Ukraine's AMC Resumes Review of Suspended Filings
November 17, 2025, marks a major regulatory development in Ukrainian merger control practice.
The Antimonopoly Committee of Ukraine ("AMC”) has formally resumed review of merger and concerted-practices filings that were suspended in spring-summer 2022.
The AMC is now encouraging parties to proactively finalise their suspended filings and has indicated it may proceed on its own initiative if parties do not engage.
Background
In March 2022, following the start of Russia’s full-scale invasion, the AMC issued guidance temporarily pausing merger filing review activity. Between March 30, 2022, and June 17, 2022, (the "Suspension Period”), all filings submitted to the AMC were effectively put on hold. Although the AMC later resumed to normal operations, this backlog of "frozen filings” remained pending.
The AMC has now amended its guidance, setting out clear procedures and deadlines to restart review of those suspended filings.
???? Key Deadlines & Procedure Changes
With the amendment published on November 17, 2025, the AMC introduced the following:
From December 1, 2025, to March 31, 2026: Applicants must submit any missing information and documents that were not provided with the initial filing made during the Suspension Period.
Upon receipt of additional materials: The AMC will resume review of the suspended application. If nothing is submitted by March 31, 2026, the AMC will proceed based on whatever documentation was originally provided. If the file remains insufficient, the AMC may declare the filing incomplete and request additional input (potentially triggering timing resets).
Voluntary resumption: Applicants may request the AMC to resume review sooner. The AMC must act within seven days upon receipt of such a request.
Official notifications: The AMC will notify applicants within five calendar days of issuing its order to resume review.
???? What This Means for Businesses
Through these changes, the AMC is clearly signalling its intention to close the chapter on suspended filings and give parties a structured pathway to end the process. Companies should view this four-month period as a unique, one-off opportunity to review and complete any pending applications, ensuring that all documentation is accurate, consistent, and compliant with current AMC standards.
Taking action now offers several tangible advantages:
✅ Clean regulatory record – close the case and avoid any lingering historical risk.
✅ Predictable, modest penalty – a fixed symbolic fine of approximately EUR 1,100 for closing without prior approval (under the AMC’s special guidance exemption).
✅ Process certainty – reduce the chance that old issues related to suspended filings resurface during future, unrelated filings.
✅ Transaction flexibility – full ability to proceed with intra-group or subsequent deals involving target without legacy encumbrances.
By contrast, if parties take no action and wait until the AMC acts on its own initiative:
⚠️ The AMC may open proceedings ex officio,
⚠️ Fines could be imposed based on turnover percentages, not the fixed symbolic amount, leading to materially higher potential fines.
⚠️ Future filings may face historical queries on frozen filings.
Our Recommendation
We kindly recommend that companies with suspended filings take advantage of this four-month window to voluntarily approach the AMC and complete the process. This will ensure clarity over the process, predictable financial exposure, controlled timing, and closure of relevant historical risks.
It remains important, however, to carefully update and verify all filing materials since the AMC has confirmed it will apply its usual attention to reviewing these suspended-period applications.
???? How We Can Help
Our Competition & Antitrust team is in constant dialogue with the AMC’s officials and ready to assist with:
assessing whether a past filing falls within the suspension framework;
preparing or updating missing information and data for submission;
guiding through and securing a smooth and predictable review process, and
strategising on potential risks and developing complex mitigating solutions.
Please contact Valentyna Hvozd, Maksym Nazarenko, or Volodymyr Sayenko for tailored advice.