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On 11/06/2025, the French Competition Authority (antitrust) fined Doctolib €4.665 million for abuse of dominance in France. At the heart of the case: exclusivity clauses, tying between scheduling and teleconsultation, and the acquisition of MonDocteur. The e-health platform is contesting the decision and says it will appeal. The Doctolib antitrust decision highlights issues around access to care. It also underscores competition in a market with strong network effects.
What The Competition Authority Reproaches Doctolib For: Abuse Of Dominance
The Competition Authority’s Decision No. 25-D-06 of 11/06/2025 sanctions Doctolib for abuse of dominance. In fact, it concerns two markets: online medical appointment booking (Doctolib Patient) and teleconsultation solutions (Doctolib Téléconsultation). The Authority identifies three complaints: exclusivity clauses imposed on healthcare providers, tying between the scheduling tool and teleconsultation, and the acquisition of MonDocteur (07/10/2018), deemed a predatory transaction.
According to the Authority, these practices helped drive out competitors and lock up the market for the benefit of the platform. The initial complaint dates back to 2019 and came notably from Cegedim Santé/Maiia.
Exclusivities And Tying: How The Market Was “Locked Up”
For years, the contracts offered to healthcare professionals included exclusivity clauses. In fact, these clauses forbade or discouraged the simultaneous use of a competing service. The Authority also points to tying: to use Doctolib Téléconsultation, users had to subscribe to Doctolib Patient. This commercial bundling reduced healthcare providers’ freedom of choice and mechanically weakened competitors.
Amount of the fine: €4.665 million. According to the decision, €4.615 million sanctions the exclusivities and tying. €50,000 sanctions the merger transaction analyzed under abuse of dominance (see below).
A “Predatory” Merger: Back To The MonDocteur Acquisition (2018)
On 07/10/2018, Doctolib acquired its rival MonDocteur. The Authority considers that this acquisition eliminated the main competitor in a still-emerging market. As a result, it creates a lasting lock-in effect. The transaction had not been reviewed ex ante because it did not exceed the notification thresholds. It is therefore assessed after the fact under abuse of dominance.
To account for the legal uncertainty that prevailed before the CJEU’s Towercast ruling (03/16/2023, C-449/21), the Authority imposes a lump-sum fine of €50,000 here. The principle: even below the thresholds, a concentration can be punished if it contributes to an exclusionary abuse.
Doctolib’s Position: “No Dominant Position,” An Appeal Announced
The company disputes the “misreading” of its activity. It says it is not in a dominant position, pointing to European competition in software for healthcare providers. It also says it equips only about 30% of healthcare providers in France (up from 10% at the time of the 2019 complaint). Doctolib says it will appeal the decision before the Paris Court of Appeal.
Beyond the amount, the company emphasizes the practical benefits for patients. It also stresses the integration of its offerings. It also aims to innovate. It says it has removed its exclusivity clauses from recent contracts and argues that its practices are aligned. Finally, it says it is in line with industry standards.
What The Law Says: Exclusivities, Tying, And The Towercast Case Law
Definition: in competition law, abuse of dominance (exclusionary abuse) includes certain practices. For example, it covers contractual or de facto exclusivities. It also includes tying. Their assessment depends on the relevant market, the company’s position, and their effects. The ***Towercast* case law** opened the door to ex post review of below-threshold mergers 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 of the MonDocteur transaction.
Issue: not allowing non-notifiable acquisitions to produce irreversible exclusionary effects in 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 bundle services. In doing so, they seek to increase switching costs for their competitors.
In this context, exclusivities and tying strengthen the adoption loop around the leading player. According to the Authority, these mechanisms have tightened access to the market. This has come at the expense of choice and potentially prices for professionals.
Timeline, Next Steps, And Required Publications
The decision was issued and published on 11/06/2025. In addition to 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 will rule on the merits of the complaints. It will also assess the amount of the sanctions.
What This Changes For Healthcare Providers And Patients
For healthcare providers. The end of exclusivities and tying should make interoperability easier between tools. It should also allow coexistence between scheduling, teleconsultation, and practice-management software. Practitioners regain freedom of choice and leverage in negotiations on prices and features.
For patients. The core issue is platform access and service quality. As a result, more open and competitive platforms can offer shorter wait times. They also provide simpler journeys and stronger data portability guarantees.
For the market. In a two-sided sector subject to powerful network effects, the Authority is sending a signal: exclusionary practices and “under-the-radar” consolidations will be closely scrutinized. Startups may see this as a fairer competitive space.
Methodology And Caveats
The procedure is ongoing and the outcome of the appeal remains uncertain. Market shares vary depending on the definitions used (products, geography, time period). The figures cited are attributed to the Authority’s documents or to Doctolib’s public statements. Any characterization of “abuse” refers to the Authority’s legal assessment and may be reexamined by the Court of Appeal.