Certification of SPA, Wellness and Medical SPA Centres in Bulgaria (2026)

Legal framework

Certification of SPA, balneological (medical SPA), wellness and thalassotherapy centres in Bulgaria is governed by two main instruments:

• The Tourism Act — Article 140 and the related provisions setting out the principles of certification, the competent authority and the legal consequences of granting or refusing a certificate.
• Ordinance No. 04-14 of 9 October 2019 on the conditions and procedure for certification of “Balneological (Medical SPA) centre”, “SPA centre”, “Wellness centre” and “Thalassotherapy centre” — a detailed act containing all minimum requirements for buildings, equipment, staff and services of each type.

The competent authority is the Ministry of Tourism. Certified centres are entered into the National Tourism Registry, a public register available on the Ministry’s website. On-site inspections mandatorily include representatives of the Regional Health Inspectorate (RHI) of the respective district.

This regime turns certification from a formality into a genuine market-access restriction: without a certificate, a venue may neither operate under the regulated name nor use it in its marketing.

Brand protection — who may use the name

This is the rule most often overlooked by investors. Only centres that have received a valid certificate from the Minister of Tourism may use in their name, advertising materials and website the words:

• “SPA”
• “Balneological” or “Medical SPA”
• “Wellness”
• “Thalassotherapy”

The prohibition covers not only facades and business cards, but also:

• the legal name of the operating company, if it includes any of these terms;
• domains and websites (“xyz-spa.bg”, “wellness-xyz.com” etc.);
• printed brochures, flyers, service menus;
• online advertising, social media profiles, booking platforms;
• contracts with tour operators and tourism packages.

Unauthorised use of these terms constitutes a breach of the Tourism Act, with administrative penalties including fines and orders to cease use. The practical consequence is that even a small hotel with a pool and massage room cannot call itself a “SPA hotel” unless it has a certified SPA centre attached. Many Bulgarian hotels therefore use descriptive phrases like “wellness zone” or “relaxation area” to avoid using the regulated terms until they obtain certification. See also our note on trademark registration, which offers additional protection for the brand once certification is secured.

The four types of centres

Ordinance No. 04-14/2019 defines four categories of centres, each with a different focus and different requirements:

Choosing the correct category at the investment-planning stage is critical because each type has its own set of requirements, its own fee and its own inspection scope.

Requirements to operate

To be certified, the operator of the centre must simultaneously satisfy several baseline conditions:

1. Legal form

The operator must be a registered legal person or sole trader — ET (sole trader), EOOD, OOD, AD or a non-profit legal entity (NPLE). Natural persons cannot act as operators. See also company registration.

2. Financial standing

The company must not be in insolvency or liquidation proceedings. This is declared in the application and verified ex officio by the administration.

3. Qualified staff

Both medical and non-medical staff must have the educational and professional qualifications, language skills and experience required by the Ordinance. For medical SPA this means a physician, physician’s assistant or rehabilitation therapist; for SPA — certified cosmeticians and massage therapists; for wellness — fitness instructors and healthy-lifestyle coaches.

4. Experienced manager

The centre’s manager must have specific education, professional qualification, command of at least one foreign language and experience in the relevant field. This is not a formality — the commission checks education and experience documents on site.

5. Suitable premises and equipment

The building, premises, furnishings and equipment must meet the minimum technical requirements of the Ordinance, which differ by type of centre. Medical SPA has the heaviest requirements (medical rooms, consultation area, physiotherapy equipment); thalassotherapy requires access to sea water; wellness requires adequate fitness and relaxation zones.

All these conditions are checked in combination: on paper (through documents) and on site (through a commission).

Certification procedure (step by step)

The certification procedure follows a clear sequence that normally runs between 2 and 4 months:

1. File an application-declaration with the Minister of Tourism using the standard form.
2. Document review — 10-day review period; if documents are incomplete, 10 days to cure.
3. Issuance of a temporary certificate — if documents are in order, the Ministry issues a temporary act valid 3 months, during which the on-site inspection takes place.
4. On-site inspection — a commission from the Ministry of Tourism, joined by representatives of the RHI, inspects the building, equipment, staff and services.
5. Inspection report — the commission draws up a report with findings and a proposal to certify or refuse.
6. Expert Commission for Certification of Tourism Sites — within 7 days of its meeting, it issues a reasoned proposal.
7. Minister’s order — within 7 days, the Minister of Tourism (or an authorised official) issues an order certifying or refusing.
8. Issuance of certificate and plate — on a positive order the centre is entered into the National Tourism Registry and receives its certificate and category plate.

Required documents

The application-declaration is filed with the Ministry of Tourism together with mandatory and recommended annexes:

• Standard application-declaration form containing data on the operator, the venue, the type of centre and declarations of legal form and financial standing.
• Copy of the document evidencing the right to use the premises — notarial deed, lease, free-use contract etc., unless the right is already recorded in the property register.
• Explicit power of attorney, if the application is filed through a representative (attorney or other agent).

Strongly recommended additional documents that speed up the process and reduce the risk of a negative inspection report:

• Diplomas, certificates and attestations of education and professional qualification of manager and staff.
• Documents evidencing language qualification (TOEFL, IELTS, Goethe, DELE etc.).
• Employment records or references proving experience in the field.
• Job descriptions and internal rules of operation.
• Catalogue of services and procedures offered.

