CCI Proposes Relaxed Timelines for Antitrust Commitment Framework to Streamline Compliance

Competition Commission of India Proposes Significant Changes to Commitment Framework

The Competition Commission of India (CCI) has proposed significant changes to its commitment framework, aimed at addressing practical difficulties experienced during its implementation. The revised framework extends the commitment application filing deadline from 45 to 60 days, along with the deadline to place a complete application before the CCI in its ordinary meeting from 7 to 15 working days.

The overall conclusion timeline of the commitment process has been proposed to increase from 130 to 180 working days. Additionally, deficient applications will now be returned, giving applicants 10 working days to cure and refile. These changes are intended to bring India's antitrust regime closer to mature jurisdictions such as the European Union, where commitment decisions play a central role in addressing competition concerns efficiently.

The commitment framework is a mechanism designed to fast-track antitrust dispute resolutions, reduce prolonged litigation, and ensure quicker market corrections. Enacted following the Competition (Amendment) Act in 2023, the framework allows businesses under investigation to voluntarily offer "commitments" (corrective behavioral changes or structural modifications) to address competition concerns without admitting to any formal finding of guilt. A successful commitment order closes the inquiry against the applicant without a formal ruling on whether a contravention of competition law actually took place.

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According to competition law experts, the changes are aimed at addressing practical difficulties experienced during the implementation of the commitment framework. The revised framework is expected to have a meaningful impact on the accessibility, efficiency, and practical viability of the commitment framework. By extending the filing deadline from 45 to 60 days, the amendments afford enterprises more adequate time to prepare thorough and well-considered commitment proposals, reducing the likelihood of incomplete submissions and procedural delays at the threshold stage.

The extension of the overall proceedings timeline from 130 to 180 working days, coupled with the explicit exclusion of time consumed by parties in furnishing information, provides the Commission with a more realistic window within which to conduct a meaningful evaluation of the commitments, invite and consider objections from third parties, and, where necessary, engage in iterative dialogue with the applicant regarding revised proposals.

The draft proposal for changes is intended to make the commitment mechanism more workable for both the regulator and their applicants by extending largely timelines in which the entire commitments process should be resolved. The net effect is greater procedural certainty for applicants and flexibility for the Commission.

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