In 2024, the number of notified mergers in Norway increased significantly compared to 2023. However, 2024 was a far less eventful year than 2023, which, as a reminder, featured the first Supreme Court ruling on a merger control case and several high-profile phase II cases.
The Norwegian Competition Authority’s (NCA) willingness to intervene in smaller, regional markets was reaffirmed in 2024. The only prohibition decision concerned the supply of emptying and pressure washing services in a regional market on the West Coast of Norway. The prohibition decision was upheld by the Competition Appeals Tribunal (CAT) in a decision issued in early 2025. This was the CAT’s third merger control-related decision since it was established in 2017.
The NCA's willingness to approve mergers during phase II was demonstrated again in 2024, by the clearance of the TGS/PGS merger just days before the Statement of Objections (SO) deadline. The NCA also cleared Vy’s acquisition of Flytoget during phase II in early 2025. Since 2020, the NCA has closed 8 out of the 16 cases investigated in phase II, clearly demonstrating that, even if the NCA opens a phase II investigation, the NCA is still willing to issue a clearance decision.
2024 also saw the NCA exercise its call-in powers in relation to a transaction that fell below the turnover thresholds. This is the 11th such instance since 2014. The transaction relates to the media surveillance and analysis market and falls well below both the individual and combined thresholds. The merger has already been completed and it remains to be seen how the NCA will assess this merger.
On the legislative side, it was confirmed that the NCA will receive a market investigation tool. Once in force, this tool will provide the NCA with extensive powers to intervene in markets on its own initiative and ultimately to break up companies. A legislative committee was also established to evaluate the Competition Act, including the merger control regulation, focusing on aspects such as the filing thresholds and the review timeline. The committee’s work will conclude during 2025.
This annual report aims to provide an overview of recent developments and the Norwegian merger control system, offering guidance to practitioners, businesses and stakeholders invested in the merger control landscape.
Thank you for your attention!
1. Summary of 2024
2. The Norwegian Merger Control System
3. BAHR – EU & Competition Law
Norwegian merger control in 2024 at a glance
– The NCA’s enforcement shows a willingness to prohibit transactions even in small, regional markets
• Interventions in 2024: The NCA prohibited one transaction, and one transaction was withdrawn by the parties in phase II
• On 24 September 2024, the NCA prohibited Norva24 Vest's acquisition of Vitek Miljø
– The NCA was concerned with non-coordinated effects in the market for emptying and pressure washing services in the geographic region consisting of former Hordaland County
– Vitek Miljø had a total turnover of approximately MNOK 103 in 2022, slightly exceeding the turnover thresholds
– Norva24 Vest appealed the decision to the CAT on 15 October 2024
– The CAT upheld the prohibition in a decision issued on 31 January 2025
• Saferoads’ acquisition of Ze Bra withdrawn in phase II
– The NCA’s concern was related to a Norwegian market for road marking
– The case was withdrawn by the parties before the SO deadline
Norwegian merger control in 2024 at a glance
– The NCA shows a willingness to clear transactions after issuing phase II decisions
• The NCA’s practice shows that despite a case being referred into phase II, the NCA may clear the transaction at any point in time during the phase II review
– Since 2020, the NCA has closed their investigation without a prohibition or remedies in 8 out of 16 phase II cases – two of these were closed after the SO
• In 2024 the acquisition of PGS by TGS was approved by the NCA in phase II shortly before the SO deadline
– In the NCA’s decision to open a phase II investigation, the NCA was concerned with competitive harm in the market for offshore geophysical data services on the Norwegian Continental Shelf
– The NCA closed its investigation on working day 67 shortly before the SO deadline (70 working days)
• On 12 February 2025 the acquisition of Flytoget by Vy was approved by the NCA in phase II
– Both companies active in train travel, with Flytoget only operating routes to and from Oslo Airport Gardermoen
– Both companies fully owned by the government, but controlled by different ministries
• The parties argued that the acquisition should not be viewed as resulting in a change of control
– Approval decision issued approximately two weeks before the SO deadline
• The NCA determined that certain regulations of the route solely operated by Flytoget and Vy, minimized the potential for anti-competitive effects
• The NCA chose not to address whether the acquisition resulted in a change of control
