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BULGARIA COVID-19 TRACKER (last updated at 18:00 on 15 April 2020)
Key legal measures affecting business in relation to COVID-19 in Bulgaria
GENERAL MEASURES .................................................................................................................................................................................................... 2
RETAIL, SERVICES, TRAVEL, LEISURE AND HOSPITALITY ........................................................................................................................... 10
TRANSPORT .................................................................................................................................................................................................................... 13
EMPLOYMENT................................................................................................................................................................................................................ 18
TAX AND ACCOUNTING .............................................................................................................................................................................................. 21
PHARMACEUTICALS .................................................................................................................................................................................................... 27
JUDICIAL, ADMINISTRATIVE AND ENFORCEMENT PROCEEDINGS............................................................................................................ 29
PUBLIC PROCUREMENTS AND STATE GRANTS .................................................................................................................................................. 33
MISCELLANEOUS .......................................................................................................................................................................................................... 36
Page 2 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
GENERAL MEASURES
1. [Supplemented] General
social distancing
measures1
Order No. РД-01-124 dated
13 March 2020 issued by the
Minister of Health
Order No. РД-01-131 dated
17 March 2020 issued by the
Minister of Health
Order No. РД-01-139 dated
19 March 2020 issued by the
Minister of Health
Order No. РД-01-143 dated
20 March 2020 issued by the
Minister of Health
Order No. РД-01-144 dated
22 March 2020 issued by the
Minister of Health
Order No. РД-01-154 dated
26 March 2020 issued by the
Minister of Health
Order No. РД-01-195 dated
On 13 March 2020, Bulgaria declared a state of
emergency for one month until 13 April 2020. The
state of emergency and the general social distancing
measures wеre further extended until 13 May 2020.
The following general restrictions were introduced:
• Business suspension measures [see below].
• All educational activities, including
extracurricular activities (excursions, study
halls, educational gatherings, etc.) are
suspended in schools, universities2 and other
educational institutions and organizations,
including kindergartens and nurseries.
• Any social events, including sports activities,
cultural events (cinemas, theaters, museums,
conferences, symposiums, sports and SPA
centers, gymnasiums, etc.) are suspended.
• Visits to parks, city gardens, sports and
children playgrounds are suspended (effective
00:00 on 21 March 2020).
Effective 13 March 2020.
Amendment effective 17
March 2020.
Amendment effective 19
March 2020.
Amendment effective
00:00 on 21 March 2020.
Amendment effective 22
March 2020.
Amendment effective 26
March 2020.
Amendment effective 10
April 2020.
Amendment effective 11
April 2020.
1 Under the State of Emergency Act, the Minister of Health will be entitled to introduce subsequent temporary anti-epidemic measures, including suspension of work
of public use facilities and mobility restrictions. 2 Except for specific classes related to the state of emergency that are held at the Academy of the Ministry of Interior (effective 2 April 2020).
Page 3 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
10 April 2020 issued by the
Minister of Health
Order No. РД-01-197 dated
11 April 2020 issued by the
Minister of Health
• Wearing of protective masks or other face
coverings is mandatory in open and closed
public places, e.g. public transport, parks,
churches, bus stations, etc. (effective 12 April
2020 until 26 April 2020).
Persons below 60 years of age are barred
from visiting food stores and pharmacies
between 8:30 and 10:30 a.m. (effective 00:00
on 21 March 2020).
Persons in contact with those infected with
COVID-19 are placed under mandatory
quarantine for 14 days and are not allowed to
leave their homes. [See exception in item 67
below]
National Information System against spread
of COVID-19 is launched by the Ministry of
Health. The system aims at receiving
information on the health status of the
population. (effective 6 April 2020)
2. Mobility restrictions for
regional centers
Order No. РД-01-143 dated
20 March 2020 issued by the
Minister of Health
Order No. РД-01-153 dated
25 March 2020 issued by the
Minister of Health
Order No. РД-01-167 dated
Checkpoints are to be set up at the entry and exit
points of each of the 27 regional centers of Bulgaria
(including Sofia) and of the town of Bansko. Travel
through the checkpoints is only allowed for urgent
reasons, related to (i) work in the relevant settlement,
(ii) health reasons of the traveler or his/her close
relatives, оr when taking care of them, (iii) buying
essential supplies from food stores and pharmacies
Effective 00:00 on 21
March 2020.
Amendment effective 25
March 2020.
Amendment effective 30
March 2020.
Page 4 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
30 March 2020 issued by the
Minister of Health
Order No. РД-01-196 dated
10 April 2020 issued by the
Minister of Health
where not otherwise available at the place of current
or permanent residence, (iv) return to the place of
current or permanent residence, or to another
temporary address, if different. Depending on the
reasons, the travel must be evidenced by: (i) office
certificate (служебна бележка), office pass; (ii)
medical document; (iii) personal ID document or (iv)
a form declaration for the reason necessary for the
travel.3. A copy of the declaration (if requested) must
be kept by the authorities every time the person
passes through the checkpoints.
Truck drivers and drivers of cash collection vehicles
(инкасо автомобили) can provide only personal ID
documents and the office certificate or the working
identification card. Specific rules also apply to
passage of agricultural workers through the
checkpoints (Effective 10 April 2020).
Some employees or suppliers, e.g., of food and
medicinal products, employees of electricity and
water utility providers, etc., have priority when
traveling through the checkpoints
Amendment effective 10
April 2020.
