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Selected cases

Federal Court of Australia · [2026] FCA 356

ACCC v Qteq

A Federal Court penalty decision about attempted cartel conduct in tendering, competitor discussions, non-compete proposals and personal...

Federal Court of Australia26 Mar 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

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Quick read

  • Cartel risk is not limited to signed price-fixing agreements.
  • A Federal Court penalty decision about attempted cartel conduct in tendering, competitor discussions, non-compete proposals and personal executive liability.

Use this to check

  • Cartel liability can arise from attempted arrangements, not only completed agreements.
  • Tender discussions with competitors need a documented legitimate purpose and tight boundaries.
  • Non-compete and non-circumvention clauses can become cartel evidence if they restrict competition in the wrong setting.

Decision snapshot

  1. 1

    What happened

    • Qteq supplied goods and services to well operators in the coal seam gas industry.
    • The ACCC alleged that Qteq and its senior executive Simon Ashton tried to reach arrangements with competitors or likely competitors about tendering and future competition.
    • The earlier liability judgment found five attempted cartel contraventions.
    • They included proposals connected with QGC tenders, an attempted arrangement with Pro-Test about gauge works and Santos-related work, and attempted non-compete arrangements involving Easternwell.
  2. 2

    What the court had to decide

    • The Federal Court had to decide the penalties and ancillary orders after earlier liability findings that Qteq had attempted to enter arrangements containing cartel provisions and that Mr Ashton had attempted to induce competitors or likely competitors to enter them.
    • The penalty issues included deterrence, whether the conduct should be grouped as one course of conduct, the effect of Qteq's post-hearing business sale and whether Mr Ashton should be barred from using insurance to pay his penalty.
  3. 3

    What the court decided

    • The Court ordered Qteq to pay $5 million and Mr Ashton to pay $1 million to the Commonwealth.
    • It also ordered Mr Ashton not to pursue or accept indemnity under an insurance policy for the personal penalty, required payment within 60 days and ordered the respondents to pay the ACCC's costs for the successful parts of the proceeding.

Practical impact

Practical read

  • Cartel risk is not limited to signed price-fixing agreements.
  • A failed attempt to divide work, limit a competitor's tender or stop another business competing can still attract serious penalties, and directors may be personally exposed.

Useful next steps

  • Cartel liability can arise from attempted arrangements, not only completed agreements.
  • Tender discussions with competitors need a documented legitimate purpose and tight boundaries.
  • Non-compete and non-circumvention clauses can become cartel evidence if they restrict competition in the wrong setting.
  • Directors and senior managers can face personal penalties for inducing attempted contraventions.
  • Train sales, tender and executive teams not to discuss bid limits, customer allocation or no-compete promises with rivals.

Practical read

This case is a strong warning for businesses that tender, subcontract or partner with competitors. The commercial setting was technical, but the core story is simple. Qteq wanted to protect its position in coal seam gas work. The Court found that it tried, through conversations, dinner meetings, emails and draft agreements, to get competitors or likely competitors to limit how they competed.

The case matters because the arrangements were attempts. The Court did not need a neat signed cartel contract before penalties were available. It looked at what was proposed, who was involved, what the tender context was, and whether the proposed arrangement would restrict competition. It also treated personal involvement seriously. Mr Ashton was penalised separately and was not allowed to use insurance to cover the penalty.

For small and medium businesses, the practical line is clear. Joint tendering, subcontracting and supplier discussions can be legitimate, but the purpose and wording must be clean. Do not ask a competitor not to bid, to bid for only a slice of the work, to stay out of a customer account, or to agree not to compete after receiving training or technical know-how. If a collaboration needs exclusivity, get advice before the conversation turns into a competition problem.

Checks to run

Key points

  • Train sales, tender and executive teams not to discuss bid limits, customer allocation or no-compete promises with rivals.
  • Use written collaboration protocols before joint tenders, referral deals or competitor subcontracting discussions.
  • Have lawyers review non-compete, non-circumvention and exclusivity clauses where competitors are involved.
  • Keep legitimate technical collaboration separate from any suggestion that a competitor should stay out of a market.
  • Check management liability insurance does not create false comfort about personal penalty exposure.

Key takeaways

  • Cartel liability can arise from attempted arrangements, not only completed agreements.
  • Tender discussions with competitors need a documented legitimate purpose and tight boundaries.
  • Non-compete and non-circumvention clauses can become cartel evidence if they restrict competition in the wrong setting.
  • Directors and senior managers can face personal penalties for inducing attempted contraventions.

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