1.  Regulatory Framework and Enforcement

 

1.1  What is the environmental framework and the key pieces of environmental legislation in your jurisdiction?

 

·         Environmental Protection Act;

 

·         Waste Management Act;

 

·         Water Act;

 

·         Soils Act;

 

·         Liability for Prevention and Remediation of Environmental Damage Act;

 

·         Plant Protection Act;

 

·         Biodiversity Act;

 

·         Protected Areas Act;

 

·         Clean Ambient Air Act;

 

·         Climate Change Mitigation Act;

 

·         Protection From Environmental Noise Act;

 

·         Protection Against the Harmful Impact of Chemical Substances and Mixtures Act;

 

·         Liability for Prevention and Remedying of Environmental Damage Act;

 

·         Ordinance on the conditions and procedure for environmental impact assessment;

 

·         Ordinance on the conditions and procedure for environmental assessment of plans and programmes.

 

1.2  Who are the primary environmental regulatory authorities in your jurisdiction? To what extent do they enforce environmental requirements?

 

In Bulgaria, the primary environmental regulatory authorities include:

 

Ministry of Environment and Water (MOEW): This is the main governmental body responsible for the state environmental policy, including the management of natural resources, water quality, waste management, noise pollution and biodiversity conservation.

 

Executive Environment Agency: affiliated to MOEW with powers concerning the practical implementation of environmental policies, monitoring and reporting on environmental conditions, and managing various environmental programs.

 

Regional Inspectorates of Environment and Water (RIEW): Regional structures of MOEW responsible for practical enforcement of environmental rules, conducting inspections, and overseeing local environmental issues.

 

The enforcement mechanisms include regulatory inspections, compliance monitoring, and the imposition of administrative sanctions for violations of environmental rules. While Bulgaria has adopted robust legislative framework, the actual implementation and effectiveness of environmental rules may vary. Efforts to enhance institutional capacity and engage public awareness are ongoing by ways of various public programs and measures.

 

2.   Permits

 

2.1  What is the framework for the environmental permitting regime in your jurisdiction?

 

The essential environmental permits include:

 

·   Greenhouse gas emissions permits – required for the operation of new and existing installations for certain categories of industrial activities under the Climate Change Mitigation Act;

 

·   Water use permits – issued for water withdrawal and for water site use under the Waters Act;

 

·   Waste management operations permits – rules are specified in the Waste Management Act;

 

·         Integrated permits (IPPC) – required for operation of new and existing installations and facilities for certain categories of industrial activities under the Environmental Protection Act (EPA).

 

2.2 Can environmental permits be transferred between entities in your jurisdiction? If so, what is the process for transferring?

 

Most of the environmental permits are not automatically transferable between business operators. The successor of the company/asset is allowed to acquire a new permit through a simplified procedure which however takes into consideration the economic and technical capacity of the new operator.

 

For instance, the rights under waste management permit may not be transferred and/or ceded. In cases of transfer or succession of the installations, subject to the permit, the rights under the permit shall be transferred to the new operator following simplified written notification to the competent authority which shall record the change ex officio by issuing a decision amending the permit.

 

The procedure in the case of transfer or succession of the installation subject to a greenhouse gas permit is similar - the rights and obligations under the permit are transferred to the new operator who shall notify thereof the Executive Director of Executive Environment Agency in order to update the permit accordingly.

 

In the event of change of the operator, to whom an IPPC permit has been issued, the new operator is obliged to notify the Executive Director of the Executive Environmental Agency so the latter can assume the rights and obligations under the permit.

 

2.3  What rights of appeal are there against regulators with regards to decisions to grant environmental permits?

 

The issued permit, the decision for amending and/or supplementing the permit, the refusal of issuance, as well as its withdrawal, is appealable before the higher administrative authority (if any) and/or the administrative court according to the procedure set out in the Administrative Procedure Code. The appeal must be submitted within the statutory deadlines, otherwise the said is precluded.

 

3.  Environmental Impact Assessments

 

Are environmental impact assessments (EIAs) for certain projects required in your jurisdiction? If so, what are the main elements of EIAs (including any considerations in relation to biodiversity or GHG emissions) and to what extent can EIAs be challenged?

 

The Environmental Protection Act provides the specific investment projects for which the EIA procedure is mandatory. In general, large infrastructure, energy, industrial and other categories of projects that are expected to have material environmental impact, are subject to EIA. In addition, the need for EIA for other categories of smaller projects is subject to ascertainment by the RIEW/MOEW.  

