The Authority has published a new study examining the competitive challenges arising from the energy and environmental impact of artificial intelligence, marking a further step in its analysis following Opinion No. 24-A-05 on generative AI. Released on 17 December 2025, the study focuses on how the rapid development and deployment of AI technologies intersect with competition law, particularly in light of growing energy consumption and pressure on natural resources.
While the large-scale adoption of AI is relatively recent and its full environmental impact remains difficult to quantify, the Authority notes that the expansion of data centres and AI infrastructures—priorities for both France and the European Union—is already leading to a significant increase in electricity demand, heightened use of water and rare materials, greater land constraints, and a substantial carbon footprint. These developments raise important questions for market dynamics and competitive conditions.
According to the Authority, constraints related to access to electricity networks and energy pricing have the potential to shape competitive outcomes in the AI sector. Limited or costly access to energy may favour certain operators and disadvantage others, thereby influencing market structure. At the same time, the growing emphasis on “frugal” AI solutions—aimed at improving efficiency while reducing environmental impact—could stimulate innovation and enable smaller or newer players to compete more effectively with established firms. In this context, environmental performance may increasingly become a key parameter of competition.
The study also highlights the importance of ongoing standardisation efforts, particularly those relating to the measurement of environmental footprints. Robust and widely accepted methodologies for assessing energy and environmental impact are seen as essential to ensuring that competition between AI providers is based on objective and comparable criteria. Without such standards, competitive distortions may arise, undermining fair rivalry in the market.
The Authority places particular emphasis on the need for reliable, transparent data regarding the energy and environmental footprint of AI technologies. Enhanced transparency would not only support effective competition but also allow sustainability considerations, including frugality, to function as genuine competitive factors. In addition, the Authority underlines the importance of preventing preferential access to critical resources—such as suitable land for data centres or low-carbon energy sources, including nuclear-generated electricity—from benefiting only a limited number of market participants.
In light of these findings, the Authority invites all stakeholders to engage actively with the issues identified in the study. It encourages companies and other actors to contact the Authority if they suspect potentially anti-competitive practices linked to energy or environmental constraints, or to seek informal guidance from the General Rapporteur on the compatibility of sustainability-driven initiatives with competition rules.