The polluter pays: Bulgaria's new waste collection fee regime

The Local Taxes and Fees Act requires all municipalities to transition from the current property value–based approach to a system founded on the "polluter pays" principle. Under this principle, anyone who generates waste – whether a household, a business or an institution – must bear the costs of its collection, transport and disposal. The goal is to distribute the financial burden according to the amount of waste produced, thereby encouraging more environmentally responsible behaviour and reducing pollution. This may result in higher costs for businesses generating significant waste volumes, while potentially reducing fees for those with effective waste reduction programmes. 

This marks a shift from per mille charges based on the tax assessment (or the accounting value for non-residential corporate properties) to a usage-based model more closely aligned with actual waste generation. The rule reflects common European practice and is consistent with EU legislation.

Calculation methodology: what changes

Currently, the waste collection fee for non-residential properties is determined either according to the quantity of waste (based on the type and number of storage containers and the frequency of collection), or through direct contracting or proportionally using a per mille rate.

From 1 January 2026, the quantity of waste is the chief basis for determining the waste collection fee. Each municipal council may adopt a different basis or bases than those specified above, provided that objective circumstances exist preventing its application.

The bases for determining the waste collection fee that a municipal council may adopt include: for household waste collection and transport services – (i) an individually determined quantity of waste for the property, including through bags with specific capacity and load; (ii) the quantity of waste for the property, determined according to the number and capacity of the required waste containers and the frequency of their transport; and (iii) the number of users of the service on the property. Similar bases apply to waste treatment services. For the service of maintaining cleanliness in public areas, the bases may be: (i) the number of users of the service on the property; and (ii) the developed built and/or undeveloped area of the immovable property.

Despite the firm implementation date of 1 January 2026, publicly announced information from the Bulgarian Minister of Finance indicates that very few municipalities are currently prepared to apply the "polluter pays" principle to determine the waste fee. Even for Sofia Municipality, the largest in Bulgaria, the situation remains unclear.

Indications for postponement

Under the currently effective Local Taxes and Fees Act, the provision allowing municipalities to roll over the previous year's methodology when the budget plan is not approved on time (i.e. by 31 January of the respective year) has been explicitly excluded for 2026, signalling that the legislator expects the new system to be implemented without exception. However, there are indications that this fallback mechanism for 2026 may be reinstated. In particular, the transitional and final provisions of the Bill for the State Budget for 2026 envisage amendments to the Local Taxes and Fees Act in this respect. In addition, if such amendments are adopted by the National Parliament, local municipal authorities would be required to report to the Ministry of Finance every six months, until 31 December 2028, on the status of their implementation of the new principle.

Current status in Sofia: method still pending

Sofia Municipality has published sample declarations that citizens and companies can complete to provide the administration with information for preparing a decision on how the waste collection fee will be determined from 2026. However, submitting declarations is not mandatory and there are no fines or sanctions for those who do not submit them. Failure to submit a declaration may only lead to the fee being determined ex officio, based on data available in the municipality and in the population register and/or information from the National Revenue Agency, Cadastral Register, Registry Agency or other systems and registers to which the Local Taxes and Fees Department has access.

Approaching the end of the year, Sofia has yet to finalise either the methodology or the fee parameters for 2026. On 17 November 2025, Sofia Municipality opened a 30‑day public consultation window concerning the 2026 budget plan for waste collection, transport, disposal/treatment, public area cleaning and amounts for residential and non-residential properties for 2026. Nevertheless, this budget plan explicitly states that it is conditional upon the adoption and entry into force of the postponement introduced by the Bill for the State Budget for 2026, which is still pending.

Key implications of this uncertainty

Commercial property owners cannot accurately forecast their 2026 waste collection fee obligations without knowing the final calculation methodology, specific rates per unit of measurement, or whether current waste management arrangements will continue.

For 2026, the deadline for approving the budget plan for of the municipalities is 31 January 2026. This means the Municipal Council could approve the budget plan after the year begins, creating potential uncertainty about fees for January 2026.

Practical steps for commercial property owners

Businesses should plan on the new regime taking effect on 1 January 2026. We recommend the following practical steps:

• Build flexible budgets accommodating multiple fee calculation scenarios (container-based, measured-quantity and user-based approaches)
• Document current waste generation and collection practices
• Strengthen recycling and waste reduction initiatives
• Monitor municipal communications closely for final methodology announcements
• Prepare to adjust operations promptly once rules are published

This text is for general information purposes only and does not constitute legal advice. The legal and regulatory position continues to evolve, and we recommend seeking specific advice for your circumstances.

author: Antoniya Peeva