Friday, 19 June 2026
Bulgaria has adopted a substantial overhaul of its competition legislation, introducing stricter oversight of market power, pricing practices and supply chain transparency. The amendments to the country’s Protection of Competition Act were approved by Parliament on 11 June 2026 and are awaiting promulgation in the State Gazette before entering into force.
The changes are among the most significant updates to Bulgarian competition policy in recent years and are expected to affect manufacturers, wholesalers, distributors and retailers across multiple sectors. While the legislation applies broadly across the economy, particular attention has been placed on food and agricultural supply chains amid ongoing concerns about inflation and consumer prices.
Joint Dominance Formally Recognised
One of the most notable reforms is the introduction of the concept of joint or collective dominance. Under the new framework, two or more independent companies may be considered jointly dominant when economic links or market interdependence enable them to behave to a significant extent independently of competitors, suppliers or customers and thereby weaken effective competition.
The legislation establishes a presumption of individual dominance for companies holding at least a 50% market share. A separate presumption of collective dominance applies when companies together account for at least 60% of a market. Once dominance is established, the companies concerned become subject to Bulgaria’s abuse-of-dominance rules.
New Restrictions on Excessive Pricing
The amendments introduce an explicit prohibition on excessively high prices charged by companies holding a monopoly position, a dominant position or a jointly dominant position. Parliament defined an excessive price as one that substantially exceeds economically justified production, acquisition and sales costs, including a reasonable profit margin, and is considered unfair either on its own merits or when compared with similar products or services.
The Bulgarian Commission for Protection of Competition (CPC) will assess pricing using several benchmarks, including cost-based analysis, comparisons with similar products, historical pricing trends and the economic value of the goods or services concerned. Businesses will be able to defend higher prices where they can demonstrate objective economic justifications, such as increases in production costs, logistics expenses or external market pressures.
Violations may result in penalties of up to 10% of annual turnover.
Broader Controls on Food Supply Chains
The legislation also expands the list of prohibited unfair trading practices within the agricultural and food supply chain. New restrictions target practices such as imposing discriminatory commercial conditions on suppliers and demanding retroactive bonuses, discounts or payments that were not agreed at the time of delivery or are not linked to a clearly identifiable service.
The government argues that the measures are intended to improve fairness and transparency within food distribution channels, although several business organisations and foreign chambers of commerce have criticised the reforms, warning that they could increase administrative burdens and create uncertainty for investors.
Digital Registry to Track Agricultural Products
Another major element of the reform is the creation of a central electronic registry designed to monitor the movement of agricultural and food products through the supply chain. Importers, producers and distributors will be required to provide information on products entering the market and their subsequent wholesale distribution.
Authorities plan to use algorithmic analysis and artificial intelligence tools to identify potential indicators of market concentration, unfair trading practices and competition law violations. Regulatory agencies will have access to pricing and transaction data submitted to the system.
Failure to comply with reporting obligations may trigger substantial fines, including penalties linked to company turnover for repeat or serious breaches.
Further Guidance Expected
Several implementing measures are expected following the law’s entry into force. These include a methodology defining how excessive prices will be assessed and secondary legislation setting out the operational rules for the new supply chain registry. Technical specifications and implementation deadlines for the registry are expected to be published in the coming months.
The reforms form part of a broader effort by Bulgarian policymakers to address concerns over rising consumer prices and market concentration. However, the new rules have already sparked debate between lawmakers, regulators and business groups regarding their potential impact on competition, pricing freedom and investment conditions in the country.
Source: CMS
