构建竞争——英国数字竞争政策的新视角

A New Lens for DigitalCompetition Policy June 2023 Authors Dom HallasExecutive Director Camilla de Coverly VealePolicy Director With special thanks as ever to our friends at Beauhurst for their hugely valuable data. About Coadec The Coalition for a Digital Economy (Coadec) is an independent advocacy group that serves Coadec was founded in 2010 by Mike Butcher, Editor-at-Large of technology news publisherTechCrunch, and Jeff Lynn, Chairman and Co-Founder of online investment platform Seedrs. Coadec works across a broad range of policy areas that matter the most to startups andscaleups: Access to Talent, Access to Finance & Regulation. We represent the startup Foreword by Jeff Lynn, Chair of Coadec When the Government published the Digital Markets, Competition and Consumer Bill in April, Iwas encouraged. As the Chair of Coadec - an organisation I helped found over a decade ago – Icould see that a competition regime that focused more closely on the dynamics of Indeed, as our Executive Director Dom Hallas said at the time, too many startups are“grappling with bed-blocking incumbents in broken markets.” But at the same time, I have first-hand experience of the Competition and Markets Authority(CMA) getting it wrong in this space. As the now exited founder of Seedrs, the equitycrowdfunding platform I helped build over the past decade, I was at the coalface in 2021 when The CMA’s decision, in my view, came down to their essentially 20th century view of howmarkets work and, as a result, their profound misunderstanding of the competitive dynamics in Entrenchment and expansion of those kind of misunderstandings, if that’s what the CMA’s It’s worth starting with the basics. The facts are clear – startups thrive in competitive markets. In recent years we’ve seen a meteoric rise in Britain’s homegrown tech sector. All this hasmade us a global powerhouse for tech. Startups have done this by beating incumbents at theirown game. In financial services, health, retail and beyond — traditional firms are being At the same time, there’s no denying that some competition issues in the tech sector havefestered for too long. When Coadec surveyed UK tech investors in 2021, 80 per cent said they The Digital Markets Unit (DMU) is set to add critical expertise to the CMA at a time when techis becoming one of the most fundamental sectors to the success of the UK’s economy. But there is also a lot of trust for regulators to repair: 60 percent of investors told us they feltregulators had only a “basic understanding” of tech startups, a further 22 percent thought As someone who has experienced that lack of understanding first hand, it’s not hard to see So regulators must learn the lessons from the journey that I and others have already been on –and need to be aware of a few key facts about the startup ecosystem that will create the Startups want a pro-competitive regime that proactively supports innovation rather than onethat ends up lazily regulating big tech like lumbering utilities. The former path challenges That means competition authorities being more taking a more expansive view of M&A amongchallengers who are building competitors to large incumbents in huge markets. It means alsocreating a pragmatic and innovative regulatory environment that recognises that competition This paper hopes to provide some thoughts on how best to do this, both for the Governmentthrough the DMCC Bill and for the CMA themselves in administering the system on the ground.For the sake of the startups that will follow me in engaging with the regulator in the coming Jeff LynnChairman, CoadecChairman, Seedrs Context & Background WhenCoadec was founded in 2010,it was to support a growing ecosystem ofbusinesses and innovators popping up around a small roundabout in Shoreditch, EastLondon. Since that time, the tech startup community – not just in a small pocket of The UK isnowhome to one of the most exciting and successful startup economies in the world.Investment into UK startups reached a record £13.5bn in the first half of 2021, trebling theamount raised in the same period in 2020. In 2021, London was the second-ranked ecosystemglobally for startup funding, with an ecosystem valued at $142bn. Startups employ people This tremendous success cannot be taken for granted. For parts of the thirteen years that Coadec has been working on startup policy, the success of But now, with the macroeconomic environment for tech firms changing rapidly and themarkets more hostile than they have ever been, there’s a cold wind blowing through the sector. Other changes are occurring too. During this time, tech giants like Google, Apple and Amazonhave moved from being heroes of politicians seeking to learn from their allure, to villains for In response, regulation has moved from a permissive green field to a far more restrictiveapproach. While the focus of Government in the 2010s was mostly on supporting tech’sgrowth, the 2020s risks having its foc