The Antimonopoly Committee of Ukraine has resumed the review of applications for merger clearances and concerted practices that were submitted during martial law between 30 March 2022 and 17 June 2022.
How the AMCU’s approach evolved during martial law
- 03 March 2022 the AMCU adopted a decision suspending the review of all applications and cases concerning mergers and concerted practices for which no decision had been taken as of 25 February 2022. The suspension applied regardless of the stage of review and remained in force until the martial law was terminated or cancelled.
- At the same time, the Committee emphasised that the obligation to obtain merger and concerted practices clearances remained in force during martial law. Therefore, a simplified filing procedure was introduced – with a significantly reduced list of documents. However, the review of such applications was also suspended until the end of martial law.
- For mergers or concerted practices implemented during this period, the AMCU introduced nominal fines:
- 3,000 tax-free minimum incomes – if the parties submitted an application but completed the merger or concerted practice without AMCU clearance;
- 20,000 tax-free minimum incomes – if the merger or concerted practice was completed without filing an application.
- 09 June 2022 the AMCU resumed the review of all applications submitted before 25 February 2022 and reinstated the standard filing procedure and the requirement for a full set of documents for new applications.
Still review of those applications filed in the begining of 2022 was suspended. The new ruling deals with such cases.
What has changed now
On 13 November 2025, the AMCU adopted amendments to its Guidelines No. 1-pp, which establish the procedure for reviewing those applications submitted between 30 March 2022 and 17 June 2022, i.e. under the simplified regime and without the full package of documents.
Applicants must now submit the full set of documents required by law to the relevant AMCU authority between 1 December 2025 and 31 March 2026.