CORAA

Competition Law Compliance Audit Checklist

Cartel and anti-competitive-agreement red flags, abuse-of-dominance indicators, and combination/merger notification thresholds under the Competition Act, 2002.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Governing law
Competition Act, 2002
Key risks
Cartels/bid-rigging, abuse of dominance, unnotified combinations
Common gap
No guidance given before trade-association meetings
Format
Microsoft Word (.docx)
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COMPETITION LAW COMPLIANCE AUDIT CHECKLIST

Entity: ___ · Period: ___

Scope: compliance with the Competition Act, 2002 — anti-competitive agreement red flags (cartels, bid-rigging), abuse-of-dominance indicators for entities with significant market position, and combination/merger notification obligations to the Competition Commission of India (CCI).

Risk & Control Matrix

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This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

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Common questions

FAQs.

Does competition law compliance apply to entities that are not market leaders?
Yes — the cartel and bid-rigging provisions apply regardless of an entity's market share or size; a small company colluding with competitors on a tender is just as exposed as a large one. Abuse-of-dominance provisions specifically require a position of significant market power, but the anti-cartel provisions do not.
What are the asset/turnover thresholds that trigger a CCI merger notification?
The Competition Act and CCI regulations set combined asset and turnover thresholds (revised periodically by government notification) above which a merger, acquisition or amalgamation must be notified to the CCI before completion, subject to certain exemptions (e.g. a de minimis "small target" exemption). Because these thresholds are revised periodically, verify the currently applicable figures against the latest CCI notification rather than relying on a fixed number, and take legal advice for any transaction near the threshold.
What kind of trade-association participation is actually risky?
Attending a trade association meeting itself is not the issue — the risk is in what gets discussed. Conversations that touch on pricing plans, output levels, customer or territory allocation, or coordinated responses to a tender are the classic fact patterns competition authorities treat as evidence of cartel conduct, even when framed informally or off the record.
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