3. Entry ban for arriving
passengers from high-risk
countries
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
Non-Bulgarian nationals, arriving from Italy, Spain,
France, the UK and Northern Ireland, Germany,
the Netherlands, Switzerland, Austria, Belgium,
Iceland, Lichtenstein, Luxembourg are to be
Effective 6 April 2020
3 The Bulgarian Ministry of the Interior published on its website a form of the declaration. The form is available here.
Page 5 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
refused entry into Bulgaria.
Exceptions:
- Bulgarian nationals, foreign nationals with
permanent, temporary or long-term residence
in Bulgaria, and members of their families.
- Medical staff, medical investigators, and
geriatric care specialists.
- Transport personnel engaged in the
transportation of goods, aircraft crew
members engaged in air transport and other
transport personnel, as necessary.
- Diplomatic staff, foreign officials (Heads of
States, members of governments) and
members of their delegations, staff of
international organizations, military and
humanitarian personnel, in performance of
their duties.
- Persons travelling for humanitarian reasons.
- Third country nationals, EU and Schengen
nationals (including nationals of San Marino,
Andorra, Monaco and the Vatican) directly
engaged in the construction, maintenance and
safety of strategic and critical infrastructure
of Bulgaria.
- Border workers and agricultural workers.
Page 6 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
[See general ban for entry for non-EU and non-
Schengen nationals below]
[See exceptions for truck drivers below]
4. Quarantine4 for all
arriving passengers
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
All passengers not included in the entry ban (see 3
above)5, arriving from abroad (regardless of
whether a COVID-19 case has been registered in
that country or not), are to be placed under
mandatory quarantine for 14 days.6 The arriving
passengers must inform border health authorities
about the address where they will be quarantined.7
[See exceptions for truck drivers below]
Effective 6 April 2020
5. General ban for entry of
all non-EU and non-
Schengen nationals
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
The entry of all non-EU and non-Schengen nationals
into the territory of Bulgaria is prohibited through all
border checkpoints regardless of the type of transport
– air, maritime, railway or road transport.
The exceptions for arriving passengers from high-risk
countries also apply to non-EU and non-Schengen
Effective 6 April 2020
4 Аccording to Order No. РД-01-217 dated 14 April 2020 issued by the Minister of Health the village of Panicherevo, Gurkovo Municipality, Stara Zagora Region, is
fully quarantined for 14 days. Entry to the village of persons having permanent or temporary residence in Panicherevo is permitted until 20:00 on 15 April. All
persons located in the village are quarantined for 14 days and cannot leave their homes except to buy food or medicinal products, or to use the services of banks, or to
seek medical help. Exceptions apply to certain medical, police, fire department, and other essential services personnel. Extensive restrictions to commercial activities
apply. The measure enters into force on 00:00 on 15 April 2020. 5 The categories of medical staff, diplomatic staff and foreign officials, transport personnel, in item 3 above, are exempted from this mandatory quarantine. 6 Art. 355, Para. 2 of the Criminal Code, provides imprisonment of until five years and a fine of BGN 10,000 to BGN 50,000 for failure to observe quarantine. 7 GUIDE/RULE/INSTRUCTION/PRECEPT FOR PLACEMENT UNDER A QUARANTINE is handed to all arriving passengers by the border health authorities.
Page 7 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
nationals.
[See full list of the exceptions in item 3 above]
[For transit through the country see item 6 below]
6. Transit through Bulgaria
to the country of residence
or establishment
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
Transit is permitted only in cases when the immediate
departure from the country is guaranteed. Foreign
nationals, for whom transit is allowed (see below),
must notify their respective diplomatic or consular
mission in Bulgaria in advance, in order for the
specific transit route to be set by the Bulgarian
authorities.
Transit through the Bulgarian territory to the country
of residence or establishment is allowed to the
following persons:
- EU and Schengen nationals (including
nationals of San Marino, Andorra, Monaco
and the Vatican) and members of their
families.
- Third country nationals having long-term
residence in an EU or Schengen Member
State (including in San Marino, Andorra,
Monaco and the Vatican) and members of
their families.
- Nationals of Serbia, the Republic of Northern
Macedonia, Montenegro and Turkey.
Effective 6 April 2020
Page 8 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
- Transport personnel engaged in the
transportation of goods, aircraft crew
members engaged in air transport and other
transport personnel, as necessary.8
[See specific rules in Transport section below]
7. General suspension of the
effects of default on
payments based on
financial agreements by
private persons and
entities
State of Emergency Act Until the end of the state of emergency, the effects of
default on payments based on financial agreements,
e.g. loans, leases, etc., of private persons and entities,
are suspended.9 The payments affected by the
suspension can be owed to financial institutions
(banks, lease companies, etc.) or to third parties in
case of assignment of the receivable. Suspension of
the effects of default on payments includes the
accrual of interest and penalties for delay,
acceleration, and the right to rescind a contract and
repossess assets.
[See item 8 for more information]
Effective 24 March 2020,
retroactively from 13
March 2020
Amendment effective 9
April 2020
8. [New] Terms and
procedures of payment
moratorium on financial
loans provided by banks
Decision dated 10 April 2020
adopted by the Bulgarian
National Bank (“BNB”)
In compliance with the Guidelines on legislative and
non-legislative moratoria on loan repayments applied
in the light of the COVID-19 crisis of the European
Banking Authority (“EBA”), the BNB adopted
respective local directions on terms and procedures of
Effective 10 April 2020
8 This category of foreigners who are allowed transit through the country, are exempted from the obligation to notify their respective diplomatic or consular mission
in advance. 9 For the period from 13 March 2020 until 8 April 2020, the general suspension of the effects of default on payments applies to all delayed payments of private
persons and entities regardless of the type of the obligations, i.e., it is not necessary for them to be based on financial agreements for this period.
