What is in force
EU rules apply directly. The Taxonomy Regulation of June 2020 defines environmentally sustainable activities against six environmental objectives, and its disclosure rules have applied since January 20221. The Climate Delegated Act of June 2021 deferred technical screening criteria for agriculture in view of the CAP negotiations, and none of the delegated acts adopted up to July 2025 sets criteria for growing crops or raising livestock (own reading)2. Since January 2026 banks may leave out of the taxonomy assessment on-balance-sheet assets whose use of proceeds is known where these together make up less than 10% of such assets in the Green Asset Ratio denominator3. The Sustainable Finance Disclosure Regulation has applied since March 2021 and the voluntary European Green Bond Standard since December 202445.
Reporting obligations were narrowed in 2025 and 2026. Bulgaria transposed the Corporate Sustainability Reporting Directive through amendments to the Accountancy Act published in August 20246. After the EU postponed the later reporting waves in April 2025, an amendment in force from 1 January 2026 set the first reporting periods in the Act at 2026, 2027 and 202878. The Omnibus I Directive of February 2026 limits mandatory reporting to undertakings with more than 1,000 employees and more than EUR 450 million of turnover, and Member States are to transpose it by 19 March 20279.
Climate risk is part of bank supervision. The ECB supervised significant banks in Bulgaria under close cooperation with the BNB from 1 October 2020 to 31 December 20251011, and since euro adoption on 1 January 2026 Bulgaria has taken part in the Single Supervisory Mechanism as a euro-area Member State1112. The ECB guide of November 2020 sets thirteen expectations for managing climate-related and environmental risks13. On the ECB list published in August 2026 (cut-off date 1 July 2026) four Bulgarian banks were significant entities under direct ECB supervision, namely DSK Bank, UniCredit Bulbank, United Bulgarian Bank and Eurobank Bulgaria14. EU banking rules adopted in May 2024 require banks to manage ESG risks over horizons of at least ten years and to disclose them, and Bulgaria transposed these rules into the Credit Institutions Act in July 2026151617. The BNB decided in May 2025 to apply the EBA guidelines on ESG risk management from 11 January 202618. It has also decided to apply the EBA guidelines on environmental scenario analysis and, in 2026, the joint ESAs guidelines on ESG stress testing of 8 January 2026, both from 1 January 20271920. The BNB was not among the 152 members of the Network for Greening the Financial System listed in August 202621.
Green bonds and public funds. ECB securities statistics show no green, social, sustainability or sustainability-linked debt securities issued by Bulgarian residents, the government included, from December 2020 to September 2026, while residents of Romania had EUR 6.46 billion of green debt securities outstanding at the end of 202522. Bulgaria's Recovery and Resilience Plan provides EUR 6.17 billion of grants (about US$7.16 billion at the ECB rate of 31 August 2026, own calculation), with 57.5% for climate objectives2324. Its fund for the technological and ecological transition of agriculture (investment C6.I1) had a total budget of BGN 391.7 million in the ministry's application conditions of April 2026 (EUR 200.3 million at 1.95583 leva per euro, own calculation), with grants of 50% of eligible costs and an expected 1,700 farms supported2526. By 31 July 2026 Bulgaria had received 68% of its RRF allocation27. The Modernisation Fund had confirmed EUR 216.1 million for eight Bulgarian energy investments by October 2025 (own calculation), none of them in agriculture28.
The CAP green architecture. Bulgaria's CAP Strategic Plan 2023–2027, approved on 7 December 2022 and amended for the fourth time on 27 February 2026, reserves EUR 1.03 billion of EU funds for eco-schemes (about US$1.19 billion, own calculation), equal to 25% of direct payments, and EUR 558 million, 40% of rural development funds, for environmental and climate objectives293024. The plan envisages organic support for 136,610 hectares and a pesticide-reduction eco-scheme on about 1,679,400 hectares30. The organic area reached 198,051 hectares in 2024, 3.95% of utilised agricultural area31. Development-bank credit lines with a climate component include a EUR 175 million EIB loan to the Bulgarian Development Bank signed in July 2023 and a EUR 139.7 million EIB guarantee for Allianz Bank Bulgaria signed in March 2026 that covers loans in industry, agriculture and services3233.
