Following the conclusion of a one-month public consultation, the Council of Ministers is expected to review and adopt a Regulation on the criteria, conditions, and procedures for determining the status of a household in a situation of energy poverty and the status of a vulnerable customer for electricity supply

The draft was developed by the Ministry of Energy (ME) and the Ministry of Labor and Social Policy (MLSP) pursuant to Article 38d, paragraph 2 of the Energy Act, and is a key element in the implementation of Reform C13.R1 of the National Recovery and Resilience Plan: Framework for managing energy poverty and preparing for the liberalization of the retail market.

The Ordinance pursues three main objectives:

• establishing clear criteria and conditions for determining and certifying the status of a household in a situation of energy poverty and the status of a vulnerable customer for electricity supply;
• regulating the procedure and mechanism for the operation of an information system for certifying such status;
• establishing the conditions and procedure for assessing the number of households in a situation of energy poverty.

The determination of status also serves the purpose of prioritizing the implementation of energy efficiency improvement measures by the obligated parties under Article 14a, paragraph 4 of the Energy Efficiency Act.

Criteria for Determining Status

Household in a Situation of Energy Poverty

A household in a situation of energy poverty is determined based on three cumulative criteria: average monthly disposable income of household members; expenses for typical energy consumption; and energy characteristics of the dwelling.

The average monthly disposable income per person is calculated by subtracting the annual standard energy expenditure from the total annual disposable income of household members, dividing the resulting annual income by 12 months, and then by the number of household members. For the purposes of this regulation, both declared income and all earned income for which data is available at the National Revenue Agency (NRA) are taken into account, after deducting allowable expenses, tax credits, taxes due, and mandatory social security contributions under the Income Tax Act.

Residential buildings in the country that do not have a valid energy performance certificate are divided into three types:

• Type 1 – unrenovated multi-family or single-family buildings with the highest specific annual consumption of primary non-renewable energy of 400 kWh/m²;
• Type 2 – renovated buildings or those with a valid Class C certificate or higher, with 135 kWh/m²;
• Type 3 – buildings constructed after January 1, 2024, with 90 kWh/m². The standard household area ranges from 40 m² for one person to 90 m² for six people.

If there is a person over 65 years of age, a person with 50% or more permanent disability, or a child under 18 years of age, a vulnerability coefficient of 1.3 applies (in other cases, 1.0).

Vulnerable electricity customer

A vulnerable electricity customer is a residential end-user who is critically dependent on electrical equipment due to the presence of one of four circumstances:

• A person over 65 years of age, living alone or with another person or persons over 65 years of age, with a disposable income after deduction of energy costs that is less than or equal to the poverty line.
• A person with a permanently reduced working capacity of 50 percent or more, or a type and degree of disability, with a disposable income after deduction of energy costs that is less than or equal to the poverty line.
• A person who requires assistive devices for independent living and/or life-sustaining medical devices that depend on electricity to function.
• A person who received monthly social assistance and/or targeted heating assistance under the Social Assistance Act for the previous heating season.

Procedure for determining and certifying status

Automated certification of vulnerable client status

Vulnerable client status is automatically determined and certified for a period of one year based on data provided by the Agency for Social Assistance (ASA) and the National Health Insurance Fund (NHIF). The SSA provides data monthly, by the 15th, on individuals receiving monthly social assistance, and by March 30—data on individuals receiving targeted heating assistance. The NHIF provides monthly data on individuals who have been granted assistive devices for independent living and/or medical devices that rely on electricity.

The information system performs a complex series of operations: checking the Population Register for names, addresses, and dates of death; identifying foreign nationals through the Unified Register of Foreigners; sending data to electricity distribution network operators to confirm the account holder of a metering point (MP); and finally—verifying the status and notifying the end supplier and the relevant electricity distribution network operator. End suppliers are required to indicate the presence of vulnerable customer status on the invoices they issue, along with the rights arising therefrom.

