AutoSmart GuidebooksWhat this guidebook covers
The General Authority for Competition (GAC) has already taken car agents to court, and its inspectors arrive unannounced. Obstructing a raid, by refusing entry or hiding or deleting files, carries its own fine, on top of the fines for price-fixing, market sharing and abuse of dominance.
This guidebook sets out 17 standards in the order you need them: before a raid (procedures, contact persons, training, self-assessment), during it (conduct, cooperation, no deletion, document and electronic copies) and after it (reporting and follow-up).
The 17 competition law standards
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
CMP-001Before a raid: dawn-raid procedures available and known7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- The company's dawn-raid procedure, checklists and SOPs are physically available at the site, and staff know they exist.
- What it can cost
- The SOP costs nothing. An employee who doesn't know it and blocks the door can cost the company up to SAR 5 million, before the real investigation even starts.
- Evidence
- Photo of the SOP at site + notes of staff answers
CMP-002Before a raid: dawn-raid contact persons designated24 hours
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Named people (usually Legal and Compliance, plus a site deputy) are designated to be called the moment GAC officials arrive, with names, emails and phone numbers on file.
- What it can cost
- Without a named contact, the most junior person on shift handles GAC alone. One refusal or deleted file becomes an obstruction finding of up to SAR 5 million.
- Evidence
- Contact list + test call record
CMP-003Before a raid: dawn-raid preparedness before inspection7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- The site manager knows the procedure cover to cover, staff and security know their roles, and computers hold only work files.
- What it can cost
- MediServ was fined SAR 13 million for keeping GAC officers from their work. It can start with a guard who was never told what to do.
- Evidence
- Signed read-confirmation + photo of guard card + spot-check notes
CMP-004Before a raid: contact persons displayed at reception and gate72 hours
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Reception and the security office at the gate display a sign with the names and office and mobile numbers of the people to call when government officials visit.
- What it can cost
- A wrong number on the wall means minutes lost while officers wait, and every minute of delay can be read as obstruction: up to SAR 5 million.
- Evidence
- Photos of both signs + comparison with contact sheet
CMP-006Before a raid: contact sheet checked and updated24 hours
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- The dawn-raid contact sheet is checked regularly, shows the date of its last update, and a copy is uploaded to the system.
- What it can cost
- A dead number means no Legal support while officers search. Whatever staff do alone, the company answers for: up to SAR 5 million.
- Evidence
- Contact sheet showing the update date + system screenshot
CMP-008Before a raid: site staff trained on dawn raids30 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Site staff have been trained on dawn raids by the designated contact persons, with the trainer's name and training date recorded.
- What it can cost
- Untrained staff under pressure do exactly what the law punishes: block, hide or delete. Each is an obstruction finding of up to SAR 5 million.
- Evidence
- Training record with trainer, date and attendance
CMP-009Before a raid: dawn-raid procedures known and accessible72 hours
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Responsible staff know which procedure applies in a dawn raid and can find it in seconds, on paper or on the shared drive.
- What it can cost
- Every minute spent searching is a minute officers wait. Delay can be read as obstruction: up to SAR 5 million.
- Evidence
- Time taken + screenshot of folder location
CMP-016Before a raid: documents to copy during a dawn raid7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Contact persons know the fixed list of documents they must copy during a raid: the GAC decision, officers' IDs, their report and everything seized.
- What it can cost
- Without the GAC decision and report, Legal can't tell what you're accused of, and a price-fixing finding is up to 10% of annual sales.
- Evidence
- Copy checklist + mock-raid file
CMP-017Before a raid: competition law self-assessment30 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Art. 5 (anti-competitive agreements: price-fixing, market sharing, bid rigging) · Art. 6 (abuse of dominance) · Penalties: Art. 19
- What we check
- The site has completed its latest competition-law self- assessment, checking pricing, territories, rival contacts and tenders.
- What it can cost
- One WhatsApp group agreeing prices with rival dealers can cost up to 10% of annual sales, doubled if it happens again, published in the press at your cost.
