IMPACTA LAW successfully represented one of Ukraine’s fuel station networks in proceedings before the Antimonopoly Committee of Ukraine concerning the use of partner fuel station networks in public procurement. The case, which involved the risk of a competition law infringement finding and a fine, concluded for the client with recommendations from the regulator only.
The case followed a market study launched by the AMCU in January 2025 into the light petroleum products markets. As part of the review, the Committee examined provisions of partnership agreements between fuel station operators that allowed fuel cards to be used across partner networks but required a partner’s consent for their use in public procurement. The AMCU considered that such arrangements could bear signs of anticompetitive concerted practices, as they could restrict the number of bidders and make one operator’s participation in a procurement procedure dependent on the approval of a competitor.
In a broader context, the case concerns the balance between efficient cooperation models in the fuel market and compliance with competition rules. Partner networks allow operators to expand their geographic coverage and provide access to fuel across different regions of Ukraine, which is particularly important for public procurement, critical infrastructure operations and continuity of fuel supply.
The IMPACTA LAW team represented the client throughout the proceedings and its engagement with the AMCU. The lawyers combined expertise in competition law and public procurement, economic analysis, and a deep understanding of the fuel market to assess the client’s conduct amid market volatility, supply chain disruptions, and other external factors.The matter demonstrates IMPACTA LAW’s experience in complex competition investigations involving critical markets. This is particularly important in large-scale investigations, where assessing an individual market participant’s conduct requires a clear understanding of the broader market context and the factors affecting the conduct of a business entity.
Following the review, the Committee did not impose fines but recommended that the respondents amend the relevant provisions of their partnership agreements and refrain from including similar provisions in the future.
The IMPACTA LAW team working on the matter included Partner Viacheslav Korchev, Counsel Nataliya Kovalova, and Associate Yaroslava Liamchenko.
