CCI Proposes Conduct Rules Imposing Stricter Obligations on Employees

The Competition Commission of India (CCI) published the draft CCI (Conduct) Rules, 2025, on March 7, 2025, proposing stricter constraints on investments made by its employees and heightened obligations on secrecy and misuse of official position considering the commercially sensitive nature of the work.

The regulations are intended to establish high ethical standards among staff members and fortify the regulatory framework guiding vigilance administration in the commission. In contrast to the Central Civil Services (CCS) Conduct Rules, 1964, which provide a comprehensive set of moral standards for all government workers, the CCI Rules provide enhanced obligations in respect of the following:

• Stricter Investment Limitations
  Employees of CCI and their dependent children are not permitted to invest in commodity derivatives, equity and equity-related instruments, including convertible debentures and warrants, except for mutual funds, non-convertible bonds, debentures, IPOs, etc., already held by them. The restriction also extends to the spouse and dependent parents or in-laws out of the money given by the employee. Conflicts of interest in topics pertaining to competition are intended to be eliminated by this measure.
• Speculation in stocks, shares, investments, etc.
  While the CCS Rules also prevented speculation in stocks, shares, etc., the CCI Rules place a stricter restriction on employees from engaging, directly or indirectly, in stocks, shares, securities, or commodities or other speculative activities except those already held by them. Additionally, they are prohibited from encouraging people to trade stocks on the basis of price-sensitive information that has not been made public.
• More stringent rules on maintaining secrecy
  CCI employees are expected to maintain the strictest secrecy regarding the Commission’s affairs and not divulge any official or price-sensitive information to a member of the public or to his friends or relatives, unless judicially compelled or instructed to do so by a superior officer. Employees are required to make a declaration of fidelity and secrecy in Form A annexed to the rules.
• Employment after retirement

Former employees, for a period of one year from the date when they finally cease to be in the commission’s service, are not allowed to accept commercial employment that seeks to exploit insider knowledge or employment with entities that they had had official dealings with, except with the prior approval of the commission or the chairperson depending on the nature of the employment.

• Not to misuse official position
  In contrast with the CCS conduct rules, explicit provision has been introduced in the CCI conduct rules regarding the misuse of official position. Employees are prohibited from encouraging outside agencies to call at their residences about official matters. They are also prohibited from using office facilities like letterheads or resorting to oral discussions in place of written communication. They are also restricted from using their official position to favour friends and family.

Significantly, the Draft CCI (Conduct) Rules, 2025, are specifically designed for competition law enforcement, in contrast to the CCS Conduct Rules, 1964, which are generally applicable to public officials. These modifications preserve regulatory integrity, guarantee market neutrality, and guard against insider influence—all of which are critical for fair competition in India. Comments may be shared till April 6, 2025, through a form on the CCI website.