OECD Peer Reviews of Competition Law and Policy: Kazakhstan 2025

8. Institutional co-operation

Abstract

This chapter reviews Kazakhstan’s institutional co-operation in competition policy and enforcement matters, both nationally and internationally. The chapter highlights the ways in which the Agency co-ordinates with regulators, law enforcement, and national ministries, as well as a growing engagement with regional and global partners and international organisations.

8.1. Domestic co-operation

While the Agency is the exclusive enforcer of competition law in Kazakhstan, other public (state or local) bodies and institutions participate in the implementation of competition policy as well.1 This includes the obligation to promote competition and refrain from anti-competitive actions and agreements. To be able to exercise its functions, the Agency co-operates with several state or local bodies.

First, all public bodies must report to the Agency any signs of competition law violations. Materials obtained from public bodies constitute one of the grounds for initiating an investigation.2 Further, during an investigation, the Agency can request written information from state and local bodies and have access to their premises.3

Second, the law mandates close co-operation between the Agency and law enforcement authorities. 4 The Agency must notify law enforcement of potential competition-related criminal offences and, upon request, provide expert analysis, opinions, and staff support for investigations and legal proceedings. Law enforcement authorities must, in turn, inform the Agency of identified competition violations, support joint investigations, assist in securing evidence, and help locate and bring suspects to administrative liability. In 2021, the Agency signed a Memorandum of Co-operation with the Financial Monitoring Agency to strengthen collaboration in detecting, investigating and prosecuting competition-related criminal offences.

Third, the co-operation between the Agency and sectoral regulators is of particular significance. The co‑ordination between competition policy and sectoral (industrial) policies was weak for a long time which contributed to stagnation in eliminating administrative barriers to competition (Kazakhstan, 2023[1]). The importance of improving co‑ordination was highlighted by the President in 2022 with the adoption of the 2022–2026 Competition Development Concept.5 It proposed introducing sector-specific Road Maps for the Development of Competition, to be developed jointly by the Agency and sectoral regulators following a market analysis. This aims to better align competition and industrial policies, enabling regulators to implement competition-enhancing measures within sectoral policy frameworks. To date, Road Maps for the many sectors have been adopted (Box 8.1), for instance: (i) oil and oil products, (ii) coal, (iii) civil aviation, (iv) agriculture, (v) housing construction, (vi) healthcare and education, (vii) transportation and storage of medicine, (viii) telecommunications, and (ix) solid waste.

Another form of co-operation between the Agency and regulators is through the competition impact assessment which is a mandatory part of the regulatory impact analysis. It is conducted for every proposal of a new regulatory instrument and should be considered by the public body preparing the draft. The competition impact assessment is another mechanism ensuring that regulation is more in line with competition policy.

Box 8.1. Road Maps for the Development of Competition: Three examples

Road Map for the Development of Competition in the Sphere of Civil Aviation

This Road Map was adopted jointly by the Agency and the Ministry of Industry and Construction of the Republic of Kazakhstan. It identified three main groups of measures. First, the state participation in the civil aviation sector would be reduced by, inter alia, selling all state-owned shares of two airlines, namely Air Astana and Qazaq Air. Second, the administrative barriers would be reduced by extending the term of the “open sky” regime until 2028. Third, non-discriminatory access to infrastructure for retail sellers of aviation fuel would be guaranteed.

Road Map for the Development of Competition in the Sphere of Oil and Oil Products

This Road Map was adopted jointly by the Agency and the Ministry of Energy of the Republic of Kazakhstan. It identified two objectives for promoting competition in the sector, namely access to resources and access to infrastructure. The Road Map planned an increase in exchange trading of oil products, the approval of rules of equal access to essential facilities and a development of a plan for convergence of fuel costs within the EAEU.

Road Map for the Development of Competition in the Sphere of Agriculture

This Road Map was adopted jointly by the Agency, the Ministry of Agriculture of the Republic of Kazakhstan and the Ministry of Trade and Integration of the Republic of Kazakhstan. It set four tasks for developing competition in the sector. First, access to support measures should be improved, for which a new approach to subsidies would be developed. Second, state regulation of prices would be phased out and replaced with targeted assistance. Third, the barriers in delivering agricultural products to consumers through trade networks would be removed. Fourth, exchange trade in agricultural products would be developed and improved.

Source: Road Maps, 2022 Annual Report on Competition Policy Developments in Kazakhstan, DAF/COMP/AR(2023)47.