• On 25 February 2025 the NCA opened a phase II investigation into SLB’s acquisition of ChampionX
– Preliminary concern related to markets for production chemicals, permanent well monitoring and directional drilling on the Norwegian Continental Shelf
Norwegian merger control in 2024 at
a glance
– The NCA used its call-in power for transaction falling below the turnover thresholds
• On 27 September 2024, the NCA used its call-in power in relation to the merger between the media surveillance and analysis companies Infomedia and Retriever Aktiebolag (Retriever)
– This marks the 11th call-in since the NCA was granted the power to call-in transactions below the turnover thresholds in 2014
• Publicly available information indicates that the transaction falls well below both the individual and combined turnover thresholds
– Infomedia’s Norwegian subsidiary had a turnover of MNOK 51,3, which is well below the individual threshold of MNOK 100
– Retriever’s Norwegian subsidiary had a turnover of MNOK 157,8
– A combined turnover of MNOK 209 is far below the combined threshold of NOK 1bn
• The NCA issued its call-in decision after the merger had already closed
– The standstill obligation does not entail a duty to unwind the merger, but the parties cannot take further steps to implement the merger before approval is obtained
– If the NCA ultimately prohibits the merger, the parties will be required to unwind the merger and any steps already taken to implement it
• In its call-in decision, the NCA refers to its prohibition of Retriever’s attempt to acquire another company in the same market in 2013, noting that the landscape of active companies has not changed significantly since then
• The parties filed a merger notification on 28 January 2025, and the NCA has not yet made a decision
NCA continues its focus on selected sectors
– Markets and companies subject to individualised disclosure requirements
• Certain companies within “focus markets” are subject to additional requirements to disclose M&A falling below the merger filing thresholds
– Expanded disclosure requirements are typically imposed following cartel investigations and complex merger investigations
– Failure to comply has been sanctioned several times by NCA
– The NCA uses the information to decide if further investigation is warranted and whether to call-in the relevant transaction
• Trend: Gradual expansion of the types of transactions encompassed by the disclosure requirements
– Several companies are also obliged to disclose minority acquisitions
– Wording of the requirement is becoming broader, including covering targets with “plans to offer” services to users in Norway
Companies subject to expanded disclosing requirements as of February 2025
• Fuel: Uno-X Mobility, St1 Norge, Certas Energy Norway, Circle K Norge and YX Norge (new)
• Groceries: NorgesGruppen, Coop Norge, Rema 1000 and Bunnpris IK Lykke
• News: Amedia, Polaris and Schibsted
• Security systems: Verisure and Sector Alarm Group
• Laundry services: Nor Tekstil
• Concrete: Nordic Concrete Group, Heidelberg Materials Norway and Unicon
• Accounting systems: Visma
• Sports equipment: Sport Holding
• Online classified ads: Schibsted
• EV charging networks: Mer Norway, Circle K Norge, Eviny Elektrifisering, Recharge and Tesla Norway
Most notifications are unconditionally cleared in phase I
1186 notifications during the last 10 years (2015 – 2024)
Source: kt.no, einnsyn.no, document access, BAHR Note: Five phase I cases were withdrawn in phase I
1. Summary of 2024
2. The Norwegian Merger Control System
3. BAHR - EU & Competition Law
Long tradition of merger control in Norway
• National merger control regime since 1988
• Economic analysis always been an integrated part of the merger analysis
• Strict enforcement
– Typically a number of prohibitions and conditional clearances each year
– Fines imposed for gun jumping and provision of insufficient information
Competition authorities in Norway
Transactions without EU dimension
Case review:
The Norwegian Competition Authority
Reviews all merger notifications and has the power to authorise (with or without remedies) or prohibit concentrations
Administrative review:
The Competition Appeals Tribunal (CAT)
Appeals over the NCA’s merger decisions are reviewed by the CAT
Transactions with an EU dimension
Transactions with an EFTA dimension
Judicial review: Gulating Court of Appeal
The CAT’s decisions in merger cases are subject to judicial review by Gulating Court of Appeal –only the parties can appeal CAT decisions
Judicial review: Supreme Court of Norway
Decisions by the Gulating Court of Appeal are subject to judicial review by the Supreme Court
Concentrations with an EU dimension under the EUMR are excluded from the NCA’s jurisdiction Turnover in Norway not relevant for the calculation of turnover thresholds under the EUMR
Concentrations may under exceptional (theoretical) circumstances be subject to jurisdiction of the EFTA Surveillance Authority
