Category: Issue 12.1

Gospic Plazina Stojs Partner Lana Stojs talks about banking and finance in 2025 in Croatia.

CEELM: What is in the pipeline in terms of legislation that you believe will have the most impact on the banking/finance sector in Croatia?

Stojs: Several legislative measures are expected to have a substantial impact on Croatia’s banking and finance sector. These include the implementation of the Digital Operational Resilience Act and the NIS2 Directive on cybersecurity and the transposition of the Consumer Credit Directive 2 into the Croatian legal system by way of a new Consumer Credit Act until November 2025, along with, perhaps the most pressing of them all, the alignment with the Instant Payments Regulation (IPR) which has to be completed until April, 2025 and by way of which Croatia is fully aligning with EU payment services regulations to improve security, transparency, and accessibility in the financial sector, making payment services faster, more secure, and more integrated across borders.

CEELM: Of the above, which ones are you/your clients most excited about and why?

Stojs: The IPR brings several key benefits for consumers, businesses, financial institutions, and the broader economy. The main benefits could be recognized as faster transactions, enhanced consumer experience, increased efficiency for business, financial inclusion, and cost-effectiveness. The evolving landscape will surely encourage competition within the payment services market, and the financial institutions in Croatia will need to innovate and differentiate their services to remain competitive, thus also opening doors to new fintech solutions. As the adoption of instant payments continues to grow, the benefits will likely expand, contributing to a more integrated, digital, and secure payment environment.

CEELM: On the flip side, which ones are you/your clients dreading the most and why?

Stojs: While DORA, which entered into force in February 2025, offers substantial benefits for the financial sector, its implementation poses certain challenges for banks. In terms of compliance requirements, DORA covers a broad range of areas, including risk management, governance, incident reporting, third-party management, and business continuity, all of which must be adequately addressed or enhanced. Further, given that many banks operate across different jurisdictions, complying with DORA’s provisions while also adhering to local regulations can be complex. Additional challenges lie within the upgrading of ICT systems and infrastructure while simultaneously adhering to robust cybersecurity measures, requiring banks to implement advanced security protocols. Finally, one of DORA’s key requirements is the management of third-party risks, including those related to cloud providers, outsourcing arrangements, and other external partners that provide critical services where the banks must ensure that their third-party vendors comply with DORA’s resilience requirements.

CEELM: What trends do you expect to shape the banking sector in Croatia in 2025?

Stojs: In 2025, the banking sector in Croatia is expected to further develop, driven by a combination of regulatory reforms, technological advancements, and evolving customer preferences. Digital transformation and fintech integration are expected to be dominant trends, and it is highly likely that traditional banks will continue to enhance their digital offerings. With the IPR and Croatia also moving toward a cashless society, banks are expected to adopt new technologies to accommodate digital-only transactions. Finally, sustainability and green finance are also expected to be in focus for the banks, as both regulatory frameworks and customer demand push for greater integration of ESG principles into banking operations. In 2025, Croatian banks will likely offer more green financial products, such as green bonds and credit lines that support sustainable projects, especially since, in February 2025, the European Green Bond Regulation was implemented into the Croatian legal system, thus aligning the Croatian legal framework with the European Green Bond Standard.

CEELM: What is the biggest challenge for the banking sector in Croatia at the moment, in your view, and what is the likelihood you’ll see it overcome in 2025?

Stojs: The banking sector is currently facing an excessive number of rules, requirements, and regulatory processes that need to be complied with. While regulation is crucial to ensure the stability, integrity, and safety of the financial system, overregulation imposes a range of challenges, such as compliance risks and potential penalties, regulatory uncertainty, and operational complexity. The possibility of overcoming the challenges of overregulation will highly depend on the quality of collaboration between the legislators, the regulators, and the banks. A valuable and impactful initiative in terms of simplification of certain regulatory obligations is the so-called EU Omnibus Regulation, the proposal of which is expected to be released by the end of February. The initiative recognizes the intersection between three European ESG regulations: the Corporate Sustainability Reporting Directive, the Corporate Sustainability Due Diligence Directive, and the EU Taxonomy regulation and aims to promote consistency, streamlining, and simplifying sustainability reporting requirements for businesses – including financial institutions – operating in the European Union by consolidating multiple sustainability-related requirements into a single framework.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Law Office Lazarov Attorney at Law Gordana Susuleska-Itic talks about banking and finance in 2025 in North Macedonia.

CEELM: What is in the pipeline in terms of legislation that you believe will have the most impact on the banking/finance sector in North Macedonia?

