Main Developments in Competition Law and Policy 2025 – Georgia

2025 marked the beginning of the second decade since the Georgian Competition and Consumer Agency (GCCA or Agency) started operating as an independent competition enforcer. Created to satisfy an obligation under the 2014 EU-Georgia Association Agreement on maintaining "an authority responsible and appropriately equipped for the effective enforcement of the competition laws",1 the Agency has continued its commitment to supporting robust competition on national markets and delivering benefits to consumers, primarily by enforcing Georgian Law on Competition ('GLC'). This blog post offers a brief overview of the GCCA's enforcement activities over the past year, discusses key changes in (soft) law, and highlights Agency’s advocacy efforts.

Enforcement Activities

Antitrust

Throughout 2025, the GCCA concluded four investigations. Three of these investigations concerned abuse of dominance (Article 6 of the GLC), and the remaining one investigation concerned both abuse of dominance and anti-competitive agreements (Article 7 of the GLC). The investigations covered multiple markets, ranging from vacation-related online vouchers/discounts offered by commercial banks via specialised online platforms to the wholesale of fresh fish. The Agency finished the year with two infringement and two non-infringement decisions, resulting in overall fines of 1,407,633.01 GEL (approximately 446,868 EUR).2 The above-mentioned decisions highlight two key trends regarding the GCCA's enforcement focus and procedural approaches.

First, 2025 was the year of prosecuting exploitative abuses. Both GCCA infringement cases – concerning selected generic pharmaceutical products and customs clearance-related/parking services offered within Rustavi Car Market (the largest auto-market in the Caucasus region)3 – concerned excessive pricing. Over the past years, the Agency has been increasingly engaging with the relevant markets where healthy competition is especially relevant for vulnerable consumers. In this respect, the 2025 decision regarding pharmaceuticals (named “Case II of Pharmaceutical Market” by the Agency4) has been issued less than two years after the Agency established an Article 7 violation in the same industry (see “Case I of Pharmaceutical Market” that concerned bid-rigging in public procurement regarding oncological medicines).

Second, the GCCA has become significantly bolder in deploying various substantive and procedural tools to support effective enforcement. For example, in assessing the excessive and unfair nature of the prices in both of its infringement decisions, the Agency conducted a detailed review of the existing evidence regarding the cost structures of the relevant products/services. The enforcer used pre-identified calculation methods that were most suitable for the evidence at hand. The Agency explained its rationale for using particular calculation methods in detail. While doing so, it also acknowledged that there was no single “correct” calculation method for excessive pricing cases and clarified to the objecting defendants that it did not need to deploy every existing calculation method, especially if the evidence at hand was not suitable for such an exercise and led to an unnecessary and unfruitful prolongation of the investigation procedure. Similarly, the Agency did not shy away from using the procedural tools available to it, including information requests (issued by judicial orders) and fining powers under Articles 18 and 33 of the GLC, to ensure timely and effective investigations.

Merger Control

2025 has been another active year for Merger Control at the GCCA. The Agency reviewed and cleared eighteen merger notifications across various sectors/markets, including higher education, medical services, construction, warehouse appliances and GPS devices.5 Four notifications required a second phase assessment, leading to eventual approvals. Out of these, one merger – concerning the relevant market of gray cement - was cleared subject to behavioural remedies.

The GCCA also identified fourteen gun-jumping cases, resulting in financial sanctions up to 204 414, 93 GEL (app. 64, 893 Euro) on the acquiring undertakings. The Agency once again clarified that these fining decisions do not absolve concentrating undertakings from submitting information about respective transactions for subsequent approval. Thus, the parties were instructed to submit the relevant notifications for GCCA.

Unfair Competition and Infringement of Competition by State Bodies

For the past two years, the gradual increase in the GCCA’s major antitrust case numbers and merger control enforcement activities have coincided with corresponding decline in the numbers of cases related to Articles 10 (infringement of competition by state bodies) and 11³ (unfair competition) GLC. This is a welcome trend, showing that the Agency is slowly but steadily shifting its focus on major anti-competitive cases involving market players, in the light of raised awareness in and diminished number competition law breaches from the public sector.

In 2025, the GCCA did not complete any Article 10 or Article 11³ investigations.6 For both articles, nine complaints were found inadmissible on substantive grounds, due to the inability to satisfy the standard of reasonable suspicion (a pre-requisite for commencing competition investigations in Georgia).7 Out of these complaints, four concerned alleged breaches of competition by state bodies (public infringements) and the remaining five - unfair competition claims.

