The Fuel and Energy Business Association (FEBA) participated in a roundtable discussion with the Head of the Antitrust Committee of Ukraine (AMCU), Pavlo Kyrylenko. The session was dedicated to Ukraine’s competition policy in the context of EU integration, fair competition, and transparent market rules.
The event brought together AMCU leadership—including Head Pavlo Kyrylenko and State Commissioner Serhiy Shershun—alongside representatives from the Ukrainian Business Council, the Economic Expert Platform, the Ukrainian Chamber of Commerce and Industry, the American Chamber of Commerce, and other industry associations. Discussions focused on AMCU enforcement, protection against unfair competition, merger control, the implementation of EU standards, and the business community’s role in shaping transparent market rules.
FEBA drew particular attention to the retail fuel market, which, under wartime conditions, serves as more than just a commercial segment; it is a critical component of community energy resilience, logistics, the agricultural sector, and frontline service stability.
Tetiana Dumenkova, Deputy Head of FEBA, questioned the AMCU Head regarding the growing trend of concentration in the retail fuel market. According to FEBA’s analytical research, the market is shifting from a highly competitive model to a moderately concentrated one. Indicators of concentration are rising, the number of regional and discount networks is shrinking, and “white spots”—areas with no access to fuel—are emerging in certain communities, particularly near the frontline.
FEBA emphasized that this is not merely a structural change in business; it has broader consequences for consumers and the state. A reduction in the number of independent operators weakens competition, potentially impacting price levels, regional fuel availability, and the overall resilience of the fuel infrastructure during wartime.
In response, Pavlo Kyrylenko stated that the AMCU is actively monitoring the light petroleum products market. He noted that the Committee currently has two active cases and one ongoing study, with systematic monitoring in place. The AMCU regularly tracks price changes and analyzes regional market conditions.
The Head of the AMCU added that investigations take into account fuel accessibility for consumers in frontline regions and areas where the number of operational gas stations has significantly decreased. While physical fuel availability does not always fall directly under AMCU’s mandate, the Committee considers these factors when evaluating competition, logistics, pricing, and the behavior of market participants. Kyrylenko emphasized that while Ukraine’s fuel market remains saturated and competitive, it requires detailed analysis considering regional specifics, war-related logistics costs, and wartime operational realities.
At the conclusion of the discussion, FEBA confirmed its readiness to share its internal analytics and recent State Tax Service data regarding the status of the retail fuel market with the AMCU. These materials will assist the Committee in future concentration monitoring, competitive environment assessments, and regional market risk analysis.
FEBA’s position is clear: For the retail fuel market, it is critical not to limit competitive assessment to a mere count of players. The real state of the market must be evaluated by considering:
- Fuel availability for local communities;
- The presence of local and discount networks;
- Regional density of gas stations.
FEBA believes that regular monitoring of concentration indices, regional accessibility, and the impact of tax decisions on market structure should be a key instrument of state competition policy. This is especially vital during wartime, as fuel infrastructure directly dictates economic activity, public mobility, and the continuity of critical services.
FEBA will continue its dialogue with the AMCU and other state authorities to maintain a competitive, transparent, and regionally balanced fuel market in Ukraine.
