Germany’s Federal Cartel Office has formally concluded its preliminary investigation into enterprise software giant SAP SE, deciding against initiating formal abuse of dominance proceedings at this time. The inquiry was prompted by complaints from several software companies, including Munich-based process mining specialist Celonis SE, which alleged that SAP was restricting third-party access to customer data stored within its Enterprise Resource Planning (ERP) systems to unfairly favor its own competing software solutions.
At the center of the dispute were allegations that SAP was technically and commercially impeding competitors’ access to essential ERP data generated across purchasing, logistics, finance, and human resources. Competitors claimed that these restrictive measures hindered third-party process mining applications—which analyze event logs to optimize corporate workflows—while giving preferential treatment to SAP’s in-house offerings like Signavio. Following extensive inquiries involving SAP, its corporate clients, and broader market participants, regulators determined that the evidence was insufficient to substantiate claims of anticompetitive conduct.
Andreas Mundt, President of the Federal Cartel Office, emphasized that non-discriminatory data access remains vital for maintaining effective competition on major software platforms. However, the agency’s technical assessment established that while extracting large volumes of enterprise data is inherently complex, multiple viable and permissible extraction methods remain fully operational. Furthermore, the watchdog confirmed that SAP’s updated API policy published earlier in the year did not eliminate established data extraction practices, nor was there evidence that SAP was engaging in predatory pricing by bundling or offering its Signavio software virtually free of charge to displace rivals.
Although the current inquiry has closed without regulatory sanctions, the Federal Cartel Office noted that data access frameworks, pricing models, and system integrations in digital markets are evolving rapidly. Consequently, the authority plans to maintain close oversight of platform operators controlling large volumes of competitively sensitive data, reserving the right to re-examine potential competition concerns on a case-by-case basis as the market develops.
