Sayenko Kharenko

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Ukraine merger control: 2024-2026 reforms, thresholds, control and JV rules, foreign-to-foreign reach, filing and timing, sanctions exposure, escalating fines, and draft FDI screening
PRACTICE NOTES
Ukraine merger control: 2024-2026 reforms, thresholds, control and JV rules, foreign-to-foreign reach, filing and timing, sanctions exposure, escalating fines, and draft FDI screening
NOTE—to check if notification thresholds in Ukraine and across the globe are triggered, please refer to: Where to Notify 1. Have there been any recent developments regarding the Ukrainian merger control regime and are any updates/developments expected in the coming year? Also, are there any other ‘hot’ merger control issues in Ukraine? Despite the severe disruption caused by the ongoing war initiated by the Russian Federation (RF), the Antimonopoly Committee of Ukraine (AMC) has continued to function without interruption. Notably, in 2024 the AMC reviewed over 550 merger notifications, broadly matching pre-war levels, and the volume of filings in 2025 exceeded 1,000. From 1 January 2024, reforms to the competition law framework took effect, moving Ukraine closer to European Union (EU) practice. These reforms introduced, among other measures, the partial scrapping of the outdated ‘seller attribution rule’, refinements to what constitutes a
Competition
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