This House – Implemented Legislation
CMS Sofia Managing Partner Kostadin Sirleshtov highlights recent regulatory changes in Bulgaria’s energy sector. “The new amendments to the Bulgarian Electricity Trading Rules followed the amendments made to the Bulgarian Energy Act mandated by EU Regulation 2019/943 and Directive 2019/944 and entered into force on July 1, 2025,” Sirleshtov explains. “They provide for the abolition of the National Electricity Company as the public electricity supplier, the abolition of the combined balancing groups and the balancing group of the public electricity supplier, and the creation of a new methodology for the formation of balancing electricity prices, which is no longer part of the Bulgarian Electricity Trading Rules.”
In July 2025, North Macedonia passed several laws affecting the banking and finance sector, Law Office Lazarov Managing Partner Dragan Lazarov reports, including “the law on electronic communications, laws on public roads, including amendments to energy, financial support for investments, and further enhancing the regulatory environment.” Among these, Lazarov highlights the “Rulebook on the Security of Personal Data Processing, adopted by the Agency for Personal Data Protection, which is effective from July 1, 2025, and mandates controllers to update their technical and organizational measures for data security, providing guidelines for risk management.”
LCF Law Group Partner Ivan Bondarchuk emphasizes Ukraine’s updated PPP legislation, enacted on July 30, 2025. “Rail, roads, and ports must be rebuilt and upgraded, not only to restore trade routes but also to accelerate EU integration. Ukrzaliznytsia’s plans to expand ‘Euro-gauge’ corridors open opportunities for concessions and PPPs with European operators. Similarly, new logistics hubs, dry ports, and intermodal terminals are critical for ensuring uninterrupted supply chains to and from the EU.”
“Ukraine’s updated PPP legislation, together with the evolution of Production Sharing Agreements in the energy sector, demonstrates a clear move toward internationally recognized models,” Bondarchuk notes. “For investors, this provides predictability, allocation of risks, and arbitration-friendly mechanisms.”
Drakopoulos Associate Isidoros Skavdis highlights that in Greece, Law 5222/2025 entered into force on July 28, 2025, introducing inter alia additional provisions relating to the approval of corporate transformations and subsequently amending the provisions of Law 2515/1997, Law 1969/1991, and Law 4002/2011.” Specifically, under the new law, Skavdis explains that “corporate transformations, including mergers, spin-offs, and conversions, affecting certain categories of legal entities under the supervision of the Bank of Greece, the Hellenic Capital Market Commission, or the Hellenic Gaming Supervision and Control Commission shall be subject to prior written approval by the relevant supervising authority.” In particular, “corporate transformations involving leasing companies, factoring companies, electronic money institutions, payment service providers, credit institutions, servicers, foreign exchange offices, and microfinance institutions shall henceforth be subject to prior written approval of the Bank of Greece.” On top of that, he says that “the Hellenic Capital Market Commission is now responsible for approving corporate transformations of Investment Services Firms, Mutual Fund Management Companies, Alternative Investment Fund Managers, and Investment Intermediation Firms.” Finally, Skavdis says that “Hellenic Gaming Supervision and Control Commission is now responsible for also approving any corporate transformations of companies holding licenses to conduct or operate gambling activities within the territory of Greece, irrespective of the type or scope of such licenses.”
This House – Reached an Accord
Lazarov also highlights the upcoming capital market reforms set to take effect in September 2025. “The capital market in the Republic of North Macedonia is on the threshold of significant changes following the enactment of two key laws that modernize the regulatory framework and align domestic standards with those of the European Union – the Law on Financial Instruments and the Law on Prospectus and Transparency Obligations of Issuers, both starting to apply at the end of September 2025,” he says. “The Securities and Exchange Commission has published a number of bylaws, and others are being prepared. The adjustment period for all institutions that are governed by the new laws is 12 months, and most of them, especially the banks, have started preparations. We are happy to see a dedication to the process, driven by forward-looking expectations for achieving compatibility with European counterparties, opening up new possibilities for more business.”
As for North Macedonia’s energy sector, Law Firm Ana Kolevska Partner Ana Kolevska notes that in early August, “the Ministry of Energy, Mining and Mineral Resources of North Macedonia adopted significant amendments to the Rulebook on Renewable Energy Sources. Prosumers got higher thresholds for their power plants with up to 10-kilowatts for householders and 70-kilowatts for companies and administrative buildings.”
