Bulgaria
EU AI Act implementation, 2026
Bulgaria has designated only its Article 77 fundamental-rights bodies; no market surveillance authority, notifying authority, single point of contact, penalty regime or sandbox exists, and the implementing bill was scheduled in the Council of Ministers' July-December 2026 legislative programme for consultation in September and tabling in October 2026, with the responsible minister saying in September that work was 'in its final stage'.
- Implementing law
- Draft bill
- Penalty regime (Art. 99)
- Not adopted
- Regulatory sandbox
- Planned
- Readiness rank
- 27 of 27score 15 / 100
Key findings
- No Article 70 authorities have been designated; the Commission's single-point-of-contact list (7 Sept 2026) has no Bulgarian entry and the ministry itself confirmed in January 2026 that high-risk AI is unsupervised nationally.
- Lead responsibility moved from the Ministry of Electronic Governance to the new Ministry of Innovation and Digital Transformation, which sponsors the bill under the second-half-2026 legislative programme.
- The Bulgarian Accreditation Service is the proposed notifying authority per a draft decision; the market surveillance model was undecided as of early 2026.
- The internal target of March 2026 for a national framework was missed; the revised programme points to Council of Ministers tabling in October 2026, with parliamentary adoption still to follow.
- No penalty rules, no sandbox and no register of AI systems exist; the only strategic document is the 2020 Concept for AI development to 2030.
National authorities
Not designated or not confirmed as of 21 Oct 2026.
Not designated or not confirmed as of 21 Oct 2026.
Not designated or not confirmed as of 21 Oct 2026.
Implementing law, penalties and sandbox
Закон за въвеждане на национални мерки по прилагане на Регламент (ЕС) 2024/1689 (Акт за изкуствения интелект) – Law introducing national measures for implementing Regulation (EU) 2024/1689
strategy.bg (opens in new tab)No national penalty rules under Article 99 are in force; regulators rely on existing powers.
The planned implementing law is to create a national AI regulatory sandbox; a 2026 budget request for administrative capacity and a sandbox (about EUR 213,520) was rated low priority by the Finance Ministry in October 2025.
strategy.bg (opens in new tab)Concept for the Development of Artificial Intelligence in Bulgaria until 2030
2020
oecd.ai (opens in new tab)Notable developments
-
Council of Ministers Decision No. 398 designates seven Article 77 bodies
Decision No. 398 of 18 June 2025 named seven fundamental-rights authorities: the Ombudsman, the Central Election Commission, the Commission for Protection against Discrimination, the Commission for Personal Data Protection, the Consumer Protection Commission, the State Agency for Child Protection and the General Labour Inspectorate; the Ministry of Electronic Governance itself said this covers only a limited part of the Act.
ekipnews.com (opens in new tab) -
Ministry of Electronic Governance tells BTA there is no supervision of high-risk AI
In answers under the Access to Public Information Act (BTA, 9 Jan 2026), the ministry said a draft decision would make the Bulgarian Accreditation Service the notifying authority, that the market surveillance decision had not yet entered interagency coordination, that no sanctions regime existed, and that the national framework was targeted for March 2026.
ekipnews.com (opens in new tab) -
Legislative programme July-December 2026 schedules the AI Act bill
Council of Ministers Decision No. 577 of 29 July 2026 lists the bill as item 21 under the Ministry of Innovation and Digital Transformation, with public consultation and pre-coordination in September 2026 and submission to the Council of Ministers in October 2026; it is to designate competent authorities, set penalties and create a sandbox.
strategy.bg (opens in new tab) -
Draft Digital Transformation Strategy 2026-2030 in public consultation
The draft Strategy for Digital Transformation of Bulgaria 2026-2030 and its roadmap were in public consultation from 8 to 22 August 2026; AI appears in its emerging-technology sections, but we could not confirm an explicit reference to the AI Act implementing measures.
strategy.bg (opens in new tab) -
Minister Vasilev: AI law 'in its final stage'
On 2 September 2026 Innovation and Digital Transformation Minister Ivan Vasilev told the parliamentary committee that work on the AI law was on the home stretch and that it would be published for public consultation; no date was given.
news.bg (opens in new tab)
Analysis
Bulgaria sits at the back of the EU-27 on AI Act governance. Its own ministry's January 2026 disclosures to BTA are unusually candid: no market surveillance authority, no sanctions regime, no coordination model and an interagency working group that was still being formed months after the 2 August 2025 deadline. Capacity, not policy disagreement, is the stated bottleneck, with the ministry citing lack of expertise, infrastructure needs and complex institutional coordination, and the Finance Ministry deprioritising even a modest sandbox budget line.
The legislative path is now defined on paper. Decision No. 577 of July 2026 commits the Ministry of Innovation and Digital Transformation to consult in September and table the implementing law in October 2026, and Minister Vasilev's September statement suggests the text exists. But the programme entries are planning milestones, not law: as of 21 October 2026 we could not find the draft on the strategy.bg consultation portal, and parliamentary passage, Council of Ministers designation decisions for the market surveillance and notifying authorities (measures 138 and 139 of the EU action plan), and the Commission notification all remain outstanding.
The practical consequence is that Bulgarian deployers face directly applicable EU obligations with no national enforcement counterpart, and that the Commission's leverage is the Article 258 infringement route rather than Bulgarian regulators. The Digital Omnibus postponement of high-risk duties to December 2027 gives Bulgaria roughly a year to stand up a system from scratch; whether the Accreditation Service and a yet-to-be-named market surveillance body can be operational by then is the central question.
EU AI Act 2026 Q3 Report
All 27 member-state profiles including Bulgaria, the readiness ranking, the Omnibus timeline and every source, as one print-ready PDF.
Sources
- Закон за въвеждане на национални мерки по прилагане на Регламент (ЕС) 2024/1689 (Акт за изкуствения интелект) – Law introducing national measures for implementing Regulation (EU) 2024/1689 (opens in new tab) strategy.bg
- Concept for the Development of Artificial Intelligence in Bulgaria until 2030 (opens in new tab) oecd.ai
- Council of Ministers Decision No. 398 designates seven Article 77 bodies (opens in new tab) ekipnews.com
- Draft Digital Transformation Strategy 2026-2030 in public consultation (opens in new tab) strategy.bg
- Minister Vasilev: AI law 'in its final stage' (opens in new tab) news.bg