What changed from 20 February 2026
On 20 February 2026, issue 20 of the Bulgarian State Gazette (Darzhaven vestnik) published Ordinance No. RD-02-20-1 of 5 February 2026 on the Unified Information System for Condominium Property (EISES), issued by the Minister of Regional Development and Public Works. The ordinance entered into force on the same day and launched the first mandatory registry of professional condominium managers in Bulgarian history.
The new act repeals Ordinance No. RD-02-20-8 of 11 May 2012, which was a technical rulebook and did not establish a registration regime. The statutory basis for the new registry is set out in Articles 47a and 47b of the Condominium Management Act (ZUES), adopted as part of a broader reform of the subject matter in 2025.
The key changes are the following:
- Mandatory registration regime — natural and legal persons who manage condominium property as a trade or profession must be entered in the registry before commencing activity.
- Centralised public registry at the Ministry of Regional Development — all information about registered entities is available online free of charge and can be checked by any owner.
- Automatic transfer — existing condominium associations and their data are transferred ex officio to the new EISES, without a separate application.
- Term of validity — registration is valid for 5 years and must be renewed.
According to public estimates by the Ministry, approximately 300 companies are expected to file initial applications. Full rollout of EISES as a comprehensive information system, covering other registries under ZUES, is expected in stages, with the final modules going live no earlier than June 2026.
Why registration matters — protecting owners
For more than two decades, the activity of the “professional condominium manager” in Bulgaria operated in a legal vacuum. Anyone could offer the service without qualifications, financial capacity, or liability to consumers. The results were at best inconsistent and at worst abusive — misuse of the building’s cash fund, opaque expense reporting, and managers who simply disappeared.
The new regime pursues three objectives:
- Publicity and traceability — every owner can verify whether the company managing their building is legitimate, who represents it, how long the registration is valid, and whether any recorded violations exist. Such checks previously required digging through the Commercial Register and still left the key question unanswered — whether the person had the right to operate professionally.
- Protection from insolvent or unfit operators — the new criteria exclude persons convicted of intentional crimes, directors of companies that went insolvent in the past three years, and entities with public debts. This removes the highest-risk players from the market.
- Financial protection against damages — mandatory professional liability insurance means that in case of error, omission, or damage to common property, owners have a real source of compensation rather than merely a theoretical claim against a potentially empty shell company.
The model follows the logic of other regulated professions in Bulgaria — lawyers, notaries, private bailiffs, real estate brokers under the new regime — where entry in a public registry is a condition for lawfully practising the activity.
Who must register
Under Article 47b ZUES, eligible entities for registration are:
- Natural persons registered as sole traders (ET) in the Commercial Register;
- Commercial companies in the following legal forms: EOOD, OOD, AD, EAD, limited partnership (KD) and general partnership (SD).
An important clarification: free-profession practitioners and civil-law partnerships are not contemplated forms for this activity. In practice, the most common vehicle remains the EOOD/OOD due to limited liability and administrative simplicity.
When the activity is “as a trade”
Registration is mandatory only for entities managing condominium property as a trade — i.e. regularly, for remuneration, and as a principal or substantial economic activity. The concept is borrowed from commercial law and is assessed on a combination of criteria:
- existence of a management contract with an agreed fee;
- management of multiple buildings simultaneously or consecutively;
- organised structure (employees, office, accounting);
- advertising the service to an open circle of consumers.
The registry does not apply to:
- Management by the owners themselves — when the general meeting elects a manager from among the residents, without remuneration or for a token fee.
- Occasional or one-off services lacking a systematic character.
- Owners’ associations under Article 25 ZUES — these are non-profit legal entities whose activity is reflected in a separate section of EISES, not in the registry of professional managers.
The distinction is critical: mischaracterisation risks administrative sanctions or, conversely, unnecessary regulatory burden on entities that are not professional players.