On the other hand, Kolevska stresses, “wind developers are now facing a new layer of complexity in their projects’ exploratory phase. Wind energy exploration is now subject to new regulatory requirements and permitting rules. This introduces broader implications, requiring preliminary technical analysis of the location where the wind park is intended for construction. The rulebook prescribes specific content of the analysis, particularly regarding the wind park location and the measurement equipment, as well as particular rules of presentation of the parameters. Calculations of the measurement location’s surface area and area of measurement have been amended, and minimum distances between project areas have been increased.”
“By assuming competence for permitting wind potential measurement from the former Energy Agency, the Ministry of Energy, Mining, and Mineral Resources has increased its diligence in this area, imposing the obligation for more frequent (monthly) delivery of raw measurement data from developers,” Kolevska points out.
The Verdict
Peterka & Partners Partner Adela Krbcova highlights a Czech Supreme Court ruling from July 17, 2025. A recent decision “clarifies that an employer is not obliged to make a purely formal offer if it is aware of the employee’s previous negative feedback,” she explains.
“A manager made it clear to his CEO that he had no interest in a position lower than the level of director,” Krbcova says. “When he was subsequently recalled from his managerial post, his employer, aware of his standpoint, served him with a termination notice without offering him another position. The manager claimed that such termination was invalid. Was he right?”
“According to the Czech Labor Code, when a manager with a recall and resignation clause in their employment contract is recalled from their office, their employment does not end, and they must be offered another post that meets certain criteria,” Krbcova adds. “Only if there is no such post, or if the employee refuses it, is there a reason for termination, and may the employment be ended for ‘fictional redundancy.’ Thus, the fulfilment of the duty to offer is a precondition for a valid termination notice in these cases.” In practice, she says, “refusal of the new post usually follows the offer. However, it may be the case that, even before the offer is made, it is clear that the employee would refuse or would only be willing to perform a post that the employer is unable to offer.”
Following the new court ruling, Krbcova explains that “the necessary condition for fictional redundancy, consisting of the employee’s refusal, is thus fulfilled even if no new offer was made after the recall, and the employer may issue the termination notice immediately. Proceeding otherwise would be mere formalism.”
LCF Law Group Partner Iryna Kobets points to a Ukrainian Supreme Court decision on the use of AI in contract interpretation. “In July 2025, the Supreme Court reviewed a case where the central issue involved the interpretation of provisions in a land lease agreement, specifically concerning the possibility of amending the rental fee terms,” she says. “Within this context, the Supreme Court – at the cassation level – for the first time addressed the admissibility of AI-generated information as evidence in judicial proceedings.”
“The respondent, seeking to overturn the findings of the court of first instance, filed a motion before the appellate court to consider responses generated by two AI systems: Grok (developed by xAI) and ChatGPT (developed by OpenAI). The respondent argued that these responses could support an alternative interpretation of certain contractual provisions. However, the appellate court denied the motion,” Kobets adds. “The respondent then filed a cassation appeal, asserting that the evidentiary review was incomplete due to the court’s refusal to examine the AI-generated outputs.”
“The Supreme Court emphasized that artificial intelligence may serve as a useful and auxiliary informational tool within the judicial system, but it cannot replace the role of judges or the established principles of relevance, admissibility, and reliability of evidence as defined under procedural law,” Kobets explains. “The court stated that judicial decision-making – whether explicit or implicit – must be carried out solely by judges. This function cannot be delegated or fulfilled by technological means. The autonomy of the judiciary must be preserved even when employing advanced digital tools.”
“This judgment marks the first Supreme Court decision on the merits of a commercial dispute in Ukraine that provided a legal assessment of arguments concerning the necessity of analyzing AI-generated positions during judicial review,” Kobets adds. “While the use of AI-based insights as an alternative informational source is expected to evolve, for the time being, such technology is regarded strictly as a supplementary tool that lacks procedural weight in substantiating or refuting facts within a case.”
