Oil & Gas in 2026: Antitrust & Competition

A More Deal-Friendly Approach Signaled Globally

This article is part of the "Oil & Gas in 2026: Emerging Trends & Predictions" report. For the full report, click here.

All Change at the FTC

In the U.S., new Federal Trade Commission chair Andrew Ferguson took office in January 2025, promising a more permissive approach to merger approvals that was broadly welcomed by oil & gas companies eager to do deals.

• Reduced Scrutiny of Energy Transactions: Upon entering the White House, President Trump indicated his intention to be a positive force for oil & gas transactions after the previous administration increased challenges to horizontal mergers of E&P companies. Chair Ferguson has indicated that he will be more deal friendly, with a focus on anti-competitive behavior and protecting American workers while emphasizing the need for structural remedies like divestitures rather than behavioral fixes.
  
  The best evidence of a change in policy may be the dramatically lower number of reported “Second Request” investigations issued for deals in the oil & gas space in 2025.  For example, under the last administration, the U.S. agencies issued at least four Second Requests to oil & gas-related deals in 2024, five in 2023, three in 2022 and six in 2021. By contrast, to date, we are not aware of any confirmed oil & gas-related deals that received Second Requests in 2025. This could reflect a slowdown in large oil & gas-related deals in general, but the absence of data on new investigations makes it difficult to test any broader change in approach against the Biden administration.
  
  In our private experience of dealing with the new administration in the energy space, agency staff have been open-minded, straightforward and transparent, which has been welcome.
  
  

• Less Focus on Ancillary Issues: Under the previous administration, we saw enforcement on numerous oil & gas deals where the transactions themselves were not problematic but antitrust concerns were raised on ancillary issues.
  
  In both ExxonMobil’s deal for Pioneer Natural Resources and Chevron’s acquisition of Hess, for example, the sellers’ CEOs were prohibited from taking board seats after allegations of anticompetitive behavior. Of note, both of those orders were overturned by the new FTC Chair in July 2025, supporting the view that this administration is returning to more traditional views of antitrust enforcement in this area.

Europe Refines and Distinguishes Its Approach to O&G Mergers and Policy

Despite a relatively quieter year for oil & gas M&A transactions, several interesting deals were reviewed by European authorities, against the backdrop of an increased policy focus on sustainability and the clean energy transition.

• CMA Accepts Novel Remedies in Schlumberger/ChampionX: Schlumberger’s acquisition of rival oilfield services business ChampionX involved competitive  overlaps in the supply of production chemical technologies for oil & gas exploration, development and production companies. In clearing the case, the U.K. Competition and Markets Authority accepted a remedy package featuring carve-out sales and a novel behavioral set of remedies, which features a global licensing arrangement of key IPs to an alternative developer and supply commitments to downstream competitors. Notably, the CMA coordinated on the review of the deal with the Norwegian Competition Authority, resulting in similar remedies. The CMA’s willingness to accept the relatively novel set of remedies as well as its close alignment with Norway on remedies and clearance timings, was seen as evidence of its new and more flexible approach under the Labour government.
  
  

• CMA Clears Subsea7/Saipem, with Brazil Leading Investigation and the EC Taking Jurisdiction from Individual Member States: In another oilfield services deal, the combination of Saipem and Subsea7 required various antitrust filings globally, including in the U.K., Brazil and EU. The U.K.’s swift clearance of the deal  while Brazil’s Administrative Council for Economic Defense (CADE) conducted a deep dive, prompted by vociferous complaints, further signifies the CMA’s more pro-business approach, with clearances being more forthcoming as long as there are no specific U.K.-centric concerns raised. Notably, the EC is taking ownership over the review of this deal from member states, following the parties’ withdrawals of their filings in Germany, Poland and Norway.
  
  
• Commission Watches Industry Consolidation Closely: Recent large U.S.-centric oil & gas mergers, such as Chevron/Hess and ExxonMobil/Pioneer Natural Resources, did not trigger EU filings as they did not meet the mandatory thresholds (post-Brexit, U.K. North Sea revenues no longer constitute EU revenues). Given the strategic importance of the oil & gas sector to the EU, going forward, the EC will be paying attention to the trend of industry consolidation and whether such concentrations impact any EU or global markets (see also most recently, Baker Hughes/Chart Industries, which has been in pre-notification discussions with the EC for around six months). It is worth noting that the EC retains its power under Article 22 to accept referrals from its member states to claim jurisdiction over below-threshold mergers & acquisitions, particularly if they are likely to adversely impact competition in Europe.
  
  
• Italian Competition Authority Levies Record Fines: While there was no notable abuse of dominant oil & gas cases in Europe in 2025, the Italian Competition Authority (AGCM) did levy a record €936 million fine on six major oil companies in September for colluding to fix fuel prices. Eni, Esso (ExxonMobil), IP, Q8 (Kuwait Petroleum), Saras and Tamoil were found to have coordinated on components of biofuel pricing and the fine is one of the largest in European antitrust history for the energy sector.
  
  
• EC Emphasizes Alignment of Competition Policy with the Green Deal and the Transition to a More Sustainable Economy: Led by the EC, and in stark contrast to the U.S., many European competition authorities have integrated sustainability goals into their policies, and are encouraging collaborations and mergers that also support environmental objectives, like reducing carbon emissions or promoting clean energy. In order to obtain European clearances, O&G merging parties will need to try to weave these principles into their competitive narratives.

Conclusion

More Deals Should Crystallize New Approaches

Despite changes in government in the U.S., the U.K., Germany and elsewhere, 2025 did not deliver the requisite levels of oil & gas M&A needed to showcase how antitrust policies may change. While there are indications on both sides of the Atlantic of a more deal-friendly environment, reduced scrutiny and a return to traditional antitrust approaches, until deal flow picks up, it is probably too early to say how the new administrations will handle large mergers in the oil & gas industry.