On 24 September 2025, the Belgian Competition Authority (Belgische Mededingingsautoriteit / Autorité belge de la Concurrence – BCA) launched a call inviting all stakeholders – companies, sectoral organisations, consumer organisations and experts – to share their experience with price revision and indexation mechanisms. This call forms part of a broader investigation into price revision and indexation mechanisms which the BCA initiated on 6 February 2025 (see, this Newsletter, Volume 2025, No. 1). This investigation is expected to be completed in early 2026.
Belgian Competition Authority Investigates International Cyclists’ Union Maximum Gear Ratio and Orders its Suspension
On 19 September 2025, the Belgian Competition Authority (Belgische Mededingingsautoriteit / Autorité belge de la Concurrence – BCA) opened an inquiry into a proposed technical standard adopted by the international cyclists’ union (UCI), to determine whether that standard distorts competition. UCI had tentatively decided that the maximum gear ratio (Maximum Gearing) in professional road cycling events should reflect the equivalent of a 54-tooth chainring with an 11-tooth sprocket (54x11). UCI said the Maximum Gearing was mooted for safety reasons. The test phase for this standard started on 1 August 2025 and the Maximum Gearing protocol was to apply to the Tour of Guangxi, China, between 14 and 19 October 2025.
Opening of Investigation
US based SRAM currently provides equipment to four major men’s professional teams: Lidl-Trek, Movistar, Red Bull-Bora-Hansgrohe, and Visma-Lease a Bike. It challenged the Maximum Gearing protocol, arguing that it would compel the firm to make major adjustments, while several competing suppliers, such as Campagnolo of Italy and Shimano of Japan, already rely on 54x11 gearing. According to SRAM, the Maximum Gearing protocol was adopted without consultation, lacks any supporting empirical evidence, is devoid of any genuine safety justifications, puts SRAM and the SRAM-equipped professional cyclists at a competitive disadvantage, chills innovation, and distorts competition in the market for road drivetrain systems. According to SRAM, all of this gives rise to a violation of Articles 101 and 102 TFEU and Articles IV.1 and IV.2 of the Belgian Code of Economic Law (Wetboek van Economisch Recht / Code de droit économique – the CEL).
Given the global span of this case, SRAM could have chosen the UK Competition and Markets Authority, the European Commission, or a prominent EU Member State competition authority to file its complaint. Instead, it opted for the BCA which has made a name for itself in reviewing a variety of sporting federation rules. Most recently, in August 2025, the BCA assessed the rules pertaining to football and inline hockey (see, this Newsletter, Volume 2025, No. 8). Additionally, in September 2022, the BCA imposed interim measures on the national regulatory association for the pigeon-racing sector with respect to its electronic registration system (see, this Newsletter, Volume 2022, No. 9).
Imposition of Interim Measures
SRAM not only sought a decision on the merits but also injunctive relief. On 9 October 2025, the Competition College (Mededingingscollege / Collège de la concurrence) of the BCA ordered UCI to suspend the implementation of the Maximum Gearing in professional road cycling events, no later than 13 October 2025 at the eve of the last race of the UCI World Tour which started on 14 October 2025 in Guangxi, China.
While the BCA did not doubt the safety goal pursued by UCI, it took issue with the way the Maximum Gearing had been adopted and the necessity of the test phase. The BCA observed that the procedures for developing the Maximum Gearing suffered from serious shortcomings in terms of access (due to a lack of participation of manufacturers in the development of the standard, even in the form of consultation) and transparency. The BCA noted that the criteria on which key decisions were based in the adoption of the Maximum Gearing were not documented and that UCI’s explanations showed that its decision found support “solely on vague justifications with no objective basis”. The BCA also identified discrimination issues, in that the Maximum Gearing specifically targets SRAM technology. Additionally, the BCA questioned the relevance of the information that could be obtained during the test phase, observing that the existing data on the frequency and severity of accidents in an environment where both transmission systems are available (Shimano and SRAM) should be much more useful.
The BCA concluded that the Maximum Gearing is prima facie a decision by an association of undertakings that restricts competition in breach of Article 101(1) TFEU and/or Article IV.1 CEL, without specifying whether this is an infringement by object or by effect. The BCA also found that the adoption of the Maximum Gearing without sufficient procedural safeguards constitutes, prima facie, an abuse of UCI’s dominant position contrary to Article 102 TFEU and/or Article IV.2 CEL.
