The introduction of the euro in Bulgaria as of 1 January 2026 is not only a major economic milestone but also a ground for enhanced regulatory oversight over businesses.
In the previous edition of our Legal Digest, we examined the draft amendments to the Act on the Adoption of the Euro in the Republic of Bulgaria (the “Euro Act”). On 8 August 2025 these amendments officially entered into force and became binding law, giving rise to concrete obligations and practical implications for businesses.
This article reviews the final legal framework for the euro’s introduction in Bulgaria, including the key amendments effective as of 8 August 2025, as well as certain practical questions regarding the application of the law which are already being widely raised by merchants.
1. Dual price display
For the period that already started on 8 August 2025 and is lasting until 8 August 2026 - the so-called “dual price display period” - prices of goods and services must be indicated simultaneously in Bulgarian lev (BGN) and in euro (EUR) when offered to consumers. The two amounts must be placed in close proximity, using identical font size, type and colour – the same requirement applies to the currency symbols.
The dual price display obligation is applicable to physical shops, catalogues, traders’ websites (irrespective of whether goods or services can be purchased directly online or not), and any other public sources indicating prices and directed at or accessible to consumers. Where a tariff applies both to consumers (B2C) and to business clients (B2B), the requirement for dual display must also be observed.
In practice, this means that every channel providing price information must contain both prices – in BGN and in EUR. Promotional campaigns also fall within the scope, where it is advisable that both the regular and promotional price be shown in both currencies. It is important to note that, by explicit statutory exception, tax invoices are not subject to dual display.
The requirement is undoubtedly burdensome, particularly in an online environment where, for technical reasons, systems do not always allow simultaneous display of two prices. Nevertheless, the provision was adopted in order to protect consumers and to prevent misleading practices. For the benefit of businesses, the period of dual display was shortened by more than four months, as it was initially foreseen to continue until the end of 2026.
2. Protection against speculation
During the dual price display period, prices may only be increased if there are external “objective economic factors”. The initial draft of the Euro Act amendments listed specific examples which would be considered “excusable” grounds for a price increase – e.g. an increase in the prices of raw materials and supplies, electricity, natural gas, fuels, minimum wage, tax and social security burden, force majeure events and others.
Ultimately, the definition of “objective economic factors” remained significantly more general. It was adopted as: “external to the trader providing goods and services to consumers, documentable changes in production, delivery, storage and sales costs, as well as regulatory changes, extraordinary circumstances (force majeure), and other factors which have a direct and substantial impact on cost price”.
Regardless, the initial bill clearly indicates the types of circumstances likely to be considered as justifying price increases. It is also beyond doubt that merchants must maintain detailed documentation evidencing the existence of such factors. In case of inspection by the regulatory authorities, the burden of proof that the price increase is justified and lawful will rest with the merchant, who must provide the relevant information in written within 5 days upon request to the competent authority – the Consumer Protection Commission (CPC), the National Revenue Agency (NRA) or the Financial Supervision Commission (FSC).
For large traders (with turnover exceeding BGN 10 million) in certain sectors - food products, alcoholic and non-alcoholic beverages, tobacco products, medicines, etc. - an additional requirement is introduced to publish daily, by 07:00 a.m., the prices of goods from the “large consumer basket” in machine-readable format on their websites, or, if they do not maintain such, to provide them to the CPC.
This regulation provides some legal certainty on the widely discussed issue of speculation in the country and acts as a mechanism against excessive price increases. At the same time, numerous practical questions remain unresolved and are not expressly regulated in the Euro Act, for example: according to what concrete criteria will it be assessed whether factors are “objective”; if such factors are proven, must a direct causal link be established between the factor (e.g., increased delivery/production costs) and the price of a specific product; how will short-term promotional campaigns resulting in price fluctuations be treated, etc.
Answers to these questions will likely be sought based on general legal and economic principles. However, the lack of explicit regulation and case law (at this stage) does not exclude the risk of inconsistent and potentially ambiguous administrative practice.
3. Dual circulation period
Throughout January 2026 both the lev and the euro will be legal tender. During this period traders are legally obliged to accept payments in lev (BGN). As of 1 February 2026, payments in lev will no longer be accepted. In practice this rule primarily concerns cash payments, as bank accounts will be automatically converted.
It is advisable that cash registers, POS terminals and online payment systems be adapted already in December 2025 to avoid technical interruptions at the beginning of the year.
In the context of employment relations, it is also important to clarify that there will be no need for a separate annex to employment contracts specifying remuneration in euro - salaries will be converted ex lege according to the general rules of the Euro Act. Similarly, there will be no need to indicate a new bank account if one is already provided in the contract - employees will continue to receive their remuneration in the same account, which will automatically be converted as of 1 January 2026.
4. Sanctions and “grace period”
Until 8 October 2025, violations relating to dual price display or increases in prices without proper documentation of objective economic factors will result only in written warnings from the regulatory authorities. Nevertheless, this period should be used by businesses to prepare and align their operations with the law.
Following that date, fines for violations of the dual price display requirement may reach up to BGN 5,000 (approx. EUR 2,500) for a first violation and up to BGN 10,000 (approx. EUR 5,000) for a repeat violation.
5. Conversion of company capital
It is also important to note that company capital will be automatically converted by the Commercial Register at the fixed exchange rate of 1.95583. Conversion and rounding will be carried out under the general rules of the Euro Act, which we examined in previous editions.
Formally, by 31 December 2026, companies must file with the Commercial Register an updated constitutional document (Bylaws) reflecting the capital in euro, as well as the new nominal value of one share. The law, however, provides that if another filing (e.g., change of manager, registered office, etc.) is submitted in the meantime, the updated Bylaws must be filed within that same procedure.
Since companies must also submit their annual financial statements for the previous financial year no later than 30 September, this effectively means that the updated Bylaws should be filed by that date at the latest.
The introduction of the euro in Bulgaria is both an opportunity for modernization and deeper integration of the national economy with the EU one, and a test of businesses’ readiness to adapt quickly and without disruption. For companies this requires timely updating of internal systems and websites, adapting internal rules and corporate documents, and continuous monitoring of emerging administrative and judicial practices in order to avoid compliance risks.