Preparing the file “above minimum” is the best insurance against delay or refusal.

Temporary certificate (3 months)

If the document review shows that the applicant formally meets the requirements of Art. 140 of the Tourism Act, the Ministry of Tourism issues a temporary certificate. This is a provisional administrative act that:

• is valid for 3 months from issuance;
• allows the centre to operate under the regulated name while the procedure is ongoing;
• serves as the window during which the commission performs the on-site inspection;
• does not create a right to a permanent certificate — the final certificate depends on the inspection outcome.

In practice the temporary certificate allows the investor to open the venue to customers without waiting for the full procedural cycle. This is one of the most practical features of the regime, particularly for seasonal venues in resort areas.

On-site inspection

The inspection is carried out by a commission appointed by an official of the Ministry of Tourism, which must include representatives of the Regional Health Inspectorate (RHI) of the district where the venue is located. This dual composition is deliberate — the Ministry covers tourism standards, while the RHI covers health, sanitary-hygiene and, in some cases, medical aspects.

The scope of the inspection covers:

• compliance of the building and premises with the minimum technical requirements;
• equipment (bathtubs, massage tables, physiotherapy apparatus, fitness equipment);
• staff composition and qualification on site;
• presence of a manager with the declared qualifications;
• catalogue of services and the way they are delivered;
• hygiene requirements and client-safety conditions.

After the inspection the commission draws up a constative report describing its findings and setting out a reasoned proposal to the Expert Commission for certification — to certify or to refuse. If the report contains curable remarks, a reasonable period is usually given for correction before the Expert Commission rules.

State fees (2026)

The procedural fees are of two kinds: a document-review fee (paid on filing) and a registry-entry fee (paid when the certificate is issued). Their amount depends on the type of centre:

Document review fees

Registry entry fees

Total per type

• Medical SPA: ~EUR 664.68
• SPA: ~EUR 613.55
• Wellness: ~EUR 562.42
• Thalassotherapy: ~EUR 511.29

To these should be added legal fees, notarisation, possible expert opinions and corrections, which can bring the total budget to approximately EUR 1,500–2,500. For the tax implications of the activity see taxes and social contributions.

Certificate validity and plate

The certificate for a SPA, wellness, medical SPA or thalassotherapy centre is valid for 5 years from the date of the Minister’s order. After expiry a fresh application must be filed and the procedure runs anew.

In addition to the certificate itself, the centre is issued a category plate according to the approved sample for the relevant type. Both documents — certificate and plate — must be displayed in a visible place at the venue: the certificate typically at reception and the plate on the external facade or entrance.

The plate serves a dual function: it assures clients that the venue has been vetted and certified, and at the same time signals to inspection authorities that the operator has lawful grounds to use the regulated commercial terms. We recommend starting the renewal procedure 2–3 months before expiry to avoid any legal gap.

Appealing a refusal

If the Minister of Tourism issues an order refusing certification, the applicant may appeal before the Supreme Administrative Court (SAC). The appeal is lodged under the Administrative Procedure Code (APC), within the statutory period following notification of the order.

The SAC reviews the lawfulness of the order: whether there is a factual basis, whether the procedure was followed (commission, report, expert commission), whether the reasoning is sufficient and whether the legal classification is correct. The most frequent successful grounds of appeal are insufficient reasoning of the refusal and procedural breaches during the on-site inspection.

We recommend lodging the appeal with legal assistance and with a clear strategy — including the possibility of filing, in parallel, a new corrected application if the defects are curable in practice.

Business context

Bulgaria is one of Europe’s most competitive SPA and wellness destinations. The country has more than 700 mineral springs, forming the “balneological backbone” of resorts such as:

• Sandanski — Bulgaria’s sunniest town, preferred for respiratory and allergic conditions;
• Velingrad — the largest balneological resort in the Balkans, with more than 80 mineral springs;
• Hisarya — a historic Roman-era resort with strong effects on gastrointestinal and metabolic conditions;
• Pomorie — thalassotherapy with brine, salt lakes and Black Sea climate;
• Devin — internationally recognised mineral water.

These natural advantages cannot, however, be commercially exploited without certification. For foreign investors in hotels, resort development or medical tourism, the certificate plays three roles:

• Legal legitimacy — without it the regulated commercial name (SPA, Medical SPA etc.) cannot be used.
• Marketing capital — international tour operators and medical insurers work only with certified venues.
• Local competitive advantage — clients increasingly check the certificate status before booking.

If you plan to separately register tour-operator or travel-agent activity alongside the certified centre, see tour operator registration. If you sell or rebrand SPA products, see food supplements for the regime applicable to cosmetic and health products.

Ongoing obligations

Certification is not a one-off achievement — it starts a permanent compliance regime. The operator has several key ongoing obligations:

• Maintaining standards — the building, equipment, staff and services must continue to meet the minimum requirements of Ordinance 04-14.
• Periodic checks — the Ministry of Tourism and the RHI may carry out control inspections during the validity of the certificate, both scheduled and triggered by complaints.
• Notification of changes — change of manager, change of premises, material expansion or reduction of services, change of ownership — all must be notified to the Ministry.
• Display obligation — the certificate and plate must be displayed in a visible place at all times.
• Renewal every 5 years — a new application must be filed before expiry.

Neglecting these obligations can lead to withdrawal of the certificate, including in the middle of the 5-year period, if a material breach is established.

Frequently asked questions