Susuleska-Itic: The changes in the legal regulations in the Republic of North Macedonia due to its alignment with the Markets in Financial Instruments Directive II EU regulation, especially the new Financial Instruments Law (Official Gazette of RNM no.66/2024), have imposed a need for harmonization and adjustments to the operations of banks as key market participants. The law requires harmonization in several aspects, such as internal (re)organization, changes in internal operating procedures or introduction of new ones, as well as harmonization of the bank’s internal acts. Hence, the most significant legislative pipeline items in North Macedonia are the by-laws arising from the Financial Instruments Law, which should be adopted by September 2025 – a total of 75. Currently, 26 new by-laws have been adopted, leaving 49 new by-laws to be adopted in the following six months. Their implementation will have the biggest impact on the financial sector in North Macedonia.

CEELM: Of the above, which ones are you/your clients most excited about and why?

Susuleska-Itic: The novelties imposed by the Financial Instruments Law offer several benefits for financial institutions, even though its implementation may present challenges. These benefits primarily stem from the law’s alignment with EU standards, which enhance the stability, transparency, and efficiency of the financial system. Increased market transparency and confidence will reduce uncertainty. This provides a clearer framework for conducting business and helps attract investors. By aligning with EU regulations, the law boosts trust in North Macedonia’s financial markets, attracting more foreign and domestic investors. Easier cross-border transactions and partnerships with EU-based financial entities will open new channels for investment and trade. By bringing in stricter standards, financial institutions will establish robust risk management frameworks that reduce operational risks. Financial institutions that are early adopters of the law’s provisions can position themselves as leaders in compliance and attract both institutional and retail clients who value security and regulatory adherence and can attract EU-based clients.

CEELM: On the flip side, which ones are you/your clients dreading the most and why?

Susuleska-Itic: Considering that the adoption and establishment of the latest set of regulations is an ongoing process, there is still a level of uncertainty among our clients on whether they will have the capacity to adapt and implement the novelties in their everyday business within the given timeframe.

Financial institutions may need to invest in new technologies or enhance existing infrastructure to handle the finality of transactions and settlements as per EU norms. This could involve significant costs and resource allocation, particularly for smaller institutions. With stricter regulations, financial institutions will face increased scrutiny from local and EU regulators. This could lead to more frequent audits, compliance checks, and penalties for non-compliance, which could increase operational costs.

Institutions may need to adjust their trading platforms, clearing processes, and contract frameworks to accommodate the law’s stipulations, which could involve significant operational changes and delays in implementation.

The shift to a more stringent regulatory environment increases the risk of fines or penalties for non-compliance, especially if financial institutions are slow to adopt the necessary changes.

CEELM: What trends do you expect to shape the banking sector in North Macedonia in 2025?

Susuleska-Itic: In 2025, North Macedonia’s banking sector will be characterized by digital innovation, regulatory alignment with EU standards, and a growing emphasis on sustainability and personalized services. While these trends bring opportunities for growth and improved customer experience, they also present challenges for banks that need to adapt to an increasingly competitive and complex environment. Cybersecurity, financial inclusion, and digital transformation will likely be at the forefront as the sector continues to evolve.

CEELM: What is the biggest challenge for the banking sector in North Macedonia at the moment, in your view, and what is the likelihood you’ll see it overcome in 2025?

Susuleska-Itic: While the banking sector in North Macedonia is making strides in overcoming these challenges, digital transformation and cybersecurity will remain ongoing concerns through 2025.

The implementation of AI in North Macedonia’s banking sector depends on developing the necessary infrastructure for AI education, fostering innovation, and adopting a national strategy along with ethical guidelines. Without these foundational elements, the country risks falling behind in AI advancement, despite its strong IT sector and investment appeal. AI presents significant opportunities for the banking sector in North Macedonia if addressed and implemented properly.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Greenberg Traurig Partner and Head of Project and Structured Finance Piotr Nerwinski talks about banking and finance in Poland in 2025.

CEELM: What is in the pipeline in terms of legislation that you believe will have the most impact on the banking/finance sector in Poland?

Nerwinski: First, there is a draft amendment to the Act of May 20, 2016, which proposes significant changes to wind farm investments by reducing the minimum distance between wind farms and residential buildings that could unlock a number of new wind farm projects.

Second, the above draft amendment also aims to enhance the support system for biomethane installations over 1 megawatt.

Finally, there is an update in funding for energy storage. The National Fund for Environmental Protection and Water Management is preparing a substantial funding program for energy storage facilities, with a budget exceeding PLN 4 billion.

CEELM: Of the above, which ones are you/your clients most excited about and why?