Page 9 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
payment moratorium on financial loans provided by
banks and their subsidiaries. The directions include
various mechanisms of reliefs for the borrowers, e.g.,
temporarily postponement of capital and/or interest
payments on the loan without further amending the
terms and conditions. Eligibility criteria in respect of
the borrowers apply.
9. Extension of payment
periods
State of Emergency Act The periods for payment of electricity bills by
household customers are extended from 10 to 20 days
and may be extended further by the Minister of
Energy.
Effective 24 March 2020,
retroactively from 13
March 2020
Page 10 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
RETAIL, SERVICES, TRAVEL, LEISURE AND HOSPITALITY
10. Closing of public access to
non-essential retail outlets
and services
Order No. РД-01-124 dated
13 March 2020 issued by the
Minister of Health
Order No. РД-01-144 dated
22 March 2020 issued by the
Minister of Health
Order No. РД-01-154 dated
26 March 2020 issued by the
Minister of Health
Order No. РД-01-179 dated 6
April 2020 issued by the
Minister of Health
Order No. РД-01-195 dated
10 April 2020 issued by the
Minister of Health
Order No. РД-01-199 dated
11 April 2020 issued by the
Minister of Health
Order No. РД-01-218 dated
15 April 2020 issued by the
Minister of Health
Visits to all casinos and entertainment halls, bars,
discos, restaurants, fast food restaurants, cafés,
commercial centers (i.e., Malls), except for bank and
payment service providers offices, insurance offices,
grocery stores and pharmacies on their territory, are
suspended until 13 May 2020.
Fast food outlets and food stores in the territories of
gas stations should not allow consumption on the
spot. (Effective 22 March 2020)
The work of cooperative and flower markets will be
suspended from 17 April 2020 until 19 April 2020.
Separate food stores and pharmacies on the territory
of the markets are allowed to remain open. (Effective
15 April 2020).
Takeaway services are not affected.
Online retail is not affected.
Farmers’ markets are allowed to be open observing
strict sanitary requirements introduced by the local
municipalities. (Effective 6 April 2020)
All other retail trade and services are not affected,
except as stated below, but must continue under strict
sanitary requirements.
Effective 13 March 2020.
Amended 22 March
2020.
Amendment effective 26
March 2020.
Amendment effective 6
April 2020.
Amendment effective 10
April 2020.
Amendment effective 11
April 2020.
Amendment effective 15
April 2020.
Page 11 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
11. Sanitary requirements for
retail outlets which
remain in operation
Order No. РД-01-139 dated
19 March 2020 issued by the
Minister of Health
All retail outlets, the operation of which is not
suspended by the prohibition above, should operate
so as to ensure that not more than two adults above
the age of 60 are located in their premises and the
adjacent open areas at the same time, and should
instruct patrons to keep a distance of at least 1-1.5 m.
[See also prohibition for shoppers below the age of
60 in food stores and pharmacies between 8:30 and
10:30 a.m. in item 1 above.]
Effective 19 March 2020
12. [Expected] Obligation for
food retail chains10 to offer
Bulgarian products from
local agriculture
producers
Decree No. 70 dated 14 April
2020 on providing of main
group of foods in food retail
chains produced on the
territory of Bulgaria
According to draft Decree No. 70 dated 14 April
2020 on providing in food retail chains of the main
group of foods produced in the territory of Bulgaria11,
retailers having food stores in more than three
administrative regions in the country will be obliged
to offer and to allocate specific store locations for
Bulgarian products from local agriculture producers
within their stores, e.g. milk and dairy products,
honey, some fruit and vegetables12, etc.
[expected to come into
force on 21 April 2020]
13. Suspension of all tourism
visits
Order No. T-РД-16-76 dated
17 March 2020 issued by the
Minister of Tourism
All tourism visits and ancillary tourism services in
Bulgaria of persons having permanent residence in
the country and foreigners are suspended. Organized
tourism travels abroad and the related travel
Effective 17 March until
13 May 2020
10 Based on official announcement of the Minister Agriculture, Food and Forestry, the obligation refers to chains having at least 10 food stores on the territory of the
country. 11 The final wording of the draft Decree is not published yet. 12 Local producers of fruit and vegetables can be further supported by means of short-term loans granted by the State Fund Agriculture.
Page 12 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
Order No. T-РД-16-120
dated 10 April 2020 issued
by the Minister of Tourism
arrangements are also suspended. Based on an
unofficial statement by the Ministry of Tourism, the
hotels within the country should not accommodate
visitors.
14. Refund offered by the
companies providing
tourism services for
cancelled travel
State of Emergency Act Companies providing tourism services (tour
operators) can offer a voucher instead of refunding
the amount paid for cancelled travel. If the traveler
does not accept the voucher, the tour operator must
refund the amount within one month as of the end of
the state of emergency.
Effective 9 April 2020
15. Exemption from rental
payments to public
authorities
State of Emergency Act The respective authority, in its capacity as a lessor, is
entitled to reduce the rental price or to exempt from
the entire rental price, or part of it, the lessees, whose
work was suspended or restricted due to the state of
emergency.
