French regulators fine Doctolib €4.66 million for antitrust violations

The French competition authority announced on November 6, 2025, that it has fined Doctolib €4,665,000 for abusing its dominant position in online medical appointment booking and telemedicine services. The decision marks the first time European regulators have sanctioned a company for predatory acquisition below merger notification thresholds, following precedent established by the Court of Justice of the European Union.

Doctolib faces penalties for implementing exclusivity clauses in healthcare provider contracts and acquiring rival platform MonDocteur in what authorities characterized as an attempt to eliminate competition. The company announced it will appeal the decision.

According to the Autorité de la concurrence's decision 25-D-06, the investigation originated from a 2019 complaint filed by Cegedim Santé, a competitor in healthcare management software. Authorities conducted raids and seizures in 2021 that uncovered internal documents revealing deliberate strategies to lock out competitors from the market.

The penalty consists of two components. Regulators imposed €4,615,000 for exclusivity practices and mandatory service bundling. An additional €50,000 addresses the acquisition of MonDocteur, with the authority noting legal uncertainty before the March 16, 2023 Towercast ruling by the Court of Justice of the European Union.

Market position and service structure

Doctolib operates a two-sided platform connecting healthcare professionals with patients through online appointment scheduling. The service launched in 2013 and gained substantial market share by 2017. Patients access the platform through websites and mobile applications to search for practitioners and book consultations.

The company added Doctolib Téléconsultation in 2019, providing secure video transmission infrastructure compliant with public health code requirements. Both services experienced accelerated growth during the health crisis, when government authorities assigned Doctolib, Maiia, and KelDoc responsibility for managing vaccination appointments in 2021.

According to the decision, Doctolib held market shares exceeding 50% between 2017 and 2022 in online medical appointment services, reaching above 90% in certain years. The company maintained shares above 40% in telemedicine solutions since entering that market in 2019.

Competition authorities determined these shares, combined with high market entry barriers and absence of countervailing buyer power, established dominant positions in both French markets. Doctolib serves approximately 400,000 healthcare providers and 80 million patients across Europe, employing 2,900 staff in more than 30 cities.

Exclusivity requirements blocked competition

The investigation revealed Doctolib inserted exclusivity clauses in provider subscription contracts until September 2023. These provisions, combined with anti-fragmentation language allowing contract suspension or termination, prevented healthcare professionals from using competing appointment or telemedicine services.

Internal documents obtained during raids demonstrated intentional strategy. Executives stated objectives to become "a mandatory and strategic interface between doctor and patient to lock them both in." The legal department warned that exclusivity clauses violated competition law, with one communication stating "I really insist strongly to remove it." Company leadership rejected the advice, with the president arguing "strategically we must keep it."

The exclusivity requirement limited provider choice by forcing professionals already subscribed to competing services to cancel existing contracts before accessing Doctolib Patient. Authorities found this particularly harmed smaller operators with limited resources and those backed by established medical practice management software groups. Some companies including Solocal and Qare stopped developing their services or abandoned development plans entirely.

Doctolib implemented mandatory service bundling when launching telemedicine capabilities. Subscription contracts required healthcare providers to first install Doctolib Patient before accessing Doctolib Téléconsultation. Commercial teams enforced this requirement systematically. Internal guidance instructed sales staff that practitioners using competing telemedicine solutions must "first install the agenda so that 30 days later we can install teleconsultation."

This bundling increased Doctolib Patient subscriptions and reinforced dominance in appointment scheduling. Providers seeking telemedicine functionality had no alternative to adopting Doctolib's appointment system, regardless of existing relationships with competing platforms.

Acquisition eliminated primary competitor

Doctolib acquired MonDocteur on July 10, 2018, in a transaction below thresholds triggering mandatory merger review. Competition authorities examined the acquisition under Article 102 of the Treaty on the Functioning of the European Union and Article L.420-2 of French commercial code, applying principles from the Towercast judgment.

Internal documents described MonDocteur as "competitor #1." Communications seized during raids revealed executives aimed to "kill the product," stating that value creation came "not from adding the MonDocteur asset but its disappearance as a competitor." One strategic analysis concluded that following the acquisition "Doctolib will function without any more competition in France."