 

In the basic scenario, an EIA goes through the following stages:

 

1) Informing the competent authorities and the affected population – the investor (called “assignor” within the procedure) is obliged to inform the competent authorities - the MoEW or RIEW, at the earliest stage of the investment proposal by submitting a notification form. The competent authority shall announce the proposal on its website and notify the mayor of the local municipality concerned.

 

2) Project screening –  the screening procedure helps to determine whether an EIA is required for a given project. The verification is performed according to specific criteria, namely:

 

·         characteristics of the investment proposal, e.g. size, affected area, scale, use of natural resources, subsoil, soil, water, waste generation, pollution and harmful effects, accident risks, etc;

 

·         the geographical location of the investment proposal, which may have a negative impact on the local (fragile) ecosphere;

 

·         the potential environmental and health impacts related to the population and human health, biodiversity, subsoil, soil, water, air and climate, etc;

 

·         the public interest.

 

3)  Determining the scope of content, format and conduct of consultations regarding the most important characteristics of the investment proposal, namely:

 

·         the specific features of the proposed development, activities and technologies,

 

·         the degree of development of the design solution and how it relates to existing or planned developments, activities and technologies;

 

·         the characteristics of the existing environment and all its components;

 

·         the significance of the anticipated impacts;

 

·         the alternatives for investment proposals;

 

·         measures to mitigate the anticipated negative environmental impacts.;

 

4)  Assessing the quality of the EIA report – the competent authority assesses the quality of the content in the report;

 

5)  Public consultation on the report – the competent authority shall identify the affected stakeholders and organise public consultation with them;

 

6)  EIA decision – when the public consultations are concluded, the competent body issues EIA decision, which could be either positive or negative, and usually contains measures and conditions to must be implemented by the investor. The positive EIA decision is an absolute prerequisite for the execution of the investment project.

 

7)  Monitoring of the implementation of the measures and conditions of the EIA decision

 

The control includes document verification and on-site visit by the competent authority officials. The following activities are usually subject to monitoring: implementation of the plan for prevention, reduction or elimination of significant adverse environmental impacts, assessment of the effectiveness of measures and the effects from implementation of the investment proposal over the environment.

 

Any EIA decision, no matter positive or negative, could be subject of appeal by any person that can prove legitimate legal interest. Negative EIA decisions could be appealed by the investor. Recently, the appeal of positive EIA decisions by various conservation and environmental activists and organisations became common practice.

 

The appealing procedure is carried out before the administrative court, through the competent authority, which had issued the contested EIA decision. The proceedings are comprised of two instances – the judgment rendered by the court of first instance can be appealed before a higher court.

 

А common reason for repealing of the negative EIA decisions is when the latter are based on objections, submitted after the end of the public discussions. In this event, before rendering its EIA decision, the competent body shall request new information from the investor, revising and amending of the EIA report.

 

The EIA decision is precluded and loses effect if the implementation of the investment proposal has not commenced within five years from the date of issuance of the said decision. The latter shall be ascertained by an inspection by the environmental control authorities.

 

4.  Contaminated Land and Pollution

 

4.1 What is the framework for determining and allocating liability for contamination of soil and groundwater in your jurisdiction, and what are the applicable regulatory regimes?

 

The main legislative acts regulating the matters are EPA, the Soil Act, the Waters Act and the secondary legislation thereof.

 

In line with the EU principles, the Bulgarian framework is primarily governed by general principal “the polluter pays” (explicitly mentioned in the EPA and the Soil Act),  according to which the one responsible for the contamination (damages) bear the costs of remediation.

 

The main regulatory bodies, overseeing liability and enforcement for contamination under the above acts, are the Ministry of Environment and Waters and Regional Inspectorates of Environment and Waters.

 

4.2 Under what circumstances is there a positive obligation to investigate land for potential soil and groundwater contamination? Is there a positive obligation to provide any investigative reports to regulatory authorities?

 

Generally, MOEW through the RIEW is obliged to perform monitoring of the contamination of the soils and groundwater.

 

Business operators (operators of production installations and facilities), engaged in largely polluting activities, are statutory obliged to perform self-monitoring. The self-monitoring conditions are predominantly defined in the IPPC permit’s conditions. Self-monitoring is also applied by operators carrying out EIA for their activity.

 

The terms and causes for reporting to the RIEW are determined in the IPPC permit – usually on an annual basis.

