Accounting Chamber of Ukraine: Annual Report of the AMCU Should More Fully Disclose the Impact of the Committee's Activities on the State Budget

On 10 August 10 2026, the Accounting Chamber of Ukraine approved the Report on the Results of the Analysis of the Annual Report of the Antimonopoly Committee of Ukraine for 2025, specifically regarding aspects affecting the execution of the State Budget.

For reference: the AMCU is a state body with special status, established to ensure state protection of competition in business activities and the public procurement sector. Its main task is to participate in the formulation and implementation of competition policy.

In accordance with the legislation, the Antimonopoly Committee of Ukraine submits an annual report on its activities to the Verkhovna Rada of Ukraine by 15 March. Prior to the consideration of the report at Committee meetings and plenary sessions of the Verkhovna Rada of Ukraine, the Accounting Chamber of Ukraine conducts its preliminary analysis in the part that affects the execution of the State Budget.

The analysis conducted by the Accounting Chamber of Ukraine confirmed that the AMCU had submitted and published its report for 2025 in accordance with the requirements of the law. However, its content does not fully disclose the impact of the results of the Committee’s activities on the execution of the State Budget.

The report reflects the significant volume of work undertaken by the AMCU. In 2025, the Committee examined 1 394 cases and identified or terminated 3 120 violations of the legislation on the protection of economic competition, processed 1 315 applications concerning concentrations, and reviewed 9 549 complaints in the field of public procurement.

At the same time, the data primarily characterise the volume of work performed. The report lacks the relevant metrics and analysis needed to assess its effectiveness and impact on the competitive environment and the State Budget.

In view of the legally defined scope of its analysis, the Accounting Chamber of Ukraine separately examined areas directly related to the execution of the State Budget. One such area is imposing and collecting fines.

In 2025, the Committee adopted 1 238 decisions imposing fines totalling UAH 5,9 billion. At the same time, 82% of this amount or UAH 4,8 billion, was accounted for by one decision. UAH 96,8 million or 1,7% of this amount has actually been paid, while decisions on fines totalling UAH 5,1 billion or 87,1% are at the stage of judicial appeal.

As of 31 December 2025, outstanding debt related to fines and penalties imposed under the AMCU decisions amounted to UAH 19,8 billion, representing a 30,5% increase compared to the previous year. This figure excludes UAH 644,7 million in outstanding debt arising from decisions made by inter-regional territorial offices, which the AMCU additionally reported during the analysis. Of the UAH 19.8 billion in outstanding debt, 93% is currently subject to judicial appeal or enforcement proceedings.

The report lacks consolidated information regarding the number of the AMCU decisions overturned by courts, the amounts of the overturned fines and penalties, and their impact on the execution of the State Budget. This makes it difficult to assess the budgetary risks associated with the judicial appeal against the AMCU decisions.

The Accounting Chamber of Ukraine also analysed the indicator of economic effect in the amount of UAH 3,1 billion given in the AMCU report. The applied approach to its calculation is not based on indicators that objectively reflect the results of the AMCU performance results, and does not associate this result with the receipt or use of state budget funds. Therefore, the Accounting Chamber of Ukraine has no grounds to validate it as an indicator of the Committee’s impact on the execution of the State Budget.

During the presentation of the analysis, Member of the Accounting Chamber of Ukraine Gennadiy Plis noted that based on the results of the analysis of the AMCU Annual Report for 2024 the Committee had made amendments to three internal regulations, specifically those concerning the preparation of the Annual Report, the assessment of economic impact, and the monitoring of decision implementation. However, the Annual Report for 2025 still does not provide full disclosure of the results of the AMCU’s activity and their impact on the State Budget.

"The report should reflect not only a list of actions taken by a state body, but above all, a specific, measurable impact of its activities on interests of the state and the State Budget," Member of the Accounting Chamber of Ukraine stated.

Based on the analysis, the Accounting Chamber of Ukraine recommended to:

• the Cabinet of Ministers of Ukraine to assign to the Ministry of Justice of Ukraine analysing the reasons for long-term non-implementation by state executive service bodies of the AMCU decisions regarding the collection of fines and penalties, improving enforcement mechanisms, and strengthening interagency coordination;
• the Antimonopoly Committee of Ukraine to ensure that its annual report reflects the impact of the Committee’s activity on the execution of the State Budget, improve the monitoring of the enforcement of decisions imposing fines, enhance the report's analytical value, and reconsider the approaches used to determine economic impact;
• the Antimonopoly Committee of Ukraine, jointly with the Ministry of Finance of Ukraine, to review the system of performance indicators of the budget program
• according to the code CPCEC 6011010 and supplement it with metrics that reflect the impact of the Committee's activity.

Audit Report and Decision will be sent to the Verkhovna Rada of Ukraine and its Committee on Economic Development with a recommendation to consider them at a meeting, the Cabinet of Ministers of Ukraine, the Ministry of Finance of Ukraine and the Antimonopoly Committee of Ukraine, as well as published on the official website of the Accounting Chamber of Ukraine.