Anticompetitive practices online
In November 2025, China issued17 Antitrust Guidelines for Platforms. Platforms are required to implement compliance systems and manage risks.
Из выпуска мониторинга No. 11 (23), November 2025 · выпуск целиком, PDF · на сайте Института Гайдара

The experience of China
In November 2025, China issued1 Antitrust Guidelines for Platforms. Platforms are required to implement compliance systems and manage risks.
The following rules have been established:
1. Prohibition of horizontal agreements (between platforms or platform users) on price fixing, sales volume restrictions, or restrictions on the introduction of new technologies or products by:
- Forming common data pools, agreements on interoperability between systems, using cloud storage, AI to coordinate intentions to exchange information.
- Exchanging sensitive information (about pricing, commissions, discount terms, customer bases, traffic distribution mechanisms, etc.).
- Using data, algorithms, and platform rules for coordinated uniform behavior for user segmentation, dynamic pricing, traffic distribution, and product ranking.
2. Prohibition of vertical agreements (between the platform and sellers) on setting resale prices using:
- Big data analysis, AI, and other means for automatic price setting.
- User profiles, predictive algorithms, etc. to directly or indirectly restrict resale prices.
The platform should not facilitate such agreements between platform participants.
3. Prohibition of abuse of dominance through practices such as:
- Unfairly high fees, service charges, marketing.
- Hidden price inflation (fragmentation of service packages, additional types of paid services).
- Unfairly low purchase prices (paying sellers prices for goods that are significantly lower than the prices paid by other platforms).
- Sales at below cost (e.g., subsidizing sellers' prices) to restrict competition (after forcing competitors out of the market, a sharp increase in prices).
- Refusal to deal with counterparties, restricting competition: removing goods from sale, blocking accounts, establishing excessively complex procedures for conducting transactions, restricting traffic, terminating data exchange, including through the use of algorithms for traffic distribution, product placement, etc.
- Restricting transactions, for example, including in the platform rules requirements for sellers not to work with other platforms, including under threat of exclusion from promotions, loyalty programs, blocking, lowering positions in search results, traffic restrictions, creating technical obstacles, etc.
- Requiring the purchase of certain goods (tied sales) and imposing unreasonable terms and conditions on transactions, such as the use of pop-up windows that are mandatory for completing steps in the interface, imposing costs on sellers for participating in platform promotions, restricting the methods of conducting transactions, payment, charging unreasonable fees (technical fees, traffic promotion fees, etc., which were not known in advance).
- Discrimination against platform users – different rules for connecting to the platform, charging fees for both sellers and buyers (e.g., based on preference data, transaction history, devices used, solvency analysis, etc.).
Platforms are required to implement an antitrust compliance system and conduct followup risk management (e.g., special assessment after marketing campaigns, investment transactions, etc.).
Russia’s experience
In Russia, the Platform Economy Act will come into force in October 2026, regulating certain anti-competitive practices of platforms, such as prohibiting marketplaces from forcing sellers to participate in sales, and ensuring equal access for all sellers to service opportunities (promotion in search results, etc.). However, competition legislation does not yet contain a specific list of practices characteristic of online markets, such as abuse of a dominant position through various technologies, such as slowing down browser traffic, restricting the operation of progressive applications, manipulating data collection consent forms, etc.
There has been an increase in the attention paid by authorities to anti-competitive behavior by platforms: the average annual number of antitrust cases in the digital sectors has grown from 4 cases per year in 2015 to 292 cases per year in 2015–2022.
- A data broker is a legal entity that sells, leases, trades, transfers, discloses, or otherwise provides to third parties personal data obtained from an individual, but which the organization did not collect directly from that individual. ↑
- The bill distinguishes between different age categories of minors: children (under 13 years of age) and adolescents (13 to 18 years of age). Adolescents may submit a request to delete their PD, but children cannot do so independently without a parent/guardian. ↑
- https://www.applify.co/insights/gen-ai-for-k12 ↑
- https://www.samr.gov.cn/hd/zjdc/art/2025/art_8e05960782204036af6b9583f1413378.html ↑
- https://www.cresse.info/wp-content/uploads/2024/09/2024_ps20_pa3_POIRIER_GARNEAU.pdf ↑
From the monitoring issue No. 11 (23), November 2025. Download the full issue (PDF) · issue page at the Gaidar Institute