MDPPACPB Regulations

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This table classifies infringements into Category A (Severe), Category B 
(Moderate), and Category C (Minor/Technical) offenses, along with guideline 
penalty ranges, examples, and notes on aggravating/mitigating factors. 
PENALTIES TABLE – GUIDELINE FINES FOR COMPETITION INFRINGEMENTS 
 
Category 
Nature of 
Offense 
Examples 
Indicative 
Fine 
Range 
Aggravating 
Factors 
Mitigating 
Factors 
A(Severe 
Offenses) 
Hardcore 
anti-
competitiv
e conduct 
with 
significant 
market 
harm or 
intent 
- Cartel 
agreements: 
price-fixing, 
bid-rigging, 
market 
allocation- 
Abuse of 
dominance 
with 
foreclosure 
effects (e.g., 
predatory 
pricing, 
refusal to 
supply 
essential 
facility)- 
Repeated or 
coordinated 
exclusionary 
behaviour by 
dominant firm 
or group 
3% – 5% 
of annual 
turnover 
of the 
offender 
for the 
precedin
g 
financial 
year 
- Repeat 
offender 
(recidivist)- 
Leader or 
instigator of 
the 
conduct- 
Obstruction 
of 
investigation
- Large 
market 
share or 
significant 
harm 
caused 
- Voluntary 
self-
reporting- 
Cooperation 
beyond 
legal duty- 
Early 
cessation of 
conduct- 
Established 
compliance 
program 
B(Moderat
e Offenses) 
Single-firm 
conduct or 
restrictive 
practices 
with limited 
impact or 
lower intent 
- Exclusive 
dealing 
without clear 
foreclosure- 
Tying/bundlin
g with minor 
market harm- 
Unfair 
discrimination 
between 
trading 
partners- 
1% – 3% 
of annual 
turnover 
- Continuing 
breach after 
warning- 
Moderate 
financial 
gains from 
conduct- 
Lack of 
cooperation 
during 
investigation 
- First-time 
offense- 
Limited 
market 
impact- 
Voluntary 
compliance 
after 
Authority 
intervention