Checklist: preparing a merger filing in the Western Balkans

A checklist for a buyer or investor whose deal may need a merger filing in Serbia, Montenegro, Bosnia and Herzegovina, North Macedonia or Albania. Thresholds, deadlines and standstill rules were checked on 29 September 2026 against our merger control guides. To test your deal, use our Merger Control in the Balkans tool at /merger-control-in-the-balkans-the-app/.

Checklist · Last updated 30 September 2026

Draft for review by DRG lawyers. Prepared from the firm's published articles and official sources; not yet approved for publication.

011. Do you need to file?

Turnover is taken from the preceding year. Test every jurisdiction where a party has turnover, and, in most of them, also where only the buyer has turnover. Our tool at /merger-control-in-the-balkans-the-app/ runs these tests for you.

Collect turnover for the preceding year for every party and its group: worldwide, and in each country.Serbia: file if combined worldwide turnover exceeds EUR 100 million and at least one party has turnover in Serbia above EUR 10 million; or if combined turnover of at least two parties in Serbia exceeds EUR 20 million and at least two parties each exceed EUR 1 million there.Montenegro: file if combined turnover in Montenegro exceeds EUR 5 million; or if combined worldwide turnover exceeds EUR 20 million and at least one party has turnover in Montenegro above EUR 1 million. The new law of 2026 did not change the thresholds.Bosnia and Herzegovina: both conditions must be met: combined worldwide turnover above EUR 50 million, and either at least two parties each with turnover in BiH above EUR 4 million, or combined market share in BiH above 40 percent.North Macedonia: file if any one applies: combined worldwide turnover above EUR 10 million with at least one party registered there; combined turnover there above EUR 2.5 million; or one party above 40 percent or the parties together above 60 percent market share.Albania: the thresholds are set in ALL: combined worldwide turnover above ALL 7 billion with at least one party above ALL 200 million in Albania; or combined turnover in Albania above ALL 400 million with at least one party above ALL 200 million. Euro amounts are only indicative.Check foreign-to-foreign deals: a filing can be required even when the target has no turnover in the country. In Bosnia and Herzegovina this matters only in the context of joint control.Serbia: a takeover bid must be notified even when turnover thresholds are not met, and two or more transactions between the same parties within two years count as one concentration.For Bosnia and Herzegovina and North Macedonia the market share alternatives need a view on the relevant market. Prepare a market definition before you decide.

Sources: DRG, Merger Control in Serbia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Montenegro: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Bosnia and Herzegovina: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in North Macedonia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Albania: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Montenegro: New Rules Enter into Force (2026-04-08); Law on Protection of Competition (Paragraf Lex) (2026-09-30); Competition Authority of Albania (caa.gov.al), Concentrations (2026-09-30); DRG, Merger Control App: iOS Version Is Here! (2023-04-20); DRG, Merger Filing in the Balkans: The App (2018-03-19)

Practice area: Competition / Antitrust

022. What to prepare

The content of the filing follows the Serbian Decree (Official Gazette 5/2016) in Serbia. Forms in the other jurisdictions differ, so ask for the current form early. Serbia, Montenegro and Albania have a short or fast-track procedure for cases without competition concerns; Bosnia and Herzegovina and North Macedonia use one form for all.

Identification and registration documents of each party, and contact details of the representatives and authorized persons, with powers of attorney.Charts of the group structure with ownership percentages, before and after the deal, and lists of related and connected undertakings.The transaction documents (agreement, status change, acts on acquiring control or creating a joint venture) and a description with the implementation timeline.Financial statements for the preceding year, and turnover for the last three years, worldwide and in the country, net of VAT.Lists of the largest suppliers and customers with values (in Serbia the five largest).A proposed definition of the relevant market and market data: activities, market size, sales, market shares of the parties and competitors, distribution networks.A list of filings made or planned in other jurisdictions.Serbia: documents in Serbian; foreign documents with a certified translation, one paper copy in A4 and an electronic version.Decide with counsel whether the short form is available and worth using, and whether to keep the option of a fuller filing if the authority asks for one.