 

4.3  If land is found to be contaminated, or pollutants are discovered to be migrating to neighbouring land, is there a duty to report this contamination to relevant authorities?

 

Along with the annual reports, the complex permit holders are obliged to report to the regulatory bodies immediately if an incident occurs, or there are measured concentrations of harmful substances above the emission standards set out in the permit. This applies also in cases where the pollution has migrated to neighboring land.

 

4.4  Does the owner of land that is affected by historical contamination have a private right of action against a previous owner of the land when that previous owner caused the contamination?

 

The EPA provides for special civil claims against polluters, including cases where the polluted property is state/municipality owned. The affected parties by the pollution may file a claim against the polluter for cessation of the violation and for elimination of the consequences of pollution.

 

5.  Waste

5.1  What are the key laws and controls governing the regulatory regime for waste in your jurisdiction?

 

The main legal act governing the waste management regime in Bulgaria is the Waste Management Act (the “WMA”) and its respective subordinate legislation. The WMA provides for measures for protection of the environment and human health by way of minimizing waste generation, reducing its negative impacts, and improving the efficiency of resources.

 

The WMA sets requirements for products that generate hazardous or ordinary waste during production or after use and establishes extended producer responsibility to encourage reuse, prevention, recycling, and recovery of waste.

 

Specific waste categories (e.g., radioactive, air, and explosive waste) are governed by separate acts.

 

The regulatory and control bodies responsible for waste management include MOWE, RIEWs, the mayors of municipalities and the Executive Environment Agency, which is part of the EU Environmental Protection Agencies Network.

 

5.2  Do producers of waste retain any liabilities in respect of the waste after having transferred it to another person for treatment or disposal off-site (e.g. if the other person goes bankrupt or does not properly handle or dispose of the waste)?

 

The WMA mandates that when waste has been submitted for preparation prior to recovery or disposal, the original producer’s or holder’s responsibility for complete waste recovery or disposal still remains.

 

5.3  To what extent do producers of certain products (e.g. packaging/electronic devices) have obligations regarding the take-back of waste?

 

Persons placing on the market products which, after use, form the so-called ordinary waste, shall be responsible for their separate collection and treatment, as well as for attaining the relevant targets for separate collection, re-use, recycling and/or recovery.  One may fulfil his/her obligations either through collective schemes represented by a recovery scheme operator or individually. When an operator carries out the obligations individually, it shall be obliged to take back at the point-of-sale waste generated after use of the relevant products.

 

Regarding batteries and electronic devices, the producers are obliged to implement appropriate nationwide measures to collect products with expired life. This is usually effected with placing of containers in the retail chains.

 

6.   Asbestos and other Deleterious Materials

 

What are the duties of owners/occupiers of premises in relation to asbestos, or other deleterious materials, found on their land and in their buildings?

 

The national regulation related to the management of deleterious materials such as asbestos is laid down in the Environment Protection Act and its respective subordinate legislation (e.g. for asbestos there are two ordinances in force, which regulate the overall usage of this material and the specific conditions for protection of workers). The national legislation is aligned with the respective EU law requirements.

 

National legislation mandates that operators, owners, occupants and etc. shall take preventive measures to protect public health when performing activities, which pose risks of contamination/exposure to deleterious materials. Obligations include conducting risk assessments, developing work plans, providing proper training, and using protective equipment. Before commencing hazardous works, one shall notify the respective authorities (construction, health, labor, environmental, etc.) and obtain the respective permits. In order to mitigate risks during and after the activity there shall be continuous monitoring, air quality testing, and decontamination performed. Following the activity, a proper collection, transportation, and disposal of the hazardous waste shall be conducted.

 

7.   Product Regulation

 

To what extent are product regulations (e.g. REACH, CLP, TSCA and equivalent regimes) applicable in your jurisdiction? Provide a short, high-level summary of the relevant provisions. 

 

In consideration that Bulgaria is a Member State of the EU, Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) as well as Top of Form

 

Bottom of Form

 

Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP) are directly applicable.

 

Two national legislative acts are in force in order to regulate the application of REACH and CLP in line with the country’s specifics – the Bulgarian Protection Against the Harmful Impact of Chemical Substances and Mixtures Act (PAHICSMA) concerning the products that are placed on the market by economic operators that are and the Bulgarian Plant Protection Act (PPA) concerning phytosanitary measures regarding plants and plant-based products.

 

8.  Energy Efficiency

 

What provisions are there in your jurisdiction concerning energy efficiency (e.g. energy efficiency auditing requirements) in your jurisdiction?