Effective 9 April 2020
Page 13 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
TRANSPORT13
16. Measures for Bulgarian
truck drivers arriving
from countries where a
case of COVID-19 has
been registered
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
Bulgarian nationals – truck drivers, arriving from
countries where a COVID-19 case has been
registered, must remain quarantined at home for 14
days. During this period, truck drivers are allowed to
go through the country, load and unload goods, drive
the truck and leave the country before expiry of the
period of the quarantine.
[For the truck drivers passing through the country,
see item 17 below]
Effective 6 April 2020
17. Measures for foreign
truck drivers – third
country nationals or
arriving from high-risk
countries
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
Non-Bulgarian nationals – truck drivers, who are
third country nationals, or arriving from, or have
passed through Italy, Spain, France, the UK and
Northern Ireland, Germany, the Netherlands,
Switzerland, Austria, Belgium, Iceland,
Lichtenstein, Luxembourg, may enter the country
in order to deliver the loaded goods and then leave
Bulgaria immediately, or, in case of transporting
goods intended for other countries – transit through a
route set in advance by the Bulgarian Road
Infrastructure Agency (green corridor).
Effective 6 April 2020
13 On 1 April 2020, the Council of Ministers defined the border points on Bulgarian territory through which unobstructed transit of goods will be ensured, i.e. so-
called “green corridors”.
Page 14 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
Truck drivers, whether Bulgarian nationals or not,
who go through the country, must obtain a
document14 issued by the Bulgarian Road
Infrastructure Agency which sets the latest possible
date and time, and the exact border checkpoint, for
leaving the country. (the time spent in Bulgaria
cannot exceed 24 hours).
If the transit through the border checkpoint
determined by the Bulgarian authorities is banned by
а neighboring country, the Bulgarian authorities will
determine a parking place where the driver and the
truck must remain until the ban is lifted.
[Truck drivers who are non-EU and non-Schengen
nationals are exempted from the general entry ban –
see item 3 above.]
18. Measures for aircraft
crew members arriving
from non-EU and non-
Schengen countries or
from high-risk countries
Order No. РД-01-183 dated 6
April 2020 issued by the
Minister of Health
The following applies to aircraft crew members
arriving from non-EU and non-Schengen countries,
or from Italy, Spain, France, the UK and
Northern Ireland, Germany, the Netherlands,
Switzerland, Austria, Belgium, Iceland,
Lichtenstein, Luxembourg:
i. Aircraft crew members are not to be
quarantined if they did not spend time on
the territory of any of the above countries
(except within the airport) and the time spent
Effective 6 April 2020
14 An English form of the document issued by the Road Infrastructure Agency is available here, page 15.
Page 15 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
within the airport was only for pre-flight
preparation of the aircraft;
ii. Aircraft crew members arriving from any of
the above countries are permitted to enter
into Bulgaria if they do not leave the aircraft
(except for the mandatory pre-flight
preparation of the aircraft) and the time for
the next takeoff does not exceed the
permitted flight duty period (“FDP”), but not
more than 12 hours.
iii. Aircraft crew members, nationals of any of
the above countries, arriving in Bulgaria for
delivering an aircraft for technical service,
are permitted to enter the country if they do
not leave the aircraft (except for the
mandatory pre-flight preparation of the
aircraft) and the time for the next takeoff
does not exceed the permitted flight duty
period (“FDP”), but not more than 12 hours.
iv. If a passenger on an aircraft landing on
Bulgarian territory shows symptoms of
COVID-19, the cabin crew who took part in
the particular flight must not plan their next
flight and must be put under mandatory 14-
Page 16 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
day quarantine, as per the instructions of the
state health authorities.
19. Sanitary requirements for
air travel Order No. 45-01-156 dated
17 March 2020 issued by the
Director General of DG CAA
Airport and ground handling operators, companies
providing aircraft technical services and all air
carriers transporting passengers, cargo and mail from
and to the airports within the country must take strict
sanitary measures according to Safety Directive No.
SD-2020-01 dated 13 March 2020 issued by the
European Union Aviation Safety Agency15.
Effective 17 March 2020
20. Sanitary requirements for
maritime transport and
mandatory quarantine for
ships arriving from high-
risk countries
Measures adopted and
enforced by the Bulgarian
Maritime Administration
(“BMA”)16
Ships having on board one or more persons (crew
members or passengers) infected with COVID-19
must stay at anchorage quarantine area for 14 days.
Ships arriving from high-risk countries (not listed
by the BMA) for dry dock/ships repair shall also stay
at anchorage quarantine area for the same period.
Ships arriving from high-risk countries for cargo
operations are inspected by health inspectors. The
crew is placed under quarantine for 14 days on board,
cargo operations are to be carried out.
Effective 20 March 2020
21. Requirements for railway
transport
Measures adopted by the
Bulgarian State Railways
All cross-border trains to/from the country are
suspended (effective 17 March 2020).
In case a city/village is quarantined, the route of the
Various
15 Available here. See also Safety Directive SD No. 2020-02. 16 Full text of the measures is available here.
Page 17 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
trains will be adjusted, so that the trains do not stop at
the stations under quarantine (effective 24 March
2020).
Page 18 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
EMPLOYMENT
22. Remote work. Sanitary
measures at the
workplace.
Order No. РД-01-124 dated
13 March 2020 issued by the
Minister of Health
All employers are instructed to transfer to remote
work mode for their employees, where possible.
