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Algorithmic Collusion And CCI’s Wake-Up Call In The 2025 Report




Anushka Pachauri, UPES Dehradun


ABSTRACT


Artificial intelligence-driven pricing algorithms are transforming competition law enforcement by enabling collusive outcomes without human communication or explicit agreement. This article examines "algorithmic collusion" through the lens of the Competition Commission of India's (CCI) September 2025 Market Study on Artificial Intelligence and Competition, in which 37% of AI-using start-ups identified algorithmic collusion as their foremost competitive risk. Drawing on the CCI's four-fold taxonomy of collusion-prone algorithms and the OECD's October 2025 report on algorithmic pricing across G7 jurisdictions, the article analyzes how self- learning and signaling algorithms can produce a "black-box" problem that undermines the "meeting of minds" requirement central to Section 3 of the Competition Act, 2002. It evaluates India's regulatory trajectory—including the Samir Agrawal v. ANI Technologies precedent and the 2023 hub-and- spoke amendments—and critiques the CCI's proposed self-audit framework as a light-touch response. The article argues that meaningful enforcement powers and technical capacity-building are essential to prevent undetectable, algorithmically stable cartels.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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