The Antimonopoly Office of the Slovak Republic (AMO) has penalized a major cartel agreement involving the public procurement of medicines. The first-instance decision, rendered on January 20, 2026, marks the first time in the authority’s history that a cartel was successfully dismantled using evidence and information provided by a whistleblower. This breakthrough led to the imposition of fines totaling nearly €7.8 million against two prominent entrepreneurs, alongside a prohibition on their participation in future public procurement processes.
The investigation focused on a coordinated effort to manipulate public tenders for the supply and distribution of categorized medicines conducted by the General Health Insurance Company between December 2017 and September 2020. By coordinating their bids, the parties undermined the competitive process essential for ensuring cost-effective healthcare services. The AMO has underscored the gravity of this case, noting that they consider this method of uncovering anti-competitive conduct to be “extremely important and effective” in protecting the economic interests of the state and its citizens.
The financial penalties distributed in this case reflect the scale of the infringement and the degree of cooperation provided by the parties involved. PHOENIX Zdravotnícke zásobovanie received a fine of €7,595,200 and a one-year ban from public tenders. Notably, PHOENIX utilized the settlement institute by admitting to its participation in the competition rules infringement. As a result, the AMO reduced the company’s fine by 30% and shortened the duration of its procurement ban. Conversely, TRANSMEDIC SLOVAKIA, currently in bankruptcy, was fined €201,800 and received a more severe three-year ban from public procurement.
This case also highlights the financial incentives now available to individuals who assist in regulatory oversight. Under the Act on the Protection of Economic Competition, a whistleblower who provides the first decisive evidence or information regarding an agreement restricting competition is entitled to a reward. Specifically, the reward is set at 1% of the total fines imposed, capped at a maximum of €100,000. In this instance, the whistleblower’s contribution proved to be the catalyst for the subsequent inspection and the eventual successful prosecution of the cartel members.
Beyond the immediate penalties, the AMO is using this decision to draw market attention to its settlement and leniency programs. These mechanisms allow entrepreneurs who admit responsibility for law violations to significantly mitigate their legal and financial exposure. For cartels and abuses of dominant positions, the AMO offers fine reductions of up to 30% for those who choose to settle, while vertical agreements can see reductions of up to 50%. This enforcement action signals a robust new era of vigilance in Slovakia, where internal disclosures are increasingly becoming the most potent tool for regulatory authorities.