Where not possible, they must ensure the introduction
of increased anti-epidemic measures, including
filters, disinfection and regular airing of the premises,
instructions to staff on personal hygiene, and must
not allow access for employees or visitors having
symptoms of acute contagious diseases.
On 13 March 2020, the General Labor Inspectorate
Executive Agency announced to the employers on its
website that they need to include the introduced anti-
epidemic measures in the risk assessment in
accordance with Ordinance No. 5 dated 11 May 1999
on risk assessment.
Effective 13 March 2020
until the end of the state
of emergency.
23. Remote and home-based
work State of Emergency Act Employers are allowed (depending on the nature of
the work and possibility for remote work or work
from home), to assign to employees, without their
consent, remote work or work from home
Effective 24 March 2020,
retroactively from 13
March 2020
24. Unilateral right of
employer to grant the use
of up to ½ of the annual
paid leave
State of Emergency Act The employer may unilaterally order its employees,
without their consent, to use up to one half of their
annual paid leave.
Effective 24 March 2020,
retroactively from 13
March 2020
Page 19 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
25. Suspension of work State of Emergency Act Any employer or a public authority may, by an order,
suspend work at the enterprise, part of it or of
individual employees until the end of the state of
emergency. Where a public authority has suspended
work, the employer is barred from allowing
employees to access their workplaces.
Effective 24 March 2020,
retroactively from 13
March 2020
26. Rights of the employer
during suspension of work
State of Emergency Act Where work is suspended during the state of
emergency (see above), the employer can enforce the
use of the unused annual paid leave of the employees.
Employers must pay 100% of the gross salary to all
employees during the period of suspension of work,
regardless of the reason for the suspension (whether it
is by decision of the employer or of a public
authority).
Effective 24 March 2020,
retroactively from 13
March 2020
27. Obligation to grant leave
to certain categories of
employees
State of Emergency Act Employers are obliged to allow the use of paid or
unpaid leave at the request of certain categories of
employees, such as pregnant employees, single
parents, employees under the age of 18, etc.
Effective 24 March 2020,
retroactively from 13
March 2020
28. Introducing part-time
working hours
State of Emergency Act Employers may introduce reduced working hours for
employees who work full-time for the entire duration
of the state of emergency.
Effective 24 March 2020,
retroactively from 13
March 2020
29. Extension of the possible
term for seasonal farm
employment contracts
State of Emergency Act An employer – registered farmer can conclude a
short-term seasonal farm employment contract for a
period longer than 1 day.
Effective 9 April 2020
Page 20 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
30. State aid for partially
covering salaries of
employees
State of Emergency Act For a period of up to 3 months, the National Social
Security Institute may transfer to an employer 60% of
the amount of the individual social insurance income
for January 2020 of certain employees, based on
criteria adopted by the Bulgarian government.
[See item 31 below for more information]
Effective 24 March 2020,
retroactively from 13
March 2020
31. Criteria for granting state
aid for partially covering
salaries of employees
Decree of the Council of
Ministers on the conditions
and procedure for paying
compensations to employers
for maintaining employment
of employees for the state of
emergency declared by the
National Assembly on 13
March 2020
According to a Decree of the Council of Ministers,
the possibility for companies to claim the support for
partial (60%) co-payment of salaries for a period of
up to 3 months during the state of emergency, is
available for:
i. employees whose work was suspended on the
basis of a government authority in relation to the state
of emergency;
ii. employees whose work was suspended on the
basis of an order of the employer in relation to the
state of emergency;
iii. employees whose working hours have been
reduced on the basis of an order of the employer in
relation to the state of emergency.
The availability of aid is subject to a number of
exceptions and conditions.
The state aid scheme was approved by the European
Commission of 14 April 2020.
Effective 1 April 2020,
retroactively from 13
March 2020
Page 21 of 37
No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE
DATE/PERIOD
TAX AND ACCOUNTING
32. Extension of the deadline
for publication of the
annual financial
statements
State of Emergency Act The deadline for publication of the annual financial
statements is extended until 30 September 2020. In
addition, dormant entities must submit a declaration
of dormancy by 30 June 2020.
Annual financial statements can be signed by
electronic signatures without further professional
stamps of the auditors or hand-written signatures.
Effective 24 March 2020
33. Extension of the deadline
for filing corporate
income tax returns
State of Emergency Act The deadline for submission of the Corporate Income
Tax (CIT) returns for 2019, as well as for payment of
the corporate income tax due, is extended until 30
June 2020.
If the company is required to make advance corporate
tax instalments for 2020, the instalments will have to
be reported by 15 April 2020. For this purpose, the
template of the CIT return only with the part for
advance instalments will have to be submitted by 15
April 2020.
[See more details about the advance instalments in
item 36 below.]
Effective 24 March 2020
34. Extension of the deadline
for declaration and
State of Emergency Act Entities obliged to pay alternative taxes instead of
general corporate income tax (e.g., entities Effective 24 March 2020
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payment of alternative
taxes under the Corporate
Income Tax Act
conducting vessels operations or ancillary and
auxiliary activities under the Gambling Act) will
have to submit their tax returns and pay the
alternative tax by 30 June 2020.
In addition, entities conducting ancillary and
auxiliary activities under the Gambling Act can also
submit their annual activity report by 30 June 2020.
35. Extension of the deadline
for declaration and
payment of tax on
expenses under the
Corporate Income Tax
Act
State of Emergency Act The deadline for reporting and paying the one-off tax
on expenses is extended until 30 June 2020.