Nerwinski: Among the legislative initiatives mentioned, the Battery Energy Storage System (BESS) subsidy program is generating the most excitement for us and our clients. This program is seen as a critical component in transitioning Poland’s energy sector. The subsidy program presents substantial opportunities to improve and expand business plans for BESS projects. By providing financial support, it enables developers and investors to bridge the financing gap that might currently block some projects.

CEELM: On the flip side, which ones are you/your clients dreading the most and why?

Nerwinski: One of the primary concerns for us and our clients is the pervasive bureaucracy and overregulation impacting various areas of economic activity in Poland. These regulatory hurdles can often stifle innovation, slow down project timelines, and increase operational costs. A recent joint initiative by the government and entrepreneurs, led by Rafal Brzoska, CEO of Inpost, to introduce deregulation amendments, is a promising development that we are closely monitoring. So far, 24 proposals have been presented, with more expected, aimed at simplifying the regulatory environment. However, until these changes are implemented, the existing bureaucratic challenges remain a concern.

CEELM: What trends do you expect to shape the banking sector in Poland in 2025?

Nerwinski: Banks in Poland, like their counterparts in the EU, are expected to expand their green finance offerings. This includes providing green loans, which are specifically designed to fund environmentally friendly projects such as renewable energy installations, energy efficiency improvements, and sustainable agriculture.

ESG criteria are becoming integral to banks’ lending and investment decisions. This approach aligns with broader EU policies and frameworks promoting sustainability. Consequently, we see many corporate financings in the form of sustainability-linked loans, which allow for reduced loan pricing if the borrower achieves certain ESG targets. Despite changes in policy direction in other parts of the world, such as the potential departure from ESG principles under former President Trump, the EU, and Poland are expected to maintain their commitment to sustainability. This continued focus reflects the broader European commitment to the Paris Agreement and the European Green Deal, which aim to make the EU climate-neutral by 2050.

At the same time, economic conditions – including interest rates and inflation, as well as geopolitical factors – will continue to influence the banking sector. Banks will need to navigate these uncertainties while managing risks and capitalizing on opportunities in the market. As economic and geopolitical factors evolve, regulatory frameworks may also change, requiring banks to adapt quickly. Staying compliant while remaining competitive will be a key challenge for the sector.

CEELM: What is the biggest challenge for the banking sector in Poland at the moment, in your view, and what is the likelihood you’ll see it overcome in 2025?

Nerwinski: While Poland’s economy thrives, local banks face headwinds in their lending activities. Regulatory pressures, the high cost of CHF loan portfolios, and recent government interventions have added to these pressures. “Loan holidays,” initiated to support households in times of economic distress, have historically weakened bank revenues, complicating their lending strategies. As the economy continues to recover, there may be less need for government interventions like loan holidays, allowing banks to stabilize their revenue streams.

Another challenge is high interest rates. While interest rates have stabilized at relatively high levels, they enable lenders to report record-breaking financial results in the short term. However, the downside of the high-interest rate environment is its impact on borrowing costs and loan demand. As a result, the number of new financing transactions is lower compared to times of low rates. Most analysts expect interest rate cuts on the Polish Zloty to occur only in the second half of the year, and these will not be significant reductions.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

ZSP Advokati Partner Jelisaveta Stanisic talks about banking and finance in 2025 in Serbia.

CEELM: What is in the pipeline in terms of legislation that you believe will have the most impact on the banking/finance sector in Serbia?

Stanisic: There are two key legislative developments in Serbia’s banking and finance sector. First, lawmakers are working on a draft law on real estate investment trusts (REIT). When it enters into force, the legislation will represent a significant upcoming regulatory change for Serbia’s financial markets.

This framework will establish the first regulated vehicle for capital market-based real estate investment in Serbia. The legislation aims to transform traditional property investment practices by providing a market-based alternative to direct real estate ownership.

Secondly, the forming of the working committee for updating FX legislation hints at potential updates and modernization of FX regulations. However, given the early stages, the scope and impact of these planned changes are yet to be seen.

CEELM: Of the above, which ones are you/your clients most excited about and why?

Stanisic:  We expect that the REIT legislation will generate substantial interest among investors. Serbia’s culture has historically favored real estate investments, but this has been limited to direct property acquisitions.

The new framework promises to enhance market liquidity through securities trading while offering tax incentives and broader access to diverse real estate portfolios. Despite the underdeveloped state of local capital markets, regulators anticipate that the combination of liquidity benefits and tax advantages will attract significant investor interest.

CEELM: On the flip side, which ones are you/your clients dreading the most and why?

Stanisic: In my view, market participants have not expressed significant concerns regarding upcoming legislative changes, suggesting the reforms are viewed as market-enhancing rather than restrictive.

