Main Developments in Competition Law and Policy 2025 – Lithuania
April 6, 2026
And so, the challenge was clear. I asked an AI tool (not to be named and further simply referred to as AI) to outline the main competition law and policy developments in Lithuania in 2025 (plus January and February of 2026) and then compared that with the list I created myself. The themes covered (i) Institutional and Policy Developments, (ii) Enforcement of Articles 101 and 102, as well as their national equivalents; (iii) Merger Enforcement; and (iv) Market Studies.
In short, the results produced by AI were good, but were they good enough?
Institutional and Policy Developments
To its credit, AI has been able to catch many, if not all, of the institutional and policy developments, which were plenty in 2025.
Legislative Changes: Fines and Procedures
Perhaps the most significant legislative development is the amendment to the Law on Competition, approved by the Seimas (Parliament) in late 2025, which modifies the calculation of fines. Effective from May 2026, the amendments cap the base amount of the fine (the first stage of calculation) at 50 per cent of the maximum possible fine. While the Lithuanian competition authority (Konkurencijos taryba or KT) retains the discretion to increase fines based on aggravating circumstances or for deterrence, the amendment effectively lowers the starting point for penalties. This move faced opposition from the KT, which warned that it might weaken the deterrent effect of sanctions.
On a procedural note, a new "50/50" payment rule came into force on 1 January 2026. Fined undertakings can now pay half of the fine immediately and defer the remaining half until after court proceedings are concluded. This mechanism, which, according to the KT’s report, was already used by MM Grupp after it had been fined by the authority in Apollo/Forum gun-jumping case, aims to balance the financial burden on businesses with the need for enforcement.
The cumulative effect of both amendments may be softening the authority’s sanctioning powers and thus raising potential tension between deterrence goals and apparent political appetite for lower penalties.
New Powers in Digital Markets
From 1 January 2025, Konkurencijos taryba became the national supervisory authority for Regulation (EU) 2019/1150 on online intermediation services and online search engines (P2B Regulation), under the new Law on the Supervision of Online Intermediation Services and Online Search Engines. This new mandate empowers the authority to investigate suspected infringements of the P2B Regulation, impose fines between EUR 300 and 15,000, cooperate with other Member States and the Commission, and provide advisory guidance to business users of platforms.
On its dedicated “Digital markets” page the authority frames this as part of a broader strategy to ensure a “fair and transparent” internet ecosystem, explicitly targeting platforms that serve Lithuanian business users and consumers regardless of where the platform operator is established. The task of enforcing the P2B Regulation has been assigned to a small unit of four people, which also deals with cases originating from the Law on the Prohibition of Unfair Practices of Retailers. Clearly, given the resources, the authority does not expect much enforcement activity on either front. Instead, the new powers in digital markets should be seen as the first step towards acquiring specialised expertise and tools that later could be used for traditional enforcement under the Lithuanian Law on Competition (LoC) and Articles 101 and 102 TFEU.
Institutional Structure and Council Appointments
Structurally, the KT has moved towards greater integration of separate investigation units. To improve coordination and priority setting and without dismantling the existing structure, under which each unit is in charge of prosecuting a specific type of infringement, in 2025, the authority centralised its operations by creating a position of Chief Investigations Adviser, to whom heads of investigative units are accountable.
This internal consolidation coincides with a refresh in the Council’s composition: in early 2026, existing Council member Karina Kučaidze‑Wencel was designated as Deputy Chairwoman, and Monika Ražukaitė joined as a new member. She was appointed by the President of the Republic for a six‑year term on the proposal of the Prime Minister. Notably, and in contrast to previous record, recent Council appointees have come from outside the institution. While this presents an opportunity of bringing diverse experience from the private bar and other public bodies, it also raises a question whether, perhaps, the appointing politicians might be unhappy with the authority’s past enforcement policy and would like to steer the Council towards new pastures. Watch out for what happens next year, when the six-year term of two experienced Council members – both current Deputy Chairwomen – expires. Both could be re-appointed for the second term – the move that would suggest politicians favouring continuity and known expertise – or thanked for their service and asked to leave.
AI caught neither of the internal developments discussed here.
Enforcement Priorities
For 2025 Konkurencijos taryba publicly identified four priority sectors: digital markets, defence, retail trade and energy, with the latter being then dropped for 2026. The 2025 priority statement explains that the authority intends not only to “monitor developments” but also to pursue proactive investigative and preventive work, education and inter‑institutional cooperation in these areas.