- Mar 2014Climate Change Mitigation Act in force34Law
- Jun 2020EU Taxonomy Regulation adopted1Law
- Oct 2020ECB starts supervising significant Bulgarian banks under close cooperation10Institution
- Nov 2020ECB Guide on climate-related and environmental risks13Finance
- Dec 2022
- Jul 2023EIB EUR 175 m loan to the Bulgarian Development Bank with a climate quota32Finance
- Aug 2024Accountancy Act amendments transpose the CSRD6Law
- May 2025BNB decides to apply the EBA guidelines on ESG risks18Finance
- Oct 2025Climate neutrality by 2050 written into the Climate Change Mitigation Act34Climate
- Jan 2026
- Feb 2026
- Mar 2026EIB EUR 139.7 m guarantee for Allianz Bank Bulgaria33Finance
- Jul 2026
| Date | Instrument or event | Issuer | Content |
|---|---|---|---|
| March 2014 | Climate Change Mitigation Act (State Gazette No. 22 of 11 March 2014) | National Assembly | National climate policy, EU emissions trading, National Green Investment Scheme, later the Modernisation Fund34 |
| November 2019 | Regulation (EU) 2019/2088 (SFDR) | European Parliament and Council | Sustainability disclosures by financial market participants, applies from 10 March 20214 |
| June 2020 | Regulation (EU) 2020/852 (Taxonomy Regulation) | European Parliament and Council | Six environmental objectives, taxonomy disclosures from 1 January 20221 |
| October 2020 | Close cooperation between the ECB and the BNB (Decision (EU) 2020/1015) | European Central Bank | ECB supervision of significant Bulgarian banks under close cooperation from 1 October 2020 to 31 December 20251011 |
| November 2020 | Guide on climate-related and environmental risks | European Central Bank | Thirteen supervisory expectations for significant institutions13 |
| June 2021 | Delegated Regulation (EU) 2021/2139 (Climate Delegated Act) | European Commission | Technical screening criteria, criteria for agriculture deferred2 |
| December 2022 | Directive (EU) 2022/2464 (CSRD) | European Parliament and Council | Corporate sustainability reporting, transposition by 6 July 202435 |
| November 2023 | Regulation (EU) 2023/2631 (European Green Bonds) | European Parliament and Council | Voluntary EU green bond label, applies from 21 December 20245 |
| May 2024 | Regulation (EU) 2024/1623 and Directive (EU) 2024/1619 (CRR III and CRD VI) | European Parliament and Council | ESG risk management, transition plans and ESG disclosure for all institutions1615 |
| August 2024 | Act amending the Accountancy Act (State Gazette No. 72 of 27 August 2024) | National Assembly | Transposes the CSRD, in force from 6 July 20246 |
| January 2025 | Guidelines on the management of ESG risks (EBA/GL/2025/01) | European Banking Authority | Apply from 11 January 2026, the BNB decided on 22 May 2025 to comply3618 |
| October 2025 | Climate Change Mitigation Act amended (State Gazette No. 81 of 3 October 2025) | National Assembly | National goal of climate neutrality by 205034 |
| December 2025 | Act amending the VAT Act, whose § 65 amends the Accountancy Act (State Gazette No. 115 of 30 December 2025) | National Assembly | Transposes Directive (EU) 2025/794 and moves first reporting periods to 2026, 2027 and 20288 |
| February 2026 | Directive (EU) 2026/470 (Omnibus I) | European Parliament and Council | Sustainability reporting limited to undertakings above 1,000 employees and EUR 450 million turnover, transposition by 19 March 20279 |
| July 2026 | Act amending the Credit Institutions Act (State Gazette No. 67 of 24 July 2026) | National Assembly | Transposes CRD VI ESG risk provisions17 |
| Instrument | Allocation or reservation | Paid or confirmed | Reference date | Note |
|---|---|---|---|---|
| Recovery and Resilience Facility, whole plan | EUR 6,174 million of grants, 57.5% for climate objectives | 68% of EUR 6.17 billion received | 31 July 2026 | Fourth payment of EUR 896 million, three milestones and targets outstanding2327 |
| RRP investment C6.I1, Fund for the technological and ecological transition of agriculture | BGN 391.7 million (about EUR 200.3 million at 1.95583, own calculation) | Not published in the sources checked | 20 April 2026 | 50% grants for 1,700 farms, procedure BG-RRP-6.004 BGN 378.7 million excluding VAT in the April 2026 application conditions25 |
| CAP Strategic Plan, eco-schemes | EUR 1,026.6 million of EU funding, 25% of direct payments | Not published in the sources checked | February 2026 version | Pesticide-reduction eco-scheme on about 1,679,400 ha30 |
| CAP Strategic Plan, rural development environment and climate | EUR 558.2 million of EU funding, 40% of rural development | Not published in the sources checked | February 2026 version | Includes organic support for 136,610 ha30 |
| Modernisation Fund | 5.84% share of the Fund for 2021–2030 (and a 4.9% share for 2024–2030) | EUR 216.1 million confirmed for eight investments (own calculation) | 6 October 2025 (latest confirmation) | Energy networks and heating, none in agriculture, EUR 50 million disbursed in 2025342844 |