Requirements for applicants
Article 47b(3) ZUES establishes substantive conditions that the applicant must meet at the time of filing and maintain throughout the term of registration. The requirements are divided into those applicable to natural persons (i.e. the managers and members of governing bodies of companies) and those applicable to the companies themselves.
| For natural persons / members of governing bodies | For companies |
|---|---|
| No conviction for an intentional crime of general character (except where rehabilitated) | No public debts (except for debts not in force, rescheduled, deferred, or secured) |
| No participation in the management of insolvent companies in the past 3 years where creditors remained unsatisfied | At least 1 employee on a labour contract (administrative capacity) |
| Not deprived of the right to hold a position of financial responsibility | |
| Not included in the list under Article 4b, item 3 of the Measures Against Financing of Terrorism Act |
These circumstances are certified by a declaration under Article 47b(3), items 1–5 ZUES, signed by the legal representative. False statements are a criminal offence under Article 313 of the Criminal Code and, in addition, lead to refusal of registration or removal from the registry.
The requirement of at least one employee on a labour contract is particularly important in practice — it is designed to exclude “shell” companies with no operational capacity, which simply collect fees and pass problems to subcontractors.
Registration procedure — step by step
The procedure is relatively straightforward and follows the classic Bulgarian registry model. The sequence of actions is as follows:
- Preparing the documents — application form approved by the Minister of Regional Development and Public Works; declaration of the circumstances under Article 47b(3) ZUES; proof of paid state fee; where applicable, a notarised power of attorney if the application is filed through a representative.
- Filing with the Ministry — documents are submitted on paper at the Ministry’s registry desk or electronically through the Ministry’s portal using a qualified electronic signature. Electronic filing is cheaper (see the “Fees” section).
- Formal review — the administrative authority verifies completeness and regularity of the file.
- Curing of defects — if defects are identified, the applicant is notified and has a 14-day period to cure them. Failure to cure leads to termination of the proceedings.
- Decision on registration — the competent authority rules within 30 days of receipt of a regular application. Refusals must be reasoned.
- Issuance of the certificate — the registered entity receives a certificate of entry in the registry of professional condominium managers.
- Conclusion of insurance — within 15 days of issuance of the certificate, the registered entity must conclude the mandatory professional liability insurance.
- Submission of the policy — within 7 days of conclusion, the insurance policy must be submitted to the registry. Failure at this stage can trigger removal.
Refusals of registration may be appealed under the Administrative Procedure Code before the competent administrative court. Proceedings are two-instance and typically take between 6 and 12 months in practice.
State fees
The ordinance sets state fees in euro, reflecting Bulgaria’s adoption of the euro as of 1 January 2026. Fees differ for paper and electronic filing, with electronic filing carrying a 10% discount — a measure designed to encourage digitalisation of the process.
| Service | Paper | Electronic |
|---|---|---|
| Initial registration in the registry | EUR 80.00 | EUR 72.00 |
| Entry of a change in circumstances | EUR 49.00 | EUR 44.10 |
On top of these amounts, the annual premium on the mandatory professional liability insurance is a separate cost of doing business. Minimum premiums are determined according to the volume of property under management and are reassessed at each renewal.
When analysing the total cost of registration, indirect expenses should also be considered — legal fees for preparing the documentation (if counsel is used), any notarial fees for a power of attorney, and the internal cost of organising the required administrative capacity (at least one employee on a labour contract).
Mandatory professional liability insurance
Professional liability insurance is a cornerstone of the new regime and turns the professional condominium manager into a responsible economic actor. Without it, registration cannot be maintained and the activity cannot be lawfully performed.
Conclusion and submission
The policy must be concluded within 15 days of issuance of the registration certificate and submitted to the registry within 7 days of conclusion. Missing these deadlines leads to removal from the registry, regardless of fees already paid.
Scope of coverage
The insurance covers damages caused to owners or third parties as a result of the manager’s acts or omissions in the performance of his duties — improper collection or safekeeping of common fund resources, failures in organising routine or emergency repairs, violations of the rules on convening and running general meetings, breaches of statutory requirements under ZUES, and similar.
Minimum threshold
The minimum insured amount and minimum premiums are set by the ordinance and depend on the number and size of the properties under management. The policy is renewed annually and proof of renewal must be submitted to the registry.
