(A) Introduction
Bid-rigging in the building maintenance sector has long been a primary target of Hong Kong Competition Commission (the “Commission”).
Over the past two years, the Commission has intensified its crackdown through a series of enforcement actions, including two joint operations with the Independent Commission Against Corruption (the “ICAC”) in April 2024 [1] and August 2024 [2], followed by two independent operations in August 2025 (the “August 2025 operation”) [3] and September 2025 (the “September 2025 operation”) [4].
The Commission’s latest operation on 28 - 29 January 2026 (the “January 2026 operation”) [5] marks a significant evolution in its enforcement strategy. Unlike previous actions triggered by new intelligence, this operation emerged from a deep analysis of evidence collected in earlier cases, uncovering a sophisticated and previously hidden bid-rigging syndicate. In this operation, the Commission executed search warrants at 27 premises, targeting 14 companies, including project contractors and a consultancy firm, as well as the residences of the individuals involved. The companies were suspected of engaging in bid-rigging, in contravention of the First Conduct Rule of the Competition Ordinance (the “Ordinance”).
This article analyzes the Commission’s three most recent sole operations (August 2025, September 2025 and January 2026) and concludes with implications for Hong Kong’s evolving enforcement landscape.
(B) Similarities of the Operations
The three operations share the following similarities:
(1) Sector Focus
All the operations targeted bid-rigging in Hong Kong’s building maintenance sector:
(a) The August 2025 operation involved tender manipulation for a private housing estate in Kowloon City.
(b) The September 2025 operation targeted a bid-rigging case involving 25 building maintenance projects across 23 residential estates/ buildings and 2 industrial buildings.
(c) The January 2026 operation addressed bid-rigging in the tendering process of building maintenance projects at residential estates/ buildings as well as industrial and commercial buildings.
(2) Key Actors and Syndicate Composition
Each operation involved organized collaboration between multiple parties.
Each operation involved organized collaboration between multiple parties.
(a) In August 2025, a building maintenance consultant was suspected of colluding with a contractor.
(b) The September 2025 operation uncovered two structured syndicates comprising several contractors coordinating bids.
(c) The January 2026 operation identified a deeply embedded syndicate, led by a mastermind contractor and actively supported by a consultancy firm which leaked confidential cost estimates.
(3) Enforcement Tools
The Commission consistently deployed its statutory powers during these operations, including executing search warrants at offices and residences, demanding document production and information disclosure and summoning individuals to provide relevant information.
(C) Differences of the Operations
The three operations reveal a clear evolution in the Commission’s strategy and the scale of the violations uncovered. They differ across four key aspects:
(1) Trigger and Investigative Origin
The operations demonstrate a shift from reactive to proactive, intelligence-led enforcement.
(a) The August 2025 operation was triggered by a referral (external tip-off).
(b) The September 2025 operation stemmed from the Commission’s own detailed study and information gathered from prior joint operations with the ICAC.
(c) The January 2026 operation was initiated based on the Commission’s in-depth analysis of evidence collected during earlier investigations.
(2) Scope and Scale of the Violations
The geographical reach, number of projects and contract values expanded significantly across the operations.
(a) The August 2025 operation focused narrowly on a single private housing estate in the Kowloon City District, with a contract value of around HK$40 million.
(b) The September 2025 operation broadened to 25 building maintenance projects of 23 residential estates/ buildings and 2 industrial buildings, spanning 10 districts across Hong Kong, Kowloon and the New Territories. The total value of the relevant contracts exceeded HK$600 million.
(c) The January 2026 operation involved 17 housing estates and buildings across 9 districts in Hong Kong. The total value of the relevant contracts was around HK$700 million.
(3) Scale of the Enforcement Actions
The Commission’s operational response grew in intensity.
(a) In the August 2025 operation, the Commission executed search warrants at 4 premises, including the offices of a building maintenance contractor and a building maintenance consultant, as well as the residences of the individuals involved.
(b) The September 2025 operation was a two-day operation targeting 19 premises, including the offices of 9 project contractors and residences of the individuals involved.
(c) The January 2026 operation was the largest raid to date, a two-day operation covering 27 premises and involving 14 companies, including contractors and a consultancy firm.
(4) Nature of Violations and Syndicate Complexity
Each case revealed increasingly sophisticated and deeply embedded forms of collusion.
(a) The August 2025 operation focused on collusion between a consultant and a contractor, with the notable escalation of violent intimidation used to coerce potential bidders.
(b) The September 2025 operation uncovered two established syndicates with cohesive organizational structures, comprising various project contractors and other relevant parties. They allegedly coordinated bidding prices and submitted cover bids (commonly referred to as “pig quotes”). Such conduct amounts to bid-rigging, price-fixing and the exchange of competitively sensitive information, contravening the First Conduct Rule of the Ordinance.
(c) The January 2026 operation revealed a deeply hidden syndicate led by a mastermind contractor, supported by a consultancy firm which leaked confidential project cost estimates. The scheme involved systematic cover bidding and turn-taking arrangements among contractors to rig multiple tenders. Such conduct amounts to bid-rigging, price-fixing and exchange of sensitive information, contravening the First Conduct Rule of the Ordinance.
(D) Key Takeaways
Undoubtedly, bid-rigging is a year-long and serious issue in Hong Kong’s building maintenance sector. The Commission has significantly intensified its focus, not only through standalone enforcement, but also via deepened inter-agency collaboration, particularly with the ICAC. This partnership has been demonstrated by two joint operations in 2024, the signing of a Memorandum of Understanding in December 2024 [6] as well as the joint participation in the Building Management Summit in June 2025.
The Commission has reiterated that bid-rigging in building maintenance is a top enforcement priority. The unprecedented scale of its latest operation targeting sophisticated and multi-district syndicates signals a major escalation in its proactive crackdown on such anti-competitive conduct.
At present, bid-rigging cases are subject to the civil standard of proof to establish a defence, namely the balance of probabilities. This means that while the Commission must prove the prohibition applies in principle beyond a reasonable doubt, the burden shifts to the business to demonstrate that its arrangement meets the criteria for an exclusion. As such, there is a growing concern on whether criminalizing bid-rigging with its higher standard of “beyond reasonable doubt” is necessary to act as a stronger deterrent. It certainly takes time (may be years) to establish such a legal framework. Further, whether criminalizing bid-rigging will be effective in combating it remains an open question.
In the meantime, as industry self-regulation is in fact the quickest and most effective solution to the problem, it is necessary for companies in the building maintenance sector to take proactive steps. They should urgently review and strengthen their internal compliance programmes. Key measures include establishing clear protocols for handling tender invitations, formulating bids and managing interactions with competitors, as well as strictly prohibiting any discussions with competitors regarding pricing, bidding strategies, market allocation, or tender outcome.
[1] https://www.compcomm.hk/en/media/press/files/Joint_operation_PR_EN.pdf
[2] https://www.compcomm.hk/en/media/press/files/PR_Joint_operation_AUG_EN.pdf
[3] https://www.compcomm.hk/en/media/press/files/building_maintenance_search_PR_EN.pdf
[4] https://www.compcomm.hk/en/media/press/files/Janus_PR_EN.pdf
[6] https://www.compcomm.hk/en/media/press/files/CC_ICAC_MoU_PR_EN.pdf
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