Bulgaria extends prohibition on unjustified consumer price hikes following euro adoption
Key issues for business
The amendments introduce requirements affecting traders, manufacturers, distributors and retailers in Bulgaria:
- a ban on economically unjustified price increases with traders having to justify any increases;
- expanded information-gathering powers for the Consumers Protection Commission (CPC);
- daily price-reporting obligations for large retailers;
- a new “fair price” transparency; and
- substantially higher fines for non-compliance.
Ban on unjustified price increases
The amendments prohibit consumer-price increases that are not economically justified. A price increase is unjustified unless the trader demonstrates a direct and proportionate link to objective factors such as supply-production costs, labour costs, energy prices, tax changes, exchange rate fluctuations or other factors beyond the control of the trader that influence trading terms.
The burden of proof is on the trader. If challenged, the trader must substantiate the increase by presenting the price breakdown before and after the change. If the trader does not provide sufficient and substantiated evidence to support the increase, the price increase will be presumed to lack economic justification. The government must adopt an assessment methodology by 8 August 2026.
Daily price reporting for large retailers
Retailers with an annual turnover exceeding EUR 25 million who sell food, beverages, tobacco, non-food consumer goods or pharmaceuticals must publish the selling prices of products in the large consumer basket (as defined by the CPC) on their websites in machine-readable format by 7:00 am each day and submit this data to the CPC. Different prices across various outlets of the same retailer must be reported separately.
The CPC will maintain a public portal displaying reported and wholesale prices, and a calculated “fair price” for each product.
Retailers with a turnover below the stated threshold may voluntarily announce their prices.
Expanded powers of the Consumers Protection Commission
The CPC can require anyone to provide information relevant to investigations, including data on price levels during a certain period, pricing methodology, supply/production/other costs, price components, and other information relevant to identifying infringements. The minimum response deadline is five working days, which can be extended to ten working days if the initial information was incomplete.
Refusal to provide information on the grounds of a trade secret is not permitted.
Significantly higher fines
The amendments introduce substantially increased penalties:
- In case of an unjustified price increase: EUR 10,000 to EUR 100,000.
- For failing to comply with the obligation to provide information, or for providing incomplete, inaccurate, false or misleading information: EUR 5,000 to EUR 50,000.
- Obstructing inspection or non-compliance with CPC orders: EUR 10,000 to EUR 100,000.
Comment
The amendments introduce significant compliance burdens for consumer-facing businesses, particularly large retailers. Price increases remain permissible if economically justified and proportionate.
Businesses should consider:
- adapting systems for daily pricing data collection and submission in accordance with the amended rules of the CPA;
- maintaining documentation of cost drivers for price increases (e.g. supplier invoices, logistics costs, raw material indices) for price justification;
- establishing processes for responding to CPC information requests.
For more information on the recent amendments and their impact on businesses, contact your CMS client partner or the CMS experts who contributed to this article: Nevena Radlova, Andrea Andreev.
