This House – Implemented Legislation
Highlighting Montenegrin real estate, Komnenic & Partners Managing Partner Milos Komnenic reports that “the Parliament has recently passed a new Law on the Legalization of Unauthorized Buildings, a long-awaited reform that is reshaping the real estate market. Under this act, owners of residential, commercial, and ancillary buildings without the necessary permits, or with significant deviations from approved plans, are now required to submit applications for legalization. Eligible properties must be visible in aerial and satellite imagery taken in July 2025, registered in the cadaster with settled property rights over the building and the land, while not being constructed on land designated for infrastructure or other public-interest facilities and not exceeding boundary or ownership lines in areas without valid planning documents. Importantly, owners have six months from the law’s entry into force to apply, and failure to do so could result in demolition of the object and the owner’s obligation to pay the annual usage fee until the object is demolished.”
From the market’s perspective, Komnenic stresses that this legislation introduces a major shift. “According to the provisions of the adopted law, properties that have not been legalized cannot be sold, pledged, or utilized for commercial or other activities.” As a result, he says, “real estate activity has seen a temporary slowdown, as notaries must now verify the legal status of properties prior to any transaction.” Additionally, “concerns persist regarding its implementation and its impact on the real estate sector. Bearing in mind that previous attempts to regulate the legalization of unauthorized constructions have repeatedly failed and given the low number of legalized buildings under the former Law on Spatial Planning and Construction, it remains uncertain whether the law will be effectively implemented this time or whether, due to administrative inefficiency, it will once again remain merely declarative.”
SOG in cooperation with Kinstellar Managing Associate Ana Arambasic highlights temporary restrictions in the retail sector in Serbia. “On September 1, 2025, the Decree on Special Conditions for Trade in Certain Types of Goods came into force in Serbia,” she says. “The decree prescribes special conditions for conducting trade for a certain type of goods, limitation of margins in wholesale and retail trade, limitation of the total amount of fees, as well as the method of submitting price lists to ensure price transparency, limit excessive profit margins, maintain fair terms of trade, and consumer protection. The decree remains in force for six months. It covers a large number of goods (about 23 product groups, approximately 20,000 individual products), including essential foodstuffs (flour, oil, sugar, bread, pasta, dairy products), household chemicals, hygiene products, and personal care items.”
Arambasic adds that “the maximum retail and wholesale margin (mark-up) is limited to 20%. If a lower margin was in place before the decree came into effect, the lower one must be honored. Certain products, such as fresh fruit and vegetables, meat, coffee, and cocoa, are excluded from the restrictions due to specific market conditions and seasonal/international price fluctuations.” One of the important transparency requirements, according to Arambasic, “is the obligation for retailers (and wholesalers) to provide electronically to the Ministry of Internal and Foreign Trade the valid price lists for goods every Monday during the validity period of the decree. Fines for legal entities might amount to RSD 300,000.”
Peterka & Partners Partner Adela Krbcova points to recent changes in the Czech labor code. “Based on an amendment to the Czech Employment Act, from October 1, 2025, foreign employees, including EU employees, must be notified to the competent regional Labor Administration before they start working,” she explains. “This means that, for example, if an employee starts working on October 15, the notification must be delivered on October 14. Previously, notification of the starting date was still acceptable. Now, if an employer fails to notify the start of employment and this is discovered, it could be fined up to CZK 3 million for what is known as ‘unnotified work,’ contrary to a fine of only up to CZK 120,000 according to the previous regulation. If the notification is submitted within five days of the starting date, the inspection authority may dismiss the case if the inspection has not yet begun. Either way, the decision to dismiss the case will be recorded.”
This House – The Latest Draft
As for the labor in Poland, in August 2025, the Polish government presented a package of draft legislative acts, according to Wolf Theiss Associate Marta Wasil, including an amendment to the Act on the National Labor Inspectorate (PIP), an amendment to the Act on the Social Insurance System, an amendment to the Act on Trade Unions and the Act on the Provision of Information to Employees and Conduct of Consultations with Employees, and an amendment to the Labor Code.
