The rapid consolidation of artificial intelligence capability among a small number of well resourced technology companies has placed unprecedented strain on merger control regimes that were designed chiefly to catch conventional asset and share acquisitions rather than the loose, contractual and often partial arrangements through which control over artificial intelligence talent, data and computing infrastructure is now frequently acquired. This article undertakes a comparative review of how the United States, the European Union and the United Kingdom have responded to that strain. It examines the legal foundations of merger control in each jurisdiction, from Section 7 of the Clayton Act and the 2023 Merger Guidelines in the United States, through the EU Merger Regulation and Article 102 of the Treaty on the Functioning of the European Union, to the substantial lessening of competition test applied under the Enterprise Act 2002 in the United Kingdom. It then turns to recent enforcement practice, including the United Kingdom Competition and Markets Authority's treatment of the Microsoft and Inflection, Microsoft and Mistral, and Amazon and Anthropic partnerships as reviewable mergers, the ongoing scrutiny by the Federal Trade Commission of the Microsoft and Inflection transaction, and the European Commission's conclusion that the Microsoft and OpenAI partnership does not, at least for now, constitute a notifiable concentration. The article also considers the Court of Justice of the European Union's landmark 2024 judgment in Illumina and GRAIL, which sharply curtailed the European Commission's ability to review transactions falling below ordinary notification thresholds. Drawing these threads together, the article argues that artificial intelligence driven acquisitions expose structural gaps common to all three regimes, gaps concerning jurisdictional thresholds calibrated to revenue rather than strategic significance, an underdeveloped doctrine for assessing nascent and potential competition, and an absence of settled tools for evaluating concentration in data, computing infrastructure and technical talent. It closes with a set of recommendations for modernising merger control to meet these challenges without abandoning the legal certainty that transaction parties reasonably require.

Dr. Yuvraj Pandharinath Jadhav, "A Comparative Review of Merger Control in an Era of Heightened Scrutiny of Artificial Intelligence Driven Acquisitions" International Journal of Humanities and Social Sciences Research Studies, V1(4): Page(108-120) September-October 2026. ISSN: 3139-0854. www.ijhssrs.com. Published by Scientific and Academic Research Publishing.