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The EU Merger Guidelines consultation has received 106 responses from stakeholders, calling for a robust overhaul to ensure the guidelines address current EU challenges such as competitiveness, resilience, and strategic autonomy. Respondents highlight the need for clearer and forward-looking guidance, including novel theories of harm, and a more dynamic approach that reflects firm and market specificities. Telefónica welcomes the call for simplification and reform, and is confident that the Commission will reflect these claims in the draft revised Guidelines expected by Spring 2026.

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