- Evidence
- Self-assessment report + action log
CMP-005During a raid: conduct during a GAC inspection7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M · Officials' ID and letter of investigation checked under Art. 39 · Truthful answers: Art. 7
- What we check
- Staff welcome officials calmly, check their IDs and investigation letter, call Legal at once, answer only what they know, and stamp and copy everything officials take.
- What it can cost
- Refuse entry, argue or stall, and the company faces up to SAR 5 million for obstruction on top of whatever GAC came to investigate: up to 10% of sales.
- Evidence
- Mock-raid scorecard + copies of the forms used
CMP-010During a raid: cooperation with authority searches7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Staff understand they must let GAC inspectors search their office, laptop, mobile phone and documents at work, even when they contain personal or confidential information.
- What it can cost
- One employee hiding a phone can turn an inspection into an obstruction case: up to SAR 5 million, plus whatever GAC finds on the phone later.
- Evidence
- Staff answers + SOP section reference
CMP-011During a raid: no deletion of documentsImmediate
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M (concealing or destroying documents)
- What we check
- Staff understand that no document, file, email or chat may be deleted or destroyed once a raid has started.
- What it can cost
- A deleted file is obstruction (up to SAR 5M) and evidence that something was worth hiding. GAC treats it as exactly that.
- Evidence
- Staff answers + IT legal-hold procedure
CMP-012During a raid: handling questions outside own knowledge7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M (false information) · Truthful answers: Art. 7
- What we check
- Staff know not to guess or estimate. If a question is outside their knowledge or responsibility, they refer officers to the person responsible.
- What it can cost
- A casual guess about margins or discounts can open a price-fixing case. In Dec 2025 that cost 13 companies SAR 36.9 million.
- Evidence
- Staff test notes + SOP responsibility list
CMP-013During a raid: responding to market share questions7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M · Abuse of dominance: Art. 6 · Penalties: Art. 19
- What we check
- Staff know not to estimate market share. Questions about position in the market are referred to Legal and answered in writing.
- What it can cost
- "We own this city" can make you dominant in GAC's eyes, and abuse of dominance carries up to 10% of annual sales or SAR 10M.
- Evidence
- Staff test notes + SOP reference
CMP-014During a raid: handling requests for document copies7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- When officers ask for copies, staff provide them, mark each page "Confidential", sign and stamp it, and keep a complete copy for the company.
- What it can cost
- Refuse a copy request and it's obstruction: up to SAR 5 million. Hand over papers without keeping copies and you're defending blind.
- Evidence
- Copy log template + photo of stamp + mock-raid set
CMP-015During a raid: handling requests for electronic copies7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M
- What we check
- Electronic documents requested by officers are handed over on CD/DVD (not USB), and an identical copy is kept by the company.
- What it can cost
- Delay or refuse an electronic copy and it's obstruction: up to SAR 5 million. Hand it over without a copy and you can't check what GAC is relying on.
- Evidence
- Export procedure + copy log + photo of media
CMP-007After a raid: post-inspection reporting and follow-up7 days
- The law
- Competition Law (Royal Decree M/75 of 29/06/1440H) and its Implementing Regulations · General Authority for Competition (GAC) · Readiness control linked to the Obstruction-of-inspection provision: fine up to 5% of total annual sales, max SAR 5M · Substantive penalties: Art. 19
- What we check
- Right after officials leave, the site completes the dawn-raid information sheet, sends every document to Legal and books a briefing on next steps.
- What it can cost
- Ignore the aftermath and you lose the window to act. A rival that reports first may get immunity while you face up to 10% of annual sales.
- Evidence
- Information sheet + email to Legal + briefing invite
How to run a dawn-raid readiness audit in Saudi Arabia, step by step
- Confirm what applies. Every site can be raided, so the audit covers every showroom, workshop, parts store and head office; N/A needs Legal's approval.
- Walk the site, standard by standard. Score each checkpoint Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Ask reception and gate staff what they would do if GAC arrived, and check the procedure and contact sheet are on site.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: the dawn-raid procedure on site, the contact sheet with its update date, training records and the self-assessment.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Dealer principals
- Legal and compliance teams
- Site managers
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
