That seems problematic. It appears to be equivalent to financial punishment for appealing a ruling. And in the EU competition law is enforced via the rule of es

That seems problematic. It appears to be equivalent to financial punishment for appealing a ruling. And in the EU competition law is enforced via the rule of essentially one woman and her department - competition laws are so vague that she effectively has the power to levy huge fines at will, unchecked by anything except the right to appeal, because she doesn't have to prove anything in court to begin with. If the Commission is now able to levy such massive fines and lower them if you promise not to appeal, in a binding way, then they can simply make whatever sum they pull out of thin air 10% higher, give a 10% "reduction" for cooperation, and that's effectively a second fine for appealing the first.