This House – Implemented Legislation
For M&A in Greece, Drakopoulos Senior Associate Sofia Angelakou highlights a key compliance update. “Although issued in June 2025, Joint Ministerial Decision Number 46982/2025 relating to administrative sanctions for non-compliance with the General Commercial Registry (GEMI) rules remains highly relevant, as the compliance grace period extends until December 31, 2025,” she notes. “During this period, entities are encouraged to register with GEMI, complete any pending registrations, and correct any errors or omissions in existing registrations. They should also submit any late filings, particularly those relating to previous financial years’ financial statements.” Starting from January 1, 2026, Angelakou says that “entities that fail to comply will be subject to fines following a notification procedure. Fine amounts will range from EUR 100 to EUR 6,000, depending on the company’s type and size, as well as the nature of the violation. Failure to file financial statements may incur fines of up to EUR 100,000. Reduced fines may apply in cases of voluntary corrective actions or for companies under liquidation.”
This House – Reached an Accord
Wolf Theiss Associate Zofia Zarebska highlights that in Poland, starting December 24, 2025, new provisions of the Labor Code regarding pay transparency will enter into force, partially implementing Directive (EU) 2023/970 of the European Parliament and of the Council. “Under the amended rules, employers will be required to inform job applicants about the remuneration for a given position, either by specifying the exact amount or by providing a defined salary range,” Zarebska notes. “Where applicable, employers must also disclose relevant details from collective bargaining agreements or internal remuneration policies. Pay levels must be determined using objective and gender-neutral criteria. This information must be shared at one of the following stages: in the job advertisement, before the interview, or prior to the conclusion of the employment contract. Employers will also be required to ensure that job postings and titles are gender-neutral and that the recruitment process is free from discrimination.”
In addition, Zarebska says that the amendment restricts the scope of information employers may request from candidates. “While employers may continue to inquire about a candidate’s work history, they will no longer be permitted to ask about previous salary levels.” She says that other key obligations set out in the directive, “such as the employer pay gap reporting requirement and the duty to take corrective action when the gender pay gap exceeds 5% in a particular category of workers, have not yet been introduced into national law.”
Schoenherr Bulgaria Head of Real Estate Dimitar Vlaevsky emphasizes regulatory updates in Bulgaria’s real estate. “As part of the process of joining the Eurozone, amendments to anti‑money‑laundering rules were implemented, clarifying beneficial‑ownership reporting for property‑holding entities and lowering thresholds for suspicious‑activity reporting by real estate professionals,” he notes.
Hristov & Partners Partner Dragomir Stefanov reports that the FDI screening regime in Bulgaria is now fully operational. “After entering into force at the end of July, Bulgaria’s new FDI screening regime became fully operational with the establishment of the FDI Council in mid-August,” he points out. “Soon after, the first filings began arriving at the Bulgarian Investment Agency, which is the authority responsible for verifying the completeness of applications before forwarding them to the FDI Council. Preparing an FDI filing closely resembles a merger notification, requiring substantial information gathering, organization, and good time management. While the requirements in the secondary FDI legislation regarding supporting documentation requirements are formulated overly broadly, the authorities accepted our pragmatic approach, focused on avoiding unnecessary paperwork. Nonetheless, formalities such as apostilles and legalized translations are strictly enforced.”
“An important feature of the FDI regime is the exemption for ‘portfolio’ investments,” Stefanov notes. “Unfortunately, the legislation lacks a definition of portfolio or passive investments despite requests made in that regard during the legislative process. The FDI Council did not address our request for clarification or a no-jurisdiction letter and instead approved their investments (essentially meaning that the “portfolio investment” exemption did not apply), thus creating an early administrative precedent that hopefully will be reconsidered as practice evolves.” Stefanov adds that “although the statutory review period is 45 days (subject to extensions), the authorities have so far acted efficiently, issuing clearances well within the prescribed timeframe.”
Highlighting updates in TMT in the Czech Republic, the country “is preparing for the entry into force of its new Cybersecurity Act, scheduled for November 1, 2025,” Rowan Legal Partner Jan Tomisek notes. “The act represents the principal national instrument for implementing the EU NIS2 Directive and establishes a comprehensive framework for cybersecurity governance in the country. In anticipation of its effectiveness, the National Cyber and Information Security Agency is working on a set of implementing decrees. These secondary regulations will define in detail the obligations imposed on regulated entities, including requirements regarding security measures, organizational safeguards, and the reporting of cybersecurity incidents.”
