The AMCU’s 2026 priorities: what to expect and what to do now?

Which areas will be under increased scrutiny in 2026?

1. The fuel and energy sector;
2. access to infrastructure, including ports, construction sites, and transport;
3. digital platforms, online search engines, and price comparison services;
4. medical products and essential goods, including medicines, medical devices and equipment, essential consumer goods for children, and dietary supplements;
5. the defence sector;
6. housing and communal services;
7. electronic communications.

What types of violations are most detected?

1. Anti-competitive concerted practices:

• manipulation of the outcomes of tenders, auctions, competitions, or bids.

2. Abuse of monopoly position:

• restriction of competition or infringement of the interests of other businesses or consumers;
• imposition of prices or trading terms that could not exist under conditions of significant market competition;
• application of different prices or terms to similar transactions without objective justification;
• partial or complete refusal to purchase or supply goods when no alternative sources are available; 
• creation of barriers to market entry (or exit) or to removal from the market.

3. Violations related to concentrations and concerted practices:

• implementation of a concentration (transaction) without prior clearance; 
• violation of the requirement prohibiting entities whose primary business activity consists of financial or securities transactions from voting in the governing bodies of a target company where the shares are acquired for subsequent resale.

4. Unfair competition:

• dissemination of misleading information;
• unlawful use of third-party designations;
• unlawful use of trade secrets;
• disrepute of a business entity.

5. Information-related violations:

• failure to provide information;
• submission of incomplete information; 
• submission of inaccurate information.

6. Other violations:

• failure to comply with, or incomplete compliance with, the AMCU’s decisions and preliminary decisions.

What should businesses in priority sectors do now?

1. Analyse interactions with competitors for risks of anti-competitive concerted practices;
2. review pricing policies and contractual terms with counterparties to ensure economic justification and the absence of discriminatory conditions;
3. assess antitrust risks of planned transactions and verify compliance of transactions completed over the past five years;
4. review marketing and advertising materials for misleading information or unlawful use of designations;
5. ensure readiness to interact with the AMCU by establishing internal procedures for responding to the AMCU’s requests and ensuring the completeness and accuracy of information provided;
6. verify full implementation of the AMCU’s decisions and recommendations; 
7. introduce or update antitrust compliance measures, including internal policies and training for key teams.

The GOLAW team provides comprehensive support to businesses in the field of antitrust and competition law, including:

1. antitrust audits of business activities: pricing, contractual arrangements, and interactions with competitors);
2. assistance in obtaining AMCU clearance for concentrations and approval for concerted practices;
3. development and implementation of antitrust compliance policies;
4. support in interactions with the AMCU; 
5. representation in proceedings concerning violations of competition law.