CEELM: What trends do you expect to shape the banking sector in Serbia in 2025?

Stanisic: Several key developments are expected to shape the sector. We expect to see an expansion of capital markets debt through anticipated dinar-denominated bond issuances.

There will also be a potential entrance of leading Serbian companies into international bond markets – a trend already kickstarted in the second half of 2024 by Telekom Serbia’s Eurobond issuance. Additionally, we expect intensified competition among banks in the prime borrower segment.

CEELM: What is the biggest challenge for the banking sector in Serbia at the moment, in your view, and what is the likelihood you’ll see it overcome in 2025?

Stanisic:  I believe that the primary concern centers on the potential economic impact of the current political climate. There are concerns about possible economic deceleration, though the banking sector remains optimistic about maintaining stability.

The combination of new investment vehicles, particularly REITs, and evolving market dynamics suggests a period of significant development for Serbia’s financial sector.

While challenges exist, the institutional framework appears sufficiently robust to support continued market development. 

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

ACI Partners  Legal Manager Carolina Parcalab talks about competition in Moldova in 2025.

CEELM: Do you expect the competition authority to be more or less active in 2025 compared to 2024? Why?

Parcalab: We expect the Competition Council to be more active, mostly because of Moldova’s EU accession plans and the high expectations placed on the council. Right now, it has a twinning project ongoing with three authorities from the EU – Romania, Poland, and Lithuania – all working together to enhance the institutional capacity of our council. This means that, in the near future, we can expect an increase in the quality of enforcement techniques, more investigations, and more market studies.

We can also see how the Competition Council is already active in pursuing enforcement – just in the first two months of 2025, a couple of significant investigations were closed, resulting in high fines. One concerning price-fixing in the sunflower oil sector ended with a total fine of up to EUR 10 million for both entities involved. Another significant case was a bid-rigging cartel for public procurement, resulting in fines for four companies that coordinated their conduct.

Undoubtedly, enforcement actions are intensifying, and companies operating in Moldova must prioritize competition compliance.

CEELM: What is in the pipeline in terms of legislation that you believe will have the most impact on competition in Moldova?

Parcalab: We expect activity to be high in this regard as well – again, due to the EU accession process and ongoing harmonization plans. According to the most recent plan, we have more than 120 EU acts that require transposition into Moldovan legislation in the next two years.

The most important one of these additions on the horizon is focusing on merger controls. Stronger rules are expected and the Competition Council has already produced the required regulatory changes, with the economic concentration framework expected to be tightened up soon. With fewer interventions, as a result of higher thresholds, we expect to see activities that carry more significant market impact.

Also, we expect stricter oversight when it comes to state aid – legislative updates are likely to occur in this regard too. We anticipate that the Competition Council will enhance its enforcement technique by implementing digital solutions and forensic technology, meaning that it will be better poised to screen anti-competitive behavior.

CEELM: What trends do you expect to impact competition practices across Moldova the most in 2025?

Parcalab: The most significant one is related to the accession to the EU. This is, by far, the biggest trend that will influence the markets. Moldovan legislation will be aligned with the EU acquis, and we will definitely see more stringent enforcement.

Moreover, increasing the institutional capacity of the Competition Council will become more evident. Experts involved in the ongoing overhaul of the council are engaged in actively training the council staff, and the ripple effect will be felt in all facets of its activities. Additionally, the council will engage in increased cooperation with its international counterparts, which will improve its efficiency.

Crucially, the council will likely continue to prioritize investigations in the agricultural market, putting a stronger focus on it as well as on the retail industry. These industries have, so far, been highlighted as being of high interest, not just by the council but also by other public authorities as these are often faced with more nuanced issues that require immediate action.

CEELM: What would you identify as the main challenges faced by companies in terms of competition matters at the moment in Moldova, and how likely is it in your view that these challenges will be addressed in 2025?

Parcalab: Uncertainty in enforcement. I don’t think it will be possible to tackle this in 2025, especially with the new rules that will first need to be interpreted and then subsequently applied. This might cause some hiccups, especially seeing how the hitherto competition practice has been, at times, inconsistent. Having said that, the dealings of the council will offer much-needed clarity.

Another challenge is symbolic investigations – even the ones that end with high-profile decisions. Some businesses argue that actual structural issues continue to persist and remain unresolved. It isn’t clear if 2025 will be the year when this changes, but there is a demand for better transparency and stronger enforcement tools, all of which means that businesses will need to stay more alert in order to ensure compliance.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Nestor Nestor Diculescu Kingston Petersen Partner Anca Diaconu talks about competition in Romania in 2025.