Mandatory notification if statutory thresholds exceeded
1
1
Applies to concentrations
Definition of concentrations harmonized with the EU:
• Mergers, acquisition of de jure or de facto control and full-function joint ventures
• Rights, agreements or contracts giving rise to decisive influence over assets to which a market presence can clearly be attributed
2
If turnover thresholds are met
• Combined turnover in Norway of all the undertakings concerned ≥ NOK 1bn (≈ EUR 86.0 million / USD 93.1 million)*, and
• Turnover in Norway for each of at least two parties ≥ NOK 100m (≈ EUR 8.6 million / USD 9.3 million)*
Definition of undertaking concerned harmonised with EUMR. Relevant turnover (not harmonised) = “sales revenues” as defined in the Norwegian accounting act and associated regulations
Foreign-to-foreign transactions covered if sales to or in Norway exceeds the turnover thresholds. The NCA has indicated that foreign-to-foreign transactions may escape mandatory notification if no effect
The
NCA has the power to call-in transactions of non-controlling shareholdings and concentrations falling below thresholds
Non-controlling shareholdings
1 2
No mandatory notification, but may be called in by the NCA or submitted voluntarily
Call -in decision must be issued by the NCA within three months after final agreement or completion of transaction (whatever occurs first)
The NCA has used this power twice – and intervened in one of these (reduction in ownership share)
Concentrations falling below thresholds
No mandatory notification, but may be called in by the NCA or submitted voluntarily
NCA deadline for using its call-in power: three months after final agreement or completion of transaction (whatever occurs first)
The NCA actively seeking to uncover potential harmful transactions below thresholds
• Several market players have been ordered to inform the NCA of all transactions in selected markets, irrespective of thresholds
• Screening of markets and whistle-blower form on the NCA web site
11 call-in decisions issued since the current notification thresholds were introduced in 2014
• Voluntary notifications are possible
Call-in power used in 11 cases (below thresholds)
Number of call-in decisions Cases
21/3/2014 Ulefos/Kongsberg Esco Water supply and sewerage products Cleared phase I
12/4/2016 AT Skog/SB Skog Forestry products Cleared phase II
24/8/2018 Sector/Nokas Home security Conditions phase II
21/2/2020 Amedia/Nu Publishing Local media Cleared phase I
12/3/2020 Schibsted/Nettbil Online classified Cleared by the Supreme Court after prohibitions from the NCA and CAT
29/6/2021 Bonnier/Strawberry Publ. Book publishing Order withdrawn before notification
24/6/2022 Axess Logistics/ATS Auto transport Cleared phase II
22/12/2022 SKion/Enwa Water treatment Cleared phase II
27/9/2024 Infomedia/Retriever Media surveillance and analysis Ongoing
Timeline for NCA merger review
Prenotification
• Not required in simple matters
• ∼1-2 months in complex matters
• Longer if remedy discussions
Phase I
• 25 working days
• 35 wd if remedies proposed before day 20
Clearance, Remedy decision, or Phase II
Phase II
• 70 wd (from notification)
• Max 85 wd if remedies proposed
Clearance, Remedy decision, or SO
Parties’ comments to SO
• 15 working days
NCA Final assessment
• 15 WD
• Max 45 wd if remedies offered after SO
Clearance, Remedy decision, or Prohibition
• Automatic standstill until final decision or conclusion of investigation
• Phase II-deadlines not affected by remedies proposal in phase I
• Extensions in phase II if remedies proposed before SO
– 15 wd extension from latest remedy proposal – no extension if latest remedy proposal made at day 55 or before
– Maximum extension 15 wd (to maximum 85 wd from notification)
• Maximum 100 working days from notification to final decision if no extensions – max 145 working days if all possible extensions
– Extensions if remedies proposed late in phase II or after statement of objections (SO)
• Stop-the-clock possible if the parties do not respond to an RFI within time
• Automatic clearance if any NCA deadline passes without action
Referrals between the EU Commission and the NCA
Concentrations may be referred between the EU Commission and the NCA under the same basic principles as referrals to and from EU Member States, albeit with some variations
Post-notification referrals
Pre-notification referrals
• The parties may request a referral to the EU Commission where at least three EU Member States are capable of reviewing the transaction
• Note that Norway as an EFTA State does not count in this respect
• The NCA has no general veto power, and may in principle also initiate parallel proceedings
• The parties may request a referral from the EU Commission to the NCA by means of a Form RS
• The NCA has no right to request referral to the EU Commission at its own initiative, but may adhere to requests from EU Member States
• 2020: The NCA joined the Danish Competition and Consumer Authority’s Article 22 request in M.9744 MasterCard/Nets
