With the promulgation in March 2026 of the entirely new Law on Transparency in the Representation of Interests (“LTRI”), a new comprehensive framework for regulating so-called lobbying activities in Bulgaria is being introduced. The act aims to increase transparency in interactions between the private sector, organizations and public institutions, while ensuring equal access to the decision-making process and greater accountability to the general public.

At the heart of the new legislation lies the concept of “representation of interests,” which encompasses any oral or written communication with public authorities for the purpose of influencing the creation, amendment, or content of legislative acts, policies or strategic documents. This means that the scope of the law is broad and includes not only traditional lobbying but also various forms of participation in the policy-making process. At the same time, the LTRI clearly outlines exceptions (i.e. cases that are not considered representation of interests)—for example, the actions of citizens in their personal capacity, the activities of public authorities within the scope of their powers, etc.

The LTRI also introduces clear rules regarding who is considered a “representative of interests.” This may be any natural or legal person who seeks to influence the decisions of institutions in defence of a public, group, or private interest. At the same time, restrictions are imposed on certain categories of persons who cannot hold such a capacity, namely—persons holding public office, civil servants, and so on. A “cooling-off” period is also provided for after leaving the relevant position, during which the prohibition on representing interests with respect to these categories of persons remains in effect.

The law applies to a wide range of institutions—from the National Assembly and the executive branch to local government bodies and other public institutions with the authority to adopt legislative or administrative acts. This ensures that the transparency rules will cover virtually all levels of public administration.

One of the key elements of the new framework is the principles underlying the interaction between institutions and interest representatives. These include openness, transparency, accountability, good faith and integrity. The LTRI requires the decision-making process to be traceable by ensuring access to information, the publication of opinions and the reasons for accepting or rejecting proposals.

The concept of the so-called “legislative footprint” is also introduced, which allows for tracking the influence of external participants on a given legislative act.

Particular attention is paid to the transparency of “lobbying” contacts. Institutions will be required to maintain public calendars of meetings with interest representatives, specifying the participants, the date and the topic of the meeting. This is a significant step toward greater openness and accountability in the decision-making process.

A central feature of the LTRI is the creation of an electronic Transparency Register, which will be maintained by the National Audit Office. It will require the registration of individuals who engage in interest representation as a profession, on a commercial basis, or for remuneration. The register will contain information about the individuals engaged in this activity, including their identity, area of interest and specific projects on which they are working. Public access to the register is envisaged, which will allow the public to monitor who is exercising influence and on what issues.

At the same time, the law provides for a number of exemptions from the registration requirement. These include, for example, lawyers in the course of their professional practice, political parties, labor and employer organizations, as well as individuals participating in officially organized consultations or providing expert opinions at the invitation of institutions. This demonstrates an effort to strike a balance between transparency and the protection of legitimate professional activities.

Penalties are also provided for non-compliance with the requirements of LTRI, including fines for individuals who engage in activities without registration or who submit false information. At the same time, the law provides for a transitional period during which sanctions will not be imposed, in order to allow affected individuals to adapt to the new regime.

It is important to note that some of the provisions, including those related to the registry and sanctions, will enter into force at a later date (end of 2026). This means that the actual implementation of the LTRI will proceed in stages, pending the adoption of subordinate legislation to specify the technical and procedural aspects.

In summary, the new law represents a significant step toward regulating lobbying activities in Bulgaria and introducing higher standards of transparency and accountability. It is expected to have a significant impact both on the way public policies are formed and on the practices of businesses and organizations when interacting with state institutions.

This article has been prepared for and is part of the Legal Digest issued by Penkov, Markov & Partners. The publications therein do not constitute legal advice and are not binding. Penkov, Markov & Partners reserves all rights to this material, and any distribution thereof is subject to the prior written consent of the law firm.