“The most significant change proposed by the amendment to the PIP is the extension of the powers of labor inspectors,” she notes. “They will be authorized to issue administrative decisions confirming the existence of an employment relationship when a civil law contract has been formally concluded, but the work is actually performed under conditions characteristic of employment. These decisions will be enforceable immediately, meaning the employer must treat the individual as an employee before any appeal is heard in court. The Council of Ministers is scheduled to adopt the draft in the fourth quarter of 2025.”
An amendment to the Act on the Social Insurance System, according to Wasil, “stipulates that the Social Insurance Institution (ZUS) will be responsible for paying sick leave benefits from the first day an employee is out sick. Currently, employers bear the cost of sick pay for the first 33 days of an employee’s absence from work due to illness (or 14 days for employees over 50 years of age), after which the ZUS assumes the obligation. This change is intended to relieve employers of financial and administrative burdens.”
Another amendment “stipulates that communication between trade unions and the employer at the enterprise level, as well as between the works council and the employer, may be conducted in writing, electronically, or in documentary form,” she adds.
Finally, “the key amendment proposed to the Labor Code concerns the definition of ‘mobbing.’ Under the proposed definition, a single incidental act, even if it infringes on an employee’s personal rights, will not qualify as mobbing,” Wasil notes. “To constitute mobbing, the harassment must occur repeatedly or continuously over a certain period. The draft provisions also strengthen victims’ rights to pursue claims.”
AECO Law Partner Cagri Cetinkaya highlights forthcoming changes in Turkiye’s data protection landscape. “According to the Medium-Term Plan (2026-2028) published by the Presidency of the Republic of Turkiye, published in the Official Gazette dated September 7, 2025, the Turkish Data Protection Law will be further amended to align with the GDPR,” he says. “Complementary secondary regulations will also be introduced to ensure consistency with the EU Artificial Intelligence Act. In addition, a National Data Strategy and Action Plan will be launched to strengthen data-driven policymaking while upholding high standards of privacy and security. Public authorities will be expected to modernize their IT systems in accordance with a forthcoming Public Cloud Policy and an updated State Digital Transformation Strategy.”
In August, Serbia’s energy sector saw significant activity. “A public debate was held on the Draft Strategy for the Management of Mineral and Other Geological Resources in Serbia for the Period 2025-2040, with projections extending to 2050,” JPM & Partners Senior Partner Jelena Gazivoda reports. “The strategy attracted the attention of environmental organizations and concerned citizens, particularly in the context of potential lithium exploitation under the Jadar Project.”
In the Works
Turning to Serbia’s nuclear energy plans, “Serbia has intensified activities related to the potential development of strategic partnerships in the field of nuclear energy,” Gazivoda points out. “These efforts follow the completion of a preliminary technical study on the peaceful use of nuclear energy, ahead of the expected lifting of the national ban on nuclear power plant construction in November 2024. As part of this initiative, Serbia signed a memorandum of cooperation with the South Korean company Korea Hydro & Nuclear Power, covering nuclear energy and hydrogen technologies. Additionally, preliminary discussions have commenced with the Russian company Rosatom regarding possible collaboration in the nuclear sector.”
Done Deals
Looking at the energy sector in Bulgaria, CMS Sofia Managing Partner Kostadin Sirleshtov highlights increased transactional activity. “Despite the holiday period, we saw a few landmark deals in August 2025, including Renalfa IPP closing its EUR 1.2 billion investment program in photovoltaic, battery electricity storage systems, and wind projects and quite some regulatory developments, and AB Investment Group finalizing its licensing process before the Bulgarian Energy and Water Regulatory Commission for its 27-megawatt PV and 24-megawatt-hour BESS Albena Solar Project,” he says.
Regulators Weigh In
Nestor Nestor Diculescu Kingston Petersen Partner Anca Diaconu points out that the Romanian Competition Council recently reported a moderate rise in basic food prices. “Following a recent analysis, the Romanian Competition Council (RCC) has reported that prices for basic non-seasonal food products rose by an average of 1.53% in August compared with June, according to data from six major retail chains,” she says. “The increase remained below the level that would be expected solely from the recent VAT increase, suggesting that large retailers and suppliers absorbed part of the cost, says RCC president Bogdan Chiritoiu. The RCC president noted that the market and competition are working, as companies seek to retain customers with attractive pricing, adding that food prices rose less than those of non-food goods and services. He indicated, however, that food prices remain sensitive to additional pressures, including fuel and electricity costs, and underlined the influence of Romania’s inflationary trends and the country’s large budget deficit on prices.”
