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Revisiting leniency: Chanelle Cattin and Sophie Hill for ThoughtLeaders4 Competition Magazine

Posted on 8 October 2025

This article first appeared on the website of the Thought Leaders4 Competition and is reproduced with its kind permission. 

Chanelle Cattin, Managing Associate, and Sophie Hill, Trainee Solicitor at Mishcon de Reya, review the Competition and Markets Authority’s (CMA) proposed revised guidance on leniency and "no action" in cartel cases in the latest issue of ThoughtLeaders4 Competition Magazine.

The article highlights key proposed changes, including an updated definition of "cartel activity," revised protections for Type B and C applicants, changes to admission requirements, and a new online application process. The CMA proposes removing upfront immunity for Type B applicants and automatic protection from competition disqualification orders for both Type B and C applicants, with criminal immunity for employees and directors only in exceptional cases.

Chanelle and Sophie also write about concerns that these changes could reduce incentives for leniency applications, but also point out that the revisions should provide greater clarity for applicants. The CMA is expected to publish updated guidance following its review of consultation feedback.

Read the article.

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