• 2021: The NCA joined the French Competition Authorities’ Article 22 request in M.10188 Ilumina/GRAIL
• 2023: The NCA joined the Danish and Finnish competition authorities’ Article 22 request in M.11241 EEX/ Nasdaq Power
• Time limits for Norwegian merger review suspended when EU Member States request referral
• The EU Commission may refer cases to the NCA, and has done so in several cases:
• M.2683 Aker/Kværner (II), M.4611 Egmont/Bonnier (books), M.6752 Orkla/Rieber and M.6982 Altor Fund III/Tryghedsgruppen/Elixia/ HFN Group (“SATS/Elixia”)
Harmonised SIEC-test
“The NCA shall prohibit concentrations which would significantly impede effective competition, in particular as a result of the creation or strengthening of a dominant position”
• Substantive test: Harmonised with the EU with SIEC-test
• Consumer welfare standard; only efficiencies with impact on pricing are relevant
• The substantive test was amended from 1 July 2016
– Previously, Norway applied a SLC/total welfare test
– No significant apparent changes in review intensity or number of interventions
The Competition Act Section 16
Interventions/conditional clearances since 2015
V2015-1 TeliaSonera / Tele2 Norge & Network Norway
Prohibitions and conditional clearances: 2014–2024
4 phase II clearance decisions after SO since 2014
• NorgesGruppen/Tiger (2015)
– Convenience retail
– Closed after 105 working days
• Telia Company/Phonero (2016)
– B2B mobile telephone services
– Closed after 104 working days
• Gjelsten Holding and O.N. Sunde/Gresvig Retail Group (2020)
– Sports retail
– Closed after 107 working days
• Norwegian Air Shuttle/Widerøe (2023)
– Air passenger transport
– Closed after 94 working days
Procedure
No formal deadline for filing
• Standstill obligation for all concentrations subject to mandatory notification
• Prenotification dialogue or draft notification not required but recommended in more complex matters (and expected by the NCA)
• Prenotification may be necessary if seeking phase I remedy decision
Phase I
Within 25 working days, the NCA must approve the transaction or decide to continue the investigation (“Phase II decision”)
• If the parties propose remedies within the first 20 working days after the notification the period is extended to 35 working days
• A decision to continue the investigation is normally short and briefly indicates the NCA’s concerns and theories of harm
• No formal decision if the NCA authorises a concentration unconditionally in phase I, but confirmation by email
Phase II: Before statement of objections
Within 70 working days from receipt of complete notification, the NCA must issue its statement of objections or clear the case
• If the parties propose commitments later than 55 working days after notification, phase II is extended accordingly
• Unconditional phase II clearance decisions are normally brief, only outlining the key arguments for closing the inquiry
Phase II: After statement of objections
• The parties have 15 working days to submit comments
• The NCA must issue a final decision (clearance, prohibition or acceptance of remedies) within 15 working days of receipt of the parties’ comments
• 15 working day extension if the parties propose remedies after the draft prohibition decision
• Additional 15 working day extension if the parties request or approve a request from the NCA
Automatic standstill until final decision
Automatic standstill for all concentration subject to mandatory notification until final decision
Standstill also for mergers called in by the NCA or where notification is submitted voluntary
• From the moment the NCA issues the call-in decision or the notification is submitted voluntarily
• If the transaction has been completed when standstill comes to force, the NCA will typically indicate that no further implementation can take place
• Though the legal basis for this approach may be questioned after C-633/16 Ernst & Young
Exemptions:
• The NCA may grant a derogation from the standstill obligation:
• Derogation only granted if significant negative impact on the parties or society as a whole can be established
• Derogation may be granted for “rescue operations” (e.g. risk of bankruptcy) in cases without substantial issues
• The NCA appears to prefer a swift approval rather than derogation
• Partial exemption for public bids and series of transactions in publicly-traded securities (similar to EUMR Art.7(2))
The notifying party/-ies can offer remedies
The notifying party/-ies have the sole responsibility for offering remedies
• Both behavioural and structural remedies possible, but the NCA has historically preferred structural remedies
• Remedies may also include the appointment of a trustee
• Normally a dialogue between the notifying party/-ies and the NCA prior to offering remedies, but the NCA’s guidance is often brief
The NCA may issue a decision including remedies offered by the parties without full review of possible anti-competitive effects resulting from the concentration