 

The Bulgarian Energy Efficiency Act (EEA) provides the main regulatory framework and mechanisms to impose and promote energy efficiency. The energy efficiency is implemented in a two-fold manner:

 

Firstly, in the field of construction, the newly commissioned buildings must carry a certificate for energy characteristics in line with the regulatory requirements to take into account the technical, environmental and economic feasibility of high-efficiency alternative installation and systems, the potential implementation of self-regulation devices and envisaging to design the buildings with near to zero energy consumption.

 

The buildings that are already in exploitation can be audited with respect to their energy efficiency, which upon completion results in an issuance of an energy performance certificate regarding the respective building. Public service buildings in use with total size of over 250 sq.m.,  as well as public outdoor lighting systems shall be subject to a mandatory energy efficiency audit and certification.

 

Heating, combined heating and ventilation installations along with air-conditioning installations in buildings are also subject to a mandatory audit of their energy efficiency at a certain period of time depending on the capacity and size of the installation.

 

Identical rules apply for the machinery, equipment and installations that are owned by large enterprises, i.e. undertakings with more than 250 employees and turnover exceeding 50 million euros and/or total value of the assets over 43 million euros, whose industrial systems (with an annual consumption of over 3000 MWh), machinery and production buildings must be obligatory audited for energy efficiency on a regular basis.

 

9.  CLimate Change

 

9.1  What are the key policies, principles, targets, and laws relating to the reduction of greenhouse gas emissions (e.g. emissions trading schemes) and the increase of the use of renewable energy (such as wind power) in your jurisdiction?

 

In 2016, Bulgaria signed and ratified the Paris Agreement under the United Nations Framework Convention on Climate Change (“Paris Agreement”) whose objectives are reflected at national level in the Bulgarian Climate Change Mitigation Act (CCMA).

 

The CCMA also provides the implementation of the EU Emissions Trading Scheme (EU ETS), which is in force in Bulgaria being a Member State of the EU, this including rules over the administration of the National Registry for Greenhouse Gas Emission Allowance Trading (NRGGEAT) and the measures to reduce greenhouse gas emissions from liquid fuels and energy for transport. The EU ETS remains the main tool to reduce the greenhouse emissions as per the target set for 2030 to cut down greenhouse gas emissions by 55% in comparison to 1990 levels.

 

In this regard, the Integrated Energy and Climate Plan of the Republic of Bulgaria for 2021-2030 (“the Integrated Plan”) sets a target of least 34.48% share of renewable energy in gross final consumption by 2030. Those targets numbers are to be revised to correspond accordingly with the new targets of at least 42.5% share of renewable energy in gross final consumption for EU Member States, introduced with Directive (EU) 2023/2413 as regards the promotion of energy from renewable sources (RED III Directive).

 

Furthermore, the National Recovery and Resilience Plan adopted in line with Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility envisages the creation of zones for development of RES projects that would be regulated by simplified procedures in order to promote the reduce of carbon emissions by production of energy from renewable sources .

 

9.2  Does your jurisdiction have an overarching “net zero” or low-carbon target and, if so, what legal measures have been implemented in order to achieve this target.

 

The Integrated Energy and Climate Plan of the Republic of Bulgaria for 2021-2030 also sets out step-by-step actions in accordance with the country and EU targets for net-zero carbon emissions by 2050. The Integrated plan provides in-depth guidelines and targets for reducing carbon emissions for most of the economic sectors (construction, energy production, transport, agriculture, etc.) of Bulgaria.

 

9.3  Are companies under any obligations in your jurisdiction to have in place and/or publish a climate transition plan? If so, what are the requirements for such plans?

 

Under the current Bulgarian law, there are no legal requirements for the companies to elaborate and/or publish a climate transition plan concerning their business and economic activities.

 

9.4  To what extent does your jurisdiction regulate the ability for products or companies to be referred to as “green”, “sustainable” or similar terms?  Who are the regulators in relation to greenwashing allegations?

 

Currently, there are no explicit regulations in Bulgaria regarding the labelling of products as “green”, “sustainable” or any similar term.

 

However, the EU is currently working on a piece of legislation with the working title “Green Claims Directive”, which aims to introduce a verification system for companies that want to make environmental-related claims along with a ban on “greenwashing” claims. After its adoption, the Directive would have to be transposed in the Bulgarian national law by elaborating and adopting respective national implementing acts.

