CAMP Submission to the Competition Bureau’s Proposed Anti-Competitive Conduct and Agreements Enforcement Guidelines
As part of its mandate, Canada's Competition Bureau routinely publishes and updates guidance on how the agency enforces different aspects of the Competition Act. In January 2026, the Bureau completed a public consultation on its proposed changes to its guidance related to the enforcement of Canada's laws against anti-competitive conduct and agreements. To ensure public interest voices were present, CAMP participated in the consultation with a short submission summarizing our perspective on the proposed guidance.
CAMP supports the Bureau’s move toward a unified, conduct-first approach for enforcement guidance, greater use of temporary orders to speed the resolution of competition issues, the inclusion of a more up-to-date understanding of market power and dominance, and recognition that anti-competitive conduct and agreement provisions can address serial acquisitions that fall outside traditional merger review. While room for improvement exists, CAMP encourages the Bureau to move quickly to adopt this guidance and begin a more active and assertive era of competition law enforcement.
Check out CAMP's full submission here
Letters: Clipped Wings
January 25, 2026Welcome to Letters from CAMP, a newsletter on anti-monopoly activity in Canada and abroad, brought to you by the Canadian Anti-Monopoly Project. In this instalment we have:
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Bureau Cuts Clash with Competition CommitmentsLast year, Minister of Industry Melanie Joly said her government would be “hawkish” on competition. This week, it’s looking like the emphasis in that statement is going to be on the “ish.” As reported this week by Peter Nowak at Do Not Pass Go, the Competition Bureau is cutting 24 positions over the next three years, about 5% of its current staff. While these cuts are in line with the sufficiently bureaucratic “workforce adjustment” across the federal public service, the move undermines the government’s own commitments on promoting competition in Canada. If you’re looking at federal spending, you would need a microscope to find the Competition Bureau. At $70 million a year, the law enforcement agency makes up about 0.01% of annual spending. But like any investment, the real question is the rate of return on this investment. Competition investigations have the potential to shift multi-billion-dollar markets. Take the Bureau’s ongoing investigation into whether the policies of real estate associations are limiting competition in the market for realtors. A quick back of the envelope with Canadian Real Estate Association (CREA) data suggests Canadians could be spending as much as $15 billion annually on commissions for realtors. This means even a 0.5% shift in favour of buyers and sellers would put the budget of the Bureau back in the pockets of Canadians. But these wins do not come easy. Every day the Competition Bureau squares off against the legal teams and resources of some of the largest companies on the planet, with ongoing investigation and litigation against Rogers, Google, DoorDash, and Amazon. Effectively enforcing Canada’s competition law takes proper financial and human resources. Moving in the wrong direction on Bureau funding means Canadians can expect less relief as the agency narrows its scope in response. As affordability remains a top priority for Canadians, adequate Bureau funding is an extremely cost effective signal that the government is serious about its previous commitments. Reversing this shortsighted decision and instead boosting the resources of the Competition Bureau is an easy way for this government to make good on its hawkish talk. Even If You’re Not on Amazon, You’re on AmazonThere’s always been one obstacle for Amazon to live up to its moniker as “the everything store”: literally everything cannot be found on Amazon. Despite its digital dominance, businesses of all sizes, whether they use tools like Shopify or stand up their own sites, continue to avoid the platform in their operations. But a new brief from the Institute of Local Self Reliance shows that Amazon has the cure for this independence: scraping the sites of independent businesses without their permission, displaying their wares on the platform, and using bots to anonymously purchase the products. With the introduction of a special “Buy For Me” button, Amazon can display the offerings of independent retailers and send an AI agent to buy the product, breaking the link between customer and business. While the independent retailer may get a sale, they are cut out of the relationship and critical data that comes with every purchase, only selling to a faceless Amazon agent. That this is a bad deal for retailers is evident in Amazon’s conduct when the conduct flows in the other direction. The company swiftly sent a cease and desist letter to AI search company Perplexity when it discovered the company was scraping the e-commerce giant’s own listings. As ILSR shows, the straightforward way to prevent this is to ban scraping and proxy purchasing without the express consent of retailers. One of the reasons entrepreneurs start businesses is because they want the freedom to forge their own path. Policies like these would put control back in the hands of the people who own and operate their own businesses amid the steady march of centralization in our economies. If a business decides to use Amazon that’s their choice, but even the largest companies on the planet need to respect the decision to remain independent. 📚 What We’re Reading 📚
