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Bulgaria’s Amendments to Energy Act Change Licence-Fee Terms of Payment to Regulator

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Recent amendments of the Bulgarian Energy Act (EA) are changing the terms of payment for the annual licence fee in the energy sector. Previously, the annual licence fee was payable in two installments – by 31 March and by 30 November for every year following the year that the licence was issued.

According to Art. 29 of the amendment, payment of the licence fee must now be made by 31 March of the respect year in one payment only. Licencees who have not paid the first installment of the licence fee for 2025 by by 31 March must pay the annual licence fee in full by 30 November 2025 together with interest for the unpaid first installment for the period from 1 April 2025 to the payment date, but no later than the date the Act on Amendments and Supplements to the Energy Act entered into effect.

Another change brought about in the amendment is that Bulgaria’s State Energy Regulatory Commission (EWRC) may initiate a proceeding for termination of a license if the obligation for payment of the annual fee is not met by a licensee within the statutory term.

All licensees under the EA should review outstanding obligations to the Regulator not later than 30 November 2025 and note that the annual information lists on license fees will be required in January/February 2026.

Further details on the ammendment will be publicly available on the EWRC’s website by the end of 2025.

By Kostadin Sirleshtov, Managing Partner, and Elena Yotova-Yordanova, Senior Associate, CMS Bulgaria

Bulgaria Knowledge Partner

Schoenherr is a leading full-service law firm providing local and international companies stellar advice that is straight to the point. With 15 offices and 4 country desks Schoenherr has a firm footprint in Central and Eastern Europe. Our lawyers are recognised leaders in their specialised areas and have a track record of getting deals done with a can-do, solution-oriented approach. Quality, flexibility, innovation and practical problem-solving in complex commercial mandates are at the core of our philosophy.

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