Energy audit requirements and standards in Bulgaria

1. What is the current status in your jurisdiction of implementation of the mandatory energy audit requirements of Article 8 of Directive 2012/27/EC on Energy Efficiency (the Energy Efficiency Directive or EED)?

Implemented in the Energy Efficiency Act, promulgated in the State Gazette No. 35 dated 15/05/2015.

2. What are the routes to compliance/key obligations?

Qualifying undertakings must undertake mandatory energy audits every four years. A new mandatory energy audit must be carried out one year after major changes:

  1. i. in technical equipment and/or production systems, change in the fuel base and the way of conversion of energy for industrial systems; and/or
  2. ii. in the installation or where the lighting requirements have been changed for systems for outdoor artificial lighting

The first compliance date is one year from the entry in force of the Energy Efficiency Act (15/05/2016), unless the qualifying undertakings have already carried out a mandatory energy audit in compliance with the repealed Energy Efficiency Act.

3. Who has to comply/what are the qualification criteria?

Qualifying undertakings are:

  1. i. production or service provider undertakings which as at the qualification date have:
    1. a. ≥ 250 employees; and/or
    2. b. a turnover of > BGN 97.5 (approx. EUR 49.85m) and a balance sheet of > BGN 84m (approx. EUR 42.95m);
  2. ii. those with industrial systems with an annual energy consumption of over 3,000 MWh;
  3. iii. those with systems for outdoor lighting, placed in locations with a population over 20,000 people.

4. If relevant, what is the first qualification date?

There is no concept of “qualification date” under Bulgarian law. Qualifying undertakings have to comply with the obligations from the date on which the implementing legislation enters into force and must complete energy audits by the compliance deadline.

5. What are the sanctions for non-compliance?

Administrative sanctions in the form of a fine in the amount EUR 5,100 – EUR 15,300 or a penalty in the amount of EUR 25,500 – EUR 51,100.