European Accessibility Act Compliance in Bulgaria

Bulgaria transposed the European Accessibility Act with the Закон за изискванията за достъпност на продукти и услуги (Law on the accessibility requirements for products and services), passed by the 51st National Assembly, promulgated in Държавен вестник (State Gazette) issue 31 of 11 April 2025 and in force since 28 June 2025. That is nearly three years after the EU transposition deadline of 28 June 2022, and Bulgaria was taken to the Court of Justice over the delay. The law covers e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media services and parts of passenger transport.

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National law Закон за изискванията за достъпност на продукти и услуги (Law on the accessibility requirements for products and services), passed by the 51st National Assembly on bill 51-402-01-16 of 11 December 2024, promulgated in Държавен вестник (State Gazette) issue 31 of 11 April 2025, in force from 28 June 2025. The exact plenary date on which the law was passed could not be confirmed from a primary source, so it is not stated here. Paragraph 5 of the transitional provisions, which amends the law on the national 112 emergency call system, takes effect on 28 June 2027. Paragraph 4(3) lets self-service terminals lawfully in use before 28 June 2025 stay in service to the end of their economic life, and for no more than 20 years from first use. Transposition was late. The deadline in Directive (EU) 2019/882 was 28 June 2022, the Commission referred Bulgaria to the Court of Justice for failing to communicate transposing measures, and the Court gave judgment in Case C-646/24, European Commission v Republic of Bulgaria, on 19 March 2026. The operative part of that judgment, including whether any financial sanction was imposed, could not be confirmed from a primary source at the time of writing.

Web standard The Bulgarian law names no standard. Article 6 for products and Article 48 for services grant a presumption of conformity to harmonised standards whose references are published in the Official Journal of the European Union, and Annex 2, which attaches to Article 4 and Article 46, sets out the accessibility requirements taken from the Directive. In practice the working reference is EN 301 549, the European standard for ICT accessibility, which carries the WCAG success criteria. One caveat is worth stating. The Commission's list of harmonised standards does not yet include Directive (EU) 2019/882, so the presumption of conformity in Articles 6 and 48 may have nothing cited to attach to. EN 301 549 V3.2.1 is the version cited as harmonised for the public sector Web Accessibility Directive, and the Bulgarian Ministry of e-Government applies that version under Article 58v of the Закон за електронното управление when it monitors government sites. Bulgaria applies no separate national accessibility standard for websites.

Enforcement Under Article 34, market surveillance of products rests with the Chairperson of the Държавна агенция за метрологичен и технически надзор (State Agency for Metrological and Technical Surveillance), acting through the agency's market surveillance officers. Conformity of services is split by sector under Article 54(1): Комисия за регулиране на съобщенията (Communications Regulation Commission) for electronic communications, Съвет за електронни медии (Council for Electronic Media) for access to audiovisual media services, the civil aviation, road transport, railway and maritime administrations for the passenger transport services, Комисия за финансов надзор (Financial Supervision Commission) and Българска народна банка (Bulgarian National Bank) for most consumer banking, Министерство на културата (Ministry of Culture) for e-books, and Комисия за защита на потребителите (Commission for Consumer Protection) for e-commerce services and for one category of consumer banking. Complaints route: under Articles 62 to 64, consumers and organisations of and for people with disabilities may file a complaint on paper or electronically with whichever body under Article 34 or Article 54(1) is competent, naming the economic operator and setting out the grievance. Complaints are handled under Chapter Eight of the Administrative Procedure Code, and Article 63(1) says no proceedings are opened on anonymous complaints. Articles 67 to 70 also let organisations of and for people with disabilities bring injunction and damages claims, including claims for named consumers. Penalties sit in Chapter Six and are written in leva in the law as promulgated. Article 89 is the residual services penalty: for a breach of Chapter Three on the accessibility of services for which no other penalty is prescribed, a fine of BGN 1,500 to 10,000 on an individual or a pecuniary sanction of BGN 3,000 to 20,000 on a company, and double those ranges on a repeat offence. Article 87 covers failing to give a competent body information it requested under Article 53, at up to BGN 15,000 on a company and up to BGN 30,000 on a repeat offence. Article 88 covers obstructing a service inspection, at up to BGN 15,000 on a company and up to BGN 30,000 on a repeat offence. Article 73 covers non-compliant products, at a fine of BGN 1,000 to 5,000 on an individual or a pecuniary sanction of BGN 5,000 to 25,000 on a company, rising to BGN 10,000 to 50,000 on a repeat offence. Bulgaria adopted the euro on 1 January 2026 at the fixed rate of BGN 1.95583 to the euro, so BGN 20,000 is about EUR 10,200 and BGN 50,000 about EUR 25,600. Whether the figures in the text have since been formally redenominated could not be confirmed, so treat the euro amounts as conversions. Paragraph 3 of the transitional provisions cut every Chapter Six amount by 50 percent for infringements committed up to 1 June 2026, and that reduction has expired.