A notable feature of the Czech approach, according to Tomisek, “is the adoption of a dual-level regulatory model. Two separate decrees will be issued: one applicable to entities subject to a ‘lower regime,’ and another imposing enhanced obligations on providers designated under the ‘higher regime.’ The distinction is designed to ensure proportionality of regulation while simultaneously securing critical infrastructure and services. The two-tier system, however, introduces additional compliance considerations. Determining the applicable regime will require careful legal and operational assessment, and entities may need to adapt group-wide cybersecurity policies to reflect Czech-specific rules. Compared to jurisdictions opting for a uniform set of obligations, the Czech framework thus creates a unique regulatory environment, demanding heightened attention from in-house legal teams and compliance officers.”
This House – The Latest Draft
For transactions in Ukraine, a major impact will be a new draft law on the FDI regime, according to Avellum Managing Partner Mykola Stetsenko. “The Ukrainian Parliament has introduced a draft law proposing the establishment of a comprehensive system for screening foreign direct investment. This system is modeled after those operating across the European Union and the US and is intended to safeguard national security,” he notes. “The FDI screening applies to any acquisition of control or significant influence by a non-Ukrainian investor in a company operating in a critical sector of the economy. Significant influence includes specific shareholding thresholds, veto rights, or the right to appoint board members. Critical sectors are defined as those relating to national security and public order, including defense and military industry, dual-use products, energy, telecommunications (digital/data), critical infrastructure (transport, water), etc.” According to Stetsenko, “a newly established commission under the Ministry of Economy will be responsible for FDI screening. The review of a complete application must be completed within 90 calendar days.”
DLA Piper Hungary Partner Zoltan Kozma adds that Hungary strengthens cybersecurity with a draft government decree aligning with the EU Cyber Solidarity Act. “It aims to strengthen capacities in the EU to detect, prepare for, and respond to significant and large-scale cybersecurity threats and attacks. The act includes a European Cybersecurity Alert System, made of Security Operation Centers interconnected across the EU, and a comprehensive Cybersecurity Emergency Mechanism to improve the EU’s cyber resilience.”
“A government decree transposed the EU’s NIS2 Directive into Hungarian law,” Kozma adds. “The proposed amendment of the government decree responds to new EU requirements, especially those introduced by the Cyber Solidarity Act and the evolving landscape of cross-border cyber threats. The amendment officially designates Hungary’s National Cyber Security Center as the body responsible for participating in the European Cybersecurity Alert System and for cross-border cyber cooperation. This ensures Hungary’s active involvement in the EU’s collective cyber defense mechanisms. To harmonize with EU law and international standards, the decree also replaces the term ‘event’ with ‘incident’ or ‘cybersecurity incident’ throughout the Hungarian cyber legislation. This change clarifies reporting and response obligations for Hungarian organizations.”
In the past month, the key development in Bulgaria’s TMT sector has been the publication of “the Draft Law on the Use and Development of Artificial Intelligence, submitted to Parliament on October 8, 2025,” Boyanov & Co Partner Nikolay Zisov reports. “The bill is designed to align with and implement the EU Artificial Intelligence Act (Regulation (EU) 2024/1689), establishing a clear legal structure for the safe, ethical, and innovative integration of AI. The draft legislation aims to regulate AI use across both the public and private sectors. The law applies to state and local government bodies, employers, enterprises investing in AI, and very large online platforms where AI could create systemic national security risks.”
According to Zisov, “a dual-ministerial governance model is established under the Minister of e-Government and the Minister of Innovation and Growth. A newly created National AI Coordinator will oversee the implementation of Bulgaria’s National AI Strategy. The proposed framework also introduces key tools like regulatory sandboxes and dedicated registers for high-risk AI systems used in critical infrastructure. By balancing risk control with incentives, this draft positions Bulgaria as an early mover in implementing the EU AI Act, creating new opportunities for the TMT sector in compliance advisory, data governance, and AI-driven public procurement.”
The Verdict
Peterka & Partners Partner Adela Krbcova highlights a recent judgment of the Czech Constitutional Court that ruled in favor of an employer – “a secondary school, which had immediately terminated the employment of two of its employees for a very substantial violation of their obligations – and upheld the employer’s constitutional complaint. The case involved two teachers who had allegedly consumed alcohol in their office instead of teaching and refused to take a breathalyzer test.” According to Krbcova, “The lower courts, including the Supreme Court, declared the terminations invalid. However, the Constitutional Court found that the general courts had violated the school’s right to judicial protection by failing to consider all of the relevant circumstances of the case, misinterpreting the evidence, and acting arbitrarily. The Constitutional Court also stated that teachers should set an example for their students and are expected to demonstrate a higher level of moral integrity and dignity. The case is therefore being returned to the lower courts for review.”