Special co-operation is envisaged between the Agency and the National Bank of the Republic of Kazakhstan, as well as the Agency for Regulation and Development of the Financial Market, as the financial markets’ regulators (ARDFM). The Agency co‑ordinates with the National Bank and ADFM to prepare the methodology for conducting a market analysis in financial markets. In addition, the Agency and ARDFM jointly determine the notification thresholds for concentration control in this sector. 6 The decisions of the Agency concerning an economic concentration in financial markets are shared with the parties to the transaction.

Fourth, the Agency also collaborates with ministries. For instance, the Ministry of Trade and Integration sends drafts of international trade agreements to the Agency for review of competition law compliance. The Agency issues an approval of an international trade agreement if it complies with Kazakhstan’s competition legislation.

8.2. International co-operation

The Agency’s international co-operation has been growing in recent years, and cross-border relationships are gaining ground (as discussed in detail below), supporting the Agency’s development as well as its ability to investigate and deal with firms that are present in multiple jurisdictions. However, its International Unit is rather small, with only four staff, whereas the Agency’s regulation stipulates a minimum of five. As the international co-operation grows in importance, this is putting an increasing strain on staff while also potentially jeopardising the Agency’s ability to fully benefit from its broadening international reach. More attention should be paid to this unit whose contribution to the work of the Agency is increasingly crucial (Box 8.2).

Box 8.2. The International Co-operation Unit of Kazakhstan’s Competition Agency

The Agency’s International Co-operation Unit serves as the main interface between the Agency and the international competition community. It is responsible for developing and co-ordinating the Agency’s external engagements, with a focus on advancing Kazakhstan’s role in regional and global competition frameworks. The Division’s work includes:

• co-ordinating Kazakhstan’s participation in the Eurasian Economic Union (EAEU), including contributions to working groups, expert discussions and the formulation of national positions on decisions made by the Eurasian Economic Commission

• engaging with international organisations such as the OECD, UNCTAD and the World Bank, including preparing input for annual meetings, thematic roundtables, and research collaborations

• supporting the development of legislation and policy on competition, based on comparative international experience and best practices

• preparing strategic briefs, analytical materials, and speeches for the Agency’s leadership for use in high-level bilateral and multilateral meetings

• managing a steady flow of incoming and outgoing international correspondence, requests for information, and co-ordination of business trips and expert missions

• participating in the negotiation and legal review of international treaties and co-operation agreements

• co-ordinating the Agency’s contributions to joint economic research initiatives and monitoring follow-up actions from international engagements.

With its broad mandate and numerous institutional partnerships, the Division manages a high volume of technical, legal and diplomatic tasks, playing a critical role in ensuring that Kazakhstan’s competition policy remains aligned with evolving global standards and obligations.

Source: Internal regulation: Annex 12 to the Order of the Chairman of the Agency for Protection and Development of Competition of the Republic of Kazakhstan 2023.

8.2.1. Cross-border effects of competition law

Kazakhstan’s competition law provisions apply not only to actions carried out on the territory of the Republic of Kazakhstan but also to actions carried out abroad, if one of the following two conditions is satisfied:

• the actions directly or indirectly affect fixed assets or intangible assets located in the territory of the Republic of Kazakhstan, shares of market entities, property or non-property rights in relation to legal entities of the Republic of Kazakhstan

• competition in the Republic of Kazakhstan is restricted.

The law treats foreign market entities equally as domestic market entities.7

In cross-border cases, the Agency co-operates with other competition authorities within the framework of regional co-operation (particularly the Eurasian Economic Union, the Commonwealth of Independent States or the Organisation of Turkic States, the Shanghai Co-operation Organisation) and international co-operation (OECD, UNCTAD, ICN and others).

8.2.2. Co-operation within the Eurasian Economic Union

The Eurasian Economic Union (EAEU) is a regional organisation for economic integration (Vinokurov, 2017[2]), of which Kazakhstan is also a Member State. Competition law is one of the pillars of the Treaty on the Eurasian Economic Union (EAEU Treaty). In 2021, the OECD conducted an extensive Peer Review of Competition Law and Policy of the EAEU (OECD, 2021[3]).

Competition law competence of the Eurasian Economic Union

For Member States of the EAEU like Kazakhstan, competition law exists at two levels – at national and EAEU level. Thus, the delineation of competences between EAEU and Member States is significant for establishing who and under what law a Member State can scrutinise and prosecute a specific anti-competitive conduct. Competition enforcement on the Member State level is carried out by the national competition authorities (such as the Kazakh Agency), while “suppressions of violations of the general rules by business entities”8 at the EAEU level is carried out by the Eurasian Economic Commission, the executive body of the EAEU.