What it means for agricultural lenders
No taxonomy criteria for crop and livestock farming by 2025
Agriculture among the sectors banks assess under the EBA guidelines from 2026
Reporting thresholds raised to 1,000 employees in 2026
RRP grants of 50% of eligible costs in the April 2026 conditions
Climate quotas in development-bank credit lines
| Year signed or announced | Financier | Bank or intermediary | Amount | Green or agricultural content |
|---|---|---|---|---|
| 2023 | EIB | Bulgarian Development Bank | EUR 175.0 million (signed 11 July 2023) | At least 20% of loans for climate action and environmental sustainability, SMEs and Mid-Caps32 |
| 2024 | EBRD | ProCredit Bank Bulgaria | EUR 60 million (announced 12 January 2024) | On-lending for green projects in Bulgaria and Greece, including energy efficiency and climate resilience46 |
| 2026 | EIB | Allianz Bank Bulgaria | EUR 139.7 million guarantee (signed 31 March 2026) | SME and Mid-Cap portfolio in industry, agriculture and services, 25% climate action share33 |
| Not signed | EIB | Eurobank Bulgaria (Postbank) | About EUR 100 million proposed | Under appraisal since 3 March 2025 and not signed by 20 October 2026, 20% for climate action47 |
| Listed in October 2026 | Bulgarian Development Bank | Commercial banks | Bridge loans up to BGN 22 thousand (EUR 11.2 thousand) for photovoltaic systems | Guarantee for household renewable energy loans pending grants from the Ministry of Energy48 |
Sources cited on this page
- Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (Taxonomy Regulation), OJ L 198, 22.6.2020, p. 13 — Publications Office of the EU (EUR-Lex)verified
- Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 establishing the technical screening criteria for climate change mitigation and adaptation (Climate Delegated Act), OJ L 442, 9.12.2021, p. 1 — Publications Office of the EU (EUR-Lex)verified
- Commission Delegated Regulation (EU) 2026/73 of 4 July 2025 amending Delegated Regulation (EU) 2021/2178 as regards the simplification of taxonomy disclosures, OJ L, 2026/73, 8.1.2026 — Publications Office of the EU (EUR-Lex)verified
- Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR), OJ L 317, 9.12.2019, p. 1 — Publications Office of the EU (EUR-Lex)verified
- Regulation (EU) 2023/2631 of 22 November 2023 on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and for sustainability-linked bonds, OJ L, 2023/2631, 30.11.2023 — Publications Office of the EU (EUR-Lex)verified
- Закон за изменение и допълнение на Закона за счетоводството (Act amending the Accountancy Act), ДВ No. 72 of 27.08.2024 — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Directive (EU) 2025/794 of 14 April 2025 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates of application (stop-the-clock directive), OJ L, 2025/794, 16.4.2025 — Publications Office of the EU (EUR-Lex)verified
- Закон за изменение и допълнение на Закона за данък върху добавената стойност (Act amending the VAT Act, § 65 amending the Accountancy Act), ДВ No. 115 of 30.12.2025 — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Directive (EU) 2026/470 of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting and due diligence requirements (Omnibus I), OJ L, 2026/470, 26.2.2026 — Publications Office of the EU (EUR-Lex)verified
- Decision (EU) 2020/1015 of the European Central Bank of 24 June 2020 on the establishment of close cooperation between the ECB and the Bulgarian National Bank (ECB/2020/30), OJ L 224I, 13.7.2020, p. 1 — Publications Office of the EU (EUR-Lex)verified
- Council Decision (EU) 2025/1407 of 8 July 2025 on the adoption by Bulgaria of the euro on 1 January 2026, OJ L series, 14.7.2025 — Publications Office of the EU (EUR-Lex)verified
- Council Regulation (EU) No 1024/2013 of 15 October 2013 conferring specific tasks on the European Central Bank concerning policies relating to the prudential supervision of credit institutions (SSM Regulation), OJ L 287, 29.10.2013, p. 63 — Publications Office of the EU (EUR-Lex)verified
- Guide on climate-related and environmental risks. Supervisory expectations relating to risk management and disclosure, November 2020 — European Central Bank, Banking Supervisionverified
- List of supervised entities, cut-off date for changes in group structures 1 July 2026 (August 2026 edition) — European Central Bank, Banking Supervisionverified
- Directive (EU) 2024/1619 of 31 May 2024 amending Directive 2013/36/EU as regards supervisory powers, sanctions, third-country branches, and environmental, social and governance risks (CRD VI), OJ L, 2024/1619, 19.6.2024 — Publications Office of the EU (EUR-Lex)verified
- Regulation (EU) 2024/1623 of 31 May 2024 amending Regulation (EU) No 575/2013 (CRR III), OJ L, 2024/1623, 19.6.2024 — Publications Office of the EU (EUR-Lex)verified
- Закон за изменение и допълнение на Закона за кредитните институции (Act amending the Credit Institutions Act), ДВ No. 67 of 24.07.2026 — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Compliance table for EBA/GL/2025/01 Guidelines on the management of ESG risks (Excel) — European Banking Authorityverified
