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At a time when the Czech Office for the Protection of Competition (UOHS) is pushing through the most ambitious overhaul of the Czech Competition Act in over two decades, the Authority has also published its Annual Report for 2025, alongside a sector inquiry re-port into the market for non-alcoholic beverages. Taken together, these documents offer a valuable snapshot of where Czech competition enforcement actually stands – and, per-haps more tellingly, where it is heading. Neither will keep you up at night on a first read, but dig a little deeper and a number of trends emerge that practitioners and businesses would do well not to ignore.
For businesses, the picture emerging from the UOHS's 2025 output is one of cautious recalibration rather than dramatic change. Enforcement volumes remain modest, and the headline fine figures flatter to deceive – inflated by re-imposed sanctions in legacy cases rather than fresh enforcement action. That said, the signals should not be dismissed. The Authority is investing in more sophisticated investigatory tools, expanding its reach into digital markets, and piling up resources for cases in the pipeline. RPM enforcement shows no sign of abating, and bid-rigging cases demonstrate that investigations can be triggered from unexpected quarters, including other state bodies. The sector inquiry into non-alcoholic beverages, while ultimately uneventful in its conclusions, illustrates the Authority's readiness to scrutinise pricing anomalies at short notice. Looking ahead, the proposed overhaul of the Czech Competition Act may reshape the enforcement landscape considerably, but the absence of a clear prioritisation framework for 2026 leaves businesses with limited visibility on where the UOHS will strike next.
New toys in the investigatory toolbox
The UOHS continues to develop its investigatory capabilities by sharpening its teeth on the tech side, with the Annual Report indicating more frequent use of new software and AI-powered tools in the conduct of investigations. Our understanding is that this will concern, among others, the dawn raid software used to search the computers of investigated entities, potentially enabling more precise searches and improved identification of related documents.
Fewer cases, record fines (just don't look too closely)
On paper, 2025 looks like a quieter year for the UOHS: just four new proceedings on prohibited agreements and two on possible abuse of dominance – a noticeable dip from prior years. But fewer cases do not necessarily mean less ambition. The more likely explanation is that the Authority is saving its firepower for larger, more complex cases already in the pipeline. At year-end 2025, a total of 17 administrative proceedings on competition law violations were ongoing: 13 on prohibited agreements and four on abuse of dominant position. The statistics on concluded cases are consistent with long-term trends.
Now for the headline that deserves an asterisk (or perhaps several). The UOHS proudly reports that total fines in 2025 reached nearly CZK 500m, the highest in a decade and among the highest in the Authority's history. Impressive, until you look under the hood. The meal voucher cartel, the taxi case and BabyDirekt alone account for well over CZK 300m – and all three concern re-imposed sanctions in cases decided years ago, where earlier decisions were annulled or sent back for further reasoning. These fines already featured in the statistics when they were first handed down, which means the record-breaking 2025 total is partly recycled from previous years' headlines. Strip out the reruns and the real enforcement output drops to what can charitably be described as below average. The UOHS is not so much breaking new ground as repaving old roads – and counting the mileage twice.
On the merger front, the UOHS opened 75 proceedings, of which 57 were simplified, and issued a total of 60 decisions in simplified proceedings – a record figure. The proposed amendment to the Czech Competition Act, which increases the monetary thresholds for mandatory notifications, should bring this number down considerably once (and if) it enters into force.
Notable cases: easy targets, one big catch
When it comes to targets, the UOHS's enforcement output in 2025 continued to favour the low-hanging fruit. RPM cases again played a primary role for several consecutive years, in segments with broad consumer reach, such as electrical appliances and pet food.
The standout cartel case of 2025, however, had rather higher stakes. Six companies rigged bids for signalling and safety equipment at railway stations and level crossings, affecting 26 public contracts awarded by Správa železnic (the Czech Railway Infrastructure Administration) between 2015 and 2021 with a combined value exceeding CZK 850m. All six confessed and settled, although two of them subsequently appealed against the level of their fines, with the definitive sanctions reaching CZK 17.8m and CZK 24.5m respectively. The case is noteworthy for how it started: not from a dawn raid or a market tip-off, but from a complaint by the National Audit Office, with one participant subsequently applying for leniency. A useful reminder that cartel trouble can arrive from directions you might never have thought to watch.
In the dominance space, the UOHS closed its proceedings against Alma Career over job portal advertising, accepting commitments on interoperability with competing services. Digital markets have not traditionally been the Authority's hunting ground, but it appears to be developing a habit: proceedings against Seznam.cz over pricing rules for real estate ads on Sreality.cz were closed following an offer of commitments, and a further separate digital case against Seznam.cz is still on the table.
Significant market power (UTP): climbing the supply chain
On the UTP front, the UOHS is clearly reaping what it sowed: the vast majority of 2025 proceedings stem directly from earlier sector inquiries. More notable is the shift in targeting. The UOHS is moving its gaze upstream, away from the big-name retailers and towards manufacturers and processors higher up the chain. At the same time, the Authority continues to handle straightforward cases where the infringement is clear-cut, with four out of five concluded sanctioning proceedings ending in settlement.
Outlook: all of the above, none in particular
The 2026 outlook, unfortunately, is where the excitement runs dry. The UOHS recites the familiar trio – horizontal cartels, vertical RPM and exclusionary abuses – without committing to any particular sector focus, resource plan or order of battle. The Authority does indicate it will complete sector inquiries in non-alcoholic beverages (a promise already fulfilled – see below), waste management and electric vehicle charging stations, and will launch at least one new sector inquiry. That is welcome, but it is hardly a strategic manifesto. It also falls short of the kind of clear prioritisation framework published by a number of peer authorities across the EU. For businesses and their advisors, the absence of clear signposting makes it more difficult to assess risk and plan accordingly.
The sector inquiry was triggered by a sharp, above-average spike in retail prices of non-alcoholic beverages (particularly in 2022) that outpaced both the EU average and trends in several neighbouring countries. Despite that red flag, the UOHS came up empty-handed: no signs of excessive pricing, no evidence of coordination among major suppliers, and no competition concerns at the retail level.
At the retail level, the inquiry found that chains compete not only on price but also through product mix and private-label strategies – supporting the conclusion that competition at that level is intense, even among a relatively small number of key players. At the same time, the report confirms the strong bargaining power of retail chains, whose combined share of off-trade sales gives them a materially influential negotiating position vis-à-vis even highly concentrated suppliers.
Perhaps the most interesting chapter is the one that looks backwards. The UOHS revisited two previously cleared mergers: Mattoni/Pepsi and Kofola/Ondrášovka, to assess whether they had, in fact, harmed competition in manufacturing and wholesale supply. The verdict: neither did. Ex-post merger reviews remain a rarity in Czech practice, which makes this exercise noteworthy in its own right. It also gave the UOHS something every regulator quietly craves – confirmation that it got it right the first time when issuing the original ex-ante clearance decisions.
Jan
Kupčík
Counsel
czech republic