For Romania’s PPP/infrastructure sector, Musat & Asociatii Partner Ana Maria Abrudan says that the CJEU’s judgment C-282/24 from October 16, 2025, will be impactful. “This decision highlights the need to assess modifications not just from a formal, financial, or technical standpoint but based on their real impact on the structure and purpose of the framework agreement,” Abrudan explains. “This approach ensures a greater legal certainty and efficiency in public procurement processes, allowing contracting authorities to make pragmatic adjustments that reflect evolving circumstances, while observing the principles of transparency, proportionality, and fair competition.”
“For contracting authorities in Romania, this decision provides important guidance on how to approach modifications to framework agreements, as it is common practice among local authorities to be reluctant to accept changes to such agreements,” Abrudan notes. “By emphasizing the need for a thorough assessment of whether a change affects the ‘general character’ of the agreement, Romanian authorities can avoid unnecessary procedural delays and costs associated with re-launching procedures for minor adjustments.”
In the Works
“September 2025 saw a lot of new energy projects starting commercial operations in Bulgaria,” CMS Sofia Managing Partner Kostadin Sirleshtov reports. “To name a few, these projects include Geosolar Kamenyak (64-megawatt AC photovoltaic project, owned by a Bulgarian investor), Kameno (40-megawatt AC photovoltaic project, owned by Enka – the largest Turkish energy construction company), and Aratiden – stage 3 (100-megawatt AC photovoltaic project, owned by Global Biomet), etc.”
Regulators Weigh In
AECO Law Partner Cagri Cetinkaya points to a new data protection exemption introduced earlier in October. “A new decision by the Turkish Personal Data Protection Board, published in the Official Gazette dated October 1, introduces a significant exemption from the obligation to register with the Data Controllers’ Registry Information System (VERBIS). Data controllers whose primary activity is the processing of special categories of personal data are now exempt from registration, provided that they (i) employ fewer than 10 people and (ii) have an annual financial balance sheet total below TRY 10 million.” According to him, “this exemption is expected to apply notably to small-scale professionals such as doctors, dentists, and pharmacists who process special categories of personal data but operate individually or in small teams. The exemption reduces compliance obligations for small-scale professionals but may lead to confusion over remaining data protection duties, which continue to apply in full.”
Sirleshtov adds that in October, the Energy, Water, and Regulatory Commission issued various licenses in favor of new investors, “such as a natural gas trading license to VNG Handel & Vertrieb and a generation license for the 88-megawatt AC photovoltaic Karlovo Solar Park (owned by Astronergy and PCC), and it moved forward with the approval of the restructuring of R-Engineering EOOD (the local project company for Actis/Rezolv).”
ACI Partners Legal Manager Carolina Parcalab stresses that “over the past two months, the Moldovan Competition Council maintained an active agenda. In September, the council finalized a long-running investigation concerning a potential abuse of dominance by a state-owned enterprise responsible for verifying design and construction documentation.” Although no infringement was established, she says, “the council’s decision set out important clarifications for the market. First, it confirmed that state-owned enterprises qualify as undertakings within the meaning of the Competition Law, and can therefore be investigated for abuse of dominance. Second, the authority expressed concerns about the restrictive impact of existing legal and procedural frameworks governing public procurement in construction.”
“In a separate case concluded in September, the council imposed combined fines exceeding MDL 5 million on two companies that participated in a bid-rigging cartel during a tender organized by the General Police Inspectorate for portable video surveillance systems,” Parcalab says. “The companies were found to have coordinated their bidding strategies to simulate competition while agreeing in advance who would be awarded the contract.” According to her, “the council also launched new investigations targeting potential collusion in tenders for meat supply to educational institutions. In October, the council concluded a series of dawn raids at the premises of multiple companies involved in the import, distribution, and sale of meat.”
Parcalab adds that the council’s merger control department was also active. “Among others, in September 2025, the authority began analyzing the proposed acquisition of control over Purcari Wineries Public Company Limited by the Romanian subsidiary of Maspex Group,” she says. “The council is also reviewing the acquisition by Vion‑Impex SRL of retail stores owned by both active in the trade of hygiene, cosmetics, and perfumery products under the brands Zolusca and Casa Curata.”
Redcliffe Partners Partner Yuriy Terentyev highlights investigations in pharma chains in Ukraine. “In October 2025, the Antimonopoly Committee of Ukraine (AMCU) opened a formal investigation against several of the country’s largest pharmacy chains,” Terentyev notes. “The case reportedly stems from complaints by domestic pharmaceutical producers who allege that leading retail networks acted in concert to discontinue purchasing their products – allegedly restricting access to shelves and distorting competition in both wholesale and retail segments.”
