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AMC Restarts War-Time Merger and Concerted Practice Filings Review - Earlier than Expected

Ukraine
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The Antimonopoly Committee of Ukraine (AMC) has issued an important update for parties who filed merger or concerted practice notifications during the early months of the war.

  • Background

When Russia’s full-scale invasion began and martial law was imposed, the AMC temporarily stopped reviewing all merger and concerted practice filings. Under the rules in force at that time, notifications submitted between 30 March 2022 and 17 June 2022, were put on hold until martial law is lifted and peace is restored.

  • Latest Development

Now the AMC has changed its approach. Even though martial law is still in effect, the authority has decided to resume work on these pending cases.

This means filers who made submissions during that early “pause” period are now being asked to provide current information and documentation to update and complete their notifications.

  • What does this mean for filers?

Anyone who filed a merger or concerted practice notification during the above-mentioned period need to update and complete their filings between 1 December 2025 and 31 March 2026. The AMC will then proceed with the review of the relevant filings.

By Igor Svechkar, Partner, and Sergiy Glushchenko and Pavlo Verbolyuk, Counsels, Asters

Asters at a Glance

Founded in 1995, Asters is the largest Ukrainian law firm with offices in Kyiv, Washington D.C., Brussels and London.

The Firm provides efficient transactional legal advice and represents clients on a broad spectrum of matters arising in the course of doing business in Ukraine. Asters has extensive industry-specific experience and plays a leading role in advising clients in various market sectors.

Asters’ 130-strong legal team combines world-class professionalism and quality with clear understanding of local realities so that our clients receive practically oriented advice in the most client-friendly manner. Asters’ lawyers received law degrees from the best European, Ukrainian and US law schools, including Yale, Harvard, Chicago University.

Asters has consistently remained at the top of the Ukrainian legal market throughout its history being acknowledged as Ukraine Law Firm of the Year by Who's Who Legal (2018-2022), The Lawyer European Awards (2020-2021), Chambers Europe Awards 2020 and holds top positions in the most authoritative international market reviews: The Legal 500, Chambers Global and Chambers Europe, IFLR 1000, Who's Who Legal, Best Lawyers.

Firm's website.