Vassilev & Chisuse Law Firm · 2026-10-03
As of 27 September 2026, online stores in Bulgaria must comply with new consumer information requirements affecting product pages and the ordering process. The amendments concern information on guarantees, durability, software updates, repair, spare parts and delivery options, as well as certain information that must be displayed immediately next to the order button.
The new rules are particularly relevant to traders selling goods, goods with digital elements, digital content and digital services. Some of the newly required information must be provided only where the manufacturer or supplier has made that information available to the trader. In those cases, the trader's obligation is to pass the information on to the consumer rather than create it independently.
Compliance with the Bulgarian Consumer Protection Act therefore requires more than a review of an online store's terms and conditions or returns policy. Product pages, guarantee information, software update information, repair information and the content displayed immediately before an order is placed may also need to be reviewed.
From 27 September 2026, the scope of mandatory consumer information has been expanded. The new requirements primarily concern the sale of goods, goods with digital elements, digital content and digital services.
Depending on the type of product and the information supplied by the manufacturer or provider, an online store may be required to provide information concerning the legal guarantee of conformity, a commercial guarantee of durability, the minimum period for free software updates, repairability, spare parts and certain environmentally friendly delivery options.
There is therefore no single generic answer to what information every online store must display. Some requirements depend on the product concerned and on whether specific information has been provided to the trader by the relevant manufacturer or supplier.
For the sale of goods, consumers must receive a visible reminder of the legal guarantee of conformity, including its minimum two-year period. The Consumer Protection Act provides for this information to be given through the harmonised notice under the implementing acts referred to in Article 22a(2) of Directive 2011/83/EU.
An additional requirement applies where the producer provides a commercial guarantee of durability free of charge for a period exceeding two years and has made this information available to the trader. In that case, the trader must indicate the guarantee while also reminding the consumer of the legal guarantee through the relevant harmonised label.
A reminder of the legal guarantee of conformity is also required for digital content and digital services.
Online guarantee information therefore needs to take account both of the legal guarantee of conformity and of certain commercial durability guarantees where the statutory conditions are met.
For goods with digital elements, digital content and digital services, the trader must provide information on the minimum period during which free software updates will be made available where the manufacturer or provider has supplied that information.
This requirement is relevant to online stores selling products whose operation depends on software, as well as digital content and digital services. It does not mean that the trader must independently determine or create information about the period for which updates will be provided. Where the obligation depends on information supplied by the manufacturer or provider, the trader's role is to communicate that information to the consumer.
Where a repairability score is applicable to a product, that score must be provided to the consumer.
Where a repairability score is not applicable but the manufacturer has provided the relevant information, the trader must inform consumers about the availability of spare parts, their expected cost and how they may be ordered, the availability of repair and maintenance instructions and any restrictions on repair.
These requirements have direct implications for online product pages. Where the relevant information is required, it forms part of the information that must be provided before the consumer concludes the contract.
Where environmentally friendly delivery options are available, they form part of the delivery information that must be provided to consumers.
The requirement does not mean that every online trader must create a new delivery method. It concerns the disclosure of environmentally friendly delivery options that are actually available.
Not in every case. Some of the new information obligations apply only where the relevant information has been provided to the trader by the manufacturer or supplier. In those cases, the trader is required to communicate the information to the consumer rather than create it.
This limitation is particularly relevant to commercial guarantees of durability, the minimum period for free software updates and certain information relating to spare parts, repair and maintenance. A compliance review should therefore consider both the types of products sold and the information received by the trader from its manufacturers or suppliers.
For a distance contract concluded electronically that places the consumer under an obligation to pay, specified information must be displayed clearly and prominently immediately next to the order button. This requirement is not new, but the information covered by it was expanded from 27 September 2026.
The information displayed next to the button must include the main characteristics of the goods or services, the total price, the duration of the contract and, for contracts of indeterminate duration or contracts that renew automatically, the conditions for terminating the contract, as well as the minimum duration of the consumer's obligations.
From 27 September 2026, the relevant information under Article 47(1)(12a) concerning the producer's commercial guarantee of durability and the harmonised label is also added to the information displayed at this stage.
For traders selling goods, this means that placing the relevant information only on the product page may not be sufficient. Where the requirement applies, the information must also appear immediately next to the order button.
For distance contracts concluded electronically that place the consumer under an obligation to pay, the button must contain only the words corresponding to “order with obligation to pay” or another equally unambiguous formulation. This requirement has existed since 2014 and was not introduced by the 2026 amendments.
The 2026 change concerns the information that must appear immediately next to the order button. From 27 September 2026, this includes the applicable information concerning the producer's commercial guarantee of durability and the relevant harmonised label.
A checkout compliance review should therefore distinguish between the wording used on the order button itself and the mandatory information displayed immediately next to it.
If the requirements of Article 49(2) of the Bulgarian Consumer Protection Act are not complied with, the consumer is not bound by the contract or order. This consequence is not new and continues to apply following the 2026 amendments.
The information displayed at the final stage of the ordering process should therefore not be treated as a purely formal design requirement. Failure to comply may affect whether the contract or order is binding on the consumer.
Failure to comply with the information obligations under Article 47 of the Consumer Protection Act is subject to a pecuniary sanction of EUR 700 to EUR 3,000 for each individual infringement for sole traders and legal entities.
The underlying analysis also identifies the same sanction range of EUR 700 to EUR 3,000 for each individual case for failure to provide information under Articles 47, 47a, 48 and 49, including information required next to the order button.
In addition to the administrative sanction, non-compliance with the information requirement immediately next to the order button must be considered together with the consequence under Article 49(3) that the consumer is not bound by the contract or order.
Online traders should review whether their product pages contain the applicable new information concerning guarantees, durability, software updates and repair, and whether information received from manufacturers or suppliers is being properly communicated to consumers.
The checkout process should be reviewed separately. Where information concerning a commercial guarantee of durability is applicable, it must also be displayed immediately next to the order button rather than only on the product page.
Online stores selling goods with digital elements, digital content or digital services should also review the information provided about free software updates where such information has been supplied by the manufacturer or provider. For goods covered by the new repair information requirements, the trader should also review the applicable information concerning repairability and spare parts.
The new requirements have applied since 27 September 2026.
Vassilev & Chisuse Law Firm can assist with the legal review of online product pages, guarantee information, software update information, repair and spare parts information, and the information displayed immediately next to the order button.
The review may also cover which of the new requirements apply to particular categories of goods, digital content or digital services and which information must be communicated on the basis of data received from manufacturers or suppliers.
This material reflects the legal framework as of 4 October 2026, is provided for information purposes only and does not constitute individual legal advice.