“The case marks a new phase in the AMCU’s pharma-focused enforcement campaign, which began in 2023 with advocacy and analytical work aimed at improving transparency and non-discriminatory access along the pharmaceutical supply chain,” Terentyev highlights. “Having initially examined upstream relationships between manufacturers and distributors, the AMCU is now turning its attention downstream – to the conduct of the “dominant” pharmacy networks. Notably, the key initiator of the complaints, one of the domestic producers, has itself been the subject of law-enforcement probes earlier this year, adding both complexity and context to the unfolding investigation. Against this backdrop, the process may further intensify existing tensions between local manufacturers and retail chains within the Ukrainian pharmaceutical market. Whether the AMCU’s findings confirm coordinated behavior or reveal coincidental market dynamics, the case will be closely watched as an indicator of how far the regulator is prepared to extend its sectoral focus from advocacy to enforcement in line with broader EU trends.”
In Related News
Cetinkaya adds that in Turkiye, “the new National Action Plan sets forth an ambitious roadmap across digital, data protection, AI, cybersecurity, and related domains, aiming to align Turkiye’s legal framework with EU norms. Key initiatives in the digital domain include: amendment of the Personal Data Protection Law to harmonize with the EU’s GDPR and Law Enforcement Directive, issuance of a framework regulation for AI-based products, adoption of secondary legislation under a new Cybersecurity Law, aligning with EU rules on targeted advertising, ‘dark patterns,’ and protection of children’s privacy, etc.” These reforms, he says, “will require companies operating in Turkey to undertake substantial legal, technical, and governance adjustments, especially in data processing, AI deployment, product compliance, and cross-border risk management.”
Other broader updates in Bulgaria’s real estate sector, according to Vlaevsky, include a range of initiatives. “Following EU Green Deal targets, the government launched an expanded grant window and tax incentives for energy‑efficiency retrofits in residential and multifamily buildings, with stricter enforcement of Energy Performance Certificate requirements in transactions. The Agency for Geodesy, Cartography, and Cadaster accelerated the rollout of electronic cadastral services and e‑signature integration, reducing registration timelines for urban transfers and streamlining title searches. Additionally, following devastating floods at the coastal resorts, state authorities initiated inspections targeting irregular developments and construction.”
Finally, for Serbia’s energy sector, JPM & Partners Senior Partner Jelena Gazivoda says that “the end of September and the beginning of October in Serbia were marked first by the announcement that NIS would no longer be granted special licenses that were required in order to ensure business after NIS was placed on the OFAC list in January 2025, and then by the beginning of the application of sanctions.”
“Although everyone in Serbia hoped for another postponement of the start of the application of the sanction, it did not happen, which consequently put the Republic of Serbia in a difficult situation, since the participation of NIS in the total sale of oil and oil derivatives on the market of the Republic of Serbia is about 70% (the remaining about 30% goes to foreign-owned companies that have been operating on the Serbian market for a long time),” Gazivoda notes. “The Republic of Serbia currently has reserves that are a guarantee in preparation for the most difficult scenario, but these reserves cannot cover a period longer than the end of the calendar year 2025. At this moment, solutions are certainly being sought to bypass the situation by supplying the market through foreign (not Russian-owned) entities that are already operating in Serbia, but this will not be able to cover the current needs of the market in the Republic of Serbia.”
“This is a time of great uncertainty with many different directions and possibilities of action. Solving the issue of sanctions to NIS from the perspective of OFAC concerns, first of all, the issue of ownership of NIS, which opens the issue of making long-term strategic decisions in the direction of reducing the percentage participation of Gazprom Neft and its related entities from the Gazprom Group,” Gazivoda says. “This question is delicate because it is related to the problem of dependence of the Republic of Serbia on energy imports, which further complicates the situation before the beginning of winter and the limited duration of the gas arrangement with Gazprom. The current issue can have numerous effects on the economy of the Republic of Serbia, with special emphasis on the future of FDI, the attraction and maintenance of which was the basis of Serbia’s economic growth in previous years. Even if a solution is found, there will be an increase in the price of both fuel and, consequently, the prices of all products that include transport costs. The overall consequences of the current situation are difficult to fathom, but it is almost certain that it will lead to an additional increase in the cost of living and affect both the overall economy and the standard of living of citizens in Serbia.”
This article was originally published in Issue 12.9 of the CEE Legal Matters Magazine.