Certification via Application-Declaration

In all other cases, certification is carried out on the basis of an application-declaration submitted by the interested party in person or through a representative to the Agency for Social Assistance (ASA) or another entity serving as an administrative service center. The application-declaration may be submitted electronically (including via the e-government portal), at an administrative service center, or through a licensed postal operator. It contains information about the applicant and household members, the ITN holder, the type of building, implemented energy efficiency measures, expert decisions by TELK/NELK, information on medical devices provided, and non-taxable income.

After the application is submitted, the system performs automated checks: queries the General Directorate of Civil Registration and Administrative Services (GD GRAO) for address registration; checks with NELK for a valid expert decision; receives data from the Energy and Water Regulatory Commission (KEVR) on standard electricity prices; from the Agency for Energy Efficiency (AUE) regarding the building’s specific energy consumption; and sends data to the National Revenue Agency (NRA) for income verification. The NRA performs an automatic check to determine whether the calculated average monthly income per household member, after deducting energy costs, is less than or equal to the poverty line. Electricity distribution network operators confirm ITN data within three business days. In case of non-compliance with the criteria, the applicant is given a 30-day period to rectify the issue; if the issue is not resolved, the director of the “Social Assistance” Directorate issues a denial order. The status certificate is valid for 12 months from the first day of the month following the month of issuance.

Information System and Institutional Mechanism

The information system for certifying status is created and maintained by the Ministry of e-Government, and the Agency for Social Assistance administers the processes within it. The system exchanges data with the information systems of numerous primary administrators: the Social Assistance Agency (SAA), the National Health Insurance Fund (NHIF), the National Expert Medical Commission (NEMC), the General Directorate of Civil Registration and Administrative Services (GD CRAS) (Population Register), the National Revenue Agency (NRA), the Agency for Energy Regulation (AER), the Energy and Water Regulatory Commission (EWRC), electricity distribution network operators, and the Ministry of the Interior (MoI). Users of anonymized data from the system include the Ministry of Energy, the Ministry of Labor and Social Policy, the Ministry of Regional Development and Public Works, the Ministry of Transport, the Social Assistance Agency, end-use electricity suppliers, the Energy and Water Regulatory Commission, and the Ministry of the Interior.

The system consists of a public and an administrative section. Access is granted via a qualified electronic signature, and every action is automatically logged with details regarding the user, the time, and the type of processing. Data is processed in accordance with Regulation (EU) 2016/679 (GDPR) and the Personal Data Protection Act, and security is ensured in accordance with the Cybersecurity Act.

Methodology for Cost Assessment and Standard Prices

The Regulation includes two methodologies as annexes. Annex No. 1 defines the formula for calculating the annual energy cost per household: REG = EGOD × TP × KUD × C1 × 0.7 + EGOD × TP × KUD × C2 × 0.3, where 70% of consumption is attributed to the daytime tariff and 30% to the nighttime tariff. With a single tariff (C3), the formula is simplified.

Appendix No. 2 regulates the formation of the standard prices C1, C2, and C3, including the base cost of electricity, the component for the end supplier, the price for network services (access and transmission through the transmission and distribution network), and the price for public service obligations. For customers in the free market, C3 includes the forecast market price of base load, deviation coefficients, and supplier costs, as well as VAT. A separate standard price C14 is also provided for cases where the price for access to the electricity distribution network is determined based on allocated capacity (kW/day) rather than on energy consumed.

Public Consultation

The draft Regulation has been published for public consultation on the Public Consultation Portal strategy.bg (consultation No. 12151-K) by the Ministry of Energy, with a consultation period from February 10 to March 12, 2026. During the public consultation, comments and proposals were received from EVN, WWF Bulgaria, the Bulgarian National Association of Active Consumers, Elektrohold Bulgaria EOOD, the Ombudsman of the Republic of Bulgaria, the “Trust for Social Alternative” Foundation (supported by nine other organizations and experts), and from individuals.

According to the summary of the proposals received, published on April 1, 2026, the vast majority of the proposals were not accepted, particularly those coming from the industry (end suppliers and electricity distribution companies) and from civil society organizations.

