Fuel Trade in Bulgaria — Registration, Licensing and Requirements (2026)

Regulated Activities under ЗАРИДНПНП

Pursuant to Art. 2, para. 1 of the ЗАРИДНПНП (Law on Administrative Regulation of Economic Activities Related to Petroleum and Petroleum Products), the following activities are subject to mandatory registration:

Definitions

Petrol station (бензиностанция) — a facility for fuelling motor vehicles with liquid fuels, comprising a tank farm, dispensing pumps, a canopy and service premises, commissioned pursuant to the ЗУТ (Spatial Development Act).

Internal facility (вътрешен обект) — a facility for fuelling vehicles and machinery that does not serve external customers and is intended exclusively for the owner's needs.

Who Must Register

Pursuant to Art. 3 of the ЗАРИДНПНП, any natural or legal person that carries out or intends to carry out any of the regulated activities under Art. 2 is required to register before commencing operations. Carrying out a regulated activity without registration constitutes an administrative violation, punishable by fines ranging from BGN 20,000 to BGN 200,000 (EUR ~10,226 – 102,258).

Exemptions

• State and municipal bodies where they perform the activities in fulfilment of statutory functions (e.g. the State Reserve).
• Persons who carry out activities exclusively within tax warehouses under the ЗАДС (Excise Duties Act) — these are regulated by the Customs Agency.

Registration Authority and Register

Registration is carried out by the Minister of Economy and Industry or an authorised official. The Ministry maintains a public electronic register of registered persons, accessible on the Ministry of Economy and Industry website. Entries include data on the person, the type of activity, the facilities and the registration period.

Capital Requirements

The ЗАРИДНПНП introduces minimum requirements for the amount of registered capital entered in the Commercial Register, differentiated by type of activity and revenue volume. These thresholds ensure the financial stability of market participants:

Capital requirements must be met at the time of filing the registration application. For wholesale trade, the capital amount is subject to annual reassessment based on the reported revenue for the preceding financial year.

Security Deposits

In addition to the capital requirements, the ЗАРИДНПНП requires the mandatory establishment of a security deposit in favour of the Ministry of Economy and Industry. The security deposit guarantees the performance of the registered person's obligations and may be enforced in the event of serious violations.

Form of the Security Deposit

The security deposit may be provided in one of the following forms:

• Cash deposit — deposited in an escrow account held by the Ministry of Economy and Industry.
• Irrevocable bank guarantee — issued by a licensed bank with a validity period of no less than 1 year and 6 months.

Exempt Persons

No security deposit is required from:

• Licensed warehouse keepers within the meaning of the ЗАДС (Excise Duties Act);
• Registered agricultural producers who store and dispense fuels exclusively for their own needs;
• Budget organisations.

Registration Procedure — Step by Step

The registration procedure is governed by Chapter Two of the ЗАРИДНПНП and Ordinance RD-04-2/2019. The process follows these stages:

1. Step 1: Prepare the documents and security deposit

   Gather all required documents (see the "Required Documents" section). Deposit the security in an escrow account or obtain a bank guarantee. Ensure that the registered capital entered in the Commercial Register meets the requirements.

2. Step 2: File the application

   Submit an application using the standard form (Annex No. 2 to Ordinance RD-04-2/2019) to the Minister of Economy and Industry. The application may be filed on paper at the Ministry's registry office or electronically using a qualified electronic signature.

3. Step 3: Document review

   The competent officials review the submitted documents within 7 business days of receipt of the application.

4. Step 4: Rectification of deficiencies

   If deficiencies or irregularities are identified, the applicant is notified in writing and has 14 business days to rectify them. If the deficiencies are not rectified, the proceedings are terminated.

5. Step 5: Issuance of certificate or refusal

   Within 14 days of the Minister's decision, a registration certificate or a reasoned refusal is issued. The refusal may be appealed under the Administrative Procedure Code (АПК).

6. Step 6: Entry in the public register

   After the certificate is issued, the registered person's data is entered in the Ministry's public electronic register. The registration is indefinite unless it is struck off in accordance with the law.

Fee: The registration procedure is free of charge — no state fees are payable.

Change of circumstances: The registered person is obliged to notify the Ministry of any change in the registered circumstances within 7 days of the change occurring.