Overall, Diaconu says that “the food basket – which includes both seasonal and non-seasonal items – fell on average by 4.18% in August compared with June, driven primarily by lower fruit and vegetable prices. The analysis was based on data supplied by major retailers, covering products subject to government emergency ordinances temporarily capping mark-ups on 46 categories of basic food, a measure subject to intense debates. These measures remain in force until September 30, 2025.”
In Bulgaria, “in August 2025, Bulgaria’s electricity transmission system operator (ESO EAD) has published its ten-year network development plan (TYNDP), which was approved by the Bulgarian Energy and Water Regulatory Commission (EWRC), which has made the 400-kilovolt network the backbone of the electricity transmission network in Bulgaria, whose geographical location suggests there will be great commercial interest in using its transmission network for electricity transit,” Sirleshtov reports. “The ESO has technical solutions for the development of the electricity transmission network, after the connection of the 2,400 gigawatts of nuclear capacity at Kozloduy NPP and the 2 gigawatts of nuclear capacity at the site of Belene NPP. TYNDP confirmed that there is a possibility of obtaining ‘synthetic inertia’ from battery energy storage systems, but its contribution to the inertia of the system is limited.”
In August 2025, it was also confirmed that the Bulgarian natural gas consumption is set to “almost double from 28 terawatt-hours to 51 terawatt-hours by 2034, in accordance with the TYNDP of Bulgaria’s natural gas transmission system operator (Bulgartransgaz EAD), as adopted by EWRC,” Sirleshtov adds. “According to the TYNDP, local Bulgarian production of natural gas is expected to increase in step with permits that have been issued for oil and natural gas exploration and production, particularly surrounding discoveries of gas deposits in the Black Sea.”
Forgo, Damjanovic & Partners Managing Partner Zoltan Forgo emphasizes that recently, the Hungarian Government has prohibited the foreign acquisition of a Hungarian-owned dairy company. “Hungary’s Ministry of National Economy announced on September 16, 2025, that the foreign acquisition of Alfoldi Tej Kft., a Hungarian-owned dairy company, has been prohibited,” he says. “The transaction involved a foreign investor – allegedly a Greek consortium seeking to acquire 100% of the shares in Alfoldi Tej Kft., a strategic company within the meaning of point 3 of Section 2 of Government Decree 561/2022.”
“The Minister of Economic Development prohibited the execution of the transaction relying on the ground of ‘national interest’ referred to in Section 8. (1) (b) of the decree,” Forgo says. “According to the government’s statement, the proposed transaction had the potential to cause substantial market disruption in domestic milk production and procurement, as well as high supply security risks due to the company’s significant market share, which accounts for 20% of farmgate purchases of milk. As a response to the government’s veto, Alfoldi Tej Kft. offered to sell its quotas to the Hungarian State under the same conditions. The offer is currently being reviewed by the authorities.”
“It is worth noting that, based on subsequent press releases, the target’s decision to sell its quotas to the foreign investor was based on its dire financial state, associated with its lagging product development and the price policies implemented by the Hungarian Government,” Forgo adds. “As evidenced by this case and two other notable veto decisions (on the acquisition of Aegon Insurance business by Vienna Insurance Group and on Xella’s acquisition of Janes es Tarsa Kft.) as well as the significant legislative changes implemented this summer concerning Hungary’s Special FDI Regime, foreign investors should dedicate special attention to Hungarian FDI screening even more than in the previous years.”
As for Ukraine’s competition sector, Redcliffe Partners Partner Yuriy Terentyev highlights increased attention to the banking sector. “The Antimonopoly Committee of Ukraine (AMCU) has issued recommendations to 10 banks, urging them to properly inform consumers about the terms, restrictions, and exceptions of their cashback programs. According to the regulator, several banks promoted ‘cashback’ offers in a way that created expectations of unconditional rewards, while in reality, the programs were subject to exclusions, transaction-type restrictions, or limits that were not clearly disclosed. The AMCU stressed that banks must ensure transparency and accuracy in their communications to prevent consumer deception and safeguard fair competition in financial services.”
