#e4mExclusive:  Not just Dentsu, two more independent agencies helping CCI in ad cartel probe

The Competition Commission of India’s investigation into alleged cartelisation in the advertising industry has widened beyond the information provided by Dentsu. At least two independent advertising agencies are now assisting the regulator in decoding the alleged collusion and connecting the dots across agencies, broadcasters and commercial arrangements, according to top sources privy to the investigation. 

The agencies are understood to be providing information and industry context to the CCI’s investigative arm, including inputs that could help investigators understand how pricing, discounts, commissions and other commercial terms were allegedly coordinated among players in the advertising ecosystem, the official said. 

One notice, reviewed by e4m and issued on 19 March, 2026 to an independent agency seeks specific details and information regarding the probe. This includes material related to a joint meeting involving industry players and a media buying deal concerning a major advertiser. CCI has also sought details about AAAI membership through a notice.

Read earlier report on IBDF discloses CCI search

The notice indicates that the CCI’s investigation is examining individual commercial interactions and meetings as part of its effort to establish the sequence of events and determine whether there were any links between them and the alleged coordination under investigation.

The source said investigators seek this information as investigators attempt to connect separate pieces of evidence and establish whether the commercial practices examined were isolated transactions or part of a wider pattern of coordination.

As the CCI’s Director General continues the investigation despite legal challenges mounted by some of the agencies before the Delhi High Court. According to the sources, the court proceedings and interim relief granted in certain matters have not brought the DG’s investigation to a halt, although the regulator must comply with court directions regarding specific summons or parties.

“The investigation is continuing. The court proceedings have not stopped the DG from examining the material available or following leads emerging from the investigation.”

Read earlier report - TLG India added to media cartel investigation

The source added that the role of the independent agencies assisting the CCI is not necessarily limited to providing documents. Their inputs are helping investigators understand the commercial practices of the industry and establish linkages between different pieces of information available with the regulator.

The agencies could therefore become important sources of corroborative evidence as the CCI attempts to establish whether the conduct under investigation represented isolated commercial practices or a broader pattern of coordination.

Publicis Groupe set to challenge probe - Read earlier report 

Investigation moves beyond original whistleblower input

The CCI’s advertising industry investigation was triggered after Dentsu made disclosures under the regulator’s leniency programme in February 2024. Under the programme, companies involved in cartel conduct can seek reduced penalties by making disclosures and assisting the regulator with evidence.

The investigation subsequently expanded significantly, culminating in search and seizure operations in March 2025 at the offices of several major advertising and media agencies as well as industry bodies.

Dentsu India had said that its decision to approach the CCI under the leniency framework in February 2024 was a proactive step taken to support reform within the industry. “Dentsu India is among the country’s leading agency networks and with that comes the responsibility to act with integrity and accountability. We had a choice – to remain passive or drive change,” the company said. 

It added that it had approached the CCI suo moto and that the move “was not a reaction to external pressure but a decision to support reform from within.” Dentsu said it subsequently implemented measures including enhanced audits, stricter governance and tighter internal controls. 

“These reflect our ongoing commitment to build trust through transparency, action, and accountability to safeguard the interest of our clients,” it said. The agency added that it remained committed to industry-wide reform, saying, “Change can't be affected by walking away,” and that the current period presented an opportunity for “collective reform” for the future of the industry.  

The CCI searched the premises of top media agencies across Mumbai and Delhi. The CCI also searched the offices of industry bodies including the Advertising Agencies Association of India (AAAI), Indian Society of Advertisers (ISA) and Indian Broadcasting and Digital Foundation (IBDF).

The regulator is examining alleged anti-competitive conduct involving advertising rates, discounts and commercial terms. CCI’s preliminary assessment included allegations that agencies coordinated pricing through a WhatsApp group and entered into arrangements relating to business and commercial terms. These remain allegations under investigation and do not constitute a final finding of liability.

The involvement of additional independent agencies could give the CCI another layer of information with which to test evidence obtained from the original disclosures and subsequent searches.

Investigators are looking at the entire chain and not one particular transaction or one particular company. Inputs from independent players can help establish whether the practices being examined were industry-wide, bilateral or limited to specific relationships.

Delhi HC proceedings have not stopped DG probe

The development comes amid a series of legal challenges by companies named in the investigation.

Madison Communications approached the Delhi High Court in October 2025 seeking to challenge the CCI investigation and alleging procedural violations during the search and questioning of its executives. The agency also sought relief in relation to summons issued to its senior executives.

Publicis’ Indian business, TLG India has separately approached the Delhi High Court over access to case records and the manner in which its entity has been identified in the investigation. In 2025, Publicis had sought access to documents, arguing that without the case records it could not properly understand the allegations or prepare its defence.

More recently, the Publicis matter has centred on the distinction between the global Publicis Groupe brand and TLG India, the Indian legal entity that houses much of the group’s advertising business in the country. The dispute has resulted in further court proceedings around the investigation.

Separately, IBDF disclosed this week that it too had been subjected to a CCI search and seizure operation at its registered office in New Delhi on March 18, 2025. According to the disclosure, the organisation subsequently appointed external lawyers to inspect the CCI’s case records and understood that the investigation related to possible violations of Section 3 of the Competition Act.

IBDF also disclosed that some of its employees had received summons to appear before the DG-CCI and that proceedings relating to summons were before the courts.

CCI examining commercial relationships across ecosystem

The investigation is significant because the alleged conduct under examination goes beyond individual advertising agencies and potentially touches the broader relationship between agencies, advertisers and broadcasters.

The CCI’s original proceedings followed a prima facie assessment that led to an investigation under Section 3 of the Competition Act, which covers agreements or arrangements that have, or are likely to have, an appreciable adverse effect on competition.

BCI flags overbroad rules: Read e4m report

Investigators are understood to be examining a range of commercial interactions, including agency commissions, discounts, pricing practices and arrangements involving broadcasters.

The March 2025 searches were aimed at collecting documentary and electronic evidence that could help investigators reconstruct communications and commercial decisions. The involvement of independent agencies at this stage could allow the regulator to cross-check information obtained from larger agency networks against the experience and records of players that may not have been part of the alleged coordination.

Evidence-building phase could be critical

The latest development indicates that the investigation has moved into an evidence-building phase in which the DG’s office is seeking to corroborate information from multiple sources rather than relying exclusively on the original leniency disclosure.

The notice reviewed by e4m to one of the independent agencies provides an indication of the level of detail being sought by investigators, with questions around a joint meeting and a media buying arrangement for a major advertiser forming part of the information sought.

This is particularly important in cartel investigations, where regulators generally need to establish not merely that similar commercial practices existed, but whether there was an agreement, understanding or coordinated conduct between competitors.

The independent agencies could therefore provide investigators with comparative information on prevailing commercial practices, negotiations and industry norms, while helping establish whether specific conduct identified during the investigation was unusual or part of a wider pattern.

The CCI’s final findings will determine whether the alleged conduct amounted to a contravention of competition law. Until then, the allegations against the agencies and industry bodies remain under investigation.

The investigation, which began with allegations around advertising rates and commercial coordination, is consequently evolving into a broader examination of how agencies, advertisers and broadcasters interact in India’s advertising market.