Article 76(7) of the EAEU Treaty provides that the Eurasian Economic Commission has power to ensure the application of general rules of competition law if the violation affects or can adversely affect competition on cross-border markets in the territory of two and more Member States. The delineation of competence between EAEU (Eurasian Economic Commission) and Member States (national competition authorities) thus depends on the definition of cross-border markets.9

Cross-border markets are defined in the Decision of the Supreme Eurasian Economic Council entitled “Criteria of Market Classification as Cross-Border Market”.10 For a market to be defined as cross-border, a general criterium and violation-specific criteria must be met. According to the general criterium, a market is classified as a cross-border market if geographical boundaries of the relevant product market include the territories of two or more Member States. Violation-specific criteria differ across various violations of the general rules of competition law:

• anti-competitive agreements – at least two economic entities participating in the agreement are registered on the territory of different Member States

• unfair competition – the economic entity whose actions constitute unfair competition and its competitor who is or may be injured as a result of unfair competition are registered on the territories of different Member States

• abuse of dominant position – the share of sales or purchases of an economic entity occupying a dominant position of the total volume of goods circulating in the territory of each affected Member State is at least 35% and the infringement leads to prevention, restriction, or elimination of competition in the territories of two or more Member States.11

If these criteria are met, the Eurasian Economic Commission has the power prosecute violations and ensure that the general rules of competition law are adhered to. If these criteria are not met, competition law enforcement falls within the competence of the national competition authorities, namely the Agency in case of Kazakhstan. Under the EAEU Treaty, the Eurasian Economic Commission has no powers to control concentrations, nor does it possess the power of extraterritorial jurisdiction (with respect to entities from third countries) – these lie exclusively with the national competition authorities.

Co-operation between a Member State and the Eurasian Economic Commission

Since the competition enforcement competences are divided between EAEU and Member States, close co-operation between the Eurasian Economic Commission and the national competition authorities, such as the Agency, is necessary. The details of this co-operation are described in Annex 19 to the EAEU Treaty. This includes EAEU acts governing the review of applications, investigations, and case handling. The Agency regularly provides comments on analytical conclusions, including on market definition and the division of competences, and participates in relevant cases. In 2024, it submitted comments to the EEC on the definition of product boundaries in the garage equipment market for motor vehicles and the assessment of unfair competition violations.

The Agency refers materials to the Eurasian Economic Commission (EEC) to identify and assess signs of:

• unfair competition (e.g. unlawful use of trademarks, names, photos for advertising)

• abuse of dominant position, and

• co‑ordination of economic activity in cross-border EAEU markets involving entities from Member States.

Transfer of cases from the ECC to National Authorities

The process also works in reverse. If the Commission concludes that a case falls within a national authority's jurisdiction, it transfers the materials accordingly. In 2017, the Commission transferred a case involving suspected abuse of dominance by JSC “National Company Kazakhstan Temir Zholy” in the empty wagon leasing market, concluding the entity operated only within Kazakhstan.

Reasoned submissions for procedural actions

The EEC may issue a reasoned submission instructing a national authority to carry out specific investigative actions, such as: (i) examining parties and witnesses, (ii) obtaining documents, (iii) conducting inspections, (iv) gathering information from public bodies, (v) forwarding documents to case participants, and (vi) conducting expert reviews. These actions may involve Commission staff and must be executed within one month. Where multiple authorities are involved, the Commission co‑ordinates their efforts. The Commission and the executing Member State must agree on the reimbursement of related expenses. Currently, Kazakhstan’s competition authority lacks the power to enforce such submissions, which limits international co-operation. However, a draft law under the 6th antimonopoly package—now under parliamentary review—proposes granting the Agency this authority.

Request for information and documents

During the investigation, the Eurasian Economic Commission can send a request for information and documents to the national competition authority. Within the established deadline, the national competition authority must submit all available information. Subsequent requests are allowed.

