Commitments in competition law: a comparative legal analysis of regulatory models

The article presents an original comparative legal study of commitment approval models in foreign jurisdictions, including the European Union, the United Kingdom, the United States, Japan, China, Canada, Turkey, Brazil, and South Africa. The author proposes a classification of these models based on institutional criteria: administrative, judicial, and hybrid. It is demonstrated that the choice of model aff ects the degree of external oversight, the legal consequences of commitments, and their integration into national legal systems. The analysis substantiates the high level of adaptability and institutional fl exibility of the administrative model, which makes it the most promising for potential implementation within the Russian legal framework. The study is of applied nature and contributes to a comprehensive understanding of the legal nature and functional characteristics of commitments in competition law enforcement.