中国出台的《反垄断法》中出现了很多亮点,其中之一是学习了美国,日本,欧盟等国家,出现了有关宽恕制度的条文。但是,我国的法条中对此的规定过于笼统,抽象,没有具体的有关实施标准,应用步骤等详细规定,这对我国《反垄断法》的充分实施产生了阻碍。本文将借鉴国外一些国家法律中有关宽恕制度的规定,通过对几个国家相关制度的比较,进而探求我国宽恕制度规定中一些可以改进的地方。 There are many bright spots in the “Anti-monopoly Law” promulgated by China. One of them has been the study of the United States, Japan, the European Union and other countries. There have been provisions on the system of forgiveness. However, the provisions in our law are too general and abstract. There are no specific provisions on the implementation of standards and application procedures, which hinder the full implementation of our Anti-Monopoly Law. This article will draw lessons from the provisions of some countries’ laws on forgiveness and compare the related systems in several countries so as to explore some areas that can be improved in our country’s system of forgiveness.