Licensing trading with Natural gas


Since 1 January 2021 the Bulgarian Energy and Water Regulatory Commission (EWRC, The Commission) started accepting applications for issuance of a license for trade in natural gas. It will be necessary for all persons who trade with natural gas after 30 September 2021.

The rules that establish the necessary paperwork for issuing a license for trade in natural gas are in force as of 31 December 2020. The required documents are listed in Ordinance № 3 dated 21.03.2013 on licensing of activities in the energy sector and they can be conditionally divided into the following groups:

Documents, proving that the legal criteria for obtaining a license have been fulfilled

These documents include: a document, certifying the current status of the company; several declarations concerning the absence or existence of certain circumstances; customer service rules; corporate information and a document for paid state fee.

Documents, proving that the technical criteria for obtaining a license have been fulfilled

The fulfillment of these criteria is being proved with: documents certifying the availability of certain material resources, including information network and software for carrying out the activity; documents certifying the technical capacity for entering of a natural gas transactions; documents, proving the availability of qualified personnel with experience in carrying out the activity; management and organizational structure data of the applicant.

Documents, proving that the economic criteria for obtaining a license have been fulfilled

The fulfillment of the economic criteria is evidenced by the business plan (prepared for a period of up to 5 years), the applicant’s Annual Financial Statements and its audit reports, if they are subject to mandatory audit, and data on the sources of financing the activity.

The fee for submission of an application for issuance of a license is BGN 1000.

Within 7 days from the date of submission of the application the Commission examines the presented documents and, if any irregularities are found, it shall give instructions for their cure. Furthermore, the Commission has the right to demand additional information at any time during the procedure to clarify facts and circumstances relevant for issuing the specific license.

The deadline for the Commission to issue its decision is up to 3 months from the submission of the application. However, this deadline is instructive (not mandatory) and the Commission may not comply with it. Nevertheless, it may issue a license with a delay and even under such conditions it will be valid as well.

In case the Commission does not issue its decision within the 3-months period, there is a hypothesis of tacit refusal, which can be disputed within one month.

For further information contact:

Aleksandar Aleksandrov, Senior Associate