Main Developments in Competition Law and Policy 2025 – Cyprus

Overview

2025 proved to be another active year in the field of competition law and policy in Cyprus. The Commission for the Protection of Competition (CPC) maintained an assertive enforcement stance across its key areas of responsibility, with significant developments in merger control, cartel enforcement, sector inquiries and judicial review. The CPC concluded several complex investigations, imposed major administrative fines, and conditionally approved a high-profile acquisition in the energy sector. The authority also pursued legislative reform and capacity building in collaboration with international partners. Altogether, these developments reflect the CPC's continued evolution as a robust and sophisticated enforcement body aligned with European Union competition standards.

Legislation

The principal laws governing competition in Cyprus remain the Protection of Competition Law of 2022 (Law No. 13(I)/2022) and the Control of Concentrations Between Undertakings Law of 2014 (Law No. 83(I)/2014).

In 2025, the CPC initiated a public consultation on the draft "Control of Concentrations Between Undertakings (Amending) Law of 2025, inviting comments from stakeholders between 15 September and 20 October. The draft legislation introduces proposed amendments to modernise the legal framework, including changes to the scope of application of the merger control regime and adjustments to notification thresholds. Additional provisions seek to align the law with applicable EU regulations and to strengthen the CPC's investigative and enforcement powers. Notably, the amendments aim to improve procedural efficiency, reinforce transparency in decision-making, and enhance the CPC's ability to assess transactions with cross-border implications.

The CPC also issued a supplementary announcement in April 2025 on the designation and handling of business secrets and confidential information submitted by undertakings during investigations and proceedings. The guidance complements previous announcements from 2022 and aims to support both effective enforcement and the protection of sensitive commercial data, in line with data protection legislation.

Notable Judgments

Three key judgments were delivered in 2025.

In June 2025, the Administrative Court dismissed an appeal brought by the Cyprus Telecommunications Authority (CYTA) against a CPC decision issued in 2020. The CPC had imposed a fine of €1,1m for abuse of dominance, specifically predatory pricing and the bundling of broadband and television services. The Court rejected CYTA’s procedural and substantive arguments, including challenges to market definition, dominance findings and the fairness of the proceedings. The judgment reinforced the CPC’s approach to addressing exclusionary practices in the telecommunications sector.

In a separate ruling in May 2025, the Administrative Court upheld a 2020 CPC decision against Hermes Airports Ltd concerning the abuse of its dominant position at Larnaca International Airport. Hermes had imposed unfair pricing terms on independent valet parking providers, restricting their ability to compete in the downstream market. The Court confirmed the CPC’s market assessment and dismissed claims of procedural irregularities, including arguments regarding the withdrawal of complaints by the affected parties.

Earlier in the year, the Administrative Court dismissed the appeal brought by HENKEL AG & Co KGaA and GPM HENKEL Ltd against a joint administrative fine of €3,3m. The CPC had found that the undertakings abused their dominant position by restricting parallel imports and interfering with the activities of independent distributors. The Court rejected all grounds of challenge, including issues of procedural fairness, jurisdiction and proportionality of the fine. The case is notable for its emphasis on maintaining open intra-EU trade and sanctioning market foreclosure strategies.

Investigations and Fines

In one of the most significant enforcement decisions of the year, the CPC concluded a long-running investigation into anti-competitive practices in the ready-mix concrete and aggregates markets. Following a review of conduct between 2010 and 2014, the CPC imposed total administrative fines of €1,947,140.71 against a number of companies active in the production, distribution and placement of ready-mix concrete. The CPC found four distinct infringements of Article 3(1) of the 2008 Competition Law, including price fixing and output restrictions (in the form of several companies having coordinated on pricing and production quotas in the Limassol district), market allocation and conditional contracting by undertakings found to have engaged in customer allocation practices and linked contracting to prior debt repayment, bid rigging through competitors having exchanged pricing information in connection with bids for the Limassol Port passenger terminal, and coordination in the aggregates sector through suppliers of aggregates colluding to fix prices and control output volumes.   The CPC imposed fines on each participant proportionate to their role and turnover. In addition to the fines, the CPC issued cease-and-desist orders and underscored the importance of compliance, particularly in markets critical to infrastructure development.  It is expected that these decisions will be challenged before the Administrative Court.

Elsewhere, the CPC exercised its investigatory powers through dawn raids conducted on 15 May 2025 at the premises of a business active in the retail market for fresh lamb and goat meat and at the offices of the Pan-Cyprian Butchers Association. These inspections were part of an ex officio investigation into possible collusion in pricing or supply arrangements in breach of Article 3(1) of Law 13(I)/2022 and Article 101 TFEU.

Concentrations

Perhaps the most important development in 2025 was the CPC’s conditional approval of the acquisition of ExxonMobil Cyprus Limited by Petrolina (Holdings) Public Limited. The transaction, notified in February 2025, raised concerns regarding its potential effects on competition in the downstream fuel distribution and retail markets and the CPC initiated a full Phase II investigation. Following extensive engagement and market testing, Petrolina offered a set of binding commitments to address the CPC’s concerns which were considered satisfactory by the CPC. These included divestment or closure of 21 fuel service stations, non-reacquisition clauses for a period of ten years and geographic restrictions on re-entry, third-party access to fuel storage infrastructure at Petrolina's Vasiliko terminal for a minimum of two years, firewalls and internal compliance protocols to prevent information exchange across vertical levels, retention of existing third-party service contracts and restrictions on the imposition of exclusivity arrangements, a prohibition on exclusive lubricant supply agreements for a ten-year period and the appointment of an independent Monitoring Trustee. The CPC declared the concentration compatible with the functioning of competition under Article 28(1)(a) of the Law, subject to these commitments. The case sets an important precedent in the energy sector in Cyprus and demonstrates the CPC's increasing sophistication in merger analysis.

Sector Inquiries

In 2025, the CPC launched a sector inquiry into the ready-mix concrete market in response to reports of price increases and public concern. The inquiry, which follows the concrete cartel investigation, aims to collect information about market structure, pricing practices and supply conditions. While the inquiry does not allege wrongdoing, it serves as a fact-finding tool to identify potential barriers to competition.

The CPC also played a key role in a European initiative aimed at combating bid rigging in public procurement. In October 2025, it hosted three workshops in cooperation with the OECD and the European Commission (DG REFORM). The workshops, targeting the private sector, oversight authorities and the judiciary, focused on enhancing compliance, identifying collusive practices and improving judicial oversight in tender procedures. The events formed part of a wider EU-funded programme covering six Member States, including Cyprus.

Looking ahead in 2026

The CPC's activity in 2025 underscores its commitment to effective enforcement, legal certainty and market transparency. The authority's approach to merger control, cartel enforcement and legislative reform reflects its ongoing alignment with EU standards and its responsiveness to domestic economic priorities.

Looking forward, the CPC is expected to maintain its enforcement momentum in 2026, with continued focus on sectors such as construction, retail, health and public procurement. Businesses operating in or through Cyprus should continue to monitor CPC developments closely and ensure robust compliance frameworks are in place, particularly in the context of mergers, distribution arrangements and pricing strategies. The ongoing legislative reform and recent judgments further emphasise the importance of proactive legal risk assessment in a maturing and increasingly rigorous competition environment.