On 06/11/2025, the French Competition Authority (antitrust) fined Doctolib €4.665 million for abuse of dominant position in France. At the heart of the case: exclusivity clauses, tied sales between scheduling and teleconsultation, and the acquisition of MonDocteur. The e-health platform disputes the decision and announces an appeal. The antitrust decision concerning Doctolib highlights the issues of access to healthcare. Moreover, it underscores the competition in a market with strong network effects.
What the Competition Authority accuses Doctolib of: abuse of dominant position
The decision n° 25-D-06 of 06/11/2025 by the Competition Authority sanctions Doctolib for abuse of dominant position. Indeed, this concerns two markets: online medical appointment booking (Doctolib Patient) and teleconsultation solutions (Doctolib Teleconsultation). The Authority identifies three grievances: exclusivity clauses imposed on healthcare providers, tied sales between scheduling and teleconsultation, and the acquisition of MonDocteur (10/07/2018), deemed a predatory operation.
According to the Authority, these practices contributed to excluding competitors and locking the market to the platform’s benefit. The initial complaint dates back to 2019 and was notably from Cegedim Santé/Maiia.
Exclusivities and tied sales: how the market was "locked"
For years, contracts offered to healthcare professionals included exclusivity clauses. Indeed, these clauses prohibited or discouraged the simultaneous use of a competing service. The Authority also highlights a tied sale: to use Doctolib Teleconsultation, one had to subscribe to Doctolib Patient. This commercial coupling reduced the freedom of choice for healthcare providers and mechanically weakened competitors.
Amount of the sanction: €4.665 million. According to the decision, €4.615 million penalize the exclusivities and tied sales. €50,000 penalize the concentration operation analyzed under the abuse of dominant position (see below).
A "predatory" concentration: review of the acquisition of MonDocteur (2018)
On 10/07/2018, Doctolib acquired its rival MonDocteur. The Authority considers that this acquisition eliminated the main competitor in a still emerging market. Thus, it leads to a lasting locking effect. The operation had not been examined ex ante because it did not meet the notification thresholds. It is therefore assessed a posteriori under the abuse of dominant position.
To account for the legal uncertainty that prevailed before the Towercast ruling of the CJEU (16/03/2023, C-449/21), the Authority imposes a lump sum penalty of €50,000. The principle: even below thresholds, a concentration can be repressed if it contributes to an exclusionary abuse.
Doctolib’s position: "no dominant position," an appeal announced
The company disputes the "erroneous reading" of its activity. It claims not to be in a dominant position, highlighting the European competition on software for healthcare providers. Furthermore, it states it equips only about 30% of healthcare providers in France (compared to 10% at the time of the complaint in 2019). Doctolib announces it will appeal the decision before the Paris Court of Appeal.
Beyond the amount, the company emphasizes the usage benefits for patients. Moreover, it focuses on the consolidation of its offerings. Additionally, it aims to innovate. It recalls having removed its exclusivity clauses in recent contracts and argues for the alignment of its practices. Finally, it aligns with industry standards.
What the law says: exclusivities, tied sales, and Towercast jurisprudence
Definition: in competition law, abuse of dominant position (exclusionary abuse) includes certain practices. For example, it covers contractual or de facto exclusivities. Moreover, it also includes tied sales. Their assessment depends on the relevant market, the company’s position, and their effects. The Towercast jurisprudence opened the door to an ex post control of below-threshold concentrations through the lens of Article 102 TFEU and Article L. 420-2 of the Commercial Code. This is the core of the Authority’s analysis for the MonDocteur operation.
Issue: not allowing non-notifiable acquisitions to produce irreversible exclusionary effects on markets with network effects.
A market with strong network effects
Online appointment booking and teleconsultation are two-sided markets: the more patients there are, the more the platform attracts healthcare providers, and vice versa. Network effects create barriers to entry and encourage dominant players to tie services. Thus, they seek to increase switching costs for their competitors.
In this context, exclusivities and tied sales reinforce the circle of adhesion around the leading player. According to the Authority, these mechanisms have tightened market access. This was done to the detriment of choice and potentially prices for professionals.
Timeline, follow-ups, and imposed publications
The decision was rendered and published on 06/11/2025. Besides the financial penalty, the Authority orders Doctolib to publish a summary of the decision, notably in Le Quotidien du Médecin and on its own channels. The announced appeal is not suspensive. The Paris Court of Appeal must rule on the merits of the grievances. Moreover, it will assess the amount of the sanctions.
What this changes for healthcare providers and patients
For healthcare providers. The end of exclusivities and tied sales should facilitate interoperability between tools. Moreover, it should allow the coexistence between scheduling, teleconsultation, and business software. Practitioners regain a freedom of choice and a negotiation leverage on prices and features.
For patients. The core issue is the access and quality of service of the platforms. Consequently, more open and competitive platforms can offer shorter delays. Moreover, they propose simpler pathways and enhanced guarantees of data portability.
For the market. In a two-sided sector subject to powerful network effects, the Authority sends a signal: exclusionary practices and consolidations "under the radar" will be scrutinized. Startups may see a more equitable competitive space.
Methodology and reservations
The procedure is ongoing and the outcome of the appeal remains uncertain. Market shares vary according to the definitions retained (products, geography, period). The figures provided are attributed to the Authority’s documents or public statements by Doctolib. Any qualification of "abuse" refers to the legal assessment by the Authority and may be re-examined by the Court of Appeal.