Effective 24 March 2020
36. Extension of the deadline
for filing tax returns
concerning corporate
income tax advance
contributions
State of Emergency Act The corporate income tax advance instalments in
2020 are made under the requirements of Chapter
XIV of the Corporate Income Tax Act considering
the following:
i. If the CIT return for 2019 has been filed
before the effective date of the State of
Emergency Act, the tax advance instalments
are to be made according to the income
declared in the tax return for 2019. Further
revising declaration under Art. 88 of the
Corporate Income Tax Act may be
submitted;
ii. If a tax return for 2019 has been filed by 15
Effective 24 March 2020
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April 2020, the tax advance instalments are
to be made according to the income declared
in the filed tax return;
iii. If a tax return for 2019 has not been filed by
15 April 2020, the tax advance instalments
have to be declared with the annual tax return
by 15 April 2020. The annual tax return has
to be filled in only in the sections concerning
the tax advance contributions.
37. Extension of the deadline
for filing personal income
tax returns for sole
traders
State of Emergency Act The deadline for submission of personal income tax
returns for 2019 and payment of the tax due for sole
traders is extended until 30 June 2020 with a discount
of 5% if tax is paid by 31 May 2020.
Otherwise, the deadline for submitting personal
income tax returns for 2019 and payment of the tax
due remains 30 April 2020, with a discount of 5% if
tax is paid by 31 March 2020.
Effective 24 March 2020
38. Extension of the deadline
for benefitting from
property tax discounts
State of Emergency Act The deadline for the discount of 5% in case of
prepayment of the real estate tax or the vehicle tax
for the whole year is extended until 30 June 2020.
Effective 24 March 2020
39. Suspension of procedural
deadlines and limitation
periods under the Tax
and Social Security
Procedure Code
State of Emergency Act The limitation periods for public (including tax)
liabilities are suspended until the end of the state of
emergency, except for limitation periods under Art.
172, Para. 1. of the Tax and Social Security
Procedure Code.
Effective 24 March 2020
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No new enforcement proceedings under the Tax and
Social Security Procedure Code are to be initiated
until the end of the state of emergency, subject to
limited exceptions.
All existing enforcement procedures are suspended,
subject to limited exceptions.
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FINANCIAL SECTOR17
40. Extension of time limits
for companies in the
financial sector
State of Emergency Act Certain time limits for the submission of regular
financial statements and for fulfillment of reporting
obligations18 by UCITS, alternative investment funds,
public companies and other issuers, etc., are
extended, as follows:
i. Under the Public Offering of Securities
Act
The deadline for submission of quarterly reports by
bond issuers is extended until 30 September 2020
The deadline for public disclosure of standalone and
consolidated financial statements by public issuers is
also extended until 30 September 2020. However,
each issuer is obliged to publish its annual financial
statement (“AFS”) by 31 July 2020. The issuers
must notify the Financial Supervision Commission
(FSC) if the initial deadlines will not be met and
information on the exact reasons for the delay must
be provided.
The annual general meetings of public companies can
Effective 24 March 2020,
retroactively from 13
March 2020
17 The local Financial Supervision Commission supports the European Securities and Market Authority’s (“ESMA”) views and recommendations for mitigating the
impact of COVID-19. A Public Statement by ESMA is available here. 18 See also ESMA's guidance on accounting implications of COVID-19.
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be held until 30 September 2020.
In addition, the time limit for the investment firms to
provide the information on the clients’ assets to the
FSC and to the Investor Compensation Fund is
extended until the end of the month, following the
reporting period.
ii. Under the Markets in Financial
Instruments Act (“MFIA”)
Investment firms and market operators can submit
their annual financial statements and reports to the
FSC until 31 July 2020.
iii. Under the Collective Investment Funds
and Other Undertakings for Collective
Investments Act (“Collective Investments
Act”)
Management companies and investment companies
need to submit their annual and ongoing reports
under Art. 60 and Art. 92 until 31 July 2020 for the
annual reports and until 31 July 20 for the ongoing
reports, respectively.
Some other facilitating measures have been adopted
as well.
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DATE/PERIOD
PHARMACEUTICALS19
41. Possible ban for exports
of medicinal products
State of Emergency Act The Minster of Health may prohibit exports of
medicinal products until the end of the state of
emergency.
Effective 24 March 2020,
retroactively from 13
March 2020
42. Extension of validity of
prescription protocols
State of Emergency Act The validity of prescription protocols for high value
treatment medicines, which expire during the period
of the state of emergency, is extended for that period
and an additional two months after that.
Effective 24 March 2020,
retroactively from 13
March 2020
43. Extension of support for
assisted reproduction
procedures validity
State of Emergency Act The validity of orders for support of assisted
reproduction procedures is extended for a period of
six months after the end of the state of emergency.
Effective 24 March 2020,
retroactively from 13
March 2020
44. Extension of validity of
TELK and NELK
decisions
State of Emergency Act The validity of the decisions of TELK (Expert Labor
Medical Commission) and NELK (National Expert
Medical Commission) for determining long-term
disability and its level is extended for the period of
the state of emergency and an additional two months
after that.
Effective 24 March 2020,
retroactively from 13
March 2020
45. Ban for export of
medicinal products based
Order No. РД-01-141 dated
20 March 2020 issued by the
The export of medicinal products having quinine as
raw material is prohibited.
Effective 20 March 2020
19 On 25 March 2020, the Council of Ministers decided to request from the European Commission to exempt the import of medicinal goods related to treatment of
COVID-19 from customs duties and VAT.
