Failure to respond to an AMCU information request may result in a fine of up to 1% of annual turnover

A letter from the Antimonopoly Committee of Ukraine is not a document that a business can simply set aside and answer whenever convenient.

On 4 September, the South-Eastern Interregional Territorial Office of the AMCU published preliminary findings in a case involving a private enterprise.

According to the AMCU, the company failed to provide information within the prescribed deadline in response to an official request from the territorial office.

The most significant issue is the potential liability.

The AMCU proposes imposing a fine of up to 1% of the revenue from the sale of products, goods, works, and services for 2025.

In other words, the fine may depend not on the value of the particular transaction of interest to the Committee, but on the company’s annual revenue.

For a company with annual turnover of UAH 100 million, a potential 1% fine would amount to as much as UAH 1 million.

For a company with turnover of UAH 500 million, it could reach UAH 5 million.

And all of this may arise simply from failing to provide information at the AMCU’s request.

Under the Law of Ukraine “On Protection of Economic Competition,” failure to provide information to the Antimonopoly Committee or its territorial office within the prescribed deadline constitutes a separate violation of competition law.

Therefore, businesses should understand that even if a company believes it has committed no violation, this does not mean that an AMCU request may be ignored.

Upon receiving a request, it is necessary to immediately verify:

– who issued the request and within what authority;
– what information the AMCU requests;
– the period covered by the request;
– the deadline for the response;
– whether the company possesses all requested information;
– whether the documents contain commercial confidential information or other restricted-access information;
– how to prepare the response correctly so that it does not itself create additional risks for the company.

There is one more important point.

In this specific case, no final decision to impose a fine has yet been made.

The AMCU has published preliminary findings. The company has the right to submit its explanations, objections, and evidence, and the hearing is scheduled for 17 September 2026.

This is a useful example of why legal protection is needed not only after a fine has already been imposed.

Sometimes, the most important stage is responding appropriately to the very first request from a public authority.

You can seek legal advice now rather than need legal representation later.

Have you received a request from the AMCU or another supervisory authority and are unsure how to respond properly?

📞 Call: 096 574 81 02
📧 Email: info@uk-winner.com

Author — Maksym Bahniuk, Head of the Tax and Customs Law Practice at WINNER Law Firm.