The notification threshold is one thing, dominance scrutiny another; moreover, turnover must be calculated on a group-consolidated basis. Special rules such as the technology exception must not be overlooked either — a short threshold memo closes off this risk.
And staying under the thresholds does not put conduct out of reach: abuse of a dominant position and restrictive agreements are assessed on their own terms regardless of size. The threshold memo should therefore flag not just notification but any behavioural exposure, so a “no filing needed” conclusion is not mistaken for “no competition risk.”
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