 

9.5  Are there any specific arrangements in relation to anti-trust matters and climate change issues?

 

The Commission on Protection of Competition (the Bulgarian Competition Authority) is the authority that supervises the legality and the expediency of public procurements placed by the public (national and local) authorities. In this regard, with an ordinance of 2024 on environmental requirement for certain products subject to public procurement, mandatory minimal “green criteria” and ecological threshold are introduced for certain products and services within public procurement procedures.

 

9.6  Have there been any notable court judgments in relation to climate change litigation over the past three years?

 

In light of the fact that the initial piece of legislation explicitly introducing objectives, targets and principles in relation to climate change mitigation was adopted in 2014 – the Bulgarian Climate Change Mitigation Act, there is currently an absence of significant and notable court judgment regarding this matter. Lawsuits related to climate change that are brought before the Bulgarian court are still extreme rarity. The climate change issues are usually addressed rather indirectly in litigation cases, where the subject matter relates to environmental protection (water and air, soil pollution, protection of forests and natural parks, etc.).

 

9.7 In light of the commitments of your jurisdiction that have been made (whether at international treaty meetings or more generally), do you expect there to be substantial legislative change or reform in the relation to climate change in the near future?

 

The competence for adopting environment and climate change legislation is 'shared' between Bulgaria and the EU with respect to the rules under the Treaty on the Functioning of the European Union (TFEU).

 

Taking into consideration that the EU has adopted numerous acts with respect to this objectives, targets, principles and strategic documents such as Fit for 55, European Green Deal, European Climate Law etc., any significant legislative changes or reforms shall come from the adoption of new concept regarding climate change on an EU level.

 

10.  Liability

 

10.1 To what extent can the following persons be held liable for breaches of environmental law and/or pollution caused by a company: (a) the company itself; (b) the shareholders of the company; (c) the directors of the company; (d) a parent company; (e) entities (e.g. banks) that have lent money to the company; and (f) any other entities?

 

In the context of the direct applicability of EU primary law, the Bulgarian environmental laws are based on the “polluter pays” principle. This main principle is applied in the EPA, which provides that in the event of environmental damage or pollution in excess of the permissible levels and/or in case of non-compliance with the established emission values and restrictions, civil sanctions shall be imposed on the offending companies.

 

The concept of “piercing the corporate vail” is not recognized by Bulgarian law. Thus, shareholders in the capital companies in Bulgaria (limited liability company or joint-stock company) are not personally held liable for any breach of the environmental laws and/or pollution caused by the company. The shareholders in these types of legal entities are liable up to the amount of the capital or in-kind contributions in the companies in case of insolvency proceedings.

 

The shareholders in the companies with a personal element (various types of partnerships), where at least one or more of the partners are fully liable for the company’s operations, may be held liable jointly with the company. However, it should be noted that such structures are rarely used in practice. 

 

The same principle applies to the parent company, being a sole shareholder of the company.

 

In their daily operations, the directors of the companies should apply the principle of good businessman. If the environmental damage is caused to third parties by the directors by performing their managerial duties, they might be jointly liable with the company for compensation of such damage. In case the company is managed by collective body (board of directors, management board), any director may be discharged from liability if it is established that he/she was not at fault for the damage.

 

Pursuant to the provisions of the Bulgarian law, the lenders could not be held liable for any damage done by the borrower. Such liability may be assumed on a contractual basis by the lender, but in practice. no lender would assume such liability.

 

No other legal entities might be held liable for environmental damages done by a company.

 

For sake of exhaustiveness, it should be pointed out that directors’ personal liability might be attracted in case of wrongdoing by the company, if it is explicitly provided by the administrative and criminal law.

 

10.2  To what extent can: (a) a buyer assumes any pre-acquisition environmental liabilities in an asset sale/share sale; and (b) a seller retains any environmental liabilities after an asset sale/share sale in your jurisdiction?

 

In case of share sale, all matters concerned the liabilities distribution between the parties are reflected in the representation and warranties section and the seller assume engagement for a certain period of time (e.g. 5 years of the date of the completion of the deal) to be held liable for any potential environmental damages that might arise from actions taken during the time it has been the owner of the company. The buyer is liable for all potential environmental damages after the completion of the transaction.

 

In case of asset sale, the buyer becomes a universal successor of the seller’s rights on the asset, but it does not assume seller’s existing liabilities. The pre-acquisition environmental liability of the seller might be assumed on a contractual basis by the buyer. In practice, the seller typically retains the environmental liabilities associated with the asset prior the sale, while the buyer becomes liable after the completion of the transaction.

