Recognition and Enforcement of Foreign Court Judgments in Bulgaria — Complete Guide (2026)

The Two Regimes for Recognising Foreign Judgments

Bulgarian law provides two fundamentally different paths for the recognition and enforcement of foreign court judgments. Which path applies depends on the origin of the judgment:

This dual system reflects the deep integration within the EU, which enables free movement of judgments, and the more traditional approach to relations with third countries, where state sovereignty requires additional verification.

Recognition Under Regulation (EU) 1215/2012 (“Brussels I bis”)

Regulation 1215/2012, known as “Brussels I bis” (or “Brussels I recast”), is the principal legal instrument governing the recognition and enforcement of judgments in civil and commercial matters between EU Member States. The Regulation represents a major step forward from the previous regime by abolishing the exequatur procedure.

Automatic Recognition (Art. 36)

A judgment given in another EU Member State is recognised in Bulgaria without any special procedure. This means the judgment produces legal effect in Bulgaria by virtue of the Regulation itself — there is no need to file an application with a court or to conduct separate recognition proceedings.

Enforcement Without Exequatur (Art. 39)

An enforceable judgment from another Member State can be enforced directly in Bulgaria without the need for a declaration of enforceability (the so-called exequatur). In practice, the creditor can approach a private enforcement agent (bailiff) directly with the judgment and the certificate under Art. 53 of the Regulation, without going through a Bulgarian court to obtain a writ of execution.

This procedure is implemented in Bulgarian procedural law through Art. 621 and Art. 622a of the Civil Procedure Code (CPC), which transpose the Regulation’s requirements into the national legal framework.

Required Documents for EU Judgments

To proceed with the enforcement of a judgment from another Member State, you will need the following set of documents:

1. Certified copy of the judgment — a copy of the judgment certified by the court that rendered it. It must satisfy the conditions for establishing its authenticity.
2. Standardised certificate under Art. 53 of Regulation 1215/2012 — issued by the court of origin using the form set out in Annex I to the Regulation. The certificate contains information about the parties, the judgment, its enforceability and any protective measures ordered.
3. Translation into Bulgarian — a translation is only required if requested by the Bulgarian court or enforcement body. In practice, however, it is advisable to always have a certified translation available to avoid delays.

Important: for documents issued by courts of EU Member States, no legalisation or apostille is required. The Art. 53 certificate serves as the attestation of authenticity and enforceability.

Grounds for Refusal of Recognition (Art. 45 of the Regulation)

Despite the principle of automatic recognition, the Regulation provides an exhaustive list of grounds on which recognition or enforcement may be refused. These grounds are set out in Art. 45 and may be invoked by the debtor:

1. Manifest contrariety to public policy — recognition would be manifestly contrary to the public policy (ordre public) of the Republic of Bulgaria. This criterion is applied restrictively and covers only cases of fundamental violation of the basic principles of the rule of law.
2. Default judgment with defective service — the judgment was given in default of appearance and the document instituting the proceedings was not served on the defendant in sufficient time and in such a way as to enable the defendant to arrange for their defence.
3. Irreconcilability with a Bulgarian judgment — the foreign judgment is irreconcilable with a judgment given in a dispute between the same parties in Bulgaria.
4. Irreconcilability with an earlier judgment from another state — the foreign judgment is irreconcilable with an earlier judgment given in another Member State or in a third country involving the same cause of action and between the same parties, provided that the earlier judgment fulfils the conditions for recognition in Bulgaria.
5. Violation of special jurisdiction rules — the judgment was given in breach of the special jurisdiction rules applicable to insurance, consumer contracts or individual employment contracts.

No grounds for refusal exist beyond this list. In particular, the Bulgarian court may not review the judgment on the merits — it cannot examine whether the foreign court correctly applied the substantive law or established the facts.

Enforcement of EU Judgments in Bulgaria

The practical enforcement procedure for a judgment from another Member State in Bulgaria proceeds as follows:

1. Approach a bailiff — the creditor presents the certified copy of the judgment and the Art. 53 certificate to a private enforcement agent (bailiff) serving the district where the debtor’s assets or address are located. No writ of execution from a Bulgarian court is required.
2. Service on the debtor — the bailiff serves the Art. 53 certificate on the debtor and, if necessary, the judgment itself. The debtor is given an opportunity to examine the instrument.
3. Time limit for objection — the debtor has 1 month from service of the Art. 53 certificate to file an objection against enforcement of the judgment.
4. Proceeding to enforcement — if the debtor does not file an objection within the prescribed period, the bailiff proceeds with compulsory enforcement under the CPC — attachment of bank accounts, encumbrance of immovable property, inventory and sale of assets, etc.

