On January 9, 2026, the French Competition Authority put the final piece in a regulatory puzzle it began assembling two years ago. By launching an ex officio opinion procedure, it is now targeting the “last mile” of AI: conversational agents.
Behind this initiative, there is neither technological fascination nor a communication stunt. It reflects a three-step regulatory strategy:
1️ Upstream (2024): Control over AI models and large-scale access to training data.
2️ Infrastructure (2025): Barriers to entry linked to energy, data centers, and computing power.
3️ Downstream (2026): The user interface where market power becomes tangible.
Why does this matter?
Conversational agents are no longer purely informational tools. They are becoming decision-making intermediaries. They compare, filter, and are beginning to autonomously execute transactions.
The risk is no longer theoretical. It is structural:
🔹 Leveraging effects: Can an operator favor its own services through its agent?
🔹 Algorithmic transparency: On what criteria does the agent base its recommendations?
🔹 Lock-in effects: How can freedom of choice be preserved if the agent becomes the primary gateway to the market?
The neutrality of conversational agents is emerging as a new compliance battlefield. The message is demanding: integrating AI into a customer journey is no longer merely a UX or innovation issue. It is now a matter of economic compliance in its own right. Documenting the absence of bias and ensuring algorithmic fairness will become, as early as this year, a major competitive advantage.
This national initiative echoes ongoing European work related to the implementation and assessment of the Digital Markets Act (DMA). As the European Commission examines the contestability of digital markets, the French Competition Authority is questioning the ability of new entrants to survive within vertically integrated ecosystems.
The key issue is no longer whether an AI model is performant, but whether the interface that deploys it complies with competition law and preserves consumers’ freedom of choice.
