For years, Doctolib was presented as the model of a French scale-up turned essential service.
Then, on November 6, 2025, the French Competition Authority issued a landmark decision (25-D-06), sanctioning the company for abuse of dominant position in the online medical appointment-booking market.
A reminder that even for a national champion, compliance with competition law admits no exceptions.
⚖️ What exactly does the Authority reproach?
The findings rely exclusively on established facts.
1️⃣ Exclusivity clauses (2017–2023)
The Authority found that contracts prohibited the use of competing services, with suspension or termination possible in case of breach.
Internal documents show the company had identified the anticompetitive nature of these clauses—an element that weighed in the legal assessment.
2️⃣ Tying practice (from 2019 onward)
Access to Doctolib Téléconsultation required subscribing to Doctolib Patient.
For a dominant company, such tying is restrictive when it artificially links two distinct services.
3️⃣ Acquisition of MonDocteur (2018)
The decision applies, for the first time in France, the Towercast judgment (CJEU, 2023), allowing concentrations below notification thresholds to be assessed under Article 102 TFEU.
The Authority relied on internal documents referring to a desire to neutralize a direct competitor.
The fine, however, remains symbolic (€50,000), acknowledging the legal uncertainty that existed prior to Towercast.
📊 A clearly established dominant position
According to the Authority’s findings:
- over 70% market share (and sometimes more) in appointment booking since 2017,
- over 40% in teleconsultation,
- significant network effects, characteristic of two-sided platforms.
This context is what makes the identified practices legally problematic.
🔍 A necessary sanction… but what about the strategic reading?
From a strictly legal perspective, the decision appears coherent:
✔ application of Article L. 420-2 of the French Commercial Code and Article 102 TFEU,
✔ qualification supported by documented evidence,
✔ moderated fine regarding MonDocteur in the name of legal certainty.
🧭 Yet a broader question emerges
👉 Is France applying stricter scrutiny to its own tech champions than other jurisdictions?
👉 To what extent might such rigor affect the ability of European actors to compete with US or Asian platforms?
This is not a criticism nor a political stance, simply a legitimate question, given how competition law and industrial strategy increasingly intersect.
