CEELM: Were there any new laws or amendments in 2025 that significantly affected competition oversight in Ukraine?
Denys Medvediev: In 2025, the Antimonopoly Committee of Ukraine (AMCU) consolidated its return to its pre-full-scale war operational capacity. Merger review timelines became more predictable, initial rejection rates declined, and enforcement activity intensified across priority sectors. A defining feature of the year was not so much new legislation as the active enforcement of reforms adopted in 2023-2024. In particular, the AMCU applied its revised leniency framework in several cases, signaling that the instrument is becoming operational in practice and reflecting a broader shift toward EU-style enforcement tools and a deterrence-based policy.
Merger control remained dynamic. A notable development was the court annulment of the AMCU’s Phase II clearance in the CRH cement transaction (CRH Ukraine/Dyckerhoff Cement Ukraine). The ruling confirmed that Ukrainian courts may scrutinize not only procedural compliance but also the substantive assessment of mergers, increasing litigation risk in complex transactions and potentially encouraging third-party challenges. Gun-jumping enforcement was also prominent, with fines imposed on both Ukrainian and foreign companies. In a high-profile case, a beverage producer was penalized over EUR 800,000, marking the largest gun-jumping fine imposed in 2025.
The AMCU further increased fines for informational violations (i.e., failure to provide information, provision of incomplete information, or provision of misleading information), creating incentives for undertakings to cooperate fully rather than conceal additional breaches. Unfair competition enforcement, particularly concerning deceptive health-related claims, became one of the main areas of activity. Fines were imposed across the pharmaceuticals, dietary supplements, cosmetics, bottled water, and food additives sectors, with a EUR 200,000 penalty in June signaling stronger deterrence. Enforcement increasingly relied on expert input from the Ministry of Health.
Internationally, 2025 was marked by recognition of institutional progress. Reports by the European Commission and the OECD acknowledged the AMCU’s advancement toward the EU acquis communautaire and OECD standards, reinforcing its reform trajectory.
CEELM: Were there any new laws or amendments in 2025 that significantly affected competition oversight in Ukraine?
Denys Medvediev: Most structural legislative reforms were introduced in 2023-2024, including settlement procedure, strengthened leniency, clearer investigation deadlines, and refinements to merger control. In 2025, the key development was the practical implementation and enforcement of these instruments rather than the adoption of entirely new frameworks.
In March 2025, the pharmaceutical sector underwent significant regulatory changes following high-level political initiatives. New legislation introduced prescriptive rules affecting distributor markups and market share limitations. Although sector-specific, these measures have direct competition implications and increased the AMCU’s role in monitoring structural market conditions.
In parallel, the authority continued developing proposals to abolish the prior approval regime for concerted practices, clarify the application of structural remedies, and introduce periodic penalty payments for ongoing infringements. While not fully enacted in 2025, these initiatives signal continued convergence with EU competition architecture and the gradual operationalization of best practices.
CEELM: Which sectors or types of violations attracted the most competition authority’s attention in 2025, and what stood out as particularly notable?
Denys Medvediev: Pharmaceuticals remained the most intensively scrutinized sector. The AMCU’s focus extended across the supply chain: a cartel investigation against two major distributors resulted in heavy fines of around EUR 50 million each; a formal probe was launched into five leading pharmacy chains for alleged concerted conduct; and multiple unfair competition cases concerning misleading health claims also resulted in fines.
At the same time, deceptive therapeutic or health-related marketing claims were pursued across a broader range of industries (including cosmetics, bottled water, food additives, and other FMCG products), reflecting a cross-sector policy priority rather than a pharma-only campaign.
The food and beverage sector also saw significant activity, including fines for misleading origin claims and a high-profile gun-jumping case. As often happens, once the AMCU focuses on a sector, its information requests generate a chain reaction of related compliance issues.
The financial sector attracted attention through softer enforcement tools. The AMCU issued recommendations to banks regarding the transparency of cashback programs, signaling potential future scrutiny of loyalty schemes and consumer-facing practices.
Overall, 2025 was characterized by sector-focused enforcement campaigns, increased sanctions for informational violations, the operationalization of leniency, and visible alignment with EU and OECD standards. Proactive compliance (particularly in marketing claims, merger notifiability, and cooperation with the authority) became critical in an environment of more assertive and structured enforcement.
CEELM: Looking ahead to 2026, how do you expect trends in enforcement and sector focus to continue or evolve?
Denys Medvediev: In 2026, the AMCU is expected to continue along the enforcement trajectory established in 2025, maintaining sector-focused campaigns alongside broader market oversight. Pharmaceuticals, FMCG, and health-related claims will remain priority areas, while the authority is likely to increase scrutiny of socially sensitive and strategic markets, including fuel, energy, port services, digital platforms, and essential goods linked to reconstruction and defense.
Methodologically, the AMCU will consolidate guidance on market definitions and dominance assessments and support the implementation of legislation under the second stage of competition law reform. Overall, 2026 is likely to feature structured, deterrence-driven enforcement aligned with Ukraine’s economic and social priorities, blending preventive guidance, reactive investigations, and targeted sectoral oversight. Businesses should anticipate continuity in focus areas and evolving enforcement tools, underscoring the importance of robust compliance strategies.
This material was originally published in CEE Legal Matters Issue 13.1.