{"id":8636,"date":"2026-08-04T22:29:46","date_gmt":"2026-08-04T22:29:46","guid":{"rendered":"https:\/\/dextora.agency\/?post_type=insight&p=8636"},"modified":"2026-08-05T11:26:25","modified_gmt":"2026-08-05T11:26:25","slug":"bulgarian-online-store-2026-euro-language-fiscal-rules","status":"publish","type":"insight","link":"https:\/\/dextora.agency\/en\/insights\/bulgarian-online-store-2026-euro-language-fiscal-rules\/","title":{"rendered":"A Bulgarian Online Store in 2026: the Euro, the Bulgarian Language, Naredba N-18 and Safety Gate"},"content":{"rendered":"

Bulgaria adopted the euro on 1 January 2026. The irrevocable conversion rate is 1.95583 leva to one euro, fixed by Council Regulation (EU) 2025\/1409 of 8 July 2025<\/a> amending Regulation (EC) No 2866\/98. Article 12 of the Bulgarian euro introduction act adds the arithmetic rule that implementations most often get wrong: conversion divides by the full rate with all five decimal places, and the rate is neither rounded nor truncated.<\/p>\n

That is the backdrop. The operating obligations of a shop, however, come from four separate instruments that nobody has synchronised with each other, and that is precisely what makes them easy to miss.<\/p>\n

Dual pricing is ending, and has not ended<\/h2>\n

Article 15(2) of the Act on the Introduction of the Euro in the Republic of Bulgaria<\/a>, as amended in State Gazette issue 65 of 2025, states it plainly: the period of dual display of prices of goods and services in euro and in leva begins on 8 August 2025 and ends on 8 August 2026.<\/p>\n

The precise framing matters more than usual here, because this article will be read long after it is written. The window is a fixed twelve months with a fixed end date. As this is published the obligation is still live and is in its final days. Once the period closes, merchants stop owing the second price and listings carry a euro price alone. The failure mode we would expect to see in August 2026 is merchants stripping the leva price early on the strength of a headline saying dual pricing has ended. The rule applies to the date the statute names, not to the date a summary rounded it to.<\/p>\n

While it applies, Article 16 governs how it has to look: the two prices sit in immediate proximity, are written clearly, legibly, unambiguously and understandably, in the same size, type and colour of font, in a way that does not mislead consumers, and each carries its currency designation. Article 15(3) lists exceptions, including tobacco prices printed on packaging, fuel price totems, taxi meters, electronic scale labels, self-service machines, personalised paper travel documents and books. Almost none of them apply to an online shop, and Article 16(3) says most of them do not release the trader from displaying both prices by some other suitable means.<\/p>\n

The penalties are not the ones being quoted<\/h2>\n

A range of BGN 2000 to 50 000 circulates as the penalty for breaching dual display. The number is in the statute, but not for that breach. Article 59 sets it out.<\/p>\n\n\n\n\n\n\n\n
Breach<\/th>\nFine on a natural person<\/th>\nPecuniary sanction on a sole trader or legal person<\/th>\n<\/tr>\n<\/thead>\n
Articles 15(1) and 16: the dual display duty itself and how it is presented<\/td>\nBGN 400 to 5000<\/td>\nBGN 600 to 7000, and 1200 to 14 000 on repetition<\/td>\n<\/tr>\n
Article 15(4): good faith and transparent pricing during the window<\/td>\nBGN 1000 to 10 000<\/td>\nBGN 5000 to 100 000, and 10 000 to 200 000 on repetition<\/td>\n<\/tr>\n
Failure to comply with a coercive measure under Article 57(5)<\/td>\nBGN 2000 to 50 000<\/td>\nBGN 5000 to 100 000<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The 2000 to 50 000 band is the penalty for ignoring a coercive measure that has already been imposed, not for a missing second price. The difference matters for risk modelling: a first breach of Article 16 by a company starts at BGN 600, roughly EUR 307 at the fixed rate.<\/p>\n

The expensive provision is Article 15(4), added in 2025: during the dual display period traders must form prices in good faith and transparently, every increase has to be justified by objective economic factors, and on request the trader must produce evidence to the control authorities. There the sanction on a legal person reaches BGN 100 000 and is set by reference to gravity, duration and consequences.<\/p>\n

