The AMC’s 2026 Priorities: What Businesses Should Watch Closely

At its meeting on 22 January, the Antimonopoly Committee of Ukraine ("AMC”) approved its enforcement and policy priorities for 2026. These priorities provide valuable insight into the sectors likely to face heightened regulatory scrutiny in the year ahead and offer important guidance for companies reviewing their competition compliance frameworks and transaction planning.

While many of the AMC’s focus areas continue to be shaped by the ongoing war, reconstruction efforts, and acute energy and social challenges, several priorities have now been articulated with greater precision, signalling a more targeted enforcement agenda.

In addition to traditionally sensitive markets such as access to port infrastructure, digital platforms, and defence procurement, the AMC is significantly intensifying its focus on regional pharmaceutical markets. This signals increased regulatory attention towards pharmacy chains and pharmaceutical distributors. The sector has long been under scrutiny, culminating last year in a record fine exceeding UAH 4 billion imposed on pharmaceutical distributors for anticompetitive concerted practices[1]. This development underscores the AMC’s readiness to pursue enforcement in markets perceived as socially sensitive.

The energy sector remains a central enforcement priority. Since the beginning of the full-scale invasion, activity in fuel and energy markets has accelerated, including asset acquisitions and lease transactions by major market participants such as WOG, OKKO, and UPG. These transactions frequently trigger merger control obligations, while increasing market concentration heightens competition law risks. Energy companies should therefore anticipate sustained regulatory scrutiny, ensure early transaction planning, and reassess their competitive strategies accordingly.

Socially important sectors continue to attract particular regulatory attention. These include access to infrastructure facilities in utilities, housing infrastructure, and electronic communications. Ensuring non-discriminatory access to such infrastructure is critical, especially for electronic communications providers engaged in network deployment and modernisation. In this context, the AMC plays a key role in safeguarding market access and promoting infrastructure recovery and development.

As Ukraine enters a large-scale reconstruction phase, fair competition in public procurement remains paramount. The AMC also intends to strengthen oversight of concentrations and concerted practices involving online platforms, including search engines and price comparison services, reflecting their growing influence on consumer behaviour[2]. Companies active in digital markets or contemplating M&A in this space should carefully assess regulatory exposure and engage proactively with the AMC.

Upcoming legislative reforms are expected to introduce a mechanism allowing lease and sale decisions concerning public and municipal property to be challenged directly before the AMC, mirroring public procurement appeal procedures. In parallel, the AMC will intensify its focus on concessions, public-private partnerships, and donor-funded procurement to support private-sector participation in reconstruction. State aid control is also expected to resume following amendments to the Law of Ukraine "On State Aid”, alongside deeper international engagement, including enhanced cooperation with the OECD.

The AMC’s 2026 priorities go beyond signalling enforcement trends. They provide a strategic framework for business planning. Companies operating in sensitive sectors, pursuing M&A, or participating in reconstruction-related projects should reassess regulatory risks early and integrate competition compliance into their broader commercial strategies.

[1] The AMC has fined drug distributors more than UAH 4 billion.URL: https://amcu.gov.ua/news/amku-oshtrafuvav-dystrybiutoriv-likarskykh-zasobiv-na-ponad-4-mlrd-hrn

[2] See e.g. recent EC decision AT.40670 (Google – Adtech and Data-related practices)