Among the few accepted proposals are consent for the processing of personal data when submitting an application-declaration, sending ITN information to the end supplier and the network operator to prevent supply interruption, the use of the ITN as the sole identifier instead of a customer/ subscriber number, regulation of the date of commencement and termination of the status, inclusion of technical requirements for integration with the information system in the ordinance, recognition of the need for a multi-factor model including a housing criterion, a more comprehensive approach to assessing building types, linking the status to priority access to energy efficiency programs and the Social Climate Fund, clarifying the inconsistency in Article 7, paragraph 1, and the table for Type 2 buildings (TSA Foundation); and adapting the formula for C3 for seasonal/hourly tariff structures.

The Ombudsman’s recommendations regarding the need for an approach that takes social aspects into account have also been accepted in principle—citing data that 21% of Bulgarians cannot keep their homes sufficiently warm.

Proposals to include end suppliers and traders as users of anonymized data and to provide them with data from the information system have been rejected. Proposals to define housing vulnerability and to introduce alternative methods for proving actual occupancy in the absence of a title deed were also rejected. Proposals by the Bulgarian National Association of Active Consumers to set specific deadlines for all institutions and to train contact points were also rejected.

Risks and challenges from the perspective of end suppliers and electricity distribution companies

The implementation of the ordinance creates a number of operational, financial, and regulatory risks for end suppliers and electricity distribution network operators:

• Significant operational burden from integration with the information system. Network operators are required to provide “real-time” data (Art. 36, para. 4), which implies significant investments in IT systems and interfaces, without the ordinance specifying the technical specifications, deadlines for development and testing, or mechanisms for financing these investments. Although one of the proposals to include these requirements in the regulation or in a technical annex was accepted in principle, it is unclear how this is reflected in the final text in concrete terms.
• Unclear customer identification. Despite the acceptance in principle of the proposal to use only the ITN as a unique identifier, the initial text provides for the parallel use of a customer number and a subscriber number, which creates a risk of inconsistencies between the systems of different companies and potential errors in identifying vulnerable customers.
• Prohibition on Disconnection. The Regulation requires end suppliers and operators to prevent the disconnection of vulnerable customers. This creates a significant financial risk in the event of debt accumulation by vulnerable customers, without the ordinance providing for a compensation mechanism or clear rules of conduct in the event of prolonged non-payment. In practice, suppliers assume a credit risk that is not recognized in price regulation.
• Requirement to indicate status on invoices. End suppliers are required to indicate the vulnerable customer status and the resulting rights on invoices, which requires adaptation of invoicing systems. The proposal to limit the indication to the mere existence of the status (without a detailed description of the specific rights arising therefrom) was not accepted.
• The short three-day response period for electricity distribution network operators (Art. 26, para. 1, item 8) when verifying and cross-checking data on the holder of an ITN is potentially insufficient in the event of a mass submission of applications, especially during periods around the start of the heating season.
• Limited access to data. The proposals to include end suppliers and traders as users of anonymized data and to provide data to them have not been adopted. This means that suppliers will receive limited information, which may hinder portfolio planning and risk management related to vulnerable customers.
• The volume of personal data exchanged (personal identification numbers, names, addresses) between the information system and operators creates significant liability under the GDPR. The proposal to limit data to only personal identification numbers was not accepted, which increases the risk of personal data breaches and the associated penalties.
• Uncertainty regarding the dates of commencement and termination of status. Despite the proposal to regulate these dates being accepted in principle, legal uncertainty remains for suppliers regarding the exact moment from which the customer is protected from disconnection and regarding billing until the specific provisions are reflected in the text.

Overall, the regulation imposes significant new obligations on end suppliers and electricity distribution network operators—for system integration, data exchange, adaptation of billing systems, and credit risk management—without providing for corresponding compensation mechanisms or sufficient transition time for technical preparation. The risk of inaccurate identification of vulnerable customers, combined with the absolute ban on supply disconnection, could create serious financial imbalances, especially given the growing number of registered vulnerable customers in the context of full liberalization of the electricity market.