CEELM: Do you expect the competition authority to be more or less active in 2025 compared to 2024? Why?

Diaconu: Last year witnessed intense activity from the Romanian Competition Council (RCC) on all fronts: the highest number of finalized investigations in seven years, hefty fines for diverse traditional antitrust practices, investigations, and dawn raids in novel areas of competence, as well as, transaction-wise, the highest number of cleared mergers in 21 years. The application of the FDI screening regime stood out yet again, with 471 transactions reviewed in 2024. We expect the tight enforcement trend to continue in 2025. The authority has been signaling this at conferences and its actions at the beginning of this year only confirm it – with several new sanctions or investigations being announced in January and February. The authority has been laying the foundation for this in previous years by extending its toolkit at the statutory level. We therefore expect more enforcement on grounds such as the exploitation of superior bargaining positions or the unfair trading practices in the food and agricultural supply chains.

CEELM: What is in the pipeline in terms of legislation that you believe will have the most impact on competition in Romania?

Diaconu: The competition legislation has already undergone several rounds of amendments, partly motivated by the need to ensure the full transposition of the ECN+ Directive. This led to increased powers for the authority, such as the competence to conduct announced inspections or dawn raids outside an investigation. Although additional changes are currently under discussion as to the antitrust regime (mostly on procedural aspects), perhaps the most influential project is represented by the draft guidelines concerning FDI screening. The document seeks to address some of the most pressing uncertainties associated with the interpretation of this broadly drafted regime, including rules for value computation – which is one of the two cumulative conditions triggering a filing obligation, and guidance on the filing process. These are currently under public consultation until mid-March – stakeholders are invited to make their views heard until then.

CEELM: What trends do you expect to impact competition practices across Romania the most in 2025?

Diaconu: Quite predictably, the enforcement trend in Romania is influenced by that at the EU level. The authority has investigations ongoing in the tech/digital sector, which has been at the forefront of the European Commission’s efforts lately and will be particularly interesting to follow. While debates were ongoing as to the standard of proof in abuse of dominance cases at the European Commission’s level, the RCC – although continuing to also make use of the tools related to the abuse of dominance – started to enforce the provisions relating to exploitation of superior bargaining position. Investigations were launched, and dawn raids were conducted against companies that, albeit falling short of dominance, allegedly abused an imbalanced relationship with trading partners. These concerns include diverse markets and activities, including dietary supplements, medical oxygen, and car repair shops. FDI screening also deserves a special mention – against the backdrop of increased scrutiny at the European level, we see no relaxation of the rules on the horizon.

CEELM: What would you identify as the main challenges faced by companies in terms of competition matters at the moment in Romania, and how likely is it in your view that these challenges will be addressed in 2025?

Diaconu: From our experience, companies at the EU level more broadly are concerned about the level of predictability associated with competition enforcement. Faced with novel practices or areas of priority/concern, authorities struggle to adapt the traditional tools to modern-day realities. In this pursuit – which may be a legitimate one – enforcers should not sacrifice predictability and smooth decision-making/clearance, which are essential to fostering innovation and bolstering investments.

In recent years, companies were kept particularly busy by the interpretation/application of the FDI regime – which, being national security-centered, was designed to catch various fields and activities under its scope. The authority has taken steps in the right direction with the expected guidelines. As always, the devil is in the details, and it will be essential to see the level of granularity addressed in the final version of these guidelines.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Actecon Knowledge Counsel Hanna Stakheyeva talks about competition in Turkiye in 2025.

CEELM: Do you expect the competition authority to be more or less active in 2025 compared to 2024? Why?

Stakheyeva: I expect the Turkish Competition Authority to remain just as active in 2025 as it was in 2024, with no signs of slowing down. Statistics indicate a significant rise in investigations – nearly double compared to 2020 – particularly in dawn raids, which have surged by 65%. This trend is likely to continue, especially as Turkiye closely monitors and aligns with EU competition policy developments. The emphasis on digital market regulation and the introduction of the new Leniency Regulation, and Guidelines on Competition Infringements in Labor Markets are expected to drive further investigations and cases. Additionally, the relatively new technology undertaking exception will continue to sustain high merger control activity, particularly in the technology-driven sectors. These factors reinforce my view that the TCA will remain highly active.

CEELM: What legislative developments will have a significant impact on competition in Turkiye in 2025?

