Vassilev & Chisuse Law Firm · 2026-10-06
As of 24 September 2026, the Bulgarian Consumer Protection Act provides the Consumer Protection Commission with a new accelerated mechanism for certain infringements involving sales through online marketplaces. Where the statutory conditions are met, the procedure may ultimately result in access to specific webpages being blocked.
The new regime is particularly important for traders selling through online platforms and marketplaces. It applies where the trader has failed to provide required identification and contact information, has supplied false or incomplete information, or cannot be contacted by the Consumer Protection Commission through the communication channels provided.
The rules are also relevant to online marketplace operators because the measure may affect webpages located within their interfaces. The short statutory deadlines and the special notification mechanism make accurate trader information and functioning communication channels particularly important.
The Chairperson of the Bulgarian Consumer Protection Commission may issue an order requiring an infringement to cease in three principal situations concerning trader information on an online marketplace.
The first applies where the trader has failed to provide the online marketplace with the information required under Article 47(1)(2)-(4) of the Consumer Protection Act. This includes information identifying the trader, its registered office and management address, telephone number, email address and address for consumer complaints.
The second situation is where the information provided is false or incomplete.
The third applies where an official of the Consumer Protection Commission is unable to contact the trader through any of the communication methods supplied on more than three occasions within ten working days.
These grounds specifically concern the trader's identity and contact details. The underlying analysis notes that some media reports described the new mechanism as relating to payment, delivery and withdrawal information, whereas the enacted wording of Article 47b concerns identification and contact information under Article 47(1)(2)-(4).
A trader selling through an online marketplace must provide the required identification and contact information. For the purposes of the new mechanism under Article 47b, the relevant information includes the trader's identity, registered office and management address, telephone number, email address and address for complaints.
It is not sufficient for this information merely to appear in the trader's profile. It must be complete and accurate, and the communication channels provided should actually allow the trader to be contacted.
This is particularly relevant to traders operating multiple seller accounts or using more than one marketplace. Information displayed through each relevant online interface should remain current and usable for effective communication.
Yes. The Act expressly provides a ground for action where an official of the Consumer Protection Commission cannot establish contact with the trader through any of the communication methods supplied on more than three occasions within ten working days.
A telephone number or email address that formally appears in the trader's profile but is not actually monitored may therefore be relevant to the application of Article 47b.
The underlying analysis identifies maintaining complete and accurate information and genuinely monitored communication channels as an important practical measure for traders.
The order requiring the infringement to cease is published on the website of the Consumer Protection Commission on the day it is issued. The persons concerned are deemed to have been notified on the day of publication.
The legislation does not provide for separate individual notification.
From the date of publication, the persons concerned are required to remedy the infringement.
This method of notification is significant because the statutory deadlines become relevant regardless of whether the trader has actually seen the publication.
If the infringement is not discontinued within three days after publication of the order, the Consumer Protection Commission may proceed to the next stage of the procedure.
The three-day deadline makes a rapid response important. Because of both the short deadline and notification by publication, the underlying analysis recommends regularly monitoring the website of the Consumer Protection Commission.
No. The legislation provides for a procedure under which the Consumer Protection Commission applies to the Chairperson of the Sofia District Court for an order requiring access to the relevant webpages to be blocked if the infringement has not been discontinued within the three-day period.
The technical blocking of access is therefore not carried out unilaterally by the Consumer Protection Commission.
Where the statutory conditions are met, the Commission submits an application to the Chairperson of the Sofia District Court. The court may order undertakings providing public electronic communications networks and/or services to block access to the webpages identified in the Commission's order.
This distinction is important when describing the Commission's new powers. The Commission initiates the statutory mechanism, while blocking follows the judicial order provided for under Article 47b.
After the Consumer Protection Commission refers the matter to the court, the Chairperson of the Sofia District Court must rule within 72 hours.
Following publication of the court order, undertakings providing public electronic communications networks and/or services must block access within 24 hours.
The legislation therefore creates an accelerated procedure: the trader has three days following publication of the Commission's order to discontinue the infringement, the court rules within 72 hours, and the relevant providers must block access within 24 hours after publication of the court order.
The Commission's order is immediately enforceable irrespective of whether it has been appealed.
This rule increases the practical importance of the short deadlines in the procedure. Challenging the order does not in itself mean that its enforcement is automatically suspended.
Yes. The same procedure applies where goods or services prohibited by legislation falling within the Consumer Protection Commission's supervisory powers are offered through an online marketplace. This follows from Article 47c of the Consumer Protection Act.
The mechanism is therefore not limited to false or incomplete trader information or inability to contact the trader. It also applies to the offering of prohibited goods or services through an online marketplace in the circumstances specified by the Act.
Yes. Although the obligations under Article 47b concern traders, the mechanism also has direct practical significance for marketplace operators because it can affect webpages located within their interfaces.
The underlying analysis states that traders should maintain complete and accurate identification and contact details and genuinely monitored communication channels, while platforms should verify trader information.
The new regime is therefore relevant both to individual online sellers and to operators of marketplaces through which those sellers conduct business.
Traders using online marketplaces should review whether the information concerning their identity, registered office, management address and contact details is complete and accurate.
They should also verify that the telephone numbers, email addresses and other communication channels provided are actually monitored so that the Consumer Protection Commission can establish contact if necessary.
Monitoring publications on the Commission's website is also important. Because notification occurs through publication and the period for remedying an infringement is only three days, the underlying analysis recommends checking the Commission's website regularly.
The new mechanism has applied since 24 September 2026.
The principal risk under the new regime extends beyond the finding of an infringement. If the Commission's order is not complied with within the statutory three-day period, the procedure may continue to a court order blocking access to the relevant webpages.
The sanctions summary in the underlying analysis identifies incomplete or false trader information on an online marketplace, inability to contact the trader and prohibited goods and services as grounds for a coercive measure that may result in access to webpages being blocked.
Trader information displayed on a marketplace should therefore not be treated as a purely administrative formality. Under the statutory conditions, it forms part of a mechanism capable of directly affecting access to the relevant webpage.
Vassilev & Chisuse Law Firm can assist with the legal review of information provided by traders selling through online marketplaces, including identification and contact details and their compliance with the Bulgarian Consumer Protection Act.
Legal assistance may also include analysis of the applicability of the coercive measures under Articles 47b and 47c, as well as matters relating to an order requiring an infringement to cease and the subsequent procedure for blocking access to webpages.
This material reflects the legal framework as of 7 October 2026, is provided for information purposes only and does not constitute individual legal advice.