In the Works
Sirleshtov points to a major project underway in Bulgaria. “In July 2025, Renalfa IPP boosted its EUR 1.2 billion investment program in photovoltaic, battery electricity storage systems, and wind projects across CEE, with a focus on Bulgaria by securing a EUR 315 million club loan facility led by the EBRD and backed by an InvestEU loss guarantee. Renalfa IPP, a joint venture between the Bulgarian Renalfa Solarpro Group and Rgreen Invest, is developing a portfolio of 1.6 gigawatts of generation capacity and 3.3 gigawatt-hours of BESS, of which more than 655 megawatts are operational and over 550 megawatts are under construction.”
Forgo, Damjanovic & Partners Managing Partner Zoltan Forgo draws attention to the acceleration of Hungarian military transactions. “The state-owned N7 Holding Zrt. will merge its state-owned military assets into a joint venture with a private company, 4iG Ur es Vedelmi Zrt., owned by 4IG Nyrt.”
According to Forgo, “as the first step, N7 Holding Zrt. established N7 Defence Zrt., after which N7 Holding Zrt. will contribute its nine shareholdings in military subsidiaries (mostly factories and development plants) as in-kind contributions to N7 Defence Zrt. In the second step, 4iG Ur es Vedelmi Zrt. will acquire a majority share (75% + 1 vote) in N7 Defence Zrt., while the Hungarian state (through N7 Holding Zrt.) will retain only a minority share (25% -1 vote).”
Forgo adds that in July, “4iG Ur es Vedelmi Zrt. continued its expansion by signing a non-binding agreement to acquire a 63% share of HeliControl Kft. (one of Europe’s leading helicopter maintenance companies), and signed a cooperation agreement with Kazakhstan’s state-owned space company, Kazakhstan Gharysh Sapary, and with the United Arab Emirates’ defense technology giant, EDGE Group.” Moreover, “the 4IG Nyrt. and the Israeli state-owned defense industry company Aerospace Industries Ltd. submitted a joint debt settlement offer for the settlement of the bond debt of Space-Communication Ltd., an Israeli publicly traded company operating and developing AMOS satellite systems,” he points out. “Under the debt settlement plan, Aerospace Industries would acquire an 80% share and become the controlling shareholder, while 4iG Nyrt. would retain its 20% share and remain a strategic partner of Space-Communication.”
Regulators Weigh In
Sirleshtov notes that in July 2025, “both Bulgarian transmission system operators, ESO (for electricity) and Bulgartransgaz (for natural gas), presented their respective Ten-Year Network Development Plans (TYNDP). The TYNDP for Bulgargaz envisages that the Bulgarian natural gas consumption will almost double by 2034, thus focusing on the necessary investments in the natural gas transmission network. The TYNDP for ESO provides for the planned developments, including a new 400-kilovolt ring and major investments in the 110-kilovolt network. The ESO also confirms that it has technical solutions for the development of the electricity transmission network, after the connection of the 2,400 megawatts of nuclear capacity at Kozloduy NPP and the 2,000 megawatts of nuclear capacity at the site of Belene NPP.”
Redcliffe Partners Partner Yuriy Terentyev points to recent competition law developments in Ukraine, noting that “the Antimonopoly Committee of Ukraine (AMCU) has adopted two notable decisions in the pharmaceutical sector, highlighting its focus on unfair competition cases linked to misleading product claims.”
“In the first decision, the AMCU imposed a fine of UAH 5.4 million on Hledfarm Ltd, and ordered the company to cease disseminating misleading information about its dietary supplement Sakhnil,” Terentyev says. “The committee found that the product had been advertised with claims suggesting therapeutic effects that could not be substantiated. Such practices were deemed capable of misleading consumers and distorting competition in a highly sensitive market. Hledfarm was obliged to stop using the disputed claims and ensure that future communications meet the standards of accuracy required under Ukrainian law.”
In a parallel decision, Terentyev notes, “the AMCU fined Ilan Farm UAH 2.2 million for engaging in unfair competition by presenting misleading information about the characteristics and effectiveness of its products. Importantly, the decision records that the sanction was reduced in light of the company’s cooperation with the investigation and the discontinuation of the conduct in question. This may signal a growing willingness by the AMCU to apply ‘settlement-like’ considerations in competition enforcement, thereby encouraging undertakings to mitigate liability through constructive behavior during proceedings.”