The transaction added 10,000 healthcare professionals to Doctolib's client base and substantially increased market share on a lasting basis. Internal planning documents indicated the acquisition would "reduce price pressure" and provide leverage to "increase prices by 10 to 20%." Doctolib subsequently implemented multiple price increases exceeding initial projections by three percentage points, without experiencing customer loss or hindered growth, despite competitors offering lower prices.

Competition authorities determined the acquisition constituted predatory behavior designed to foreclose the market and consolidate dominance. The decision represents the first sanctions under Articles 102 TFUE and L.420-2 for predatory acquisition following the Court of Justice's Towercast ruling, which clarified that concentration operations could independently constitute abuse of dominance even without prior merger notification.

The Court of Justice specified in its March 16, 2023 decision that mere strengthening of dominant position proves insufficient to characterize abuse. Authorities must demonstrate the resulting domination substantially impedes competition by leaving only companies whose behavior depends on the dominant firm.

Legal uncertainty influences penalty calculation

Regulators acknowledged uncertainty surrounding predatory acquisition doctrine before the Towercast judgment. The Court's 2023 decision reaffirmed principles from the February 21, 1973 Continental Can ruling, which applied abuse of dominance rules to merger transactions.

Because Doctolib's acquisition preceded this clarification, authorities applied reduced sanctions. The €50,000 penalty for predatory acquisition reflects consideration of legal ambiguity existing before March 2023. The substantially larger €4,615,000 penalty addresses exclusivity and bundling practices that authorities characterized as a single, complex, continuous infringement implementing a global anticompetitive strategy.

Andreas Mundt, president of Germany's Bundeskartellamt, offered relevant commentary on similar issues in June 2025. "Competition in Germany's online retail trade is largely determined by the rules Amazon sets for its trading platform," he stated regarding pricing restrictions. "As Amazon directly competes with the Marketplace sellers on its platform, influencing its competitors' pricing, including in the form of price caps, is inherently problematic from a competition perspective."

This principle applies directly to Doctolib's market position, where the company operates both as platform provider and potential competitor to other services seeking provider relationships.

International context for platform enforcement

The Doctolib decision arrives amid intensified regulatory scrutiny of digital platforms across jurisdictions. European authorities imposed €700 million in Digital Markets Act fines against Apple and Meta on April 23, 2025, for anti-steering violations and inadequate consumer choice provisions.

France's competition authority previously fined Apple €150 million on March 30, 2025, for App Tracking Transparency implementation creating unfair advantages. The authority concluded that "competition law and the right to privacy are not mutually exclusive, but both aim to guarantee a fair and transparent market that safeguards consumer interests and well-being."

United States courts have ruled against Google in search and advertising technology monopolization cases, with Judge Leonie Brinkema determining the company "willfully engaged in a series of anticompetitive acts to acquire and maintain monopoly power" that "substantially harmed Google's publisher customers." Publishers including Dotdash Meredith and Penske Media have filed private antitrust lawsuits seeking damages.

Germany's Bundeskartellamt issued a preliminary assessment on June 2, 2025, finding Amazon's algorithmic pricing controls likely violate competition law through non-transparent restrictions affecting marketplace sellers.

These enforcement actions reflect common regulatory concerns about dominant platforms leveraging market position to foreclose competition, impose unfavorable terms on business users, or enter adjacent markets while restricting alternatives.

Healthcare provider implications

The competition authority found Doctolib's practices created particularly severe harm for smaller application publishers lacking sufficient proprietary data to develop alternative targeting mechanisms. Smaller healthcare technology providers faced systematic disadvantage when attempting to compete against a platform controlling access to both practitioners and patients.

Network effects intensify these dynamics in two-sided markets. Patients prefer platforms offering broad practitioner selection, while healthcare providers favor platforms used by numerous patients. Doctolib's exclusivity requirements and acquisition strategy prevented alternative platforms from achieving scale necessary to compete effectively.

The decision requires Doctolib to publish a decision summary in print and online editions of Le Quotidien du Médecin, a healthcare professional publication. This remedy aims to inform affected practitioners about anticompetitive conduct and their rights regarding service provider selection.

Doctolib disputed the authority's characterization in its November 6 announcement. "Doctolib is in no way in a dominant position," the company stated. "Despite our strong usage by the general public, Doctolib is a recent player in the software sector for healthcare providers (3 times smaller than our European competitors) and today equips only 30% of French healthcare providers (10% in 2019 at the time of the complaint)."

