Край на двойното обозначаване - новият контрол върху цените

Effective August 9, 2026 , the dual price display period in Bulgarian Leva (BGN) and Euros (EUR) came to an end. However, this does not mark the end of price regulation rules. On the contrary—this date triggers a new temporary legal framework focusing on the economic justification of any price increase.

Until August 9, 2027 , traders must be able to justify and substantiate the reasons for material price changes. Additionally, large retailers face enhanced daily public reporting obligations for specific prices.

What Changes for Businesses?

End of Mandatory Dual Labeling:Effective August 9, 2026, the mandatory dual price display in BGN and EUR was phased out. BGN equivalents are being removed from price tags, price lists, online shops, receipts, and ERP systems.
New Temporary Regulatory Framework (until August 9, 2027):Phasing out dual prices does not mean unregulated pricing. Pursuant to the newly introduced Article 68n of the Consumer Protection Act (CPA), any increase in the final retail price relative to a comparable preceding period must be economically justified.
Heightened Burden of Proof for Traders:During inspections by the Consumer Protection Commission (CPC), traders are obliged to prove the direct connection between rising direct costs and the final price. Generic references to "inflation" or "market dynamics" are legally insufficient.
Daily Reporting Obligations for Large Retailers: Retailers with an annual turnover exceeding EUR 25,000,000 for the preceding fiscal year must publish individual prices of essential goods on their website by 07:00 AM and submit them to the CPC by 08:00 AM every morning.
Cumulative Sanctions: Financial penalties for legal entities reach up to EUR 100,000 and are imposed separately for each distinct product, service, or retail location.

Control Mechanism for Unjustified Price Increases Introduced

Starting August 9, 2026, Article 68n of the CPA prohibits increasing the final retail price of a product or service offered to consumers unless the increase is economically justified. The assessment is made by comparing the new price against the price applied by the same trader for the identical product or service during a comparable preceding period.

It is important to emphasize that this framework does not constitute a general price freeze. The law does not set a statutory percentage ceiling on price increases or a fixed profit margin cap. A trader may increase prices provided there is an objective economic ground and the direct link between that ground and the magnitude of the increase can be demonstrated.

Relevant pricing factors may include changes in supply and production costs, labor and social security expenses, electricity, fuel, raw materials, transport, logistics, and other expenditure directly and materially impacting cost price.

In practice, high-level justifications such as "inflation," "market dynamics," or "shifts in demand" will be deemed inadequate unless directly linked to the specific product or service, the relevant timeframe, and the exact quantum of the price increase.

Requirements for Economic Justifications

In the event of a material price change, a trader must be prepared to establish at least the following:

the former and the new price;
the date from which the new price applies;
the comparable preceding period;
the price components prior to and following the increase;
the specific amount of the cost increase;
the manner in which each cost factor impacted the final price;
the reason why the increase is applied to a specific product or service;
whether a change in margin exists and how it is justified.

Traders must directly link specific costs to specific end prices. For example, a supplier invoice reflecting higher procurement costs serves as relevant evidence of an increased input cost, but does not, in itself, validate the final price charged to the consumer. The trader must demonstrate how that supply cost increase was factored into the overall price calculation.

Businesses are advised to maintain a dedicated 'Price File' for every material price change. This documentation may contain internal management pricing decisions, updated cost calculations, supplier invoices and quotes, logistics contracts, labor/energy cost data, as well as quantitative breakdowns.

Such structured documentation allows traders to audit their price formation methodology and respond effectively during regulatory inquiries.

The Role of the Consumer Protection Commission (CPC)

The Consumer Protection Commission is empowered to request detailed information regarding price structures, procurement and production costs, price formation models, and all supporting documentation underlying a price adjustment.

The initial statutory deadline to respond to an information request cannot be shorter than 5 (five) business days.In cases of incomplete disclosures, an additional deadline ranging from 5 (five) up to a maximum of 10 (ten) business days may be granted.Failure to provide the requested evidence within the designated timeframe creates a legal presumption that the price increase is economically unjustified.

This presumption does not automatically render every unevidenced price increase illegal per se. Rather, the procedural consequence stems from non-compliance with the evidentiary demand, placing the trader in a significantly disadvantageous position during subsequent enforcement proceedings.

Therefore, formal responses to the CPC must be thorough, structured, and backed by concrete documentary evidence rather than broad assertions concerning macroeconomic inflation or general market conditions.

Special Compliance Obligations for Large Retailers

A dedicated statutory framework applies to retail operations meeting statutory classifications whose annual turnover for the preceding fiscal year exceeds EUR 25,000,000.These entities must report individual retail prices daily for items falling within the "essential consumer basket".

The required data must be published on the retailer's official website by 07:00 AM and transmitted to the CPC by 08:00 AM daily.Submissions must be in a machine-readable format; where retail prices differ across commercial locations, data must be submitted on a store-by-store basis.

Compliance requires seamless integration between ERP systems, e-commerce platforms, corporate websites, store labels, and POS software. Furthermore, retailers must maintain verifiable audit trails establishing submission timestamps—such as automated system logs, digital file archives, and transmission receipts.

The CPC maintains a public portal reflecting reported price data alongside a "Fair Value" benchmark.Under the law, Fair Value serves purely as an indicative reference parameter r rather thana mandatory price cap or fixed ceiling.

Fair Value is determined based on:

"Wholesale Price Plus": Comprising wholesale input costs, operational expenses, and commercial markup;
Comparative Elements: Benchmarking prices for identical or equivalent goods across other EU Member States.

Offering products above the established Fair Value does not, in and of itself, constitute a statutory violation. While it may trigger a regulatory review, the CPC must conduct an individualized assessment to determine whether the specific price increase is economically justified and how the final price was derived.

Sanctions

For economically unjustified price increases, the law provides for:

an administrative fine ranging from EUR 1,000 to EUR 10,000 for natural persons;
a financial sanction ranging from EUR 10,000 to EUR 100,000 for sole proprietors or legal entities;
a separate sanction for each distinct product, service, or retail locationwhen the violation encompasses more than one of these categories.

For failure to provide, as well as for incomplete, inaccurate, non-authentic, or misleading information under the daily reporting regime, a financial sanction ranging from EUR 5,000 to EUR 50,000 is provided.

In case of obstructing an inspection or non-compliance with an administrative order, the statutory penalty is: an administrative fine ranging from EUR 1,000 to EUR 5,000 for natural persons; and a financial sanction ranging from ranging from EUR 10,000 to EUR 100,000 for sole proprietors or legal entities.

Conclusion

Following August 9, 2026, compliance requirements extend far beyond removing BGN prices from physical tags. Businesses have entered a regulatory phase where commercial pricing decisions must be fully traceable, quantitatively justified, and backed by verifiable documentation.

For major retailers, this compliance burden includes daily mandatory price disclosures. For all market participants, the risk of significant statutory fines for unjustified price increases, misleading commercial practices, or discrepancies between advertised and charged prices remains high.

In short, the sunset of dual price displays does not mark the end of price enforcement. Instead, it signals a shift toward a new regulatory paradigm where not only the final price, but the underlying justification for that price, is subject to strict legal scrutiny.

Need a compliance audit of your pricing structure or legal assistance during a CPC inspection?

The team of KGK Law Firm provides specialized advisory services and trial advocacy in administrative sanction proceedings and penalty appeals.