• In practice the NCA is not ready to hand down a remedy decision before all potential theories of harm have been investigated
• The proposed remedy must remove all identified concerns
• A decision from the NCA accepting the remedies offered may be adopted without prior notification to the parties
• Limits the NCA’s obligation to conduct a full investigation, e.g. with respect to whether the remedy goes further than strictly necessary
• Decision to clear the concentration subject to remedies may be adopted in phase I – so far only one phase I remedy decision has been made (Tieto/Evry)
Pre-notification contacts less extensive than in many other jurisdictions, but increasingly common
Pre-notification contacts are typically less comprehensive in Norway compared to many other jurisdictions
• Draft notification often submitted and reviewed in more complex matters, but no requirement for specific sign-off from the NCA before submitting formal notification
• When the NCA receives a formal notification, it can declare it incomplete within 15 working days of receipt
In more complex cases pre-notification contacts are more common
• Can be important to achieve phase I clearance in “semi-complex” cases
• Also in potential phase I remedy cases
• In less complex cases (incl. simplified notifications) high-level pre-notification contact is possible and appreciated by the NCA as a courtesy, but not necessary
• Often sufficient to give a courtesy pre-warning that a notification will be submitted
Information provided during pre-notification is not subject to public disclosure until formal notification, unless the concentration is publicly known
Information required in notifications
• No strict notification form in Norway, but minimum content requirements are regulated in the Competition Act
• Requirement to identify confidential information
– Including a reasoned opinion on why the identified information is considered confidential
– The notification will not be declared complete before such confidential information is identified with a reasoned opinion
• The NCA may declare the notification incomplete within 15 working days from receipt
Minimum content requirements:
1. Description of undertakings concerned and their business areas and the nature of the concentration
2. Name of each party’s five most important competitors, customers and suppliers in all markets with horizontal overlap (no market share threshold)
3. For horizontally and vertically affected markets, describe:
i. Market structure
ii. The most important competitors, customers and suppliers in the affected markets
iii. Barriers to entry
iv. Horizontally affected: Combined market share > 20%
v. Vertically affected: Market share > 30% in both vertically related markets
4. A short description of vertically related markets where the undertakings’ market share exceeds 30% in only one of the related markets
5. Description of any efficiency gains
6. Information on whether the concentration is subject to mandatory notification in any other jurisdictions
Internal documents not required, but normally requested in more complex matters
7. The latest version of the agreement between the parties to the concentration including annexes
8. Annual reports and annual accounts of the undertakings concerned
9. For joint ventures: Information on whether a parent continue activity in the same market as the joint venture or any vertically related markets
Simplified notification for non-complex cases
Short form notification for certain concentrations:
• Creation of joint ventures when the turnover of the joint venture is below NOK 100m in Norway and assets transferred to the joint venture is valued below NOK 100m;
• Dissolution of joint ventures (from joint to sole control);
• Horizontal mergers where joint market share ≥ 20 %; or
• Vertical mergers where joint and individual market shares ≥ 30 %
Short form notification must include the following information
• Identity of the parties
• Description of the transaction
• A statement describing why the conditions for simplified procedure is fulfilled
• List of the five most important customers, competitors and suppliers in horizontal overlap markets
• Annual reports (if not publicly available)
• In case of creation of joint ventures, an overview of markets where parent companies will remain active in the same market as the joint venture or in any vertically related or neighbouring markets
The NCA must state within 10 working days if conditions for simplified notification are not met
The NCA may order a standard notification within 15 working days after receipt of a simplified notification
• Deadlines suspended from order of notification until receipt of (complete) standard notification
• Rare; has happened twice since 2014
Publicity and access to file
• Non-confidential version of the notification and key facts published on the NCA’s website
