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 judgment creditor — a business or individual who has already won a case in a court outside Bulgaria, or holds an arbitral award, and now needs to reach a debtor's assets, bank accounts, property or business interests located in Bulgaria. It assumes the underlying dispute has already been decided elsewhere; it does not cover bringing the original claim, which is a different matter covered on the litigation lawyer and debt collection pages.
EU judgments: recognised and enforced with minimal formality
Under Regulation (EU) 1215/2012 (the recast Brussels I Regulation), a judgment given in a civil or commercial matter in one EU member state is, as a general rule, recognised in Bulgaria without any special procedure being required, and is enforceable in Bulgaria in the same way as a Bulgarian judgment, without a declaration of enforceability first needing to be obtained. In practice, the judgment creditor provides the Bulgarian enforcement authority with a copy of the judgment and the standard certificate issued by the court of origin under the Regulation, and enforcement can proceed from there through a Bulgarian bailiff. Limited grounds exist to resist recognition — for example, that recognition would be manifestly contrary to Bulgarian public policy, or that the judgment is irreconcilable with an earlier judgment — but these are narrow and rarely succeed on their own.
Non-EU judgments: a separate recognition procedure is usually required
A judgment from a country outside the EU does not benefit from the Brussels regime. Recognition and enforcement in Bulgaria instead generally proceeds under the Bulgarian Private International Law Code's own rules on recognition of foreign judgments, or, where Bulgaria has a bilateral treaty with the country concerned covering judicial cooperation, under that treaty's specific terms instead. This typically requires a formal application to a competent Bulgarian court, which examines whether the foreign court had proper jurisdiction under Bulgarian conflict-of-law rules, whether the defendant was properly served and had a genuine opportunity to defend the case, whether the judgment is final under the law of the country that issued it, and whether recognising it would be contrary to Bulgarian public policy. This is a substantive procedure, not a formality, and the specific requirements and likely timeline depend on the country of origin and whether a relevant treaty exists.
| Origin | Route | Typical formality |
|---|---|---|
| EU member state (civil/commercial) | Regulation (EU) 1215/2012 | Minimal — certificate from court of origin, narrow grounds to resist |
| Non-EU, treaty country | Applicable bilateral treaty | Formal court application under the treaty's specific terms |
| Non-EU, no treaty | Private International Law Code | Formal court application; jurisdiction, service and public-policy review |
| Arbitral award (any origin) | 1958 New York Convention | Formal court application; narrow, defined grounds to refuse |
Arbitral awards: the New York Convention route
Bulgaria is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which provides a generally more predictable and internationally consistent route than judgment enforcement. A party seeking to enforce a foreign arbitral award in Bulgaria applies to the competent Bulgarian court with the award and the underlying arbitration agreement; the court's ability to refuse enforcement is limited to a defined, narrow set of grounds set out in the Convention itself — such as the arbitration agreement being invalid, a party not having proper notice of the proceedings, the award dealing with matters outside the scope of the arbitration agreement, or enforcement being contrary to Bulgarian public policy. See the arbitration page for how an arbitration clause and the underlying arbitral process work.
Cross-border payment claims: European procedures worth knowing about
Where the underlying claim has not yet been decided and the debtor is in Bulgaria, two EU procedures can sometimes be used instead of starting fresh Bulgarian litigation from scratch: the European order for payment procedure under Regulation (EC) 1896/2006, for an uncontested pecuniary claim, and the European Small Claims Procedure under Regulation (EC) 861/2007, for lower-value cross-border claims. Both produce a result that circulates for enforcement across the EU, including Bulgaria, in a broadly similar way to a national judgment under the Brussels regime. Whether either is a better route than pursuing the claim to judgment in the creditor's own courts and then enforcing under Regulation 1215/2012 depends on the specific facts and is assessed case by case.
What the enforcement process actually involves
Once recognition is established, or is not required, enforcement itself proceeds through a Bulgarian private or state bailiff in broadly the same way as enforcement of a Bulgarian judgment: identifying the debtor's assets, bank accounts or income in Bulgaria, and applying the standard enforcement measures available under the Civil Procedure Code — account freezes, seizure of movable or immovable property, or garnishment of income, depending on what the debtor actually holds. Locating enforceable assets is frequently the practical bottleneck in a foreign-judgment matter, more so than the recognition step itself, and is worth assessing honestly before deciding whether pursuing enforcement in Bulgaria is commercially worthwhile.
Documents that typically matter
The judgment or award itself, in a form that meets the applicable regulation's or convention's requirements (including, for an EU judgment, the standard certificate from the court of origin); the underlying arbitration agreement, for an arbitral award; proof that the judgment or award is final and, where relevant, that it was properly served on the debtor; a certified translation into Bulgarian where the original is not in Bulgarian; and whatever information is available about the debtor's assets, accounts or business interests in Bulgaria, since this materially affects whether enforcement is worth pursuing at all.
Working from outside Bulgaria
This is, almost by definition, cross-border work, and the assessment, the recognition application, and most of the process can be handled remotely, with a power of attorney used where a specific filing or appearance requires it — see power of attorney for how that works.
