Czech Competition Authority Upholds $13.4 Million in Cartel Fines

Key Takeaways

• Penalties Confirmed: Czech competition authorities upheld approximately $13.4 million (CZK 279.152 million) in fines against Pluxee, Edenred and Up Česká republika.
• Years of Coordination: The three meal voucher issuers coordinated restrictions on how many paper vouchers customers could use in a single purchase between 2004 and 2018.
• Appeal Focused on the Fines: The cartel finding was already final. The latest proceedings concerned whether the penalties were lawful and properly calculated.
• Companies Challenged the Methodology: The issuers argued that the fines were excessive, relied on incorrect turnover figures and misapplied the Office’s 2018 fining guidelines. Those arguments were rejected.

Deep Dive

The Czech Republic’s competition authority has upheld approximately $13.4 million (CZK 279.152 million) in fines against three meal voucher issuers, bringing the regulator’s long-running case over a cartel that operated for more than 14 years to a close.

Petr Mlsna, chairman of the Office for the Protection of Competition, dismissed appeals from Pluxee Česká republika, Edenred CZ and Up Česká republika over the penalties, the Office said Monday. The companies had argued, among other things, that the fines were excessive, based on incorrect turnover figures and calculated through an improper application of the regulator’s 2018 fining guidelines.

The underlying infringement was no longer at issue. That finding had already become final, leaving Mlsna to decide whether the penalties imposed by the Office were lawful and sufficiently justified. He concluded that they were.

Pluxee was fined approximately $6.33 million (CZK 132.271 million), the largest of the three penalties. Edenred must pay about $4.88 million (CZK 101.94 million), while Up Česká republika faces a fine of roughly $2.15 million (CZK 44.941 million).

“Anti-competitive conduct, especially when it persists over such a long period, must be met with an appropriate penalty,” Mlsna said, adding that the Office had properly applied both the Czech Competition Act and its 2018 guidelines. He said the resulting fines were neither disproportionate nor, at present, financially ruinous for the companies.

The case concerns an agreement that the Office found had operated from May 1, 2004, through June 25, 2018. During that period, the three companies coordinated terms with retail chains governing the acceptance of paper meal vouchers in the Czech Republic. Specifically, they agreed on the maximum number of vouchers that retailers could accept from a customer in a single purchase.

The restriction may have been imposed at the checkout counter, but the Office found its effect further upstream. By coordinating those terms rather than setting them independently, the companies distorted competition in the market for issuing, selling and redeeming paper meal vouchers and related services, violating both Czech and European Union competition rules.

The Office first found the companies had participated in the cartel in September 2022. Mlsna upheld the infringement finding in October 2023, but concluded that the penalties imposed at the time required more comprehensive reasoning.

That sent the question of the fines back to the Office without disturbing the finding that competition law had been breached. In August 2025, the regulator issued a new decision and imposed the same penalties, this time with additional reasoning. The companies appealed again.

The latest decision leaves those amounts intact. Mlsna rejected the companies’ objections to the Office’s methodology and found that the regulator had adequately justified penalties tied to conduct that lasted more than a decade.

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