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on quinine Minister of Health
46. Ban for export of
protective medical
equipment
Decision No. 159 dated 8
March 2020 adopted by the
Council of Ministers
All export of disinfectants, protective medical
equipment, e.g., masks, medical gloves, shoe covers,
protective glasses, etc. is prohibited without prior
authorization under Regulation (EU) 2020/402 of 14
March 2020 issued by the Minister of Health, or an
authorized person.20
Effective 8 March 2020
47. Exemptions for
pharmacies
State of Emergency Act Until the end of the state of emergency, pharmacies
are allowed to dispense prescription medicines
without requiring a prescription, based on the latest
entries in the patient’s prescription book, subject to
rules and limits to be set by the National Health
Insurance Fund.
Effective 24 March 2020,
retroactively from 13
March 2020
48. Payments to healthcare
providers within the state
of emergency
State of Emergency Act Until the end of the state of emergency, the National
Health Insurance Fund and the Bulgarian Medical
and Dental Associations can conclude an Annex to
the respective National Framework Agreements in
order to determine terms and conditions for payments
to the medical healthcare providers within the state of
emergency.
Effective 9 April 2020
20 See also Commission Implementing Regulation (EU) 2020/402 of 14 March 2020 making the exportation of certain products subject to the production of an export
authorization.
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JUDICIAL, ADMINISTRATIVE AND ENFORCEMENT PROCEEDINGS
49. General suspension of
procedural time limits and
deadlines
State of Emergency Act Effective 13 March 2020 (retroactively) until the end
of the state of emergency:
Procedural time limits within pending litigation,
arbitration and enforcement procedures are
suspended.
However, an Annex to the State of Emergency Act
specifies and lists all exceptions where the time limits
will not be suspended. The Annex includes some
criminal, administrative and civil proceedings, e.g.,
interim measures proceedings; all court cases under
the Public Procurement Act and the Concessions Act;
cases on appeals against assessments of public
receivables; cases on appeals against administrative
acts issued due to the state of emergency, etc.
(Effective 9 April 2020)
Effective 24 March 2020,
retroactively from 13
March 2020
Amendment effective 9
April 2020
50. General suspension of
limitation periods
State of Emergency Act All limitation periods, whose expiry extinguishes or
creates rights for private persons and entities, are
suspended.21
Effective 24 March 2020,
retroactively from 13
March 2020
Amendment effective 9
21 Time limits and deadlines for fulfillment of instructions issued by an administrative authority, time barring rights or times giving rise to obligations subject to
suspension according to the initial wording of the State of Emergency Act continue to run again as of 17 April 2020.
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April 2020
51. Extension of time periods,
established by law, for
private persons and
entities
State of Emergency Act All other time periods, established by law, which
expire during the period of the state of emergency,
which are not suspended as per the above, and are
related to the exercise of rights or the fulfillment of
obligations by private persons and entities, are
extended until one month after the end of the state
of emergency.
Time limits for certain procedures, e.g. under the
Public Procurement Act, the Concessions Act, the
Spatial Development Act, the Protection of
Competition Act, etc., and under the related
secondary legislation, do not fall within the scope of
this general suspension. The exceptions come into
force on 17 April 2020.
Effective 24 March 2020,
retroactively from 13
March 2020
Amendment effective 17
April 2020
52. Extension of the validity of
expiring acts of the
administration
State of Emergency Act The validity of all acts of the administration, which
are time-limited, and expiring during the state of
emergency, is extended until one month after the
end of the state of emergency.
Effective 24 March 2020,
retroactively from 13
March 2020
53. Cancellation of court
hearings and other
procedural actions
Decision dated 15 March
2020 adopted by the
Supreme Judicial Council
Decision dated 7 April 2020
adopted by the Supreme
Judicial Council
All court hearings are suspended. Serving of court
papers is suspended.
Court judgments issued during the state of emergency
must be entered into the record book of the court and,
if possible, published on the website of the courts.
Statements of claim /applications/ appeals are
Effective 16 March 2020
until 13 April 2020
Amendment effective 7
April 2020
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DATE/PERIOD
registered upon filing with the court and new court
cases can be opened. Pending and new court cases
will be stayed and scheduled for new hearings.
(Effective 7 April 2020)
Exceptions apply.
54. Suspension of certain
enforcement actions and
notarial proceedings
State of Emergency Act Public enforcement sales and repossessions are
suspended. The relevant procedures must be initiated
anew after the end of the state of emergency.
The imposition of distraints on bank accounts of
individuals and hospitals, on salaries, on medical
equipment, as well as certain enforcement actions in
respect of real estates and movable assets of
individuals, are suspended. Exceptions apply.
Notary certifications are limited only to urgent cases.
Effective 24 March 2020
55. Holding of meetings via
remote access or
suspension of the meetings
of some authorities
State of Emergency Act
Order / Decision of the
respective authority
The State of Emergency Act permits public
authorities, state agencies, commissions, etc. (which
are not legal entities), to hold their meetings digitally
via remote access and to adopt their decisions in
absentia. (Effective 9 April) [See below for related
measures adopted by some authorities]
All meetings of the Commission for Protection
against Discrimination are suspended until 13 May
2020.
The National Council on Prices and Reimbursement
of Medicinal Products has not issued a special order
Various
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DATE/PERIOD
but has suspended its regular meeting on 19 March
2020.
Тhe Commission for Personal Data Protection will
not hold its meetings in public.
