Brasilia - Concerned about the growth of anti-competitive practices around the world and the "aggressive" entry of Chinese companies into Brazil, the Administrative Council for Economic Defense (Cade) has just mapped the food delivery market and is already signaling that it is keeping a close eye on the sector's movements.

The idea is to regulate the sector, given aggressive and prolonged private subsidies, "predatory" pricing, free shipping, high coupons, substantial bonuses for delivery drivers, and the use of large financial reserves by globally present groups to gain market share.

NeoFeed had exclusive access to a technical note from the antitrust agency, published this June, which is based on recent international experiences and already aims at "regulatory adjustments" in the Brazilian market.

The intention, says the local authority, is to preserve competition, avoid market closures, conduct future interventions in a "more calibrated" manner, and prevent any "violations of economic order."

In the document, Cade mentions "recurring concerns" regarding exclusivity clauses; abusive practices targeting restaurants, consumers, and delivery drivers; suspicious use of algorithms; restrictions on multi-homing (restaurants being able to use multiple platforms simultaneously); lack of information about the platforms; and "aggressive subsidy" strategies.

"It is concluded that continuous monitoring, improvement of investigative tools, and increasing attention to structural operations and pro-competitive solutions for preventive action are important."

The economic study was produced at the request of the Cade's general superintendence, back in November of last year, as a way to monitor commercial practices in the delivery sector in Goiânia, Rio de Janeiro, Santos, São Paulo and São Vicente (SP).

According to Cade, these markets have been experiencing "greater competitive intensity," with the entry or return to Brazil of digital delivery platforms such as Meituan (owner of Keeta) and DiDi (owner of 99Food), and the expansion of companies like iFood and Rappi (Colombia).

"It is worth highlighting that the concerns that have been driving extensive regulatory debates about platforms in China, as well as the regulatory adjustments adopted in Middle Eastern countries, directly relate to the challenges observed in Brazil in the face of the aggressive entry of new global players into the national market," says Cade.

The agency also concludes that it will have to deepen the analysis of traditional instruments for evaluating "unilateral conduct, incorporating dynamics typical of digital markets," aligned with contemporary competitive reality.

To that end, the Council submitted inquiries to antitrust authorities in Argentina, Australia, Austria, the United Kingdom, Colombia, the European Union, Japan, Mexico, Mozambique, Paraguay, Portugal, and Sweden.

CADE also analyzed several cases involving digital delivery platforms in Hong Kong, France, the United States (UberEats), Sweden, Germany, Hong Kong, and especially in China, where companies have been engaged in a fierce market dispute that has already led the Chinese antitrust authority to take action.

This week, the Chinese government's market regulator announced measures to regulate subsidies offered by food delivery platforms.

The proposed rules, still under consultation, prohibit platforms from forcing merchants to participate in subsidy campaigns or to cover those costs, from using financial advantages for unfair competition, or from selling products below cost, according to Reuters.

Meituan, the global leader, and competitors Alibaba and JD.com have already released statements committing to adopting these measures.

Effective competition

In this monitoring, Cade acknowledges that the window for "effective competitive intervention" in digital markets is often short.

The Brazilian agency points out, however, that authorities worldwide have already been adopting remedies: restrictions on exclusivity and parity clauses, monitoring of aggressive subsidies, updating traditional criteria for analyzing predatory pricing, and adopting cost metrics more compatible with the economic dynamics of platforms.

"The set of experiences mapped therefore reveals a global effort to adapt competitive and regulatory instruments to the challenges of digital platforms," says Cade in the technical note.

Among the solutions highlighted by the Brazilian antitrust authority are market studies, advocacy , and continuous monitoring as essential tools to address "systemic competitive risks" in this delivery market.

The idea is that this closer monitoring of the sector will serve as a basis for advancing reforms in legislation and specific regulatory packages, aimed at preventing economic damage and "broader" interventions.

"Taken together, the precedents indicate an expansion of scrutiny over indirect forms of consolidation, coordination, and market foreclosure—a movement that tends to intensify as the sector matures and competition becomes defined less by accelerated expansion and more by the strategic control of digital ecosystems," analyzes Cade.

CADE also draws attention to recent regulatory changes in several countries. In Dubai (United Arab Emirates), the competition authority eliminated the requirement of prior dominance to characterize predatory pricing in 2025.

Kuwait has recently approved a rule prohibiting the sale of products or services below their actual cost or average variable cost. In Saudi Arabia, measures launched last year also recommended including superior financial capacity, or " deep pockets ," as an independent criterion for identifying predatory conduct, even without a dominant market position.

In Qatar, a draft law open for public consultation since January 2026 seeks to prohibit price manipulation and the artificial exclusion of competitors. In Hong Kong, investigations into delivery platforms have resulted in formal commitments to change their conduct.

China, in April 2026, approved specific pricing rules for internet platforms, requiring immediate corrections and imposing administrative sanctions.

The case studies mapped by Cade, however, do not focus solely on disputes between digital platforms to expand their markets. Cade also raised cases of mergers and acquisitions involving the platforms, as a strategy to eliminate competitors, and their use of meal voucher companies as a market strategy.

The technical note recalls that the French antitrust authority fined the country's four main meal voucher issuers €414.7 million: Edenred, Sodexo, Natixis Intertitres, and Up. The investigation revealed that these companies, which together controlled almost 100% of the market, maintained high commission rates and prevented the entry of new digital competitors between 2002 and 2018.

"The French case is parallel to the Brazilian scenario, in which there are investigations conducted by CADE and relevant regulatory changes in the benefits voucher sector," says the Brazilian agency.

One of the investigations, according to Cade, involves allegations by the Brazilian Association of Employee Benefits Companies (ABBT) that iFood is using its "dominance in the delivery marketplace to favor and leverage its employee benefits arm (iFood Benefícios), in which the company is a new entrant."

When contacted, Cade (Brazil's antitrust agency) stated that the technical note is not related to any "specific investigation," but rather to market monitoring, and that it does not comment on cases that are still in progress.

However, there are already some ongoing proceedings within the agency related to the Keeta and 99Food brands, concerning market competition, initiated by the companies themselves.