The Saudi antitrust regime has experienced substantial changes. At the end of September 2019, Saudi Arabia issued Saudi Arabia Royal Decree No. M75/1440 On the Approval of the Competition Law (Saudi Arabia Cabinet Decision No. 372/1440 On the Approval on the Law of Competition) which substantially overhauled the Saudi merger control and antitrust regimes. With this, the Saudi competition regulator, namely the General Authority for Competition (GAC), was reorganised, and enforcement of the regime increased substantially. Despite considerable development there is still limited precedent, which makes navigating the Saudi antitrust regime difficult. With a lack of guidelines, the interpretation of some provisions of the Saudi antitrust regime remains uncertain. While application towards horizontal agreements is already further developed, the GAC’s position towards exchange of information and vertical agreements is still somewhat unclear.

• GAC: General Authority for Competition.