Co-operation between Member States of the Eurasian Economic Union

Within the framework of the EAEU, the Agency also co-operates with competition authorities of other Member States of the EAEU. The legal basis is Article 75(8) of the EAEU Treaty which envisages co-operation between national competition authorities by sending notices and information requests, carrying out consultations, informing and carrying out investigations. Kazakhstan’s legislation provides a similar legal basis in Article 90-4 of the Entrepreneur Code. In addition, according to Article 74(4) of the EAEU Treaty, Member States conduct a co‑ordinated competition (antimonopoly) policy with respect to actions of economic entities from third countries, if such actions may have a negative impact on the state of competition in the product markets of the Member States.

The specifics of co-operation between national competition authorities within the EAEU are described in Annex 19 to the EAEU Treaty. Member States are required to notify the introduction of temporary state price regulation on certain types of socially significant goods.12 For example, in February 2022, the Agency notified the EEC and the EAEU member states of the approval of the maximum allowable price for sunflower oil in the Pavlodar region of the Republic of Kazakhstan. Also in 2022, the Republic of Belarus sent information to the EEC and the EAEU member states on the introduction of state price regulation for socially important goods (28 product groups). There were no appeals about the affected interests.

Notifications

The competition authority of the Member State is required to notify the competition authority of another Member State if it becomes aware that its enforcement activities may affect the interests of another Member State. These include interests related to its own enforcement activities or to anti-competitive conduct carried out in its territory. Notifications must be sent in writing and in a timely manner. It is required to send the notification in the stage of considering the case, allowing the notified Member State to express its opinion before a decision is adopted.

Spontaneous provision of information

The competition authority of the Member State should also provide to the competition authority of another Member State any information on anti-competitive actions that is has, if it deems such information to be relevant. In contrast to notifications, this information need not be related to its enforcement activities.

Requests for information and documents

The Agency may submit requests to the competition authorities of EAEU Member States during market analyses or investigations. These requests may cover, for instance, price comparisons for similar services in other jurisdictions, volumes of services provided, consumer types, and other relevant market data. Each Member State bears its own expenses in relation to the requests.

For example, in a 2017 investigation into potential infringements of general competition rules in cross-border markets, the Agency submitted a formal request to the Federal Antimonopoly Service (FAS) of Russia. The case concerned Pharm Express LLP (Kazakhstan) and involved the distribution of speech processors used in cochlear implantation systems manufactured by Cochlear Limited. The request sought to clarify the identity of the distributor operating in the Russian Federation and to obtain the relevant distribution agreement. The inquiry followed the discovery of a non-exclusive trilateral distribution agreement signed on 1 February 2016 between Pharm Express LLP, Cochlear Europe, and LLC ANG Apparel Group (acting as distributor’s agent). The agreement imposed territorial restrictions, including a ban on product sales to Kazakhstan without the consent of Pharm Express LLP and a prohibition on resale beyond its borders. Based on FAS’s response and supporting information, the Agency identified LLC Euromax (Russia) as another entity engaged in potentially similar anti-competitive arrangements. The case materials, which indicated signs of market-sharing within the EAEU, were subsequently submitted to the Eurasian Economic Commission (EEC) for further examination.

Requests for relevant information

The competition authority of the Member State can also send a request for any relevant information regarding its case that a competition authority from another Member State may have, although not connected to a case under investigation in that Member State.

Order for conducting separate proceedings

The competition authority of the Member State can submit to the competition authority of another Member State an order to conduct separate proceedings. The executions of such an order can include: (i) examination of the subjects of investigation and witnesses, (ii) obtaining documents, (iii) inspection of the premises, objects and documents, (iv) obtaining information from state authorities, (v) submission of documents to the participants of the case, (vi) examination etc. The competition authorities can agree that separate proceedings are performed in presence or with participation of representatives of the competition authority requesting separate proceedings in another Member State. The Member States must come to an agreement regarding the reimbursement of additional expenses arising for the executing Member State.

Request for initiating enforcement actions

If the competition authority of the Member State believes that anti-competitive actions are being carried out in the territory of another Member State that adversely affect its interests, it may notify that Member State and request initiating appropriate enforcement actions. After the negotiations, the notified Member State decides on the necessity of initiating enforcement actions. If it takes enforcement measures, the notifying Member State must be informed.

Joint enforcement actions

Competition authorities two or more Member States can agree on co-operating in the implementation of enforcement activities. More efficient use of material and information as well as cost reductions might be factors in opting for joint enforcement activities. Such co-operation may involve the implementation of a co-ordinated competition policy with respect to the actions of economic entities from third countries, particularly when studying the successful practices of another competition authority in similar cases. For example, regarding the co-ordination of global mergers and acquisitions, consultations were held this year under the auspices of the Agency using the confidentiality waiver mechanism.