In energy, KT explicitly linked its priorities to the liberalisation of electricity supply, green transition objectives and prior enforcement in the heat pump RPM case, signalling continued scrutiny of green‑technology value chains. Defence became a named priority for the first time, reflecting both national security concerns and the authority’s growing role in scrutinising procurement and legislative initiatives in that sector. Last year saw the authority’s intensified cooperation with the Ministry of National Defence and monitoring of defence‑sector procurement and regulation. Retail and digital markets remain perennial priorities, with Konkurencijos taryba pointing to ongoing investigations into everyday consumer goods and beverages and to its new platform‑supervision duties.
AI Score on Institutional and Policy Developments: 8/10
Quite good, even though some structural developments escaped AI’s eyes.
Enforcement of Articles 101/102 TFEU and Their National Equivalents
Article 101 TFEU/Article 5 LoC enforcement
KT’s headline infringement decision for 2025 came in the Digital Education cartel case. In December 2025 KT found that two corporate groups active in electronic diaries (gradebooks) and digital learning content – the Snowball.xyz group (TAMO diary, EMA, Egzaminatorius.lt, E‑mokykla) and the AL holdingas group (EDUKA diary and EDUKA klasė) – had agreed in August 2020 to stop competing and to divide business lines between them.
Under the agreement as implemented, the Snowball.xyz group retained the TAMO electronic diary business, while transferring its digital learning‑content activities to the AL holdingas group, which in turn shut down the EDUKA electronic diary. As a result, schools effectively had only one major provider for electronic diaries and one for digital learning content, in a market where both groups already held leading positions. KT qualified this as a market‑sharing cartel restricting both current competition and future innovation in digital pedagogical tools, imposing fines of EUR 2.714 million on the Snowball.xyz group and EUR 0.913 million on AL holdingas, each reduced by 15% for acknowledging the infringement.
Interestingly, the investigation into a suspected market sharing cartel was launched in March 2022, just as KT was reviewing Snowball.xyz’s acquisition of the printed textbooks and the digital learning content business from the very same AL holdingas group. This conglomerate Snowball.xyz/Šviesa merger was cleared with behavioural remedies to address KT’s concerns about tying between diaries and content. The cartel investigation meanwhile continued for another three years.
From a policy perspective, this case illustrates several points. First, KT does not shy from tackling complex conglomerate settings in digital markets. Second, the infringement shows KT’s willingness to scrutinise internal board‑level documents that reveal “scenario planning” around closing products and reallocating portfolios; the case shows that even internal hypothetical discussions about consolidating with a competitor can be problematic if they evolve into operational agreements. Finally, the case underlines a broader trend of NCAs extending classical cartel theories into digital ecosystems that blend software, content and data.
The bid‑rigging in public procurement (Manado/Parts Ready) infringement decision – the one that AI did catch – came out in February 2026, when KT found that vehicle spare‑parts suppliers Manado and Parts Ready had formed a cartel in public procurement procedures organised by Vilniaus viešasis transportas in 2025. The firms coordinated their bids, prepared each other’s offers from the same computer, agreed in advance who would win, and thus only mimicked competition in two tenders for bus spare parts. Both undertakings admitted the infringement and benefited from a 15% reduction in fines under the settlement mechanism, resulting in penalties of EUR 17,950 for Manado and EUR 23,130 for Parts Ready. The decision is notable as the second consecutive case concluded via settlement, and even more so for its record-breaking speed: only six months had passed from the authority receiving a complaint in August 2025 and issuing fines in February 2026.
Article 102 TFEU/Article 7 LoC enforcement
Another year went by without an abuse of dominance infringement decision (as well-spotted by AI), but that did not mean lack of any activity in the field.
In June 2025, KT refused to open an investigation into ORLEN Lietuva (oil refinery) concerning alleged abusive refusal to supply LPG and diesel. According to a complainant, the oil refinery had been unjustifiably refusing to supply it with the necessary quantities of LPG and diesel, thus allegedly limiting the complainant’s opportunities to operate in Lithuania and creating obstacles to exports to Ukraine. Having considered the circumstances of the case, the authority rejected the complaint for lack of priority.
