Bulgaria has adopted its first dedicated transparency framework for interest representation and provided for the establishment of a Transparency Register with the National Audit Office. For Bulgarian and international market participants, this marks a shift from informal public affairs practices to a more structured, traceable and compliance-sensitive model of engagement with public decision-makers.
The secondary legislation required for the implementation of the law is yet to be adopted. A draft ordinance on the Transparency Register is currently subject to public consultation and is expected to set out the detailed rules for registration, deregistration and certification of facts and circumstances in the new register.
The new regime neither prohibits nor restricts corporate advocacy. Rather, it aims to ensure transparency in contacts with public officials, equal access for interest representatives to present their positions, and broader participation in the development of regulatory, strategic and other public acts.
Companies, business associations and other market participants should assess whether their engagement with Bulgarian public authorities qualifies as interest representation and whether registration in the Transparency Register is required. The relevant test is whether such engagement is carried out regularly as an occupation, commercially for third parties or for remuneration.
Under the law, interest representation means any oral or written communication with public authorities aimed at influencing decision-making on the creation, amendment, supplementation, repeal or content of certain public acts, including laws, secondary legislation, general administrative acts, strategic and programme documents, and Bulgaria’s positions on legally binding and strategic acts of the European Union or international organisations.
The institutional scope is broad. The law applies to interest representation before the National Assembly, Members of Parliament, the President, the Council of Ministers, ministries, regional governors, mayors, municipal council chairs, municipal councillors and other public institutions empowered to adopt regulatory or general administrative acts.
Accordingly, the regime may apply not only to classic parliamentary lobbying, but also to sectoral, regulatory and policy-facing engagement with ministries, municipalities and other public institutions.
Bulgarian businesses, foreign investors, corporate groups, professional business organisations, industry associations and chambers of commerce should assess whether their public authority engagement may trigger obligations under the new regime, particularly where it concerns legislative, regulatory or policy matters and is carried out directly or through subsidiaries, associations, consultants or other intermediaries.
The law covers natural persons, legal entities and their branches, including foreign-registered entities and unincorporated groups of persons. It is therefore directly relevant for international groups operating in Bulgaria through local structures or representatives.
Not every contact with a public authority requires registration. Registration is triggered where interest representation is carried out regularly as an occupation, commercially for third parties or for remuneration. Regular activity is defined by a quantitative threshold: at least nine contacts with the public authorities or public officials specified in the law within a three-month period.
The law provides for a number of exclusions, including for attorneys acting within the scope of the legal profession; statutory professional organisations; participants in working groups or consultative councils; persons invited by public authorities to provide information or expertise; employer organisations; associations of workers and employees; media representatives; religious communities and institutions; and diplomatic and consular representatives.
These exemptions should not be read as covering all related advocacy. Formal participation in an official consultation process may fall outside the regime, while separate direct engagement with public authorities on the same matter may qualify as interest representation.
The key practical challenge will be distinguishing ordinary regulatory dialogue from regulated interest representation.
The law introduces mechanisms to make public affairs activity traceable. Public institutions will maintain meeting calendars with interest representatives, while the new legislative footprint will record key external interventions throughout the drafting and adoption of public acts, together with related proposals, parliamentary committee reports and plenary transcripts.
Registered interest representatives must declare before the Transparency Register their areas of activity and interest, the draft acts in respect of which they carry out interest representation, the number of staff involved and whether the activity is remunerated or free of charge. Initial registration is due within one month of the relevant conditions being met and changes must be reflected within seven days. In remunerated cases, the assigning party must also be identified. Registered representatives must disclose their interest representation expenses in their annual activity report or in a dedicated declaration.
Failure to register within the statutory deadline may result in sanctions for interest representatives. The same framework applies to certain false declarations or failure to disclose the assigning party in remunerated interest representation. Repeat violations are sanctioned at double the amount. The law provides for a cure period within which the breach may be remedied before an administrative penalty is imposed.
The key transparency mechanisms for interest representation, including the Transparency Register, meeting calendars and legislative footprint, are expected to become operational by the end of 2026. No sanctions will be imposed during the first year following the establishment of the register.
This gives economic operators a reasonable period to adapt their internal processes and prepare before effective enforcement begins.
Businesses should ensure that their public affairs strategies in Bulgaria are aligned with the transparency requirements under the new law. In the future regulated environment, more companies, organisations and other market participants will need specialised local expertise in legislative and administrative procedures, a detailed understanding of institutional practice and insight into decision-making channels. For Bulgarian businesses and foreign investors alike, experienced professional interest representatives can help structure engagement with public authorities in a credible, procedurally sound and compliant manner.
The Interest Representation Transparency Act will create a framework for lawful influence over decision-making on acts of state and municipal authorities.
For businesses, this means that public affairs in Bulgaria will gradually move from informal access towards a more structured and traceable model of engagement with institutions. Market participants that review their internal processes, communication channels with public authorities and external representatives in good time will be better prepared to continue their legitimate activities in the new regulatory environment.