Stakheyeva: One to watch for is the Regulation on Fines, which has changed how the competition authority assesses fines. Previously, there were fixed percentages. Now, fines will depend on the authority’s discretion and will vary case by case. Together with the new Leniency Regulation, which may influence incentives for businesses to self-report violations, we may see a shift in enforcement dynamics. The technology undertaking exception to merger control thresholds (introduced in 2022) is another piece of legislation that impacts competition enforcement in Turkiye. It aims to ensure that M&A in the technology sector is properly scrutinized and was designed primarily to address the growing concern over “killer acquisitions.”  It exempts certain transactions from the Turkiye-related turnover thresholds once the target is classified as a technology undertaking. Since the criteria for determining what qualifies as a “technology undertaking” are not always clear, many companies are still unsure about which transactions need to be notified. Additionally, new long-awaited Guidelines on Competition Infringements in Labor Markets are anticipated to impact enforcement activities. They clarify how competition law applies to labor market practices, particularly concerning wage-fixing, no-poaching agreements, and the exchange of sensitive employee information. Lastly, the draft DMA-like amendments to the Turkish Competition Law, once adopted, will directly impact big platforms and undertakings with significant market power by imposing ex-ante obligations on them, mirroring to a large extent EU rules.

CEELM: What trends do you expect to impact competition practices across Turkiye the most in 2025?

Stakheyeva: Sustainability is gaining regulatory attention, though no specific rules exist yet for assessing sustainability agreements. The TCA evaluates such agreements under the general principles of the Turkish Competition Law, balancing their competitive effects against environmental benefits. For example, in a recent case involving detergents, environmental benefits justified what initially seemed like restrictive practices. As part of the TCA’s Strategic Plan 2024-2028, green transformation is among the key areas of focus, encouraging eco-friendly collaborations among competitors. It also considers permitting non-compete clauses over five years for resellers if manufacturers commit to significant environmental investments and redefining automotive markets to reflect electric vehicle advancements and green policies. Another trend is the growing focus on data-related competition issues. Cases involving data portability and algorithmic pricing are on the rise, and the authority has already emphasized that misuse of data can be considered an abuse of dominance. Additionally, regulatory collaboration is intensifying, with the TCA and Public Procurement Authority partnering on integrating AI tools to detect anti-competitive behavior and enhance data analysis, which helps enforcement. 

CEELM: What would you identify as the main competition challenges faced by companies in Turkiye in 2025?

Stakheyeva: One major challenge is the uncertainty around merger control, particularly with the technology undertaking exception to the merger control thresholds. As mentioned, companies often struggle to determine whether they need to notify the TCA due to uncertainty about what a technology undertaking is. Another big challenge for companies is navigating competition compliance in rapidly evolving digital markets. Digital platforms face heightened scrutiny, particularly regarding self-preferencing, algorithmic pricing, and data use. The lack of clear rules creates legal and operational uncertainties. Additionally, the interplay between competition and intellectual property laws in search-based advertising is a complex and debated issue. A key challenge for businesses in Turkiye is balancing the protection of trademark rights with compliance with competition law. While brand owners may seek to prevent competitors from bidding on their branded keywords, overly broad restrictions can limit consumer choice and distort competition. Negative keyword matching further complicates this by potentially reducing the visibility of rival brands and narrowing market options. Finally, expanding competition law into non-traditional areas, such as labor markets and sustainability, imposes additional compliance responsibilities for businesses. While some challenges may be addressed in future TCA guidelines, no concrete steps have been announced for 2025. Some issues may be resolved once the draft DMA amendments to the Turkish Competition Law take effect, but the timeline remains uncertain. Given this, businesses should focus on proactive compliance to navigate such regulatory uncertainties and mitigate enforcement risks.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Redcliffe Partners Partners Denys Medvediev and Yuriy Terentyev talk about competition in Ukraine in 2025.

CEELM: Do you expect the competition authority to be more or less active in 2025 compared to 2024? Why?

Terentyev: Since the full renewal of its operations in June 2022, the AMCU has been striving to reach the same capacity level as it was before Russia’s full-scale military invasion of Ukraine. We observed some capacity constraints faced by the AMCU in 2022-2023, but things improved in 2024. Currently, the review of filings within multi-jurisdictional projects goes smoother and within a more predictable time frame.

In 2022-2023, many law firms faced a spike in rejections of merger filings, even those believed to be “non-problematic.” Such actions resulted from the AMCU’s inability to effectively handle the incoming workload as a consequence of a shortage of personnel. Meanwhile, the rate of filings in our practice accepted without initial rejection increased significantly in 2024, the same as the number of filings that fell under the fast-track procedure. We optimistically expect that the AMCU intends to keep positive dynamics in 2025.

CEELM: What is in the legislative pipeline that will have the most impact on competition in Ukraine?