Co-operation in development of legislation

Competition authorities of Member States co-operate in the development of national competition legislation by providing information and methodological assistance. Expert meetings and consultations with the antimonopoly authorities of EAEU Member States are held under the auspices of the EEC to improve Union law (the EAEU Treaty, legal acts related to analysis, investigations, etc.), taking into account the study of best practices in competition regulation from national legislations. These innovations may subsequently be implemented by Member States into their national legal frameworks. Information and documents provided within the framework of co-operation between Member States of EAEU are confidential. The use of disclosure of the information with third parties is possible only if the competition authority of a Member State which provided the information consents in writing.

8.2.3. Co-operation within the framework of other international organisations

Co-operation with the OECD

Kazakhstan underwent an extensive Peer Review by the OECD of its Competition Law and Policy in 2015. The Peer Review resulted in a report which highlighted strengths and weaknesses of the Kazakhstan’s competition regime and recommended policy changes for improving the competition framework and enforcement. In the years following the report, Kazakhstan adopted many reforms of its competition legislation. In June 2016, Kazakhstan obtained status of the Participant in the OECD Competition Committee and its Subsidiary Bodies and regularly attends sessions of the Competition Committee, Working Parties 2 and 3, as well as the Global Forum on Competition. Kazakhstan submits annual contributions to the meetings of the OECD Competition Committee, its working parties, and the Global Forum, and actively participates (Kazakhstan’s contributions are available on the OECD website). Additionally, the Agency’s employees often participate in seminars organised by OECD’s Regional Centre for Competition in Eastern Europe and Central Asia (Kazakhstan, 2022[4]).

In 2025, one of the seminars of the OECD-GVH Regional Competition Centre will be held in Kazakhstan, which will allow for the participation of a wide range of Agency staff, including regional departments. The Agency also publishes articles in the annual OECD-RCC Newsletter. The most recent issue was released in 2025 and included an interview with the Chairman of the Agency, as well as an article by the Agency on bid rigging in Kazakhstan (Newsletter No. 25, January 2025, “Competition Policy in Eastern Europe and Central Asia”).

In 2023, an agreement was signed between the Government of the Republic of Kazakhstan and the OECD for the second Peer Review of Competition Law and Policy, the results of which are presented in this report.

Co-operation with the UN Trade and Development (UNCTAD)

Kazakhstan is a member state of UNCTAD. The Agency participates in activities under UNCTAD which relate to competition policy. For instance, the Agency attends the annual meeting of the Intergovernmental Group of Experts (IGE) on Competition Law and Policy (Kazakhstan, 2022[4]), as well as other competition-related events organised by UNCTAD.

Co-operation with BRICS

Despite not being a member state of BRICS, Kazakhstan’s competition authority co-operates with the BRICS Competition Law and Policy Centre within the BRICS+ format, particularly by attending and speaking at meetings, as well as exchanging information for research on competition-related issues (for example, the Agency provided input for a global study on the agricultural sector currently being conducted by the Centre’s team).

Co‑operation within the SCO

In 2023, at the 22nd Meeting of the Council of Heads of Government (Prime Ministers) of the Member States of the Shanghai Co-operation Organisation (SCO), the heads of delegations supported the initiative to launch a mechanism for co‑operation in the field of antimonopoly regulation and the fight against unfair competition within the SCO framework.

In this context, on 30 May 2024, a kick-off meeting of the heads of antimonopoly authorities of SCO Member States was held in Dushanbe, where participants discussed the current state and future prospects of co‑operation among competition authorities within the SCO. Joint work within the SCO is expected to contribute not only to strengthening economic relations among Member States but also to supporting a healthy competitive environment and protecting consumer interests.

On 24 April 2025, a follow-up meeting of the heads of antimonopoly authorities of SCO Member States was held in Moscow in a hybrid format. During the meeting, a decision was made to establish co‑operation in the format of an expert working group, and key areas for joint work were discussed, which are of particular importance to the competition authorities of SCO Member States.

Co-operation within the Organization of Turkic States (OTS)

As part of Kazakhstan’s chairmanship in the Organization of Turkic States (OTS), a Plenary Meeting of the heads of antimonopoly authorities of OTS Member States was held on 23 January 2024, in Istanbul to establish the “Council on Competition of the Turkic States.” The Council is intended to facilitate regional co‑operation among the competition authorities of OTS Member States in the field of competition law and enforcement.