Bounded Optimism for the FTC’s Appeal of Meta LawsuitLast year, a U.S. judge ruled that Meta did not hold a monopoly in “personal social networking services,” ruling in favour of Meta in a lawsuit aiming to reverse the company’s purchases of Instagram and WhatsApp. Despite its control over world-leading social media platforms, Judge Boasberg found that Meta had plenty of competitors. The only problem? That definition of social media included properties as disparate as TikTok and YouTube. This week, news came that the FTC would be contesting the lines the judge drew around the relevant market and appealing the decision. Market definition is a frequent sticking point in antitrust cases, leaving plenty of room for disagreement. When it comes to social media, a key question is what brings a user to the app and keeps them coming back. Mark Zuckerberg has long described Facebook as a “social utility” that underwrites everything from sharing photos to life milestones to events. The reason you use Facebook might be similar to the reasons you use Instagram or WhatsApp, but the further away we move from these original purposes the more tenuous the market definition becomes. Vertical videos do not a market make, and we’re sufficiently skeptical that consumers are coming to Facebook and YouTube for the same experience. But as our friends at American Economic Liberties Projects point out, there’s reason to be skeptical of the motivations of the Trump 2.0 FTC. The decision deserves to be overturned, but is the current FTC Chair trying to protect competition or extract more concessions from an already pliant Zuckerberg? A year into this administration’s approach to antitrust has generated plenty of room to suspect this appeal will be another case of quid pro quo competition policy and result in a sweetheart settlement. We’re happy to be proven wrong, but until then we’ll be bounding our optimism. If you have any monopoly tips or stories you'd like to share, drop us a line at hello@antimonopoly.ca
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Inside the corporate battle over your pet’s health
CBC
CAMP fellow Rachel Wasserman, participates in the discussion about independent vet clinics are being gobbled up by multinational corporations and private equity in this episode of The Fifth Estate.
Letters: Rates of Return
January 18, 2026Welcome to Letters from CAMP, a newsletter on anti-monopoly activity in Canada and abroad, brought to you by the Canadian Anti-Monopoly Project. In this instalment we have:
If you enjoy Letters, please considering sharing and supporting CAMP. Now let’s dive in.
CAMP to the CRTC: Don’t Back Down on Home Internet CompetitionInternet access is all but essential to everyday life, but Canadians continue to pay some of the highest pricesin the world for it. One reason is that the infrastructure for internet access, thousands of kilometres of fibre optic cables, exchange points, towers, and more, are expensive to build and maintain. Another reason is that the vast majority of it is owned by the Big 3 - Bell, Rogers and TELUS - who capture nearly 90% of the ISP market. Bad experiences with the telcos are as Canadian as maple syrup, and unlike the recent burst of competition we’ve seen in wireless, wireline prices remain stubbornly high. To counteract this, Canada’s telecom regulator, the CRTC, introduces competition into the market through its wholesale access system. The system requires the Big 3 to sell bandwidth in bulk to independent ISPs at regulated wholesale rates set by the CRTC. How aggressively independent ISPs can compete is a function of where the CRTC sets that wholesale rates, with lower rates allowing for lower prices. But over the holidays, the CRTC asked the industry and Canadians whether the wholesale rate should be increased. Unsurprisingly, CAMP had some thoughts to share. In our submission to the CRTC, CAMP argued that not only should the wholesale rate not increase, but that it should be brought down to allow for more intense competition. Until 2019, the market share for independent ISPs was growing steadily. But that growth has been replaced by steady decline and the roll up of independent ISPs after the CRTC flip-flopped on wholesale rates and created uncertainty for the entrepreneurs who were offering Canadians some competitive relief. To reverse this troubling trend, CAMP calls on the CRTC to do everything it can to bring wholesale rates down and provide certainty to those looking to build new competitors. CAMP is glad to be one of the few organizations fighting for the interests of consumers in front of the CRTC, and our submission in this proceeding is the preview of what will surely be an active year on the consumer protection front. 📰 CAMP in the News 📰
