Competition Bureau just put numbers on when your deal crosses the line
Canada's Competition Bureau has released updated merger enforcement guidelines that could reshape how wealth management firms approach acquisitions and consolidation strategies.
The proposed Merger Enforcement Guidelines, published November 13, 2025, establish new analytical frameworks for reviewing mergers across all industries. For wealth management firms navigating an industry where consolidation has become routine, the new rules offer a clearer picture of what regulators will scrutinize.
The guidelines put numbers to what has long been subjective. A merger draws a presumption of harm when it pushes market concentration up by more than 100 points and either drives total concentration above 1,800 or gives the combined firm more than 30 percent market share.
But the more consequential shift for wealth firms may be how regulators now view partial stakes. The Bureau will examine minority investments where firms hold pieces of competitors without taking full control, looking at both situations where investors hold stakes in multiple rivals and cases where firms own slices of direct competitors.
The question regulators will ask is whether these arrangements change how companies compete. The Bureau wants to know if a minority stake gives the investor enough sway to influence how the target firm operates, or if it changes the investor's own competitive decisions. That includes everything from pricing to investment decisions, partnerships, and future acquisitions.
The guidelines also address buyer power, which matters for larger wealth firms purchasing investment products, technology platforms, or advisory services. Regulators will consider whether a merged entity could push down what suppliers receive for their products.
In the wealth technology space, the Bureau will watch for deals that snuff out future competition before it fully develops. The guidelines specifically flag acquisitions of newer entrants that appeared ready to grow into stronger competitors. For established firms eyeing digital advisory platforms or fintech startups, this means regulators may challenge deals based on what might have been, not just what currently exists.
The Bureau casts a wide net in defining what counts as a reviewable transaction. Even buying a portion of another firm's assets can trigger scrutiny if those assets could support a standalone business.
The agency made clear it reviews deals of any size across all industries. While some larger transactions require advance notification, the Bureau also examines deals that fall below those thresholds and can review mergers both before and after they close.
The Competition Bureau has opened a public consultation period, inviting feedback until February 11, 2026.