 

10.3  What duties to disclose environmental information does a seller have in a transaction? Is environmental due diligence commonplace in your jurisdiction?

 

Depending on the business sector of the target company, the environmental due diligence is one of the most important milestones for the buyer in the evaluation process and has a tremendous place in the successful completion of the transaction. The smooth environmental operations are usually one of the most important key performance indications of the target company for the potential buyers.

 

There are no legally prescribed restrictions on the information that the seller might disclose to the buyer. The duties for disclosure of environmental information of the seller are usually agreed on a contractual basis in the term sheet between the parties, allowing the buyer to perform a for the proper the due diligence on the target company. However, due to the transposing of CSRD into Bulgarian law, the information, contained in the sustainability report (major part of which is environmental related) will be publicly available.

 

11.  INsurance

 

What environmental risks can be covered by insurance in your jurisdiction, and what types of environmental insurance policy are commonly available? Is environmental insurance regularly obtained in practice?

 

Depending of the business sector of each company, the environmental insurance policy might cover various type of risks such as body injury, pollution, biodiversity damage, microorganism, etc.

 

Usually, the companies, which are operating in sectors with a high impact on the environmental, opt to choose between environmental insurance policy and third-party liability policy. Both policies cover the damages up to the amount limited in the contract provided that the damages are a direct and immediate result from the insured event. In Bulgaria, the third-party liability policy is commonly used by such type of companies.

 

12.  Reporting and Auditing

 

12.1  To what extent are there public registers of environmental information kept by public authorities in your jurisdiction? If so, what is the process by which parties can access this information?

 

There are several public registers in Bulgaria that provide environmental information, including:

 

·                           Public pollutant release and transfer register at the national level;

 

·                           Public register containing data about the conduct of EIA and environmental assessment procedures;

 

·                           Public register of protected areas – a register of all protected areas in Bulgaria, including national parks, nature reserves, nature parks and protected areas;

 

·                           Water bodies register – it is maintained by the Basin Directorates and contains information on the state of the country's water resources, including rivers, lakes and reservoirs;

 

·                           Climate Change Registry – includes information on Bulgaria's efforts to reduce its carbon impact as well as projects and initiatives related to climate change adaptation;

 

·                           Public register of installations for the production of electricity from renewable energy sources - provides the public with up-to-date information on the electricity produced by photovoltaic, wind, hydro and other plants.

 

·                           Public commercial register and register of non-profit organizations that, from 2025, will contain the ESG related sustainability reports of the obliged economic operators under the CSRD (as part of their annual financial statements)

 

These registers are publicly available through the websites of relevant authorities.

 

12.2  To what extent is there a requirement on public bodies in your jurisdiction to disclose environmental information to parties that request it?

 

Any interested party have the right to access all available public information throughout the public register maintained by the local authorities.

 

The access to such information may be refused only in cases explicitly provided by law, for instance – the information is classified, the information represents industrial or commercial secret, the disclosure might have adverse impact on the environmental media, etc.

 

12.3  Are entities in your jurisdictions subject to mandatory greenhouse gas public reporting requirements?

 

Pursuant to the EU and Bulgarian legislation, the companies are subject to mandatory greenhouse reporting depending on their size, type of activity and the number of emissions they generate.

 

On this basis, the Executive Environmental Agency prepares a full report on the greenhouse gas emissions in Bulgaria for a previous period of time as part of country’s commitments as a member of the European Union to reduce the factors which have negative impact on the climate change.

 

13.  Updates/Reform

 

Have there been any significant updates in environmental law in your jurisdiction in the past three years? Are there any material proposals for significant updates or reforms in the near future?

 

Bulgaria’s CSRD implementation was finalised with amendments to the Accounting Act and the Independent Financial Audit Act, adopted in September 2024. The Bulgarian Ministry of Finance and Institute for Certified Public Accountants function as supervisory authorities for the transposed obligations, with sanctions for non-compliance ranging from EUR 255 up to EUR 7,600 depending on the type of offence.

 

In addition, the Directive on corporate sustainability due diligence (CSDDD), which was adopted in 2024, and have to be transposed into the Bulgarian national law by July 2026, will introduce such obligations for companies with more than 1000 employes and net turnover over 450 million euros worldwide.

 

Also, currently, Bulgaria is in the process of developing a deposit return system for certain packaging waste (beverages packages), which is expected to commence effective operations in 2027 (Return-to-Retail model).