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Starting next year, the rules on corporate criminal liability in Hungary will undergo significant reforms aimed at making companies' participation in criminal proceedings more effective, predictable and proactive. Among the most notable innovations is the introduction of plea deals for companies, intended to enhance both accountability and cooperation between companies and criminal authorities.

Schoenherr has advised Enery Element on the sale of its 50% stake in Dunav Solar Plant, the developer of the Gabare photovoltaic project in northwest Bulgaria, to OMV Petrom, as part of a 50-50 joint venture between the two companies. Simultaneously, Enery Element transferred the remaining 50% of its shares to Enery Power Holding.

In a recent landmark decision, the German Federal Court of Justice (BGH) addressed whether law enforcement authorities were entitled to unlock a suspect's smartphone by forcibly using their fingerprint. The BGH accepted this conduct under the specific circumstances and explicitly ruled out a violation of the prohibition against self-incrimination.

Bulgaria’s renewable energy sector has seen significant growth in recent years. In 2024, almost 1 gigawatt of new renewable energy capacity was connected to the grid, predominantly from solar energy. Notably, no new wind farms have been commissioned since 2012, primarily due to administrative barriers and local opposition. However, investor interest remains high, especially in the southern and northwestern regions. Projects like the 238-megawatt Tenevo hybrid solar plant in Yambol, which plans to integrate a solar park, wind turbines, and energy storage, exemplify this trend.

Significant amendments to Hungary's foreign direct investment (FDI) control regime entered into force on 24 June 2025, introducing expanded pre-emption rights for the state and revised procedural timelines.

Lenders under foreign law credit arrangements subjected to the competence of English or other non-EEA courts – whose judgments (as opposed to those from EEA courts) are not automatically recognised or enforced in Bulgaria – often seek separate guarantees, allowing them to directly sue Bulgarian guarantors (e.g. wealthy domestic subsidiaries of multinational borrowers) in Bulgaria and obtain local court injunctions. Using the typical Bulgarian law guarantee arrangements subjected to the competence of Bulgarian courts in such cases is problematic.

Schoenherr and Cerha Hempel have advised OMV on global regulatory filings, including merger control procedures before the European Commission and national competition authorities, related to the combination of OMV subsidiary Borealis, ADNOC subsidiary Borouge, and NOVA Chemicals. White & Case's Dubai office reportedly advised OMV as well. Freshfields, Gibson Dunn & Crutcher, and Latham & Watkins reportedly advised ADNOC.

Schoenherr has advised Schott Hungary on four EPC projects with Strabag, Weinberg, and Szarnyas related to the construction of new production facilities called Bau5, Bau6, Bau9, and Bau10. 

On 17 March 2025, a new Regulation of the Moldovan Competition Council (the "MCC") on Economic Concentrations (the "New EC Regulation") entered into force in Moldova (as secondary legislation). It introduces several key changes aimed at enhancing the enforcement of competition legislation and increasing transparency. The New EC Regulation transposes several European Union regulations, including the Commission Implementing Regulation (EU) 2023/914 of 20 April 2023 and the Commission Notice on a simplified treatment for certain concentrations 2023/C 160/01.

New amendments were implemented to the Hungarian Competition Act in 2024 and early 2025. Merger control proceedings increased by almost a third in 2024 compared to the previous year. The enforcement activity of the Hungarian Competition Authority (HCA) was also noteworthy, with the Hungarian watchdog imposing more fines for competition infringements than in the previous year, especially in cartel cases. In this article we explore recent legislative changes and enforcement trends, while highlighting what companies can expect for the rest of 2025.

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Schoenherr is a leading full-service law firm providing local and international companies stellar advice that is straight to the point. With 15 offices and 4 country desks Schoenherr has a firm footprint in Central and Eastern Europe. Our lawyers are recognised leaders in their specialised areas and have a track record of getting deals done with a can-do, solution-oriented approach. Quality, flexibility, innovation and practical problem-solving in complex commercial mandates are at the core of our philosophy.

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