“The AMCU understandably resorts to its advocacy tools in the financial sector, where more than 60% of total banking assets are concentrated in state-owned institutions,” Terentyev adds. “Direct enforcement cases against these entities could risk undermining their creditworthiness and, in turn, reduce their attractiveness for future privatization. By starting with soft-law recommendations, the committee seeks to balance competition concerns with broader financial stability and policy considerations.” According to Terentyev, “the AMCU’s intervention in cashback programs is likely just the first signal of a more prolonged campaign, with loyalty schemes, tying practices, and systemic competition issues in the banking sector all potential targets. With enforcement momentum picking up, financial institutions should anticipate closer scrutiny of both consumer-facing products and structural market practices.”
Cetinkaya additionally highlights the Guideline on the Personal Data Protection on Social Media issued by the Turkish Data Protection Authority (Turkish DPA). “While social media offers significant opportunities for communication and freedom of expression, it also entails substantial risks to the privacy of personal data,” Cetinkaya notes. “In this regard, the guideline highlights that, due to the inherent technical architecture of social media platforms, user behavior, and the current legal framework, personal data may be disclosed both explicitly and implicitly, subjected to algorithmic analysis for diverse purposes, and potentially exploited by malicious actors.”
“The guideline advises that, in order to safeguard privacy, individuals should foster digital literacy and awareness before sharing content, regularly review and adjust privacy settings, adopt robust authentication measures such as strong and unique passwords, exercise caution when using third-party applications, and actively monitor their digital footprint,” Cetinkaya notes. “Furthermore, it emphasizes the role of parents in guiding their children’s use of social media, exercising vigilance regarding ‘sharenting’ (the disclosure of children’s photographs online), and adopting a conscious approach toward the protection of children’s personal data. The guideline also reminds mobile application developers and public institutions of their obligations concerning data processing principles, transparency, security, and accountability. Finally, it stresses that the creation of a safer social media environment necessitates the mitigation of vulnerabilities not only from a technical perspective but also from behavioral and legal dimensions.”
Actecon Managing Partner Bahadir Balki draws attention to the activity of the Turkish Competition Authority. “Over the past month, the Turkish Competition Authority (TCA) has advanced a series of high-profile investigations, underscoring its active enforcement across diverse sectors, including digital markets, labor markets, shipbuilding, construction, meal cards, and cinema,” he says. “The TCA opened an abuse of dominance investigation into Google regarding restrictions on in-app payment systems via the Play Store as part of its continued scrutiny of digital platforms.” In the shipbuilding industry, he adds that “the TCA launched a sector-wide investigation into alleged no-poach agreements and wage-fixing practices involving 33 companies, two associations, and an HR consultancy, highlighting its growing focus on anticompetitive restraints in labor markets.”
“In the dairy sector, the TCA initiated an investigation into claims that processors tied raw milk purchases to compulsory feed purchases,” Balki explains. “Alongside, it imposed interim measures mandating transparent and voluntary contractual terms to safeguard producers’ bargaining power. Separately, it opened an investigation into Ayca Sut for alleged resale price maintenance, territorial and customer restrictions, and bans on competing brands. The cement sector also drew attention, with new investigations into Akcansa and Kavcim for alleged resale price maintenance and sales restrictions by territory and customer group. In the meal card sector, the TCA launched a major case against Edenred, Multinet, Pluxee, and Setcard, focusing on alleged collusion in tenders, customer allocation, and the exchange of competitively sensitive information.”
Finally, Balki notes, “the TCA concluded two significant investigations through commitments. In the Mars Cinema Group case, commitments concerned guaranteeing sufficient capacity for third-party films and ensuring their equal treatment in programming. In the OGM Produksiyon-Star TV case, commitments removed exclusivity provisions, enabling both parties to work with other producers and broadcasters.”
This article was originally published in Issue 12.8 of the CEE Legal Matters Magazine.