What this page does not promise
Recognition and enforcement of a foreign judgment or award is not automatic outside the EU regime, and this page does not promise a particular timeline or outcome. Whether a specific judgment or award will be recognised, how long the process will take, and whether the debtor actually has assets in Bulgaria worth pursuing are all case-specific questions assessed against the actual judgment and the actual debtor, not general propositions.
Fees
Foreign-judgment enforcement varies from a straightforward EU-judgment certificate submission to a contested non-EU recognition application, and is not priced on a single published scale. The professional fee and any expected third-party costs (court fees, bailiff fees, translation) are set out in writing as part of the proposed scope, before any work begins. See how fees are set for the general policy.
Verifiable identity
Adriana Stefanova Melnikliyska (Адриана Стефанова Мелниклийска) is a practising attorney of the Blagoevgrad Bar Association, attorney number 1900000227.
Independent national register of practising Bulgarian attorneys.
Verify registration →Local Bar association profile, office address and registration record.
View profile →1 Bratya Miladinovi Street, Floor 2, Office 8, 2700 Blagoevgrad, Bulgaria
Frequently asked questions
I have a UK judgment. Is that treated as an EU judgment for enforcement in Bulgaria?
No. Since the UK left the EU, a UK judgment no longer benefits from the Regulation 1215/2012 route and is instead treated as a non-EU judgment, generally requiring the Private International Law Code recognition procedure or an applicable bilateral instrument, depending on when and how the judgment was obtained.
How long does it take to enforce a foreign judgment in Bulgaria?
An EU judgment under Regulation 1215/2012 can generally proceed to enforcement relatively quickly once the certificate and translation are in order. A non-EU recognition application is a substantive court procedure and takes materially longer; the specific timeline depends on the court, the complexity of the jurisdictional and public-policy questions raised, and whether the debtor contests recognition.
Can a debtor in Bulgaria block recognition of a foreign judgment?
Yes, on specific, limited grounds — for an EU judgment, narrow grounds such as manifest contradiction with Bulgarian public policy; for a non-EU judgment, grounds including improper jurisdiction, defective service, or the judgment not being final. A debtor cannot block recognition simply by disagreeing with the original outcome.
Do I need to know where the debtor's assets are before starting?
It is not a legal requirement to start the recognition process, but it is a practical one: locating enforceable assets, accounts or income in Bulgaria is frequently the real bottleneck, and assessing this honestly before committing to the process avoids pursuing an enforcement that has no realistic target.
Does an arbitral award go through the same process as a court judgment?
No. An arbitral award follows the 1958 New York Convention route, which Bulgaria is party to, and is generally a more predictable and internationally consistent procedure than non-EU judgment recognition, with a narrower, defined set of grounds on which a court can refuse enforcement.
What is the European order for payment procedure, and is it relevant to me?
It is an EU procedure under Regulation (EC) 1896/2006 for an uncontested cross-border pecuniary claim, producing a result that circulates for enforcement across the EU including Bulgaria. It is relevant if the underlying claim has not yet been decided and is genuinely uncontested; it is not a route for enforcing a judgment you already hold.
Do I need a certified Bulgarian translation of the judgment?
In most cases, yes, for any judgment or award not already in Bulgarian, along with the relevant supporting documents. This is arranged as part of the scoped engagement.
Can you assess whether pursuing enforcement in Bulgaria is worthwhile before I commit to the full process?
Yes. An initial assessment reviewing the judgment or award, the applicable route, and what is known about the debtor's position in Bulgaria is the normal starting point, before a decision is made on whether to proceed to a full application.
Is there a free consultation for a foreign-judgment matter?
No. The case-assessment stage, where the judgment and the applicable route are reviewed and a scope and fee are proposed, is the paid starting point rather than a free preliminary call.
What should I send with a first enquiry?
A copy of the judgment or arbitral award, the court or tribunal that issued it, whatever is known about the debtor's connection to Bulgaria (address, business interests, known assets), and, for an arbitral award, the underlying arbitration agreement.
Which Bulgarian court actually deals with recognising a foreign judgment?
For most non-EU recognition applications this is the Sofia City Court, though the specific competent court depends on the type of judgment and, in some cases, where the debtor or the relevant assets are located. This is confirmed as part of the initial assessment rather than assumed from a general rule.
I have a default judgment where the debtor never appeared — does that change anything for enforcement in Bulgaria?
It can. Whether the debtor was properly served and had a genuine opportunity to defend the original case is one of the specific grounds a Bulgarian court checks before recognising a foreign judgment, and a default judgment invites closer scrutiny on that point than one reached after both sides participated. This is assessed against the actual service record from the original proceedings.
Sources
- Regulation (EU) No 1215/2012 (Brussels I recast) →
- Regulation (EC) No 1896/2006 (European order for payment) →
- Regulation (EC) No 861/2007 (European Small Claims Procedure) →
- Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) →
- Private International Law Code (Bulgaria) →
- Civil Procedure Code (Bulgaria) →
- Bulgarian Bar Act (Zakon za advokaturata) →
This page describes the general categories of foreign-judgment and arbitral-award enforcement in Bulgaria. It does not state findings, deadlines or outcomes for any specific matter, which depend on the actual judgment, award and debtor position and are confirmed once a matter is reviewed.