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Experts Call for Transparent and Predictable Implementation of CCI’s Settlement Framework
New Delhi, November 10, 2025: The introduction of settlement mechanisms by the Competition Commission of India (CCI) represents a transformative moment for India’s competition law regime. These regulations, if implemented with transparency and consistency, could foster a culture of compliance particularly crucial in the context of India’s fast-evolving digital economy.
The Policy Consensus Centre (PCC) hosted a high-level discussion on ‘Optimising the Settlement Laws – A New Horizon for Competition Regulations’, bringing together legal, policy, and market experts to examine how the newly operationalised settlement and commitment framework can strengthen India’s competition enforcement landscape.
The discussion comes at a time when settlement regulations are emerging as a preferred tool among Indian regulators to ensure quicker and more efficient dispute resolution. The Competition Commission of India’s recent settlement with Google, following a prolonged investigation, has underscored the practical utility of such mechanisms in driving timely compliance and market correction. Similarly, SEBI’s settlement framework, operational since 2018, has helped expedite enforcement in the securities market, as has the Enforcement Directorate’s reported offer to Flipkart under its “Compounding Rule”.
Together, these developments signal a growing trend in India’s regulatory landscape and are likely to set important precedents for future competition and enforcement jurisprudence.
Nirupama Soundararajan, Co-Founder & CEO, Policy Consensus Centre moderated the discussion and emphasised that the move towards settlements reflects a pragmatic shift in regulatory thinking. “For smaller enterprises, drawn-out litigation can be existential. While larger players may absorb the costs and delays, MSMEs often cannot. A fair and transparent settlement process can provide timely closure, preserve business continuity, and level the playing field in highly dynamic digital markets.” she said.
Drawing from both global and domestic experiences, panellists highlighted that while the Competition Commission of India (Settlement) Regulations, 2024 represent an important reform to ensure time-bound resolutions, their success will hinge on clarity, predictability, and proportionality in application. They also referenced the Google settlement case (2025) as an important precedent demonstrating timely compliance and operational changes, benefitting both markets and consumers.
During the panel, Shriram Subramanian, Founder & Managing Director, InGovern Research Services emphasized the role of technology, stating“Technology must play a central role in improving regulatory efficiency. The CCI can adopt AI tools to analyze data faster, reduce repetitive requests, and streamline hearings. A single comprehensive round of data collection and more virtual proceedings could significantly improve turnaround time.”
Neelambera Sandeepan, Partner, Lakshmikumaran & Sridharan Attorneys spoke on how the CCI’s ability to deliver on the promise of settlement will depend on how effectively it strengthens its investigative processes. She further stated that SEBI’s experience shows that detailed, evidence-based inquiries can be conducted within well-defined timelines, a discipline that enhances both credibility and efficiency. For the CCI, adopting a similar balance between procedural rigour and timeliness will be a critical precursor to the success of the settlement regime.
Arindam Goswami, Co-Founder & Partner, Policy Consensus Centre, highlighted“ As India transitions to a settlement-based approach in competition regulation, it is vital that these arrangements are continuously monitored for their long-term impact. The success of the framework will depend not just on faster resolution, but on how effectively it deters repeat offences and encourages behavioural change. Without consistent oversight and post-settlement evaluation, the true purpose of these reforms risk being diluted.”
The panel featured also Madhav Dar, Director, Numerays Consulting, who talked about the impact of these mechanisms stating, ““For the settlement framework to truly work, competition orders must be grounded not just in legal reasoning but also in sound economic rationale. Platform markets operate on complex dynamics like network effects and two-sided interactions, and unless these are adequately reflected in enforcement orders, we risk seeing only half the picture. Integrating both legal and economic perspectives will be essential for building stronger, more credible competition jurisprudence.”
During the open discussion, participants debated whether the settlement regime risks being viewed as lenient, particularly for large digital players, or if it represents a much-needed evolution towards pragmatic enforcement. Many agreed that the ultimate test will lie in consistent implementation and in expanding the framework’s scope once its efficacy is established.