2025 also marked a high point of case dismissals on procedural grounds (such as withdrawal or inability to submit relevant information accompanying the complaint). Overall, the GCCA dismissed nine claims related to Article 11³ GLC. It should be noted that dismissing a complaint does not deprive a person of the right to apply to the GCCA on the same subject matter, on the same basis, with the novel request to investigate the issue.

Amendments to the Legislation and Soft Law

The most significant legislative change of the past year concerns the future of the GCCA’s governance structure. In this respect, between 2020 and 2025, the GLC included Articles 17¹ and 18¹ that envisaged a five-member board (the main decision-making body) and an executive director (an entity providing administrative support to the board) leading the Agency, effective from January 2027.8 However, legislative amendments of February 2025 removed these two articles. This change means that GCCA will not have a collegial governance from 2027 onward. Instead, it will be led by the Chairman who is appointed and dismissed by the Prime-Minster of Georgia.9

To a certain extent, the above-mentioned development does not come as a surprise, considering the structural changes associated with a significant expansion of the GCCA mandate between 2020 and 2025. The latter now encompasses implementing legislations on consumer protection, anti-dumping, dispute resolution in public procurement, electronic commerce, and tourism alongside its core functions related to competition enforcement. It could be argued that such broadened mandate (and resulting changes to the structure and operation of the Agency) requires rethinking of the governance style that would be best suited for the enforcer, ensuring the effective administration of all areas under its umbrella. It is hoped that this rethinking process will be legislative priority for the upcoming years.

Other law-related developments include a continuous effort to introduce/amend GCCA guidelines. In 2025, the GCCA focused on antitrust law-related guidelines and investigation/fining procedures. Key developments to this extent include new guidelines on interim measures and amended guidelines on fine calculations. The Agency also continued its “best international practices” series, offering further clarifications related to the substance of Article 6 GLC (abuse of dominance) and Article 7 GLC (anti-competitive agreements) based on the recent case law by the EU Commission and the CJEU.

Competition Advocacy

Market Monitoring

In 2025, the GCCA completed market monitoring for the relevant market of passenger (taxi) transportation services provided via mobile applications (Taxi APP market), concluding that the market was competitive. It is interesting to note that, apart from the well-known international service providers such as Bolt and Uber, this market has also a couple of entrants that were established in Georgia – such as Venio and Rashi – showing that national start-ups are slowly keeping up the pace with growing digital competition.

The Taxi APP market represented one of the eight markets that the GCCA monitored throughout 2025. Some of these market inquiries – such as fuel, tobacco and FMCG – have been conducted for several years now. Considering its antitrust and merger activities in 2025, the GCCA also opened the inquiry/monitoring in the relevant market of medical services. Such monitoring remains one of the most powerful GCCA tools for raising awareness among business circles regarding the importance of market competition and informing consumers about the dynamics of the markets most relevant to them.

International Conference on Competition and Consumer Protection

The IV international conference on competition and consumer protection was held in Tbilisi on November 13-15, 2025. Five regulatory bodies (the GCCA, the National Bank of Georgia, the National Energy and Water Supply Regulatory Commission of Georgia, the Communications Commission, and the State Insurance Supervision Service of Georgia) jointly organised the conference, which focused on strengthening competition policy and enhancing consumer rights mechanisms in Georgia.

The conference brought together over 350 delegates, more than 50 local and international speakers, and more than 40 representatives from 18 competition authorities across the world, alongside the representatives from the World Bank, OECD and UNCTAD.10 The conference included seven working sessions and three international panel discussions. The covered topics ranged from protection of vulnerable consumers to supporting digital market fairness, finding right balance between competition and regulation in contemporary markets and the role of cross-border cooperation in effective competition enforcement.

The international conference remains the most significant joint effort of GCCA and sectoral regulators to raise awareness about competition issues within the country and showcase its achievements and challenges to the international audience.

• 1EU-Georgia AA, Article 204(2).
• 2This number does not include the interim fines for the failure to provide the GCCA with relevant information related to the ongoing enforcement proceedings.
• 3For details, see https://en.autobazroba.com/ab.html accessed on 15 January 2026.
• 4See https://gcca.gov.ge/index.php?m=352&cat_id=76&lng=eng published 6 August 2025, accessed on 15 January 2026.
• 5A full list of notifications can be viewed at https://gcca.gov.ge/index.php?m=356&lng=eng accessed 15 January 2026.
• 6At the end of the 2025, the GCCA had only one ongoing Article 113 investigation, as it passed through the phase of admissibility.
• 7See Article 22(1) GLC.
• 8This governance system was adopted as a part of 2020 legislative changes but was supposed to become effective at a later date due to budgetary constraints that the GCCA faced at the time.
• 9See Article 171(1) of the GLC, the latest consolidated version.
• 10See https://ccc.gov.ge/ accessed on 15 January 2026.