A Special Price, Just for YouThe days of price tags may be over as we move towards a world of highly personalized, down to the individual, pricing. This week, in a piece for the Walrus, SHIELD Institute managing director and CAMP Advisory Board member Vass Bednar writes that this world is already here. Recent work by Consumer Reports and Groundwork in the U.S. found Instacart prices could vary by as much as 23% between customers. This week, Google announced its “Universal Commerce Protocol” which will use Google’s vast trove of personal data to help retailers set and change prices dynamically, offer deals and discounts to close sales, and upsell consumers automatically and at scale. If you went into a store and the staff asked you for your income, five years of purchase history, and distance from home before giving you the price of a good you might be put off, but that’s where we’re headed when it comes to e-commerce. Companies will say they’re only using this to offer discounts, never to raise the price. But discounts and loyalty programs can also be weaponized. There’s nothing stopping companies from jacking up base prices so that “discounts” for things like using a specific payment method, setting up automatic renewal, or signing your data away become practically mandatory. CAMP’s already taken a stance on algorithmic price setting: it should be transparent for all customers, should not be based on sensitive data, and should not centralize pricing decisions across competitors. Pushback against these opaque and discriminatory prices is beginning. In Canada, the Manitoba Government has the practice in its sights for 2026 and Canada’s Competition Bureau is looking into its potential harms to competition. When markets work well, consumers get a fair deal. A key ingredient of working markets is the transparency that allows purchasers to weigh products and services against one another and drive competition. As the use of highly dynamic and personalized pricing explodes, we need to open up these black boxes to make sure Canadians aren’t being taken for a ride. 📚 What We’re Reading 📚
The Long March Against Google’s MonopoliesWhile Google scored serious antitrust wins in 2025, parallel challenges continue to emerge. Now that the U.S. DOJ made the case for the harms of Google’s decades long anticompetitive practices in online advertising, some of the victims are seeking restitution. A host of large online publishers including Vox Media, the Atlantic, Penske Media Group, and Advance Media Group (Condé Nast) are lining up to sue Google for its outsized piece of the online advertising pie. Regulators outside the U.S. remain active as well. The E.U. has ruled that Google abused its dominance in online advertising and a remedy is forthcoming, and the Competition Bureau is set to start its trial against Google next year. Google’s online advertising empire was built with what is a now textbook Big Tech strategy: claim its systems are neutral marketplaces, buy or shut out competitors, and become inescapable infrastructure for the market. Once dominance is achieved, the extraction begins; squeezing customers on costs and blocking calls for greater transparency. Now, with the launch of its Universal Commerce Protocol, Google is hoping to repeat this process with the very act of pricing, one of the most important functions in markets. The retail giants eager to partner with Google on this new frontier should heed the warnings of others left in the wake of Google’s dominance. These lawsuits are justified, but the damages they seek to address are in the rearview mirror. We need restitution for past harms, but we also need to protect the future of competition in existing and emerging markets. Here, the impending remedy decision in U.S. DOJ’s online advertising case against Google gives us some hope. Proposed remedies break open Google’s online advertising stack so they can’t represent buyers and sellers while also owning the marketplace in which these parties come together. Policy makers have a tendency to look backwards, but we need to shift our attention to the next frontier that these companies are seeking to dominate. If you have any monopoly tips or stories you'd like to share, drop us a line at hello@antimonopoly.ca
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CAMP defends wholesale system that provides much-needed home internet competition for Canadians
Canadians know that we pay too much for home internet services. While wireless prices have declined in recent years, the cost to connect in our homes has stayed stubbornly high. To promote competition in Canada's home internet market, Canada's telecom regulator, the CRTC, requires large telecom companies to lease their networks to competitors at regulated wholesale rates. This allows smaller firms to offer diverse internet options to consumers without duplicating infrastructure.
Over the holidays, the CRTC asked whether the mark up on these wholesale rates charged to independent competitors should be raised from 30% to 40%. In response, CAMP argued that the CRTC should reject industry calls to maintain or increase the 30% markup, suggesting instead that it be reduced to reflect gains in efficiency of service delivery.
The last thing that Canadians struggling with the cost of living need is an increase in their monthly internet bill. To protect competition for home internet services, the CRTC must ensure that wholesale rates remain low enough for independent competitors to offer viable and competitive retail prices.
Check out CAMP's full response to the CRTC here
Telecom complaints soar as Canadians rail over billing issues
CBC
Canada’s telecom watchdog says complaints about cellphone, internet and television services shot up by 17 per cent from 2024 to 2025, with the chief gripe being about unclear or incorrect billing.