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New Reasons to Tread Carefully in Bulgaria: A Buzz Interview with Mariya Papazova of PPG Lawyers

New Reasons to Tread Carefully in Bulgaria: A Buzz Interview with Mariya Papazova of PPG Lawyers

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Regulatory updates – mostly driven by EU acts – keep lawyers on the toes in Bulgaria with digital markets being at the forefront of the country's Competition Protection Commission according to PPG Lawyers Partner Mariya Papazova.

"At the beginning of January 2024, the Bulgarian Competition Protection Commission adopted a Block Exemption Decision," Papazova begins. "This decision reflects EU regulations on prohibited practices, including vertical and horizontal agreements, as well as certain sectors. This decision transfers the newly adopted block exemption EU regulations to the respective type of agreements and practices with effect on national markets," she explains, advising that "during the decision’s transitional period, market operators, need to be vigilant and ensure full compliance with the new legal framework. Especially in critical sectors like pharmacy, fuels, food, and energy, which are fundamental for the economy and thus, under continuous scrutiny by the Competition Protection Commission."

Focusing on the priorities list of the Bulgarian Competition Protection Commission, Papazova reports that "digital markets are at the forefront, prompted by recent EU acts. These markets are rapidly evolving. In addition, the Competition Protection Commission's sector inquiry into e-commerce of commercial consumer goods that began in 2021 is still ongoing. The sector inquiry may result in further compliance work and may also lead to antitrust investigations by the Bulgarian Commission." She adds that "this scrutiny extends to fintech, where innovation outpaces regulation, potentially leading to anti-competitive practices. Additionally, the CPC is focused on the pharmacy, food, and nutritional goods sectors, particularly in terms of pricing, labeling, and advertising practices, underlining the importance of fair competition and consumer protection."

Talking about how these developments impact the fintech and digital market operators, Papazova says that "the relative lack of regulation in fintech opens doors for non-compliant practices. Given the CPC's intent to monitor these areas closely, fintech companies, in particular, must tread carefully." 

"Companies must stay abreast of new regulations, especially those introduced in the past two years concerning consumer protection — it's a challenge but also an opportunity for businesses to align their practices with these standards, ensuring they operate fairly and transparently," she adds. "This requires diligent compliance work and an understanding of the legal landscape to navigate potential investigations effectively."

Finally, according to Papazova, merger control remains a critical area in Bulgaria, with "the number of filings and decisions remaining stable in recent years." The newly adopted national FDI regime adds an extra layer for dealmakers with the PPG Partner concluding that market players "must factor in these regulations when pursuing mergers and acquisitions, which only goes to show how our regulatory environment continues to gain complexity at a regular pace."

Bulgaria Knowledge Partner

Schoenherr is a leading full-service law firm providing local and international companies stellar advice that is straight to the point. With 15 offices and 4 country desks Schoenherr has a firm footprint in Central and Eastern Europe. Our lawyers are recognised leaders in their specialised areas and have a track record of getting deals done with a can-do, solution-oriented approach. Quality, flexibility, innovation and practical problem-solving in complex commercial mandates are at the core of our philosophy.

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