• Both the parties and interested third parties have access to file during the NCA’s review of the case
• Exceptions include: (i) business secrets, (ii) the NCA’s internal documents, except for summaries of facts, e.g. minutes of meetings, and (iii) correspondence between Norwegian and foreign authorities
• Access is not given to pre-notification documents before the concentration is made public or is notified
• The parties must submit a draft non-confidential version of notifications and remedy proposals when these are submitted
• The NCA may presume that the parties do not oppose public access to information that is not clearly marked as confidential
• Reasons for why information should be considered confidential must be given for every instance of suggested redaction
Administrative review by the Competition Appeals Tribunal
• Since 1 April 2017, the Competition Appeals Tribunal (CAT) has been the Appellate body
– The CAT has to-date reviewed three NCA merger decisions
• Full review of all aspects of the case
– The CAT may review the facts, the discretional assessment and application of law in cases that are appealed
– Not limited by the issues raised in the appeal or the decision on appeal
• Possible outcomes for appeals of different NCA decisions:
– NCA prohibition decision: The CAT is not bound by initial NCA decision and may issue a new decision
• The CAT may confirm the NCA decision, clear the transaction or issue a conditional clearance
• If the CAT clear a transaction the decision is final
• The CAT may also return the transaction to the NCA for renewed treatment
– NCA conditional clearance: The CAT may only confirm or annul the NCA’s decision
• Annulment when the CAT finds that the conditions for intervention are not fulfilled: Appeal decision is final
• Annulment due to other reasons (e.g. procedural errors or remedies considered inadequate): The NCA must adopt a new decision or issue a draft prohibition decision within 45 working days
• CAT decisions are subject to judicial review by Gulating Court of Appeal in Bergen
– Gulating Court of Appeal reviewed its first and only merger control decision (Schibsted / Nettbil ) in 2022
– Only the parties can appeal CAT decisions in merger control cases (not the NCA)
• Gulating Court of Appeal decisions are subject to judicial review by the Supreme Court
– The Supreme Court reviewed its first and only merger control decision (Schibsted / Nettbil ) in 2023
Timeline for administrative review by the Competition Appeals Tribunal
+Max 15 (+15+15+15)(3) wd (See NCA review timeline)
(1) Prolonged accordingly if parties propose commitments later than 35 working days after appeal decision
(2) Clearance decisions may be “full” or subject to (new) remedies as offered by the notifying party/-ies
(3) If remedies are offered by the parties after draft prohibition decision
1. Summary of 2024
2. The Norwegian Merger Control System
3. BAHR - EU & Competition Law
BAHR takes a holistic approach
Pre-assessment
We take pride in providing early advice and structuring the process to fit your business needs
• Early screening of where filing is required, likelihood of clearance and potential remedies
• We work closely with our M&A department to efficiently identify and structure the filing strategy, timing issues and handle information sharing
• Economic advice integrated in all phases; from preliminary assessments and throughout the filing process –including design of remedies
– BAHR is the only Norwegian law firm with an in-house competition economist
National International
We have extensive experience in handling both simple and complex cases before the NCA
• Expedient handling of simple cases
• Extensive experience with complex cases:
– BAHR has handled 3 of the 4 phase II clearance decisions issued after SO since 2014
– BAHR has handled 2 of the 3 merger cases for the CAT
– BAHR has handled the only merger case that has been overturned by the CAT
• Experience in handling extensive information requests
We are well placed to efficiently handle your multijurisdictional merger filings in close cooperation with our extensive international network
• BAHR provides a one-stop-shop for multijurisdictional filings
– BAHR has handled a large number of cases before foreign competition authorities in cooperation with our extensive international network – we frequently interact with law firms in Europe, South-America, the US, Australia and Asia
• BAHR has handled cases before the EU Commission
“The BAHR competition law team are highly knowledgeable of all relevant developments both on a national and a European level. They deliver tailor-made and ready-to-use advice based on their in-depth knowledge of our business.”
Chambers Europe 2024
“BAHR’s competition law team always deliver first-class advice. In-depth industry and economic knowledge, high degree of availability, combined with practical advice, makes them a natural trusted adviser for competition law advice, especially cross-border M&A cases.”