At the 11th OTS Summit with the participation of the heads of Member States, a declaration was adopted, positively noting the establishment of the “Council on Competition of the Turkic States” as a body that can ensure the effective functioning of market systems and contribute to the sustainable and stable development of the region’s economies. On 29 April 2025, a subsequent meeting of the Council on Competition of the OTS was held, during which a Communiqué was signed outlining the main areas for joint co‑operation in ensuring compliance with competition rules, creating favourable conditions for regional co‑operation, fostering a culture of competition in OTS Member States, exchanging knowledge, and more besides.

Co-operation within the framework of CIS

Kazakhstan is a member of the Commonwealth of Independent States (CIS), an intergovernmental organisation in Eurasia. The organisation encourages co-operation between member states in several areas, including antimonopoly policy. For this purpose, Interstate Council for Antimonopoly Policy (ICAP) was established in 1993.13 Its main tasks are improvement of national competition laws, enhancing co-operation between national competition authorities of CIS member states, competition advocacy and human resource development.14

ICAP serves as the main platform for interaction of competition authorities of CIS member states. At the meetings, many ongoing issues competition authorities are facing are discussed (Kazakhstan, 2018[5]). ICAP also facilitates conducting joint investigations through the Headquarters for Joint Investigations of Violations of the Antimonopoly Legislation of the CIS Member States (Kazakhstan, 2022[4]).

8.2.4. Co-operation within the framework of international agreements

The Agency has also signed memoranda of understanding (MoU) with multiple countries, including Lithuania (2010), Serbia (2012), Austria (2013), Romania (2013), Turkey (2013), the Kyrgyz Republic (2015), Belarus (2018), Tajikistan (2018), Mongolia (2018), China (2023), and Uzbekistan (2024). The Agency is currently working on signing new agreements with other countries — for example, an MoU with the Republic of Azerbaijan is planned for 2025. Primarily, the Agency’s co-operation takes the form of submitting requests or exchanging information in the course of conducting competition analysis in product markets, as well as holding joint meetings for the exchange of practical knowledge and experience. At the same time, there have been no joint bilateral investigations between the Agency and the abovementioned countries, with the exception of the development of joint documents (such as reports or methodological guidelines), which may be used by competition authorities in the course of investigations.

References

[1] Kazakhstan (2023), Annual Report on Competition Policy Developments in Kazakhstan: 2022, https://one.oecd.org/document/DAF/COMP/AR(2023)47/en/pdf.

[4] Kazakhstan (2022), Annual Report on Competition Policy Developments in Kazakhstan: 2021, https://one.oecd.org/document/DAF/COMP/AR(2022)47/en/pdf.

[5] Kazakhstan (2018), Annual Report on Competition Policy Developments in Kazakhstan: 2017, https://one.oecd.org/document/DAF/COMP/AR(2018)23/en/pdf.

[3] OECD (2021), Peer Reviews of Competition Law and Policy: Eurasian Economic Union, Competition Law and Policy Reviews, OECD Publishing, Paris, https://doi.org/10.1787/1bcf2117-en.

[2] Vinokurov, E. (2017), “Eurasian Economic Union: Current state and preliminary results”, Russian Journal of Economics, Vol. 3/1, pp. 54-70, https://doi.org/10.1016/j.ruje.2017.02.004.

Notes

← 1.  Article 163 of the Entrepreneur Code.

← 2.  Article 216 of the Entrepreneur Code.

← 3.  Article 90-7 of the Entrepreneur Code.

← 4.  Article 90-5 of the Entrepreneur Code.

← 5.  Decree of the President of the Republic of Kazakhstan dated 22 June 2022, no. 938.

← 6.  Article 201(5) of the Entrepreneur Code.

← 7.  Article 164 of the Entrepreneur Code.

← 8.  The EEC has established its own terminology for “competition enforcement”.

← 9.  The EAEU Treaty gave the EEC powers only to "general rules of competition" (which in fact include only four types of violations).

← 10.  The Supreme Eurasian Economic Council decision dated 19 December 2012 No. 29 on approving criteria of market classification as cross-border market.

← 11.  Some additional requirements exist when there are several economic entities occupying a dominant position.

← 12.  Paragraph 83 of the Protocol on General Principles and Rules of Competition (Annex No. 19 to the EAEU Treaty).

← 13.  https://e-cis.info/cooperation/2935/77720/.

← 14.  https://economy.gov.by/en/Interstate-Council-en/.