Medvediev: The general trend is the further approximation of the Ukrainian competition legislation with the EC’s acquis communautaire. In 2023-2024, the AMCU introduced a settlement procedure for cartels and abuse of dominance cases, improved its leniency policy, set up clear deadlines for investigations, enhanced the merger control procedure, and kept working on further development of state aid rules.

Among next steps, the AMCU intends to abolish the procedure for obtaining approvals for concerted practices, establish clear rules for the application of structural remedies, and introduce periodic penalty payments for continuing and future violations. Besides, the AMCU is now elaborating on the further introduction of a concept of abuse of superior bargaining position and strengthening the parties’ procedural rights within investigations.

CEELM: What trends do you expect to impact competition practices across Ukraine the most in 2025?

Terentyev: Even though the AMCU does a lot to ramp up its operations, it still has to reckon with its limited resources and allocate them as efficiently as possible. Ex officio investigations and market studies remain rare. Traditionally, there is intense enforcement around bid rigging. Last year, we also saw the first leniency case under the new procedure. We see a renewed attention to pharmaceutical markets. Having in mind strong statements at the top political level on the allegedly excessive price increases and limitation of competition in such markets, we anticipate further enforcement actions. The probability of elections in Ukraine may traditionally spur the AMCU’s attention to other socially sensitive topics like fuel and energy prices and utility tariffs.

We also see a growing interest in digital markets. The AMCU has investigated the unilateral conduct of BlaBlaCar, an operator of an online platform for carpooling services. The AMCU established that BlaBlaCar imposed service fees on passengers without sufficient economic justification and applied inconsistent refund policies when drivers canceled rides. The investigation ended with recommendations for BlaBlaCar to introduce a transparent fee methodology and non-discriminatory refund policy. The AMCU’s arguments in the case look rather controversial (apparently due to a lack of the AMCU’s expertise on digital markets and insufficient legal framework for digital platforms in Ukraine, meaning the AMCU had to apply conventional rules, not perfectly suited for digital markets).

The AMCU is also refining its approach to unfair competition cases to focus on those with clearer effects on competition. It tends to reject claims if the negative effect on competition is minor, even if the misleading character of advertising is obvious. Besides, the AMCU’s activity in detecting unfair competition violations has an industry focus that changes from time to time – currently, it is pharmaceuticals and related products. 2024 ended with several fines imposed for spreading misleading information on the alleged therapeutic effect of dietary supplements and cosmetics. Foods and beverages are also under the AMCU’s spotlight. We expect that in 2025, all these sectors will remain interesting for the AMCU, but the focus may shift slightly to other sectors.

CEELM: What would you identify as the main challenges faced by companies in terms of competition matters at the moment in Ukraine in 2025?

Medvediev: Among numerous challenges, we would like to focus on those related to merger control. Ukrainian thresholds are still low and catch deals with no or limited local nexus. Applicants may still face excessively formalistic treatment of certain concentration aspects beyond its substantive analysis (e.g., regarding confirmation of financing). Also, the AMCU’s lack of expertise in certain areas, such as digital markets, may increase scrutiny of a filing. And last but not least, the amount of fines for failure to notify/gun-jumping remains quite unpredictable.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Hristov & Partners Partners Pavel Hristov and Dragomir Stefanov talk about M&A in Bulgaria in 2025.

CEELM: What would be your bet at this start of the year – will 2025 see more, fewer, or the same level of activity in terms of M&As in Bulgaria?

Hristov: 2025 will likely be very different. As an open market economy, Bulgaria will be exposed to various external negative influences (unprecedented turbulence in geopolitics and global and EU economy) but also internal challenges (budget deficit, inflation, and a drop in FDI). There will be more political and economic uncertainty and instability than usual.

We have coped with crises and difficult times, even hyperinflation, in Bulgaria before. We can safely assume that M&A activity will remain at the same level or slightly lower in terms of volume. Several larger cross-border deals, such as Russia’s Lukoil exit from its oil refinery and retail gas stations and e& PPF Telecom’s potential buyout of United Group’s Bulgarian businesses, if successfully closed, may result in a higher total deal value year to year.

CEELM: What do you believe will be the main elements determining the results at the end of the year?

Hristov: Several industries will continue to outperform the overall economy and will generate the majority of the deals: technology, energy, and industrials, in particular manufacturing and production. 2024 was a difficult year for export-oriented industries. Many customers reduced or canceled their purchase orders. Consequently, the 2024 financial results of many fast-growing Bulgarian suppliers suffered. They had very optimistic expectations and financial projections in 2023-24, but the reality of the actual results was sobering. This will help set more reasonable sellers’ expectations and bridge the valuation gap that persisted in 2024. More sellers will adjust their valuations and price tags and this will facilitate the completion of more deals in 2025.