As regards the existence of a serious, imminent and nearly irreparable harm that would justify imposing interim measures, the BCA observed that Article IV.71 CEL allows it to take into account not only SRAM’s harm but also that of the teams that source from SRAM, some of which had intervened in the procedure.
- The BCA found SRAM’s harm to be manifest, as the restriction applies de facto only to SRAM (as acknowledged by UCI). UCI’s decision may lead to the exclusion of SRAM equipment from specific cycling races, to the use of SRAM equipment offering lower performance, or force teams using SRAM drivetrains to restrict them to comply with UCI’s decision. This ban and the uncertainty created by UCI are likely to permanently deter professional teams from using SRAM, even before the restriction is definitively adopted for all races. This loss of activity and capacity would go hand in hand with a loss of confidence in the brand and a knock-on effect on sponsorship and marketing in relation to SRAM’s product.
- With regard to teams using SRAM equipment, the BCA found that their harm consisted of several elements, including (i) uncertainty as to the transmission mechanism the teams will be allowed to use, (ii) the risk of penalties resulting from the use of SRAM transmission on their bicycles, in accordance with UCI regulations, (iii) insofar as they restrict SRAM transmission to comply with the Maximum Gearing, the risk of failures due to the haste with which these transitional measures are implemented without prior testing, (iv) the risk of sporting and financial damage in view of the obligation to use restricted equipment, unlike other teams that do not use SRAM equipment, and
(v) the risk of riders leaving teams equipped with SRAM transmission systems. This damage was likely to occur even before the definitive adoption of Maximum Gearing.
Both of these types of harm were both found to be serious and imminent. They were also difficult to repair because the sporting results of the races in which the Maximum Gearing is applied are already affected by it, and the Maximum Gearing could lead to the departure of riders from teams sponsored by SRAM and ultimately the disappearance of the latter. The BCA also found that the Maximum Gearing harmed SRAM’s reputation.
The Competition College of the BCA therefore ordered UCI to immediately suspend the implementation of the Maximum Gearing (or any similar measure), either until the date on which UCI adopts a new security measure replacing the Maximum Gearing on the basis of a transparent, objective and non-discriminatory procedure, or until the case is decided on the merits. The BCA also ordered UCI to publish a press release stating that the Maximum Gearing does not apply and that there are no rules imposing maximum transmission ratios in UCI competitions.
Comments
The BCA’s decision to impose interim measures is remarkable for several reasons.
First, its effects span the globe. The BCA confirmed its competence to apply Belgian and EU competition rules even if, as in this case, the practice at stake was decided abroad, none of the parties are in Belgium and the only test race was planned in China. This is because UCI is planning other test races that could potentially take place in Belgium. Even if there were no such races in Belgium, the BCA found that at least one professional team using the SRAM products in question is based in Belgium, other professional teams likely to use these products are based in Belgium, some professional cyclists concerned are Belgian, and distributors, consumers, Belgian organisers of professional races counting on the UCI World Ranking and Europe Tour Ranking, and direct and indirect customers of SRAM in Belgium are likely to be affected.
Second, the BCA’s decision protects the economic interests of economic operators (SRAM and teams using SRAM’s equipment) that are found to outweigh the safety reasons claimed to be at the basis of the UCI’s decision. Interestingly, the BCA did not identify any reason to doubt that, by adopting the Maximum Gearing, UCI was aiming to improve the safety of participants in cycling events. However, the BCA found no prima facie evidence that the test phase is necessary to establish whether a gear ratio limitation would improve rider safety. On the contrary, the BCA found that there are prima facie less restrictive means to establish this. As a result, the Maximum Gearing was found to be neither necessary nor proportionate.
Third, the interim measures are predicated on the existence of serious and nearly irreparable harm on the part of SRAM even though the standard was intended to apply only provisionally by way of a test. The BCA found that the uncertainty which the Maximum Gearing creates presents a real risk of SRAM products being excluded even before the restriction is definitively adopted for all races. Although temporary, the standard was therefore found to have, or to be likely to have, permanent effects.