For owners, the insurance offers a practical advantage: when damage occurs, they are not forced to sue the manager directly and hope for its solvency — they can bring a claim directly against the insurer under the Insurance Code.
Penalties for unregistered activity
Carrying out professional condominium management without registration is an administrative offence. Penalties are laid down in Article 56(3) ZUES in conjunction with Article 46b and are differentiated according to the status of the offender:
- For natural persons — a fine of BGN 800 to BGN 1,500 (approximately EUR 409 to EUR 767);
- For legal entities and sole traders — a property sanction of BGN 1,000 to BGN 2,000 (approximately EUR 511 to EUR 1,023).
Penalties are imposed by a penal decree of the competent supervisory authority and are subject to appeal under the Administrative Offences and Penalties Act. Repeated violations attract higher amounts. Beyond the financial sanction, unregistered activity creates commercial risk for the contracts concluded with such a “manager”: a general meeting that has appointed an unregistered entity may find itself facing nullity or termination of the contract, while fees already paid may become the subject of unjust enrichment claims.
For prudent owners this means that signing a management contract with a company not listed in the registry is, in practical terms, an unprotected transaction — without insurance, without regulatory leverage, and without public traceability.
Renewal and removal
Registration in the registry is valid for 5 years and is not automatically renewed. To preserve its status, the professional manager must file a renewal application no later than 1 month before the expiry of the term. Practice shows that last-minute filings rarely succeed — the verification procedure takes time, and any irregularity must be cured within a 14-day period.
If the deadline is missed, the registration lapses and the entity cannot lawfully continue its activity until it files a new initial application. During that transitional period, any new management contracts may turn out to be problematic.
Voluntary removal
A registered entity may request voluntary removal at any time — for example, upon cessation of activity or business restructuring. The law, however, introduces a 6-month cooling-off period: a new registration application by the same entity may not be submitted earlier than 6 months after voluntary removal. The purpose of the restriction is to prevent abuse — for instance, attempts to “clean” a negative record through rapid removal and re-registration.
Ex officio removal
Ex officio removal occurs in case of missing mandatory insurance, subsequent emergence of any disqualifying circumstance (e.g. a conviction for an intentional crime), declaration of insolvency, or upon application by the partners following voluntary liquidation.
What owners should know
The new regime is not only a burden on the industry — it is also a new tool in the hands of owners. Here is the practical minimum every owner in a condominium building should know.
How to check your manager
The registry is public and free of charge on the Ministry of Regional Development website. Before signing a management contract or continuing a relationship with an incumbent professional manager, verify the following in the registry:
- the company name and EIK (Unified Identification Code) — they must match the contract;
- date of registration and term of validity — will the registration remain active throughout the term of the contract?
- details of the legal representative and of the professional liability insurance policy;
- any recorded violations or sanctions.
How to report a violation
If irregularities are suspected, owners may report to the competent authorities. The general meeting may decide to lodge a complaint with the Ministry of Regional Development, the Consumer Protection Commission, or directly with the administrative court when challenging the manager’s acts. For damages — for example, missing cash — claims are directed to the professional liability insurer, and where a criminal offence is established, a report is filed with the prosecution.
Professional vs. non-professional manager
It is important to distinguish between the professional manager (registered, managing as a trade) and the “internal” manager elected by the general meeting from among the owners. The latter is not required to register and is not subject to this insurance regime, but remains liable on general grounds under the Obligations and Contracts Act and ZUES for his acts and omissions.
For more information on powers of attorney and representation documents, as well as the procedure for buying property in Bulgaria, see our related guides. For questions about common parts and local property taxes, see our guide on local property and vehicle taxes. For intermediation activity in property transactions, see our dedicated article on real estate brokerage in Bulgaria.
Frequently asked questions
Need legal assistance with registration or a dispute with a manager?
The Innovires Legal team advises both professional condominium managers on the procedure for registration with the Ministry of Regional Development and on professional liability insurance requirements, and owners in disputes with managers, in appeals against their acts, and in claims for compensation for damages. Send us your case and we will respond within one business day.