The company argued it "disrupted a sleepy and locked market for 30 years," developing "reliable, secure and commitment-free solutions that facilitate the daily practice of healthcare providers and help make patients healthier." Regarding the MonDocteur acquisition, Doctolib characterized it as an "absolutely commonplace" external growth operation combining two small and medium enterprises to accelerate innovation.

Doctolib challenged the authority's finding that telemedicine must integrate with other software functions. "Disconnecting it would lead to considerable difficulties for patient follow-up and the daily activity of healthcare providers," the company stated, noting that connection enables access to patient records, prescription sharing, and billing.

Marketing technology enforcement trends

The Doctolib sanctions illustrate regulatory approaches to predatory acquisitions below notification thresholds. The Court of Justice's Towercast framework permits authorities to challenge transactions that escape ex ante merger review when they constitute abuse of dominance.

This enforcement mechanism addresses concerns about "killer acquisitions" where dominant firms eliminate emerging competitors before they achieve sufficient scale for mandatory notification. Technology markets frequently involve acquisitions of smaller entrants with limited revenues but significant competitive potential.

Privacy company Proton filed a class-action lawsuit against Apple on June 30, 2025, citing similar concerns about dominant platforms using market position to exclude competitors. Independent publishers filed formal complaints with European authorities on the same date regarding Google's AI Overviews feature, alleging the company prevents opt-out from content usage without losing search visibility.

For marketing professionals operating across healthcare, travel, publishing, and other sectors, these decisions demonstrate that dominant platforms face enhanced scrutiny regarding exclusive arrangements, mandatory bundling, and strategic acquisitions. Competition authorities have signaled willingness to challenge conduct that forecloses markets or prevents emergence of competitive alternatives.

The financial penalties, while substantial for mid-sized companies, represent relatively modest fractions of revenue for dominant platforms. Doctolib reported that Mon Docteur equipped just 2% of healthcare providers at acquisition. The practical impact on competitive conditions may depend more on behavioral modifications required by enforcement actions than penalty amounts alone.

Structural remedies including divestiture remain possible in some jurisdictions. U.S. antitrust proceedings against Google have included proposals for Chrome browser separation and mandatory data sharing. European Digital Markets Act enforcement has focused primarily on conduct remedies addressing specific obligations around interoperability, data portability, and fair dealing.

Timeline

• 2013: Doctolib launches medical appointment scheduling platform
• 2017: Doctolib achieves dominant market position with shares exceeding 50%
• July 10, 2018: Doctolib acquires competitor MonDocteur
• 2019: Cegedim Santé files competition complaint; Doctolib launches telemedicine service
• 2021: French government assigns Doctolib, Maiia, and KelDoc vaccination appointment management; competition authorities conduct raids and seizures
• March 16, 2023: Court of Justice issues Towercast ruling on predatory acquisitions
• September 2023: Doctolib removes exclusivity clauses from contracts
• March 30, 2025: French authority fines Apple €150 million for App Tracking Transparency violations
• April 23, 2025: European Commission imposes €700 million DMA fines on Apple and Meta
• June 2, 2025: German Bundeskartellamt challenges Amazon pricing policies
• November 6, 2025: Autorité de la concurrence announces €4.66 million Doctolib fine; company announces appeal

Summary

Who: France's Autorité de la concurrence sanctioned Doctolib, a medical appointment and telemedicine platform serving 400,000 healthcare providers and 80 million patients across Europe, following a complaint from competitor Cegedim Santé filed in 2019.

What: The authority imposed €4,665,000 in fines for two violations: €4,615,000 for exclusivity clauses and mandatory service bundling that locked healthcare providers into using only Doctolib services, and €50,000 for predatory acquisition of competitor MonDocteur in 2018 to eliminate competition and consolidate market control.

When: The decision was announced on November 6, 2025, following investigations that began in 2019 and included raids in 2021. The anticompetitive conduct spanned from 2018 (acquisition date) through September 2023 (when exclusivity clauses were removed).

Where: The enforcement action addresses practices in French markets for online medical appointment scheduling services and telemedicine solutions, with Doctolib holding market shares exceeding 50% in appointment booking and above 40% in telemedicine since 2019.

Why: Competition authorities determined Doctolib abused dominant market positions by preventing healthcare providers from using competing services through contract restrictions and by acquiring its primary competitor to "kill the product" and operate "without any more competition in France," substantially impeding market competition and harming smaller operators unable to achieve necessary scale.