China: Beyond the Agreement – Cartel Enforcement Moves to Coordination Architecture
July 1, 2026
We are pleased to annouce that Dr. Frances Xu’s China chapter for the GCR Asia-Pacific Antitrust Review 2026 has now been published and is available free-to-view on the GCR website.
The article examines an important shift in China’s antitrust enforcement: from identifying explicit cartel agreements to assessing broader coordination architecture. In practice, enforcement attention is increasingly directed not only to what companies formally agree, but also to how they exchange information, signal intentions, align market conduct and create mechanisms that may support coordinated behaviour.
For businesses, this means that antitrust compliance should move beyond a document-based approach. The more important question is often whether internal and external communication structures, sales practices, data flows and decision-making processes may be viewed as facilitating coordination.
This article was first published by GCR in June 2026 as part of the GCR Asia-Pacific Antitrust Review 2026 at https://globalcompetitionreview.com/review/the-asia-pacific-antitrust-review/2026/article/china-beyond-the-agreement-cartel-enforcement-moves-coordination-architecture
The pdf version is also available for download here: GCR-china-beyond-the-agreement-cartel-enforcement-moves-into-coordination-architecture
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