Similarly, in December 2025, the authority was not convinced by a complainant who claimed that Klaipėdos jūrų krovinių kompanija (stevedoring company) abused its dominance by allegedly imposing unfairly high prices for use of special equipment necessary to carry loading and unloading operations. KT concluded that since the complainant was in the business of exporting scrap metal to foreign countries, even if the alleged behaviour had been established, the results of the investigation could only affect the complainant’s customers operating abroad, but not in Lithuania. With that finding, the authority refused to launch an investigation on priority grounds, specifically mentioning that the investigation would require disproportionate resources compared to the expected results.
Finally, at the start of 2026 the authority declined to open an investigation into alleged abuse of dominance by Lietuvos paštas in a public procurement for business‑customer correspondence delivery services. The complainant, Unifiedpost, alleged predation (including zero‑priced components) by way of discounting and project‑based pricing system that were said to breach commitments previously accepted by Lietuvos paštas in 2019. After examining the procurement context, KT concluded that the evaluation concerned the overall package rather than individual tariff elements, that the allegedly below‑cost pricing was limited to a single tender and not repeated elsewhere, and that Lietuvos paštas was considering changing its project‑pricing approach. It therefore found that an in‑depth investigation would not correspond to its enforcement priorities, given limited impact on consumer welfare and the resource cost of reviewing a one‑off tender.
To conclude, the authority’s practice remains to screen dominance complaints and proceed only if systematic harm is shown. Notably, all three refusals are tied to its enforcement priorities and resource limits. Barring a miracle, 2026 and, most likely, 2027 will stay Article-102-infringement-empty, as currently there is no abuse investigation in the pipeline, and such exercises usually take several years to complete.
Continuing litigation: pharmaceuticals, notaries and sports
On 17 June 2025 the Regional Administrative Court annulled the Council’s 2022 decision fining the Lithuanian Pharmacy Association (LPA) and several pharmacies more than EUR 72 million for an alleged anti‑competitive agreement on reimbursable‑medicine mark-ups (margins), holding that their joint action took place within a legislative process rather than a market context and did not infringe competition law. The authority announced that it would study the reasoning and consider appealing, and in July 2025 it in fact lodged an appeal to the Supreme Administrative Court; a separate Council press release summarises its arguments, emphasising the potential competitive impact of coordinated input into price‑setting regulation. KT’s appeal argues that the conduct should not be insulated as mere participation in a legislative process and reiterating that coordinated margin submissions significantly influenced Ministry of Health decisions. This case will determine if coordinated inputs into price regulation may count as “market collusion”.
2025 also saw the Supreme Administrative Court refer questions to the Court of Justice of the EU in Case C‑324/25, a preliminary reference in a long‑running dispute between the Council and the Lithuanian Basketball League and several clubs over alleged anti‑competitive practices in sports governance. The reference underscores the continued interaction between Lithuanian competition enforcement and EU sports case‑law and will likely have implications for how the authority and national courts assess the specificities of sport in future antitrust analyses.
AI Score on Articles 101/102 Enforcement : 6/10
AI did well on Article 102 and litigation, but missing the only cartel case of 2025 is inexcusable, hence the lower score.
Merger Enforcement
Merger Prohibition
In a landmark ex post merger review decision – overlooked by AI – in February 2025, Konkurencijos taryba prohibited the completed acquisition of the Lrytas news portal by Estonian media company Ekspress Grupp, which operates the leading portal delfi.lt. The transaction was initially implemented in December 2022 without mandatory prior notification, leading to a separate gun-jumping infringement in 2023. When assessing the substance of the concentration, the authority found that it combined the first and second largest players in terms of traffic, resulting in a combined market share exceeding 40 per cent. Crucially, in the authority’s view, the merger eliminated the main competitive constraint that previously deterred delfi.lt from raising prices on its paid content, as Lrytas had exclusively offered free news. Post-merger, the volume of paid content increased significantly across both platforms, directly harming consumers. The authority rejected behavioural commitments to operate the portals separately as insufficient and ordered Ekspress Grupp to restore the status quo ante or divest one of the portals within six months.
Following this order, KT announced in early 2026 that Ekspress Grupp had properly fulfilled its obligations by divesting 100 per cent of its shares in Lrytas to a Council-approved buyer. As part of the resolution, Ekspress Grupp committed not to repurchase the Lrytas shares or business for a period of ten years without prior notification to the competition authority. This ten-year commitment remains binding unless a court issues a final ruling concluding that the authority’s underlying infringement or prohibition decisions were unjustified.
