Paris, January 9, 2026 — Fine reductions and the launch of dawn raids remain the primary factors prompting companies to apply for leniency, according to a new study published by the French authority examining the operation of its leniency programme.
The study also finds that while exposure to follow-on damages actions has become a more significant consideration over the past decade, it has not displaced traditional incentives as the main drivers of leniency applications. At the same time, the authority notes that whistleblower reporting mechanisms, largely absent in earlier reviews, are beginning to influence corporate decision-making and are expected to have a lasting impact on the programme.
Practitioner Insights
The study is based on feedback from competition law practitioners and provides an assessment of how the leniency programme has been applied in practice over the last ten years. It builds on earlier studies published in 2014 and 2018.
According to the authority, the findings offer a clearer picture of the practical experiences of companies and advisers involved in leniency applications and highlight areas where adjustments to the programme could be considered.
Programme Framework
Introduced in 2001, the leniency programme allows companies involved in prohibited agreements to receive full or partial immunity from fines in exchange for cooperation in establishing infringements under French or EU law. The authority reported that the number of leniency applications has increased in recent years.
The authority said the latest study will inform its ongoing review of the programme, particularly with respect to protections for leniency applicants and the incentives that encourage companies to come forward.
