Written and reviewed by Adriana Melnikliyska, Attorney-at-law, Blagoevgrad Bar No. 1900000227. Last reviewed 27 September 2026.Who this page is for
This page is for a business or individual owed money by a debtor based in Bulgaria — a Bulgarian company that has not paid an invoice, a Bulgarian counterparty to a contract, or a debtor with assets in Bulgaria even if the underlying contract was made elsewhere. It covers the legal routes available and what a creditor needs to have in place before starting. It does not cover consumer debt owed by an individual outside a commercial relationship, which can involve different protections, or debts arising from criminal conduct, which is a separate matter.
What a creditor needs before starting
Before any recovery route is chosen, the underlying claim needs to be evidenced. For a straightforward commercial debt, that generally means:
- The contract, purchase order, or terms of business under which the debt arose, or clear evidence of the agreement if it was not in writing.
- The invoice(s) or statement of account showing what is owed and when it fell due.
- Proof that goods were delivered or services were performed — delivery notes, signed acceptance, correspondence confirming the work was done.
- Correspondence with the debtor about the debt, including any part-payment, acknowledgement, or dispute raised.
- Full identification of the debtor — for a Bulgarian company, its registration details from the Commercial Register; for an individual, full name and, ideally, an address or ID number.
A Commercial Register check on a Bulgarian corporate debtor is worth doing early, not just for identification: it can show whether the company is still active, whether insolvency or liquidation proceedings have been opened against it, and who currently represents it — all of which affect which recovery route makes sense.
Step one: a formal demand letter
A written demand setting out the debt, its basis, and a deadline for payment is the usual first step, both because it sometimes resolves the matter without further proceedings and because it creates a documented record that the debtor was given a clear opportunity to pay before formal proceedings were started. A demand letter from a Bulgarian attorney, referencing the contract and the Bulgarian legal basis for the claim, carries more weight with a Bulgarian debtor than an informal reminder, but it does not itself have binding legal effect — it is a step before, not a substitute for, the procedures below if it is not paid.
Step two: the Bulgarian order-for-payment procedure
For claims that are supported by clear documentary evidence — a written contract, an acknowledged debt, an invoice under a recognised commercial relationship — the Bulgarian Civil Procedure Code provides a faster, largely document-based order-for-payment procedure. The creditor applies to the competent Bulgarian court with the claim and supporting documents; if the court is satisfied on the papers, it issues an order requiring the debtor to pay. The debtor has an opportunity to object. If the debtor objects within the applicable period, the matter is generally redirected into ordinary litigation, where the claim is decided on its merits after both sides are heard; if the debtor does not object, the order becomes enforceable and can proceed directly to enforcement.
This route is attractive because it is faster and cheaper than full litigation when it works, but it is not available for every type of claim, and a debtor who has a genuine dispute can use their right to object to move the matter into ordinary proceedings. Whether a given debt is a good candidate for this procedure depends on how well it is documented.
Step three: litigation on the merits
Where the debt is disputed, where the order-for-payment route is not available or is objected to, or where the claim involves issues beyond a simple sum owed (a contractual dispute about quality, quantity, or performance, for example), the claim proceeds as ordinary civil litigation before the competent Bulgarian court. This means pleadings, evidence, and a judgment on the merits after both parties have been heard — a longer and more evidence-intensive process than the order-for-payment route, and one where the debtor's defences are actually tested rather than assumed away.
Jurisdiction — which Bulgarian court hears the claim — and the applicable procedural deadlines depend on the value of the claim, the parties' domicile, and any jurisdiction or governing-law clause in the underlying contract, and need to be confirmed against the actual contract and facts.
Step four: enforcement
An order for payment that has become enforceable, or a final court judgment, is not itself money in hand — it needs to be enforced against the debtor's actual assets. In Bulgaria this is carried out by a bailiff: either a private enforcement agent, licensed and regulated under the Private Enforcement Agents Act, or a state bailiff attached to the court system. The bailiff can, depending on what assets can be located, seize and sell movable or immovable property, garnish bank accounts, or attach receivables owed to the debtor by third parties.
Enforcement is only as effective as the debtor's identifiable assets. A debtor with no traceable assets in Bulgaria, or one that has already become insolvent, may leave even a fully proven, fully enforceable claim practically uncollectible — which is why an early check of the debtor's position (Commercial Register status, any known assets) is useful before significant cost is committed to litigation.
Cross-border tools for a foreign creditor
Where the creditor is based in another EU member state, several EU-level instruments can be faster or more direct than starting entirely fresh Bulgarian proceedings:
- Regulation (EC) No. 1896/2006 — the European order for payment. This creates a uniform order-for-payment procedure available across participating EU member states for uncontested pecuniary claims in cross-border cases, intended to be enforceable in another member state without a separate declaration of enforceability. It sits alongside, rather than replaces, the equivalent national procedure, and the creditor generally chooses whichever is more suitable to the claim.
- Regulation (EC) No. 861/2007 — the European small claims procedure. This provides a simplified, largely written procedure for cross-border claims up to a defined ceiling, designed to reduce cost and time compared with ordinary litigation, with a judgment recognised and enforceable in other member states.
- Regulation (EU) No. 1215/2012 (recast Brussels I) — jurisdiction and the recognition/enforcement of judgments. Where a judgment has already been obtained in one EU member state, this Regulation generally allows it to be recognised and enforced in another member state, including Bulgaria, without a separate exequatur procedure in most cases — meaning a creditor who has already litigated and won elsewhere in the EU does not necessarily need to start over in Bulgaria, only to enforce the existing judgment there.