Belgian Competition Authority Issues Opinion on Portability of Bank Account Numbers
On 15 September 2025, the Belgian Competition Authority (Belgische Mededingingsautoriteit / Autorité belge de la Concurrence – BCA) published an opinion (the Opinion) on Private Members’ Bill 55K0223 of 16 September 2024 aiming to facilitate switching banks (Wetsvoorstel tot wijziging van het Wetboek van Economisch Recht, met het oog op de invoering van een systeem om de overdracht van het internationaal bankrekeningnummer (IBAN) daadwerkelijk mogelijk te maken / Proposition de loi modifiant le Code de droit économique, instaurant un réel système de portabilité des numéros IBAN des comptes bancaires – the Bill).
The Bill includes three parts:
- It introduces a system of bank account number portability (via the IBAN identifier).
- It ensures that customers retain the full history of transactions made to and from that account even after switching to another bank.
- It extends the existing account switching service on payment accounts to regulated savings accounts.
The BCA has previously examined the banking sector. More specifically, on 31 October 2023 the BCA published a report (the 2023 Report), in which it pointed to several shortcomings, including deficiencies in the system for switching accounts that affect the competitive behaviour of banks (see, this Newsletter, Volume 2023, No. 12).
While focused on the Bill, this new Opinion gives the BCA the opportunity to provide an update of its 2023 findings.
IBAN Portability and Transfer of Full History of Transactions
In its Opinion, the BCA notes that, in 2023, it recommended conducting a study on the feasibility and costs of introducing a system of IBAN portability in Belgium. This is because a report by the European Commission had concluded that portability at EU level would not be economically viable as the implementation costs were expected to exceed the benefits.
The BCA reaches a similar conclusion regarding Belgium, noting that IBAN portability would create several problems.
- First, the existing IBAN system links each IBAN number to a specific bank via the BIC code, which an IBAN portability system would compromise.
- Second, the proposed portability system might not comply with Directive 2014/92/EU on the comparability of fees related to payment accounts, payment account switching, and access to payment accounts with basic features (which regulates the circulation of payments in Europe) and with SEPA regulations.
- Third, it would become more difficult for banks to draw up their balance sheets, due to the lack of association between the assets and liabilities of the IBAN number within the bank at the end of the year.
- Fourth, implementing the system would require overcoming technical difficulties and would be costly, and these costs might be passed on to consumers.
Additionally, the BCA doubts that introducing this measure would have a significant impact on banking mobility, notably due to the concentration of the Belgian market, growing competition from fintech firms offering products that are not based on the IBAN system, the inertia of Belgian consumers, and the absence of a genuine EU banking area which limits competition from banks from other Member States.
Extension of Portability Rules to Regulated Savings Accounts
The existing account switching service (the Service) is currently limited to payment accounts. It allows consumers to switch banks by filling out a form requesting their new bank to transfer their payment orders and/or close their account with their old bank.
The BCA notes that this would simplify the switch for consumers, increase the number of consumers who can benefit from it (as this Service is currently applied to regulated savings accounts on a voluntary basis only, by most but not all banks), increase competition within the retail banking market (since regulated saving accounts are mainly held by small savers and are the most popular savings products in Belgium), and enhance the effectiveness of the existing Service, as many banks link payment accounts to regulated savings accounts.
However, the BCA also observes possible downsides to this measure. In its view, limiting the extension of the Service to regulated savings accounts could increase the existing tax discrimination between various savings products in favour of the regulated savings accounts. The BCA also considers that the measure will have a limited impact on consumer interbank mobility as the issues which it identified in the 2023 Report (such as bundled sales and loss of loyalty bonus when changing banks) still exist. The practice of banks to limit withdrawals from regulated savings accounts to transfers to an internal bank payment account may also continue discouraging consumers from switching banks, as the consumer must keep a payment account with the bank with which it has its regulated savings account.
Alternative Competition-enhancing Measures
While the BCA supports the objective of strengthening competition in the retail banking market, it considers that the Bill could be difficult to implement and have limited effect. According to the BCA, easier measures that are more likely to increase competition include (i) limiting bundled sales, (ii) integrating the loyalty bonus into the base rate for regulated savings accounts, and (iii) promoting other savings instruments.
As it was submitted by members of an opposition party, this Bill is unlikely to become law in its current form. However, the governmental agreement of 31 January 2025 makes clear that increasing competition in banking and insurance and boosting customer mobility is also a priority of the current federal government (see, this Newsletter, Volume 2025, No. 2).
