory effect applies | Corporate penalties for non-notification or gun-jumping; transaction may be unwound; board must document legal advice |
| Overseas parent / ultimate owner | Aggregation rules attribute group turnover; indirect acquisitions may be caught | May trigger notification where local entity thresholds alone would not; early threshold analysis required across entire group |
| Directors / Officers | Duty to ensure corporate compliance; failure to oversee process may attract personal civil pecuniary penalties | Board-level oversight required; minutes and pre-notification approvals recommended to reduce personal exposure |
Effective compliance with mandatory merger control in Australia depends on having the right processes in place before a deal reaches signing. Deal teams should prepare and maintain the following resources as standing tools, updated for each new transaction:
Consider an anonymised example: an ASX-listed industrial services company (“Acquirer Co”) seeks to purchase a privately held competitor (“Target Co”) operating in the same sector across eastern Australia. Both companies have Australian turnover exceeding the prescribed monetary thresholds, and the acquisition would give Acquirer Co a combined market share in excess of 35% in two regional markets.
At the term-sheet stage, Acquirer Co’s in-house counsel runs the threshold calculation and confirms that notification is mandatory. Competition counsel is engaged immediately and begins preparing the notification in parallel with SPA negotiations. The SPA includes an ACCC clearance condition precedent, a 120-business-day long-stop date, interim operating covenants, and a termination right if clearance is not obtained.
The notification is lodged within days of signing. The ACCC identifies the regional market overlap and issues a targeted information request during the initial review period. Acquirer Co provides the requested data promptly and proposes a divestiture of one overlapping depot as a structural remedy. The ACCC accepts the undertaking, and clearance is granted. Total elapsed time from notification to clearance: approximately 60 business days. The deal completes within the long-stop date, and the board minutes record full compliance with the notification regime at every stage.
Mandatory merger control in Australia is now an operational reality that affects every significant M&A transaction. The following actions should be taken immediately by deal teams, boards, and in-house counsel:
This article was produced by Global Law Experts. For specialist advice on this topic, contact David Grace at Cooper Grace Ward, a member of the Global Law Experts network.
posted 8 minutes ago
posted 32 minutes ago
posted 33 minutes ago
posted 56 minutes ago
posted 57 minutes ago
posted 1 hour ago
posted 1 hour ago
posted 2 hours ago
posted 2 hours ago
posted 3 hours ago
posted 3 hours ago
posted 3 hours ago
No results available
Find the right Legal Expert for your business
Sign up for the latest legal briefings and news within Global Law Experts’ community, as well as a whole host of features, editorial and conference updates direct to your email inbox.
Naturally you can unsubscribe at any time.
Global Law Experts is dedicated to providing exceptional legal services to clients around the world. With a vast network of highly skilled and experienced lawyers, we are committed to delivering innovative and tailored solutions to meet the diverse needs of our clients in various jurisdictions.
Global Law Experts is dedicated to providing exceptional legal services to clients around the world. With a vast network of highly skilled and experienced lawyers, we are committed to delivering innovative and tailored solutions to meet the diverse needs of our clients in various jurisdictions.
Send welcome message