Supervision is split. The Consumer Protection Commission oversees Articles 15 and 16; the National Revenue Agency oversees Article 15(4). Separately, Article 55b requires retailers of food, drinks, tobacco, non-food goods and medicines with prior-year turnover above BGN 10 000 000 to publish individual selling prices daily by 07:00 on their websites in a machine-readable format. That is a large-chain duty, and it is worth knowing because it makes price movements publicly checkable.<\/p>\n

What changed in consumer law on 3 February 2026<\/h2>\n

Amendments published in State Gazette issue 13 of 2026 rewrote the product safety part of the Consumer Protection Act and tied it to Regulation (EU) 2023\/988. Three clarifications are needed, because the summaries in circulation blur all three.<\/p>\n

Safety Gate and the single point of contact apply to providers of online marketplaces.<\/strong> Article 76 of the Consumer Protection Act<\/a> requires providers of online marketplaces to register in the Safety Gate portal and to designate a single point of contact for consumers and for market surveillance authorities. An ordinary shop selling its own goods is not an online marketplace and does not owe that specific duty. If you admit third-party sellers, you probably do.<\/p>\n

The lowest-price-in-30-days rule is not new.<\/strong> It has been in Article 65 since the amendment in State Gazette issue 20 of 2022, in force from 28 May 2022: the previous price is the lowest price the trader applied over a period of not less than 30 days before the reduction, in the same outlet, website or application. The 2026 amendments touch paragraphs 3 and 4 and those revisions take effect on 5 February 2027, not in 2026.<\/p>\n

The Bulgarian language requirement is also long-standing.<\/strong> Article 5(1) requires information about the goods or service, where provided in writing, to be in Bulgarian and expressed in SI units. It applies online, and it intersects directly with the warnings requirement in Article 19 of the GPSR, which we covered separately in our piece on the product listing under the GPSR<\/a>.<\/p>\n

Naredba N-18: when it touches you at all<\/h2>\n

This is where the myths are densest. Two provisions of Naredba N-18<\/a> decide almost everything.<\/p>\n

Article 3(1) requires every person to register and account for sales by issuing a fiscal receipt, except where payment is made by depositing cash into a payment account, by credit transfer, by direct debit, by a cash transfer through a payment service provider, or by postal money order. In other words, bank transfer falls outside fiscalisation. Card payment does not: a card sale requires a fiscal receipt.<\/p>\n

Article 52m(1) requires a person covered by Article 3 who sells through an electronic shop to file information electronically, signed with a qualified electronic signature, through the revenue agency’s e-services portal, in the form of Appendix 33, before starting the activity. It is filed separately for each e-shop, updated within seven days of any change, and the agency maintains a public register of electronic shops<\/a>.<\/p>\n

The practical consequence: a shop that takes only payments falling inside the Article 3(1) exceptions has no fiscal device, and the Appendix 33 filing is drafted by reference to that same Article 3. That is a reading of the text rather than an explicit statement by the revenue administration, so if you accept bank transfers only, confirm your specific case with the agency or your accountant before skipping the filing. If you take cards, there is no question: you file.<\/p>\n

Who supervises what<\/h2>\n\n\n\n\n\n\n\n\n\n
Subject<\/th>\nInstrument<\/th>\nAuthority<\/th>\n<\/tr>\n<\/thead>\n
Dual display and how it is presented<\/td>\nEuro introduction act, Articles 15(1) and 16<\/td>\nConsumer Protection Commission<\/td>\n<\/tr>\n
Justified pricing during the window<\/td>\nEuro introduction act, Article 15(4)<\/td>\nNational Revenue Agency<\/td>\n<\/tr>\n
Previous price on reductions<\/td>\nConsumer Protection Act, Article 65<\/td>\nConsumer Protection Commission<\/td>\n<\/tr>\n
Information in Bulgarian<\/td>\nConsumer Protection Act, Article 5(1)<\/td>\nConsumer Protection Commission<\/td>\n<\/tr>\n
Fiscal receipts and e-shop declaration<\/td>\nNaredba N-18, Articles 3 and 52m<\/td>\nNational Revenue Agency<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

What that means for the build<\/h2>\n