Redcliffe Partners Partner Denys Medvediev says that “Ukraine’s merger control activity closed 2025 on a notably different footing than it began.” He notes that “the Antimonopoly Committee’s freshly published annual report points to a regulator operating at significantly higher volume and with sharper enforcement instincts – and a few patterns that any M&A practitioner advising on Ukrainian transactions should take note of.”
According to Medvediev, “the volume increase is considerable.” He explains that “the AMCU processed 1,315 merger filings in 2025, against 547 the year before – a 140% rise that requires some context to interpret correctly. Roughly 600 of those filings concerned individual petrol station acquisitions. Ukrainian law treats the acquisition of each station as a separate concentration, meaning a single commercial deal can generate multiple notifications. The UPG fuel group alone accounted for over 500. Adjusting for the fuel retail effect, the underlying M&A market still shows meaningful growth, which is worth noting given that Ukraine remains under martial law.”
He adds that “more telling than the volume, however, is how the AMCU managed the caseload. Of 1,077 substantively reviewed deals, 94.8% were cleared without deeper investigation – 703 under the standard procedure and 66 under the simplified one. Thirty Phase II proceedings were opened and 63 preliminary conclusions issued, up from 51 in 2024, reflecting a proportionate approach where the facts call for closer attention. The sectoral breakdown of approvals adds further texture: wholesale and retail trade led at 21%, followed by financial services and real estate at 19%, and industry at 16%.”
Taken together, Medvediev says, “the 2025 figures paint a picture of an institution that has grown steadily into its role – handling larger caseloads, processing routine transactions without unnecessary friction, and applying genuine rigor where it matters. For a regulator operating under wartime conditions, that is a meaningful achievement.”
This article was originally published in Issue 13.2 of the CEE Legal Matters Magazine.