The third quarter of 2025 reflects sustained increase in competition and consumer protection activity across Southeast Asia, marked by more assertive enforcement, growing cross‑border cooperation, and targeted reforms in fast‑evolving digital markets. Regulators in the region have pressed ahead with investigations and sanctions against anti‑competitive conduct and unfair trade practices, while simultaneously refining merger review processes and issuing sector‑specific guidance. Digital economy issues remain prominent, with several jurisdictions scrutinising platform conduct, AI‑enabled practices, online reviews, and e‑commerce transparency. Alongside enforcement, regulators have advanced legislative and policy initiatives to expand jurisdictional reach, accelerate procedures, and strengthen preventive tools.
Merger control
Across the region, merger activity remained robust, with regulators clearing transactions, consulting on complex deals, and enforcing procedural compliance. In Singapore, the Competition and Consumer Commission of Singapore (“CCS“) cleared mergers and acquisitions in the intermodal container leasing sector and the vehicle manufacture sector. CCS also consulted on an acquisition in the healthcare industry. In Indonesia, the Indonesia Competition Commission (“ICC“) reinforced the importance of complying with technicalities in post‑closing filings by imposing a fine for late notification of an acquisition, emphasising entity‑specific filing obligations and strict timelines.
Anti‑competitive agreements and unfair consumer practices
Regulators have also pursued a broad spectrum of cartel, coordination, and consumer‑facing misconduct. In Singapore, CCS imposed over S$5 million in penalties on remittance service providers for illegal exchange of confidential rate information, took action against unfair practices including the posting of artificial intelligence (“AI“)‑generated fake reviews and misleading consumer claims, and obtained court orders against businesses and an individual orchestrating deceptive sales tactics. In Indonesia, ICC opened a probe into alleged price‑fixing among 97 financial technology peer‑to‑peer lenders and intensified scrutiny of procurement practices involving state‑owned enterprises, while also launching market assessments into non‑subsidised fuel shortages. In Vietnam, the Vietnam Competition Commission sanctioned leading express delivery and gold trading companies for misleading conduct aimed at diverting customers, ordering public corrections and signalling heightened vigilance over consumer‑facing representations.
Legislation and policy
Regulators advanced significant reforms to modernise frameworks and deepen cross‑border and cross‑agency coordination. In Malaysia, the Malaysia Competition Commission concluded public consultation on its draft final market review of the digital economy ecosystem and signed a memorandum of understanding with the Korea Fair Trade Commission. In the Philippines, the Philippine Competition Commission enhanced inter‑agency cooperation through an agreement with the National Telecommunications Commission to bolster competition in data transmission and briefed legislators to align enforcement priorities with national development plans, including attention to algorithmic pricing issues. In Singapore, CCS marked its 20th anniversary with regulatory enhancements to streamline assessments, introducing: (i) an AI Markets Toolkit to guide competition and consumer compliance in AI deployment; (ii) enhanced e‑commerce guidelines on transparency, reviews and automated tools; (iii) a unit pricing pilot for supermarkets; and (iv) a guide to improve the quality and accuracy of marketing claims. In Thailand, the Trade Competition Commission of Thailand consulted on draft e‑commerce platform guidelines and proposed amendments to expand the Trade Competition Act’s extraterritorial reach, enhance enforcement tools, and introduce alternative dispute resolution, while publishing market size reports on online marketplaces and cold‑rolled steel. In Vietnam, authorities consulted on a draft decree revising administrative sanctions under competition law to increase transparency and enhance penalties. In Indonesia, ICC has progressed its “ICC Listens” initiative by engaging various industries on a range of competition-related issues.
Compliance reminder
In light of these developments, we strongly recommend that businesses proactively review their competition and consumer protection compliance frameworks to stay responsive to evolving regulatory guidance, with particular attention to high‑risk areas such as market information exchanges, procurement and association engagement, platform governance, digital marketing, and AI‑enabled tools. This is particularly important at this time of the year, when, apart from rushing to close deals, businesses should be actively doing a health check to ensure all is kosher within the company.
From a department-specific perspective, transaction teams should build robust merger filing protocols into deal timetables, while commercial and marketing functions should adopt clear substantiation processes for claims and controls to prevent misleading content.
The Rajah & Tann Asia Competition & Antitrust Team is committed to staying ahead of the rapid developments in competition law across the region and stands ready to assist. Please reach out to us if you wish to further discuss these developments.
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Disclaimer
Rajah & Tann Asia is a network of member firms with local legal practices in Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. Our Asian network also includes our regional office in China as well as regional desks focused on Brunei, Japan and South Asia. Member firms are independently constituted and regulated in accordance with relevant local requirements.
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