Which of these tools is available, and whether it is actually the fastest route compared with a direct Bulgarian claim, depends on where the creditor and debtor are based, the value and nature of the claim, and whether a judgment already exists elsewhere. This needs to be assessed against the specific facts rather than assumed.
If the debtor is, or may become, insolvent
If a Commercial Register check or other evidence suggests the Bulgarian debtor company is in financial difficulty, insolvency proceedings under the Commerce Act may already be open, or may open during the recovery process. Once formal insolvency proceedings begin, individual enforcement against the debtor is generally suspended, and creditors instead need to lodge and prove their claim within the insolvency process itself, in competition with other creditors and subject to a statutory order of priority. Recognising this possibility early — rather than continuing to litigate a claim against a company that is, or is about to be, in insolvency — can materially change the practical value of pursuing the debt.
Choosing between the available routes
| Route | Best suited to | Key limitation |
|---|---|---|
| Demand letter | Any claim, as a first step, especially where the debtor may simply have overlooked or deprioritised payment | No binding effect on its own; only useful if the debtor responds |
| Bulgarian order for payment | Well-documented, likely-undisputed domestic claims | Redirected to full litigation if the debtor objects within the applicable period |
| Ordinary litigation | Disputed claims, or claims involving issues beyond a simple sum owed | Longer and more evidence-intensive than the order-for-payment route |
| European order for payment | Cross-border EU claims that are likely undisputed | Only available where the creditor is in a participating EU member state and the claim is cross-border |
| European small claims procedure | Smaller cross-border EU claims under the applicable ceiling | Value ceiling applies; not suited to larger commercial debts |
| Enforcing an existing EU judgment | Creditors who have already litigated and won in another EU member state | Requires a judgment to already exist; does not itself decide the underlying claim |
Debtors based outside Bulgaria, or with assets in more than one country
Not every recovery matter with a Bulgarian element involves a Bulgarian debtor. A Bulgarian-based creditor may be owed money by a debtor located elsewhere in the EU, or a foreign creditor may hold a Bulgarian judgment that needs to be enforced against a debtor's assets in another member state. The same cross-border instruments described above — the European order for payment, the European small claims procedure, and the recognition and enforcement rules in Regulation (EU) 1215/2012 — work in both directions: they can be used to bring a claim against a debtor elsewhere in the EU, or to move a Bulgarian result to where the debtor's assets actually are. Where the debtor is outside the EU entirely, recognition and enforcement depend instead on Bulgaria's own private international law rules or any applicable bilateral arrangement, which is a materially different and more case-specific question.
Interest, costs, and what is actually recoverable
Beyond the principal sum owed, a creditor can generally seek statutory or contractually agreed interest for late payment, and, where the claim succeeds, an award of costs that typically contributes toward court fees and part of the legal costs incurred — though a full costs award covering every expense is not guaranteed, and the actual amounts depend on the claim's value, the court, and the outcome. What interest rate applies, and how it is calculated, depends on whether the contract fixed a rate, what type of claim it is, and the applicable legal provision at the time — this needs to be checked against the actual contract and the current statutory position rather than assumed.
Documents not originally in Bulgarian
Where the underlying contract, invoices or correspondence are in a language other than Bulgarian, Bulgarian court and enforcement procedures generally require a Bulgarian translation of the documents relied on, and in some cases certified or notarised translation. Preparing this translation early, alongside the rest of the evidence, avoids delay once a filing is otherwise ready to go.
Realistic timing and cost
How long any of these routes takes, and what it costs, depends on the debt's size, whether it is contested, which Bulgarian court has jurisdiction, the debtor's conduct, and whether enforcement assets can actually be located — none of which can be estimated reliably before the facts are known. We do not give a fixed timeline or promise a recovery outcome for any matter; court fees (typically calculated as a percentage of the claim), bailiff fees, and the professional fee for the work involved are all set out, to the extent they can be estimated, once the claim has been reviewed.
What this process does not do
To be clear about the limits of this page and of the underlying procedures: none of the routes described above guarantee that money will actually be recovered, and none of them work faster than the debtor's own conduct, the court's schedule, and the availability of enforceable assets allow. A judgment or enforceable order is a legal entitlement to be paid; converting that entitlement into an actual payment still depends on the debtor having something to enforce against. We do not offer a "no recovery, no fee" arrangement as a default, do not promise same-day or emergency turnaround, and do not act on a matter before a written scope and fee are agreed.
Where this sits next to accounting and operational support
Recovering a debt is a legal question — whether a claim exists, how to prove it, and how to enforce it — and is handled as such. Bookkeeping questions that sometimes accompany a bad debt, such as how to record a written-off receivable or how VAT treatment is affected once a debt is confirmed unrecoverable, are accounting matters for the creditor's own accountant, not something addressed on this page or as part of a legal recovery engagement.
Fees and how a recovery matter is scoped
A debt-recovery matter is scoped once the evidence, the debtor's identity and status, and the debt's value are known. A demand-letter-only engagement is a different scope from an order-for-payment application, a fully litigated claim, or cross-border enforcement of an existing judgment. The proposed scope and fee are confirmed in writing before any substantive work begins, and no part of this process is offered on a "no recovery, no fee" or contingency basis unless that is separately and explicitly agreed as part of the written scope.