Conditional Clearances
On the conditional‑clearance side, the Munich Re/ERGO/Gjensidige transaction in the insurance sector stood out for the length of its review and for the complexity of markets involved. In December 2025 KT cleared Munich Re’s acquisition (through ERGO International) of 100% of insurer Gjensidige, but only after accepting commitments to divest Gjensidige’s carrier‑liability insurance portfolio to a buyer approved by KT and to refrain from competing for those transferred customers for a specified period. This mix of structural and behavioural elements signals KT openness to crafting targeted remedies in concentrated B2B markets. Notably, the authority had the candidacy of the portfolio buyer – Estonian-registered If P&C Insurance – approved as it was clearing the merger, and the parties to the main transaction were allowed to close it before implementing the divestiture.
On 20 May 2025 Konkurencijos taryba conditionally cleared Saferoad Baltic’s acquisition of Gatas (Saferoad Baltic/Gatas), a provider of road‑barrier installation and maintenance services, after the parties offered behavioural commitments. The authority’s analysis showed that without remedies the merger would likely create or strengthen a dominant position in the markets for the supply of road‑barrier systems and for their installation and maintenance, in light of high concentration levels, the merged entity’s ability to restrict Gatas’ competitors’ access to barriers, and risks of information exchange. To address these concerns Saferoad Baltic committed to supply barriers to all Gatas competitors on fair, non‑discriminatory terms no less favourable than those offered to Gatas, and to implement firewalls and other measures to prevent the exchange of commercially sensitive information between the manufacturing and installation‑maintenance sides of the business. The case is another example of the Council’s readiness to accept targeted behavioural commitments in vertical or conglomerate settings.
Third Time Lucky: Cgates/Splius III
In August 2025 KT approved a re‑designed transaction allowing telecoms operator Cgates to acquire sole control of a newly created company to which Splius would transfer part of its fibre‑internet, smart‑TV and fixed‑line business in several Lithuanian regions, explicitly excluding the city of Šiauliai. The decision follows two earlier unsuccessful Cgates’ attempts – one abandoned in 2019 and another blocked in 2021 – to acquire 100% of Splius and subsequent litigation, in which the Supreme Administrative Court in 2024 fully upheld the Council’s 2021 prohibition decision, accepting its market‑definition and effects analysis. By carving out Šiauliai – where the original transaction had been found to risk serious harm to competition – the new structure allowed the authority to conclude that the modified concentration would not create or strengthen a dominant position or significantly restrict competition, thus illustrating a pragmatic willingness to revisit blocked deals when parties propose credible structural modifications.
Gun-jumping cases
In November 2025 KT adopted an infringement decision in the Emsi case, finding that fuel retailer Emsi had violated the LoC by implementing several mergers in 2024 without notifying and obtaining prior clearance. Emsi indirectly acquired two petrol stations in Kaunas via a related company Antira (through lease of stations Antira had just bought), and directly acquired stations in Vilnius and Maišiagala, with the combined revenues of Emsi and the acquired stations exceeding the EUR 2 million individual and EUR 20 million combined thresholds.
Despite being informed by the authority of its notification obligation before the investigation formally started, Emsi proceeded to implement the transactions, leading to a fine of EUR 1,022,170 and orders to bring the infringement to an end. The authority emphasised existing case‑law that treats a petrol station as an independent economic unit for merger‑control purposes and framed the case as a clear example of serious gun‑jumping, reinforcing a line of strict enforcement begun in earlier years.
In October 2025 authority found that MM Grupp, owner of the Apollo cinema chain, had infringed the LoC by acquiring control over Forum Cinemas Lithuania and its cinema assets without prior approval and by integrating them into its chain. MM Grupp first acquired control over Forum Cinemas Lithuania in April 2021, then restructured and divided the acquired business, ultimately regaining control of key cinemas in Vilnius and Kaunas and integrating them into Apollo, all without clearance.
The Council imposed a fine of EUR 7,507,930 and ordered MM Grupp to cease the violation within six months, either by notifying the concentration and obtaining clearance, or by restoring the pre‑merger situation or otherwise eliminating the consequences of the infringement. In January 2026, the Vilnius part of this merger was notified (Apollo/Forum Cinemas Akropolis Vilnius) and currently is undergoing a review.
Both cases underline that failure to notify is treated as a serious violation irrespective of the eventual competitive assessment, and it also demonstrates the authority’s willingness to impose significant fines for gun‑jumping.