Appeals

If the debtor contests enforcement, the matter is heard by the competent District Court. The district court’s decision may be appealed before the Sofia Court of Appeal, and subsequently a cassation appeal may be lodged with the Supreme Court of Cassation (SCC).

Recognition of Judgments From Non-EU Countries (PILC)

When the judgment has been rendered by a court of a country that is not an EU Member State, the Private International Law Code (PILC), Art. 117–124, applies. Unlike the intra-EU regime, a special court procedure for recognition and permission of enforcement is required.

Competent Court

The application for recognition and permission of enforcement is filed with the Sofia City Court or the district court at the debtor’s registered office/permanent address. The proceedings are non-contentious in nature but are transformed into contentious proceedings if the debtor raises an objection.

What Does the Court Examine?

The Bulgarian court does not review the judgment on the merits. It does not examine whether the foreign court correctly established the facts or applied the law. Instead, it examines only whether the formal conditions under Art. 117 of the PILC have been met.

After Recognition

If the court grants the application, it renders a decision recognising the judgment and permitting enforcement. On the basis of this decision, a writ of execution is issued, with which the creditor can approach a bailiff for compulsory enforcement under the CPC.

Conditions for Recognition Under Art. 117 of the PILC

For a judgment from a non-EU country to be recognised and permitted for enforcement, the following conditions must be cumulatively satisfied:

1. Jurisdiction of the foreign court — the court that rendered the judgment had jurisdiction in accordance with Bulgarian private international law rules. The Bulgarian court performs an indirect jurisdictional review — it assesses whether, in analogous circumstances, a Bulgarian court would have had jurisdiction.
2. Proper service on the defendant — the defendant was served with a copy of the statement of claim and was duly summoned. The principle of equality of the parties and the right of defence were not breached. This condition is an absolute procedural prerequisite.
3. No irreconcilable judgment — there is no final judgment of a Bulgarian court between the same parties, on the same grounds and for the same claim. Nor is there a pending case before a Bulgarian court between the same parties that was commenced earlier.
4. No contrariety to public policy — recognition of the judgment does not contravene Bulgarian public policy (ordre public). As with the EU regime, this criterion is applied strictly and covers only fundamental violations of the basic principles of Bulgarian law.

The required documents include: a certified copy of the judgment with a note confirming it has entered into force, an apostille (for states party to the 1961 Hague Convention) or full diplomatic legalisation (for other states), and a certified translation into Bulgarian.

Bilateral Legal Assistance Treaties

Bulgaria has concluded bilateral legal assistance treaties with a number of non-EU countries, including Russia, Turkey, Serbia, North Macedonia, Ukraine, Vietnam, Cuba and others. These treaties may provide different or simplified rules for the recognition and enforcement of court judgments compared with the general regime under the PILC.

Where an applicable bilateral treaty exists, it takes precedence over the provisions of the PILC in accordance with the principle of lex specialis. It is therefore always necessary to check whether a bilateral treaty exists between Bulgaria and the country in question and what specific requirements it stipulates.

For example, the bilateral treaty with Turkey provides specific conditions for recognition that may differ from the general conditions under Art. 117 of the PILC. The same applies to treaties with the states of the former Yugoslavia, whose successors continue to apply the relevant bilateral agreements.

Practical Steps — What You Need to Do

Steps for an EU Judgment (Regulation 1215/2012)

1. Obtain a certified copy of the judgment from the court that rendered it.
2. Request an Art. 53 certificate from the same court. The certificate is issued using a standard form.
3. Arrange a translation of the judgment and certificate into Bulgarian (certified by a sworn translator). Although a translation is not mandatory under the Regulation, it is practically necessary.
4. Approach a bailiff — present the documents to a private enforcement agent serving the district where the debtor’s assets or address are located.
5. The bailiff serves the debtor with the Art. 53 certificate and, in the absence of an objection within one month, proceeds to enforcement.

Steps for a Non-EU Judgment

1. Obtain a certified copy of the judgment with a note confirming it has entered into force.
2. Legalise the judgment — apostille (if the country is party to the Hague Convention) or full diplomatic legalisation.
3. Arrange a certified translation of the judgment into Bulgarian.
4. File an application with the Sofia City Court or the district court at the debtor’s registered office.
5. Await the court proceedings — the court examines the conditions under Art. 117 of the PILC and renders a decision.
6. Obtain a writ of execution and approach a bailiff for compulsory enforcement.

In both cases, it is advisable to consult a lawyer specialising in private international law before commencing the procedure — to ensure that the judgment meets the conditions for recognition and that you have a complete set of documents.

Frequently Asked Questions