The Lobbying Act is officially promulgated in Bulgaria

On March 27, 2026, the Law on Transparency in the Representation of Interests (often referred to as the Lobbying Act) was officially promulgated in the State Gazette. This piece of legislation is key to unlocking EU funds under the National Recovery and Resilience Plan (RRP) and for meeting OECD accession requirements. Although the act is supposed to shift and introduce transparency in the interactions with the public sector it does not go without its blind spots.

Some of the new rules, and the grey areas they create, are summarized below:

• Mandatory register: Regularly representing interests (the term "interest representation" is used to avoid the negative connotations associated with the term "lobbying") on a commercial basis might trigger an obligation to register in a central Transparency Register. Multiple exceptions, however, apply. 14 categories of individuals and entities are exempt from the registration requirements which might actually leave only a limited number of entities in scope of this obligation (arguably, the rest of the obligations of the law apply).
• Public calendars linked to the register: Public officials are now mandated to maintain a public calendar of their meetings with interest representatives, including the topic/s discussed, which will be directly integrated with the central Transparency Register.
• Evidence-based engagement: Informal, undocumented lobbying should now be limited. All policy opinions and recommendations submitted to public officials must be recorded.
• Operating outside the register carries the risk of fines up to EUR 7,500.
• Oversight of the new Transparency Register is assigned to the National Audit Office.
• The main obligations will become effective on 27 December 2026. In the meantime, the authorities should prepare the secondary legislation and the technical implementation of the register.

Ultimately, whether you are a corporation, a public affairs consultant, a trade association, or an NGO, if your work involves engaging with Bulgarian state institutions to shape policy, this new regulatory needs to be considered.

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