- Press release on the application of the EBA Guidelines on environmental scenario analysis (EBA/GL/2025/04) — Bulgarian National Bankverified
- Press release on the application of the ESAs Joint Guidelines on ESG stress testing (JC/GL/2025/78), 2026 — Bulgarian National Bankverified
- Membership page (list of members and observers) — Network for Greening the Financial Systemverified
- Securities issues statistics (CSEC), sustainable debt securities outstanding by issuer country, nominal value — European Central Bankverified
- Bulgaria's recovery and resilience plan, country page — European Commission, Reform and Investment Task Forceverified
- Euro foreign exchange reference rates – US dollar (EXR.D.USD.EUR.SP00.A), 31 August 2026 — European Central Bank (ECB), published in Bulgaria by the Bulgarian National Bankverified
- Национален план по Механизма за възстановяване и устойчивост (National Recovery and Resilience Plan page), with application conditions for procedure BG-RRP-6.004, amendment 4 of 20 April 2026 (ZIP) — Ministry of Agriculture and Food of Bulgariaverified
- Council Regulation (EU) 2025/1409 of 8 July 2025 amending Regulation (EC) No 2866/98 as regards the conversion rate to the euro for Bulgaria, OJ L, 2025/1409, 14.7.2025 — Publications Office of the EU (EUR-Lex)verified
- Press release IP/26/1713 of 31 July 2026, Belgium, Bulgaria, Denmark, and Slovenia receive more than €1.86 billion under NextGenerationEU — European Commissionverified
- What can be financed and list of investments — Modernisation Fund (European Commission and European Investment Bank)verified
- CAP Strategic Plan – Bulgaria, country page — European Commission, DG Agriculture and Rural Developmentverified
- At a glance. Bulgaria's CAP Strategic Plan, updated version February 2026 (PDF) — European Commission, DG Agriculture and Rural Developmentverified
- Organic crop area by agricultural production methods and crops (org_cropar) and Area under organic farming (sdg_02_40), Bulgaria — Eurostatverified
- Project 20220377, BDB loan for SMEs and MidCaps — European Investment Bankverified
- Project 20250730, Allianz Bank BG enhanced support SMEs & CA II — European Investment Bankverified
- Закон за ограничаване изменението на климата (Climate Change Mitigation Act), consolidated text including amendments up to State Gazette No. 16 of 10.02.2026 (Word file) — Ministry of Environment and Water of Bulgariaverified
- Directive (EU) 2022/2464 of 14 December 2022 as regards corporate sustainability reporting (CSRD), OJ L 322, 16.12.2022, p. 15 — Publications Office of the EU (EUR-Lex)verified
- Guidelines on the management of ESG risks (EBA/GL/2025/01), final report of 8 January 2025 and guideline page — European Banking Authorityverified
- Закон за ограничаване изменението на климата, ДВ бр. 22 от 11.3.2014 (Climate Change Mitigation Act, original text) — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Закон за противодействие на корупцията сред лица, заемащи публични длъжности, ДВ бр. 51 от 5.6.2026 (Act on Counteracting Corruption among Persons Holding Public Office) — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Закон за изменение и допълнение на Закона за насърчаване на инвестициите, ДВ бр. 55 от 16.6.2026 (Act amending the Investment Promotion Act) — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Climate Change Mitigation Act (Закон за ограничаване изменението на климата), consolidated text (DOCX, in Bulgarian) — Ministry of Environment and Water of Bulgariaverified
- Закон за изменение на Закона за счетоводството, ДВ бр. 17 от 28.2.2025 (Act amending the Accountancy Act) — State Gazette of the Republic of Bulgaria (Държавен вестник)verified
- Organic crop area by agricultural production methods and crops (org_cropar), Bulgaria — Eurostatverified
- Annual report on the state and development of agriculture (Agrarian Report) 2025, covering 2024 and forecasts for 2025 — Ministry of Agriculture and Food (MAF)verified
- Joint press release IP/25/3104 of 17 December 2025, Modernisation Fund announces €1.8 billion in new clean energy investments — European Commission and European Investment Bankverified
- EIB Group Investment Survey 2025, Bulgaria overview (PDF) — European Investment Bankverified
- EBRD loan to support green initiatives in Bulgaria and Greece, news of 12 January 2024 — European Bank for Reconstruction and Developmentverified
- Project 20250147, Eurobank BG (Postbank) SMEs and Mid-Caps MBIL — European Investment Bankverified
- RES (Renewable Energy Sources) for Households, programme in partnership with commercial banks — Bulgarian Development Bankverified
- Press release of 29 January 2026, Bulgaria sees jump in EIB Group financing to €646 million in 2025 — European Investment Bankverified
For more information and suggestions, please contact serkan.veziroglu@prosperaimpact.com.