Sources: Decree on the content and manner of submission of the merger notification, Official Gazette of RS 5/2016 (Paragraf Lex) (2026-09-30); DRG, Merger Control in Serbia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Montenegro: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Bosnia and Herzegovina: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in North Macedonia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Albania: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23)

Practice area: Competition / Antitrust

033. Deadlines and standstill

Do not close before approval in any of the five jurisdictions. Deadlines differ, and Montenegro changed in April 2026.

Serbia: file within 15 days of the earliest of the signing of the agreement, publication or closing of a public offer, or the acquisition of control. A filing may already be made on a serious intention (letter of intent, announced offer). Standstill until the Commission decides.Montenegro: no statutory filing deadline since 2 April 2026 (before: 15 days). Standstill until approval. Do not wait: file as early as the deal is defined.Bosnia and Herzegovina: file within 15 days of the conclusion of the agreement (or another triggering event). Standstill until approval by the Competition Council.North Macedonia: no statutory filing deadline, but the deal may not be implemented before approval.Albania: file within 30 days of the conclusion of the merger, acquisition of control or creation of the joint venture, or of the announcement of an offer. An oral agreement starts a one-week period. Standstill until approval.Put the deadlines and the long-stop date in the transaction timetable, and add the clearances as conditions precedent to closing.

Sources: DRG, Merger Control in Serbia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Montenegro: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Bosnia and Herzegovina: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in North Macedonia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); Competition Authority of Albania (caa.gov.al), Concentrations (2026-09-30); DRG, Merger Control in Montenegro: New Rules Enter into Force (2026-04-08); DRG, Merger Filing in the Balkans: The Basics (2018-02-26)

Practice area: Competition / Antitrust

044. Review periods, fees and risks

Review periods run from a complete filing, so the time it takes the authority to confirm completeness is part of your timetable. Fees below are indicative and come from our guides. Confirm them before budgeting.

Serbia: phase I is one month from a complete filing (silence means approval, but real timelines vary); phase II is up to four months.Montenegro: phase I is 30 calendar days counted from the certificate of completeness; the law sets no deadline for issuing it. Phase II is up to four months.Bosnia and Herzegovina: phase I is 30 days from the Council's confirmation that the filing is complete (which can take months); phase II is three months, extendable by three.North Macedonia: phase I is 25 working days from the certificate of completeness; phase II is 90 working days.Albania: phase I is two months from the working day after confirmation of completeness (25 working days for qualifying fast-track cases); phase II is up to three months.Budget phase I filing fees (indicative, from our guides): Serbia 0.03 percent of the parties' combined annual turnover, capped at EUR 25,000; Montenegro EUR 15,000; Bosnia and Herzegovina about EUR 3,500; North Macedonia about EUR 600; Albania about EUR 2,500 to 5,000.Avoid gun jumping. Fines for implementing without approval can reach 10 percent of turnover (Serbia: turnover in Serbia). In Montenegro the sanctions were changed by the 2026 law; the exact ceiling is being confirmed.Keep in mind that the Serbian Commission may review a completed concentration on its own initiative, for example where the parties' combined market share is at least 40 percent.

Sources: DRG, Merger Control in Serbia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Montenegro: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Bosnia and Herzegovina: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in North Macedonia: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Albania: A No-Nonsense Guide (guide updated 2026-04-23) (2026-04-23); DRG, Merger Control in Montenegro: New Rules Enter into Force (2026-04-08); DRG, Serbia: NCA Investigates Fortenova for Gun Jumping in Takeover of Agrokor Assets (2019-10-11); DRG, Merger Control in Serbia: What Are the Trends? (2021-11-23)

Practice area: Competition / Antitrust

This guide gives general information on the law as of the date above and is not legal advice. Laws and practice change; please contact us before acting on any of it.

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