Required Documents

The following documents must be submitted for registration under the ЗАРИДНПНП:

1. Application using the standard form (Annex No. 2 of Ordinance RD-04-2/2019).
2. Identity document of the manager or authorised representative (when filing on paper).
3. Proof of ownership or right to use the facility — title deed, lease agreement or other document evidencing the legal basis for use.
4. Proof of security deposit — bank statement confirming the cash deposit or original irrevocable bank guarantee.
5. Details of equipment and transport vehicles — description of tanks, dispensing pumps, tankers and other equipment, including GPS coordinates of the facilities.
6. Declaration of compliance with conditions — declaration by the manager confirming compliance with the general and specific conditions under the ЗАРИДНПНП.
7. Commissioning certificate or building permit under the ЗУТ (Spatial Development Act) — for facilities subject to such requirements.
8. Transport vehicle declaration — for registration of petroleum product transport, with details for each vehicle (registration number, capacity, ADR certificate).

All documents must be submitted as originals or notarially certified copies. When filing electronically, documents must be signed with a qualified electronic signature.

Petrol Station Requirements

Petrol stations are classified as first category facilities under the ЗУТ (Spatial Development Act), meaning that the investment project approval and commissioning are subject to oversight by the ДНСК (Directorate for National Construction Control). The main requirements include:

• Building permit — issued by the chief architect of the municipality, coordinated with the ДНСК.
• Commissioning — occupancy permit issued by the ДНСК following acceptance by a state acceptance committee.
• Fire safety — compliance with minimum setback distances from residential buildings (minimum 45 m pursuant to Ordinance No. Iz-1971 on construction and technical rules and standards for fire safety).
• Automated reporting systems — mandatory equipment with level gauging systems and remote data transmission devices (real-time monitoring) to the NRA.
• Measuring instruments — all dispensing pumps must be equipped with approved and verified measuring instruments under the Measurements Act and relevant ordinances of the ДАМТН (DAMTN).
• Physical security or alarm systems — the facility must be secured with physical security guards or a security alarm system (СОТ) connected to a licensed security company.
• Information signage — clearly visible signs displaying information on fuel types, prices and the registered person's details.

Excise Regime (ЗАДС)

Fuels are excise goods within the meaning of the ЗАДС (Excise Duties and Tax Warehouses Act). The excise regime is a key element of the regulatory framework and covers the production, warehousing, transport and trade of fuels.

Excise Rates 2026

Tax Warehouse and Licensed Warehouse Keeper

The production, processing and storage of excise goods under a duty suspension arrangement takes place in tax warehouses licensed by the Customs Agency. A licensed warehouse keeper is a person who has obtained authorisation to operate a tax warehouse and to produce, store and dispatch excise goods under duty suspension.

Registered Consignee

A registered consignee under Art. 57a of the ЗАДС is a person authorised to receive excise goods from another EU Member State under a duty suspension arrangement. Registration is carried out by the Customs Agency and is mandatory for importers of fuels from intra-Community supplies.

EKAS — Electronic Control of Excise Goods

The Electronic Control of Excise Goods system (ЕКАЗ/EKAS) provides GPS tracking of vehicles transporting excise goods. The system enables the Customs Agency and the NRA to monitor in real time the routes, quantities and end recipients of fuels.

NRA Control

The NRA exercises continuous control through a remote connection with the automated reporting systems of petrol stations. Data on every delivery and sale of fuels is transmitted in real time to the NRA's information system, enabling immediate detection of discrepancies and unregulated trade.

VAT on Fuel Trade

Fuel trade is a taxable supply within the meaning of the ЗДДС (Value Added Tax Act), subject to the following rules:

• Standard rate — 20% on the taxable amount (Art. 66 ЗДДС). The taxable amount includes the fuel price excluding excise duty, increased by the excise duty.
• Mandatory VAT registration — upon reaching a taxable turnover exceeding EUR 51,130 (BGN 100,000) over a period of 12 consecutive months (Art. 96 ЗДДС). In practice, all fuel traders exceed this threshold and are subject to mandatory registration.
• Security deposit under Art. 176v ЗДДС — a special tax security deposit amounting to 20% of the taxable amount of taxable supplies of liquid fuels for the preceding tax period, but no less than BGN 25,000. The security deposit is provided in the form of a cash deposit, bank guarantee or government securities.
• Reverse charge on intra-Community supplies — when acquiring fuels from another EU Member State, the reverse charge mechanism applies (Art. 82, para. 2 ЗДДС), under which the recipient charges and deducts the VAT.

Fines and Penalties

The ЗАРИДНПНП and the ЗАДС provide for a strict sanctions regime for violations related to fuel trade. The fine amounts reflect the high degree of public interest and the significant budgetary revenue from excise duty and VAT.

In addition to monetary penalties, in the event of serious or repeat violations, the Minister of Economy may strike off the person's registration, resulting in a ban on carrying out the activity. Where an activity is carried out without registration, sealing of the premises is also ordered for a period of up to 6 months.

Frequently Asked Questions