The Energy and Water Regulatory Commission will
hold its meetings, but will allow the presence of the
parties to the administrative proceedings only.
The Geodesy, Cartography and Cadastre Agency has
introduced some specific rules for review of
administrative procedures within its remit.
All authorities encourage the submission of all type
of documents electronically or by post.
56. Suspension of the deadline
for adoption of internal
rules under the Measures
Against Money
Laundering Act
(“MAMLA”)
State of Emergency Act The deadline for adoption of internal rules on
measures against money laundering and terrorist
financing is suspended until the end of the state of
emergency.
Non-profit legal entities obliged to draft a risk
assessment under the MAMLA must adopt their
internal rules within 4 months as of the end of the
state of emergency.
Some other time limits under the MAMLA are also
suspended.
Effective 9 April 2020
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PUBLIC PROCUREMENTS AND STATE GRANTS
57. Public procurement
exemption
Act to Amend and
Supplement the Health Act22
Purchasing of medical products and personal
protection equipment necessary to support health
measures in case of a state of emergency is permitted
without following a public procurement procedure.
Effective 14 March 2020
58. Public procurement
exemption
State of Emergency Act The following acquisitions are exempted from public
procurement rules:
1. Purchasing of sanitary materials,
disinfectants, medical devices and personal
protection equipment, needed for anti-
epidemic measures;
2. Purchasing of medical devices, medical and
laboratory equipment, needed for the
diagnostics and treatment of infected
patients, the consumables for them, as well as
associated implementation activities;
3. Utilization of pesticides and hospital waste
under Ordinance No. 1 on the requirements
for collection and treatment of waste on the
territory of the healthcare establishments
(SG, Issue 13 of 2015, as amended).
Effective 24 March 2020,
retroactively from 13
March 2020
22 State Gazette, Issue 23 of 14 March 2020.
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59. Public procurement
contracts extension
State of Emergency Act At the request of the sponsor, the duration of a public
procurement contract can be renegotiated, but [the
extension can apply] for no longer than the duration
of the state of emergency.
Effective 24 March 2020,
retroactively from 13
March 2020
60. Exemption from the rules
concerning procurement
of medical devices
State of Emergency Act Certain rules applicable to the procurement of
medical devices by the Ministry of Health, and
healthcare establishments of state and municipal
ownership, do not apply to purchases of medical
devices needed for anti-epidemic measures, for
treatment and diagnostics of infected patients.
Effective 24 March 2020,
retroactively from 13
March 2020
61. Direct award of grants by
the state
State of Emergency Act Grants can be awarded by the state, without prior
invitation for collecting offers, under reduced time
periods, with a simplified process for approval.
Effective 24 March 2020,
retroactively from 13
March 2020
62. Financial support for the
business through the
Bulgarian Development
Bank23
Decision dated 25 March
2020 adopted by the Council
of Ministers
The Council of Ministers decided to increase the
state’s share capital in the Bulgarian Development
Bank by BGN 700,000,000. The funds of the capital
increase are part of the government measures to
support the business in relation to the COVID-19
circumstances. The funds granted will be used for
issuance of portfolio guarantees in favor of
commercial banks24. The Fund Manager of Financial
Instruments in Bulgaria (“Funds of Funds”) wholly
Effective 25 March 2020
23 In addition, the Bulgarian National Bank announced а set of measures amounting to 9.3 billion BGN in relation to COVID-19 crisis for supporting the sustainability
and flexibility of the bank system. 24 Thе measure was approved by the European Commission under EU state aid rules on 8 April 2020 (see the Decision here).
Page 35 of 37
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owned by the state also announced similar measures
supporting business on 14 April 2020.
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DATE/PERIOD
MISCELLANEOUS
63. Urgent checks by
healthcare establishments,
state institutions and
telecom operators
State of Emergency Act All healthcare establishments, state institutions and
companies in the telecommunications sector are
required to make urgent preventive checks of the
electricity supply systems and capacity they own,
within 7 days of entry of the State of Emergency Act
into effect. They must inform the Ministry of Energy
of the results, without delay.
Effective 24 March 2020
64. Measures for electricity
operators
State of Emergency Act All electricity transmission and electricity grid
operators should discontinue all planned maintenance
involving interruption of electricity transmission,
with the exception of emergency repairs.
Effective 24 March 2020
65. Extension of validity and
time limits
State of Emergency Act The time limits for validity of personal documents
(e.g. IDs, driving licenses, documents for residence
of foreigners) will be extended by 6 months. Other
administrative reliefs for Bulgarian nationals and
resident foreigners will be also available.
Effective 24 March 2020,
retroactively from 13
March 2020
66. Access to telecoms data
for the purposes of
enforcing anti-epidemic
measures
State of Emergency Act Access to data kept by electronic communications
operators for a period of 6 months under Art. 251б of
the Electronic Communications Act is granted to
enforcement authorities also for the purposes of
enforcing of the anti-epidemic measures, without the
requirement for a court warrant.
Effective 24 March 2020
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67. Providing market access
to agricultural producers
Order No. РД-01-179 dated 6
April 2020 issued by the
Minister of Health
Agricultural producers can have access to their
croplands and subsequent market access for selling
the production must be provided.
In addition, employees in good health –persons in
contact with those infected with COVID-19, and
employed in animal farms can continue their work for
taking care of the animals based on a self-declaration.
The employer must ensure specific working
conditions which do not endanger the health of the
rest of the employees.
Effective 6 April 2020