“These rulings confirm the AMCU’s vigilance in sanctioning misleading claims, yet they also highlight structural limitations,” he points out. “Investigations are often lengthy, meaning corrective measures come long after the contested campaigns have influenced consumer choice. Moreover, many such disputes arise from regulatory grey zones in the marketing of dietary supplements and borderline products, where sectoral legislation is less stringent than for registered medicines. In this context, the AMCU’s advocacy function remains underused: instead of promoting clear guidance and inter-agency coordination to prevent recurrence, enforcement remains largely reactive. A stronger emphasis on advocacy could reduce uncertainty, enhance compliance, and ultimately strengthen consumer protection in Ukraine’s pharmaceutical markets.”
AECO Law Partner Cagri Cetinkaya draws attention to the Turkish Data Protection Authority’s report outlining recent enforcement actions and guidance statistics. “According to information released on Turkiye’s official news agency Anadolu Ajansi, August 4, 2025, the Turkish Data Protection Authority (Turkish DPA) has, since its establishment in 2017, received 1,793 personal data breach notifications, of which 376 were published on its website, and imposed administrative fines totaling approximately TRY 1.139 billion (around EUR 29 million),” Cetinkaya says. “Also, the Turkish DPA has issued 1,287 legal opinions, approved 13 undertakings for cross-border data transfers, and received 2,716 standard contracts for such transfers. To guide data controllers and data subjects, the Turkish DPA has published 331 decisions and nine principal decisions on its website and has processed 50,770 out of 52,749 applications received to date. The Turkish DPA has also developed 54 guides, brochures, and informational documents, along with multiple awareness videos.”
“The published statistics demonstrate the active regulatory work by the Turkish DPA and its eagerness to spread data protection awareness, within the rather short time span that it has been active in comparison with its EU equivalents,” Cetinkaya adds.
Nestor Nestor Diculescu Kingston Petersen Partner Anca Diaconu underscores a landmark mobile merger clearance in Romania. “The Romanian Competition Council (RCC) has conditionally cleared the transactions under which Vodafone Romania S.A. intends to acquire Telekom Romania Mobile Communications S.A., while Digi Romania S.A. would acquire certain assets of the same company,” she says. “This deal marks the first major mobile telecom merger in Romania, reducing the market from four to three operators. The approval is subject to a suite of commitments addressing pricing, quality, access, and network investments.”
“Initially, the RCC identified eight areas of concern in relation to the merger,” Diaconu explains. “Among them was the potential for a decline in service quality, particularly in the form of reduced average mobile data download speeds. At the same time, the authority questioned whether the spectrum resources that would be consolidated in the hands of the acquiring companies would be fully utilized.”
“The competitive impact on other market participants also featured prominently in the regulator’s analysis,” Diaconu continues. “Orange Romania S.A. faced potential restrictions on its access to co-location services on mobile telecommunication sites of Telekom Romania Mobile Communications S.A. Moreover, the terms under which Telekom provided hosting services to Veridian Systems SRL could have been adversely affected. Further concerns related to pricing as well as service availability. More structurally, the regulator was concerned about the wholesale market for mobile access and call origination services, following Telekom’s departure as a supplier.”
According to Diaconu, “the four-player market in Romania has traditionally been considered the ‘ideal’ status quo in terms of competitiveness, thus shifting away from it marks a landmark decision. As regards coverage, approximately two million Telekom subscription customers were impacted, making the deal one of the largest consumer transitions overseen by the regulator and placing it on a pedestal along with transactions such as Mega Image/Profi.”
Finally, DLA Piper Hungary Partner Zoltan Kozma flags an update under Hungary’s Cybersecurity Act, “including the requirement for in-scope entities to conclude a contract with a registered cybersecurity auditor by August 31, 2025, and to complete their first audit by June 30, 2026.” According to him, “while the law itself does not require entities to notify the supervisory authority about the conclusion of the auditor contract, recent practice shows that the authority is actively requesting such confirmation. In formal communications addressed to in-scope entities, the Cybersecurity Directorate of the Supervisory Authority for Regulated Activities requests that the entities submit proof of the auditor contract via e-Paper by September 15, 2025.”
“This indicates a shift toward proactive enforcement and monitoring, even in areas where the legislation remains silent on procedural obligations,” Kozma says. “Entities falling under the scope of the Cybersecurity Act should therefore be prepared not only to comply with the statutory deadlines but also to respond to direct requests from the authority, including documentation and confirmations.”
This article was originally published in Issue 12.7 of the CEE Legal Matters Magazine.