Who has to comply in Bulgaria

The law applies to economic operators that place covered products on the Bulgarian market and to providers of covered services to consumers in Bulgaria. Article 2(1) lists the products: general purpose consumer computer hardware and its operating systems, payment terminals, ATMs, ticketing machines and check-in machines used for covered services, interactive information terminals, consumer terminal equipment used for electronic communications and for access to audiovisual media services, and e-readers. Article 2(2) lists the services: electronic communications, access to audiovisual media services, elements of air, bus, rail and waterborne passenger transport, self-service terminals in urban, suburban and regional transport, consumer banking, e-books and dedicated software, and e-commerce services. Micro-enterprises that provide services are exempt under Article 46(3): fewer than 10 staff AND annual turnover or annual balance sheet total of no more than EUR 2 million. The exemption covers services only. A micro-enterprise that deals in products stays in scope, although Article 3(4) frees it from documenting its disproportionate burden assessment. Public sector websites and mobile applications sit under a separate regime in the Закон за електронното управление (Law on electronic governance), which transposes Directive (EU) 2016/2102, and not under this law.

The deadlines that matter

28 June 2022

EU deadline for transposing Directive (EU) 2019/882. Bulgaria did not notify a transposing measure by this date.

11 April 2025

Law on the accessibility requirements for products and services promulgated in Държавен вестник (State Gazette) issue 31

28 June 2025

Law in force. Products placed on the market and services newly provided from this date must comply.

1 June 2026

End of the 50 percent reduction on fines and pecuniary sanctions under paragraph 3 of the transitional provisions

28 June 2027

Paragraph 5 of the transitional provisions takes effect, amending the law on the 112 emergency call system, and the interim arrangement for emergency calls in paragraph 4(4) ends

28 June 2030

End of the transition period for services already provided before 28 June 2025 and for contracts signed before that date

WCAG 2.2 AA, EN 301 549

Prove your Bulgaria compliance

Conforma tests your site against WCAG 2.2 AA and EN 301 549, the working reference for Annex 2 of the Закон за изискванията за достъпност на продукти и услуги. It drafts the accessibility information that Article 50(2) and Annex 5 require a service provider to publish, and it keeps a dated record of what was found and what was fixed, which is the kind of evidence a body under Article 54(1) can request under Article 53(1). Automated testing does not prove compliance on its own. Parts of Annex 2 need manual checks and human judgement.

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Bulgaria EAA questions, answered

When did the EAA start applying in Bulgaria, and is there a transition period?

The Bulgarian law took effect on 28 June 2025, so products placed on the market and services newly provided from that date must comply. Under paragraph 4 of the transitional provisions, service providers may keep using products they lawfully used for similar services before 28 June 2025 until 28 June 2030, and service contracts signed before 28 June 2025 may run out their term, but no later than 28 June 2030. Self-service terminals lawfully in use before 28 June 2025 may stay in service to the end of their economic life, and for no more than 20 years from first use.

Is my small business exempt?

Micro-enterprises that provide services are exempt under Article 46(3): fewer than 10 staff AND annual turnover or annual balance sheet total of no more than EUR 2 million. Both conditions must hold. The exemption applies to services only. A micro-enterprise that manufactures, imports or distributes a covered product is still bound by the product rules, although Article 3(4) frees it from documenting its disproportionate burden assessment.

Which accessibility standard does the Bulgarian law require?

The law names no standard. Articles 6 and 48 give a presumption of conformity to harmonised standards cited in the Official Journal, and Annex 2 lists the accessibility requirements copied from the Directive. No harmonised standard has been cited in the Official Journal under Directive (EU) 2019/882 so far, so the working reference is EN 301 549, which carries the WCAG success criteria. Building to WCAG 2.2 AA is the practical way to meet Annex 2.

Who enforces this and what are the penalties?

Products fall to the Държавна агенция за метрологичен и технически надзор (State Agency for Metrological and Technical Surveillance). Services are split by sector under Article 54(1), with the Комисия за защита на потребителите (Commission for Consumer Protection) handling e-commerce. Article 89 sets the residual services penalty at a fine of BGN 1,500 to 10,000 on an individual or a pecuniary sanction of BGN 3,000 to 20,000 on a company, and double those ranges on a repeat offence. The 50 percent reduction that applied to infringements committed up to 1 June 2026 has expired.

This page is a plain-English summary, not legal advice. Check the cited national law for specifics.

Common fixes to check

Most sites fail the same WCAG checks first. Each guide has a plain-language fix and a before/after snippet you can copy.

WCAG 1.1.1 Images must have alt text Every meaningful image needs alt text so screen-reader users know what it shows. Decorative images get an empty alt attribute so they are skipped. WCAG 1.4.3 Text must have enough color contrast Text needs to contrast with its background so people with low vision can read it. The minimum is 4.5:1 for normal text and 3:1 for large text. WCAG 4.1.2 Form fields must have labels Every input, textarea and select needs an associated label so users know what to enter and screen readers can announce the field. WCAG 4.1.2 Links must have discernible text A link needs text that describes where it goes. An icon-only or empty link is announced as just “link”, so screen-reader users have no idea where it leads.

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See where your site stands in seconds

A free scan against WCAG 2.2 AA, a plain-language fix for every issue, and a Bulgaria-specific accessibility statement when you need one.