CCI’s Market Study - CCI’s Action Plan for a Competitive, Dynamic and Innovative AI Ecosystem

We scriberes summarise - sharing portions of interest from Competition Commission of India’s  (“CCI”) recent market study on ‘Artificial Intelligence and Competition’ published on October 6, 2025. The CCI’s action plan seeks to build a fair and innovative AI ecosystem by promoting competition compliance, reducing entry barriers, and supporting responsible AI development. It encourages self-audits to detect anti-competitive risks, transparency in AI usage, and wider access to data and infrastructure for startups. The plan also focuses on capacity building through a dedicated think tank, inter-regulatory coordination, and global collaboration to align with international best practices.

CCI’s enforcement and advocacy efforts will be directed towards:

• Developing a culture of competition compliance

• Ensuring fair competition across the AI development value chain and applications 

• Preserving and promoting incentives for innovation

Self-audit of AI Systems for Competition Compliance

• Self-audits and competition compliance programmes are proactive measures that allow businesses to identify and address potential competition concerns.

Principles for Self-audit

• Documentation of AI-based decision-making process including algorithmic objectives, data sources, and access protocols 

• Design and testing of algorithms with built-in safeguards to prevent/ detect unintended anti-competitive outcomes/practices and reduce unfair competition risk

• Regular internal algorithmic audits/periodic review of algorithmic outputs/market outcomes to proactively identify and eliminate inadvertent algorithm-driven collusion

• Review of AI driven pricing strategies to detect unintended price alignments or discriminatory practices

• Implementation of safeguards while using third-party tools

Guidance Note for Self-audit

The guidance note is structured around four fundamental objectives

1. Helping businesses develop a comprehensive understanding of the competition implications inherent in their AI systems, enabling them to recognise potential risks before they translate into actual market harm.

2. Providing a structured and systematic approach to assessing AI systems for competition compliance, moving beyond ad-hoc evaluations to establish consistent methodologies that can be applied across different types of AI usage.

3. Promoting a culture of responsible AI development and deployment throughout the organisation, extending beyond mere compliance to embed competition considerations into the core of AI development processes.

4. Enable enterprises to demonstrate their commitment to fair competition through documented processes, transparent methodologies, and verifiable compliance measures.

Framework to improve transparency and reduce information asymmetry

Enterprises are urged to adopt transparency measures so as to reduce information asymmetry. Such measures may include communicating the following to relevant stakeholders:

• Usage and purpose of deployment of AI in decision-making

• A general description of the main parameters for AI-based decisions

• Other information that may foster better understanding and trust in AI-powered systems

Focused Advocacy

• CCI will organise conferences and workshops on AI and regulatory issues and AI and Competition Compliance respectively. 

Removing entry barriers

1. Access to infrastructure: Government departments overseeing digital infrastructure may continue to focus on expanding national AI computing infrastructure with enhanced access mechanisms specifically designed for startups, small and medium enterprises, and research institutions.

2. Promotion of open-source frameworks: will facilitate access, model portability and platform-neutral deployment. 

3. Access to data: data repositories may be developed and made available to provide seamless access to high-quality, non- personal datasets to enable startups to effectively compete and contribute. 

4. Development of skilled workforce: Equipping India’s workforce with cutting-edge industry-relevant AI expertise. 

5. Enhancing technological capabilities: International technology partnerships that  include meaningful technology transfer provisions and create frameworks for cross-border data governance and joint research and development programs. 

Regulatory capacity building

• Strengthening technical capabilities and infrastructure - CCI will develop specialised expertise in AI technologies, data science, and computational methods, and track global regulatory developments.

• Setting up of a Think Tank - a Think Tank, consisting of academics (in the areas of law, economics and computer sciences), technologists and public policy experts will be set up.

Inter-Regulatory Co-Ordination

• The Competition (Amendment) Act, 2023, provides for the CCI to enter into MoUs or arrangements with any statutory authority or department of the government for the purpose of discharging its duties or performing its functions under the Act. For structured consultation and coordination, CCI will explore entering into MoUs with relevant authorities.

International Cooperation

• International Co-operation Agreements: would allow for information sharing, alignment of enforcement strategies and capacity building, knowledge sharing and collaborative policy development.

Multilateral Competition Platforms: CCI will actively participate in the multilateral competition fora such as OECD, ICN, UNCTAD etc. to keep abreast of global best practices.