We also expect more PE and VC deals and funding rounds. Bulgaria has been overlooked in the last couple of decades compared with our neighbors, but we see increased and growing interest in some major global and regional PE and VC funds.

CEELM: Are there any pieces of legislation on the horizon that you are keeping an eye on as potentially impacting the M&A market in 2025?

Stefanov: Bulgaria is finalizing the implementation of its FDI screening regime and we expect it to be fully operational in the second half of 2025.  At the end of January, the Rules of Procedure for the FDI Screening Council were adopted. The next key step is the approval of amendments to the Rules of Implementation of the Investments Promotion Act, which will outline the procedures for submitting and processing FDI applications, clarify the allocation of responsibilities among the administrative bodies involved in the screening, and establish the criteria for electing council members. However, the current legal framework raises challenges regarding transparency and predictability, as there will be limited access to documents related to the council’s activities. Coupled with restricted access to the council’s minutes, correspondence, members, secretariat staff, and experts, this will likely complicate external understanding of the criteria and timelines governing the decision-making process.

CEELM: Who do you expect to be the main buyers in Bulgaria in 2025?

Hristov: We expect mostly financial buyers, PEs, and VCs in the non-regulated sectors, and strategic buyers in the regulated industries like energy, telecoms, and media but also in industrials/manufacturing.

CEELM: What do you expect will be the most attractive targets in Bulgaria in 2025, and what will make them so?

Hristov: Tech start-ups and scale-ups – in areas such as gaming, fintech, e-commerce, enterprise software, mobility, and professional services. Renewable energy and logistics companies will continue to consolidate.

Stefanov: Deal-making in Bulgaria’s commercial real estate sector was strong in 2024, with transaction volumes reportedly exceeding EUR 360 million, driven by active investment in office spaces and retail properties. Looking ahead to 2025, the momentum is expected to continue, with the completion of over 100,000 square meters of new retail park space further fueling the market.

Hristov: As always, the most attractive targets will be those that have global or international and scalable business models, the best of class products or services and exceptional teams, have credible growth perspectives, and have won a sustainable book of business or even a solid market share in the most lucrative foreign markets: the US, major EU markets, the UK, Canada, Japan or China. We confidently believe that there are at least a handful of such businesses in Bulgaria and are prepared to act on those deals when they materialize.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.

Drakopoulos Senior Associate Sofia Angelakou talks about M&A in Greece in 2025.

CEELM: What would be your bet at this start of the year – will 2025 see more, fewer, or the same level of activity in terms of M&As in Greece?

Angelakou: The outlook for mergers and acquisitions in Greece is promising, with an anticipation of more deals compared to previous years.

At the same time, one cannot overlook the significant increase in corporate transformations and restructurings, with companies opting for demergers, spin-offs, or other divestitures as part of their strategy.

CEELM: What do you believe will be the main elements determining the results at the end of the year?

Angelakou: Greece’s commitment to reform over the past decade, together with its success in meeting significant fiscal targets, has restored confidence and attracted investors.

By the end of 2025, global macroeconomic conditions, geopolitical challenges, as well as the country’s increased focus on ESG principles and digital transformation and innovation will shape the M&A landscape in Greece.

CEELM: Are there any pieces of legislation on the horizon that you are keeping an eye on as potentially impacting the M&A market in 2025?

Angelakou: Although there is no specific stand-alone legislation governing M&A activity in Greece, it is essential to closely monitor the legal and regulatory environment, as changes in tax, labor, and competition laws, as well as ESG regulations and digital transformation, will play a key role in shaping investment activity, particularly if the target company’s operations are in the energy, technology, real estate, or tourism sectors.   

CEELM: Who do you expect to be the main buyers in Greece in 2025?

Angelakou: The current investor landscape includes international strategic buyers (particularly from the US, EU, and the Middle East) as well as PE investors (both local and international). Also worth noting are well-funded local companies seeking to consolidate their operations and optimize their core businesses.

What all investors have in common is their high level of knowledge, expertise, and sophistication in negotiating the structure, terms, and timeframe of each transaction and implementing a risk-based approach in their dealings to minimize potential risks.

CEELM: What do you expect will be the most attractive targets in Greece in 2025, and what will make them so?

Angelakou: In 2025, the most attractive M&A targets in Greece are expected to be in sectors with high growth potential that align with global trends, including logistics, technology and digital transformation, energy (especially with a focus on renewables), tourism, and real estate.

Not only do these sectors align with emerging global shifts, but they also capitalize on Greece’s strategic location, available EU funding, and strong growth potential.

This article was originally published in Issue 12.1 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.