CMA Accepts Undertakings in Schlumberger–ChampionX Merger Inquiry

The UK Competition and Markets Authority (CMA) has accepted legally binding undertakings in lieu of a phase 2 reference in connection with the proposed acquisition of ChampionX Corporation by Schlumberger Limited. This resolves the regulator’s concerns around a substantial lessening of competition in UK oil services markets and allows the transaction to proceed without an extended probe, following a process that began with an initial inquiry in late 2024.

Background to the Schlumberger–ChampionX Merger Inquiry

Interest in the proposed Schlumberger Limited acquisition of ChampionX Corporation was first signalled when the CMA began information-gathering on 26 November 2024. The regulator invited industry stakeholders to comment on the potential impact of the deal, as part of its duties under the Enterprise Act 2002. The formal merger inquiry was launched on 29 January 2025, and the decision to proceed through standard merger control procedures followed.

"The CMA has decided...this merger may be expected to result in a substantial lessening of competition within a market or markets in the United Kingdom." — Phase 1 Decision (CMA)

Key Dates in the CMA's Review Process

A structured timeline governed the CMA’s review:

• 26 Nov–10 Dec 2024: Preliminary invitation to comment issued to the market.
• 29 Jan 2025: Formal inquiry commenced.
• 27 Mar 2025: Phase 1 decision announced; identified that the deal could raise substantive competition concerns.
• 10 Apr 2025: CMA declared reasonable grounds to believe undertakings might address competition issues.
• 10 Jun 2025: Consideration of undertakings extended through 8 August 2025.
• 20 Jun–4 Jul 2025: Consultation launched on proposed undertakings in lieu of reference.
• 15 Jul 2025: Final undertakings accepted, resolving phase 1 concerns.
• 28 Jul 2025: Monitoring trustee appointed to oversee commitments.
• 25 Aug 2026: Trustee contact details finalised and published.

Focus Keyword: CMA Merger Inquiry and the Outcome for Schlumberger

The core of the CMA merger inquiry revolved around whether the transaction would result in a relevant merger situation with the likelihood of reduced competition. The authority flagged specific oil services markets in the UK as at risk and warned the parties that, absent accepted undertakings, the case would proceed to a comprehensive phase 2 investigation.

Schlumberger Limited and ChampionX Corporation responded by offering undertakings designed to address the CMA’s concerns. After a period of public consultation and an extension to allow further assessment, the CMA determined by mid-July 2025 that these commitments were sufficient to prevent a substantial lessening of competition.

Undertakings in Lieu: Mechanism and Legal Effect

The undertakings provided by Schlumberger and ChampionX, accepted under the Enterprise Act 2002, are legally binding upon both parties. They chiefly aim to mitigate competition risks identified in specific UK markets. According to the CMA process:

• The undertakings set out structural or behavioural measures to preserve market rivalry.
• Their acceptance heads off an in-depth phase 2 reference, significantly reducing the transaction timeline and associated regulatory risk.
• A monitoring trustee has been appointed to oversee effective implementation and compliance — an industry-standard practice for major remedies.

A summary of the full decision and the undertakings are available in official documents released by the regulator as part of its transparency commitments.

Next Steps for Industry Stakeholders and Implications

With phase 1 concerns addressed, the Schlumberger–ChampionX deal is cleared to move forward in the UK market. The monitoring trustee will track adherence to commitments and liaise with the CMA as required. Operators and vendors in related b2b and regulation segments should study the undertakings for indications of future enforcement priorities.

This case underscores the CMA’s approach to international M&A involving UK markets: prompt identification of potential competition harms, structured opportunities for undertakings, and ongoing oversight through appointed trusteeships. For deals raising similar issues, early engagement and remedy formulation remain critical.

Chronicle of Documents and Consultation Opportunities

All procedural steps, decisions, notices and consultation documents have been published by the CMA, with full access granted to interested parties. Notably, the agency invited written submissions from stakeholders in November–December 2024 and again in mid-2025 during the consultation on undertakings. Privacy considerations for personal data provided during these processes were addressed in the CMA’s privacy notice, with contacts maintained for ongoing engagement.

The regulatory framework for merger control in the UK remains governed by the Enterprise Act 2002, which stipulates the processes and thresholds for intervention, consultation, and the implementation of accepted remedies. The appointment of a monitoring trustee is both a transparency and compliance measure, ensuring that competition is preserved post-transaction.