Legal 500 2024
The EU & Competition Law Team outside BAHR’s Oslo offices
BAHR selected highlights in 2024
• BAHR represented the underground infrastructure maintenance company Norva24 Vest in the proposed acquisition of Vitek Miljø
• Norva24 Vest and Vitek Miljø are competitors within emptying and pressure washing services in the wider Bergen region
• The NCA prohibited the transaction on 24 September 2024
• BAHR also handled the appeal process towards the CAT, which upheld the prohibition
Prohibited by the NCA (upheld by the CAT)
• BAHR represents ChampionX in NCA proceedings in the ongoing proposed sale to SLB
• The transaction was filed 21 January 2025 following an extensive pre-notification phase
• The proposed transaction will combine two global companies within production chemicals for the oil and gas industry
• The transaction has been filed to competition authorities in nine additional countries, including the UK and US
Ongoing in phase II
• BAHR represented PGS in the merger with TGS towards the competition authorities in Norway and in the UK
• The merger created a global full -service offshore geophysical data provider serving the oil & gas and renewables industries
• BAHR assisted in securing an unconditional clearance in Norway in phase II and in the UK following an extensive phase I review
Unconditional clearance in phase II
• BAHR handled the filing of the merger between YX Betjent and Best Stasjon towards the NCA
• The merger combined the operations of two Norwegian gas station operators, a market that the NCA closely monitors
• The merger was approved in phase 1 following an extensive phase I review
• BAHR represented 4Service towards the NCA in relation to the sale to Compass Group
• The merger combines two of the leading companies within several food facility markets in Norway
• BAHR assisted in securing an unconditional clearance in phase I, following an extensive prenotification phase
Unconditional clearance in phase I
• BAHR handled the filing towards the NCA for renewable energy company Hafslund Eco’s acquisition of the wind energy company Tonstad Vindpark
• As one of the leading players within production of renewable energy in Norway, Hafslund Eco expanded its renewable initiatives with this acquisition of its competitor, Tonstad Vindpark
Unconditional clearance in phase I
Unconditional clearance in phase I
Consistent Top Ratings
Some Examples
Top ratings in all the major national and international league tables
• Top ranked as Band 1 in seven categories and Band 2 in nine categories by Chambers Europe 2024
• Ranked in all categories by Chambers Global 2025
• Top ranked as Tier 1 in fourteen categories in the 2025 edition of Legal 500
• Top ranked as Tier 1 in all categories by IFLR 1000 2024
• Top ranked as Tier 1 in all categories by World Tax 2025
• Ranked in three categories by IP Stars 2024
• Top ranked as “Gold firm” in the category Litigation and transactions by IAM Patent 1000 2024
• Top ranked as “Elite firm” in the category Competition Law by GCR100 2024
• Norway Tax Firm of the Year, ITR Awards 2024
• Firm of the Year: Norway, IFLR European Awards 2024
• Net-Zero Transition Award, IFLR European Awards 2024
• Norway Patent Disputes Firm of the Year, Managing IP Awards EMEA 2024
• Europe Patent & Regulatory Team of the Year, Managing IP Awards EMEA 2024
• European Cross-Border Patent Litigation Team of the Year, Managing IP Awards EMEA 2024
• Norway M&A Legal Adviser of the Year, Mergermarket European M&A Awards, 2023
BAHR’s EU & Competition team: Consistent
• Helge Stemshaug is ranked Band 1 and Beret Sundet Band 2 in Competition / Antitrust by Chambers Europe 2024
• Helge Stemshaug and Beret Sundet named as Thought Leader 2024 by Lexology Index: Competition
• Beret Sundet ranked in “Hall of Fame”, Helge Stemshaug ranked as “Leading Partner” and Ylva Kolsrud Lønvik as
Leading Associate” in EU and Competition by Legal 500 2024
Contact details
“As one of Norway's top experts Helge Stemshaug is well placed to handle a variety of competition law mandates ranging from merger control to large-scale cartel investigations.”
E bsu@bahr.no
“Beret Sundet is an outstanding and preferred competition lawyer in the Norwegian market. She is exceptionally good at explaining complex matters in simple words, provides practical and to-thepoint advice and demonstrates indepth knowledge of the energy sector. Excellent client handling, easy to collaborate with and very responsive..”
"He is a good strategic adviser and is capable of considering the client’s legal position and is good at understanding the client's needs."
Elin Moen returned to BAHR in August 2023 following 8 years as Senior IP and Competition Counsel with OSE-listed international media group Schibsted. Elin has also served as a member of the Norwegian Competition Appeals Tribunal, as well as deputy judge at district court level.
