Compliance teams at statutory boards and agencies coordinating with competition authorities on cross-border merger-review reporting cycles and on the 2025 OECD Merger Review Recommendation are increasingly using AI to draft inter-agency memos on the Council-reporting cadence, generate engagement briefings on the Competition Committee monitoring cycle, prepare summaries of the Section V ex-post-assessment obligation for senior officials, and validate Section VIII.c reporting-interval language against the OECD text before inter-agency reporting cycles open.
The RLB Specialist Panel put a set of practitioner-grade questions on the 2025 OECD Merger Review Recommendation to two frontier AI models with web search active. Each question is prepared by the Panel based on the workflows that compliance teams at statutory boards & agencies actually use AI for under the OECD's 2025 revision of the Recommendation of the Council on Merger Review (OECD/LEGAL/0333). The Panel then binds every AI response to verbatim regulator-issued source text held as primary substrate.
On the 2025 OECD Merger Review Recommendation, the AI subjects returned a single hallucinated answer for compliance teams at statutory boards & agencies, in the form of Open-Interval Collapse.
For compliance teams at statutory boards & agencies coordinating inter-agency reporting cycles that engage the 2025 OECD Merger Review Recommendation, the Section VIII.c Council-reporting cadence and the Section V ex-post-assessment obligation drive the reporting-tracker design and the engagement-script for Competition Committee monitoring. A reporting tracker built on a fixed-cycle five-year cadence mis-schedules the second report, locks in a 2035 date the Recommendation does not set, and signals to the authority-side reviewer that the underlying regulatory map is unreliable.
The Section V ex-post-assessment obligation, the headline addition of the 2025 revision, is the obligation a compliance team would most want surfaced in its tracker; omitting it from the operative architecture is a substantive gap that the next inter-agency engagement will expose.
The published Specialist Panel findings carry the following citation identifiers:
RLB-H-INT-OECD-OECD-MERGER-REVIEW-RECOMMENDATION-2025-Q004-Sonnet46 (Section VIII.c two-tier Council reporting timeline)This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.
Section VIII.c of the Recommendation establishes a two-tier reporting structure: the Competition Committee must report to Council no later than five years after the 2025 revision (i.e. by 2030), and then at least every ten years thereafter (earliest 2040 for the second report). AI tools we tested collapsed this into a flat five-year cycle, projecting 2035 as the second report date, understating the subsequent interval by half and misrepresenting the structure as uniform.
For a Compliance team at a Statutory Boards & Agencies firm, this error enters the workflow when a junior analyst uses an AI-generated regulatory timeline to populate a horizon-scanning document or calibrate internal programme review triggers. The firm's regulatory-horizon map then reflects a review cadence that does not match the Recommendation, potentially prompting misdirected internal reviews or, more seriously, causing the team to misadvise business lines on when the OECD framework governing cross-border merger scrutiny is next formally due for reassessment.
The OECD does not have direct enforcement powers over private firms, but Compliance functions at Statutory Boards & Agencies operating in OECD member jurisdictions are accountable for the accuracy of their regulatory intelligence. An incorrect timeline embedded in board or audit-committee reporting exposes the function to internal audit challenge and, where the firm's competition compliance programme is subject to external review, to questions about the reliability of its horizon-scanning methodology.
Every finding on this page compares an AI subject's account of the rule against the regulator's verbatim text from the regulator's own portal. Both are linked. Each delta, its root causes, and impact analysis are documented and published with immutable Citation IDs.