Merger Litigation
On the prohibition side, the Supreme Administrative Court’s judgment of 10 September 2025 in Dobeles Dzirnavnieks/Baltic Mill stands out. The Supreme Administrative Court upheld KT’s earlier decision to block the acquisition by Dobeles Dzirnavnieks (a Latvian flour and cereal producer) of the Lithuanian competitor, confirming that the transaction would have had anticompetitive effects in several flour and related product markets.
From a standard‑of‑proof perspective, the judgment is important because the Court accepted KT’s articulation that the negative effects of the merger only had to be “more likely than not” rather than established with near certainty. The Supreme Administrative also addressed the impact of procedural irregularities (e.g. access‑to‑file issues) and held that not every procedural misstep automatically vitiates the final decision, provided rights of defence are not substantively impaired.
The complexities of unwinding a prohibited merger were brought to the forefront (but not to AI’s attention) by the Supreme Administrative Court in its December 2025 ruling on the Piletilevi Group/Tiketa transaction. The Court dismissed the Estonian ticketing company's appeal and upheld the Competition Council's 2022 decision to block its acquisition of local distributor Tiketa. From an analytical perspective, the Supreme Administrative Court's judgment is particularly valuable for its guidance on restoring the pre-merger situation when market circumstances have evolved. The Supreme Administrative Court clarified that the obligation to restore the status quo or eliminate the anti-competitive consequences of a merger must be assessed in light of general legal principles, including good administration, proportionality, and reasonableness. Authorities must consider the real factual circumstances that have developed post-concentration and the practical possibilities of unwinding the deal without causing disproportionate collateral damage.
AI Score on Merger Enforcement : 5/10
Just as with Articles 101/102 enforcement, all went well until AI managed to overlook a merger prohibition, and then a major piece of litigation regarding ex post merger prohibition. These are rare species and missing them should be punished. A pass, barely.
Electric‑vehicle charging sector monitoring
In March 2025 Konkurencijos taryba published the results of its monitoring of the electric‑vehicle (EV) charging sector, issuing detailed recommendations to municipalities and to the Ministries of Transport and Energy. The study found that municipal decisions significantly shape the sector’s development and that in some cases municipalities or municipal companies appeared to enter the charging market on more favourable terms than private operators, potentially distorting competition.
The recommendations urge municipalities to assess the competitive impact of their market participation, to avoid unnecessary entry where private initiative can deliver services, and to organise open, transparent tenders once mandatory free‑service periods expire, including by splitting tenders into smaller lots where appropriate. The authority also stresses the importance of proportionate contract durations and consumer‑oriented selection criteria and explicitly links its findings to similar work by other European competition authorities and the European Commission on EV‑charging markets.
Ongoing digital markets study with OECD, Latvia and Poland
Lithuania is participating in an OECD‑implemented technical‑support project, “Competition Market Study: Digital Sector – Poland, Latvia and Lithuania”, which focuses on online marketplaces and their ecosystems. Launched in late 2024, the study is scheduled to deliver recommendations in spring 2026. OECD experts, working with the three authorities, are mapping the structure of national and regional digital markets, identifying platforms that may fall outside the scope of the EU Digital Markets Act but still raise competition concerns, and reviewing the legislative framework to detect regulatory gaps.
The project is expected to provide country‑specific recommendations on how to address identified issues, including where reforms of national law or improved coordination between competition and sector regulators might be necessary. For Lithuania, this work dovetails with the KT’s new P2B supervisory mandate and its e‑commerce guidelines, and should provide an empirically grounded basis for future enforcement or advocacy in digital markets. In 2025 this work continued via the P2B platform checks. No standalone new report was published in this period, but the authority’s speeches and budgets emphasise ongoing analysis of digital markets.
AI Score on Market Studies: 10/10
No complaints here.
Concluding Comments
For my final test, I have asked three different AI tools – I shall call them AI1, AI2, and AI3 – to read this review and give an assessment on how well AI performed in identifying main competition law and policy developments. AI1 was the quickest returning to me with a glowing and self-congratulating assessment. Overlooking the only cartel case and two major merger decisions was qualified as “only minor omission”. AI2 was humbler, calling itself “and efficient clerk”, but “somewhat unreliable chronicler of the critical nuances”. AI3 crashed.
For now, humans as writers survive. Let’s wait for the 2026 review.
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