As Bulgaria’s foreign direct investment (FDI) screening regime enters its initial phase of practical implementation, market participants are beginning to assess its implications for transaction structuring, deal timelines, and the broader investment environment.

On 25 March 2026, DGKV, in partnership with the American Chamber of Commerce in Bulgaria (AmCham), hosted a business breakfast focused on the early application of the regime and the emerging insights from practice.

The event brought together representatives of key public institutions, the legal community, and the business sector to examine the operation of the framework following its entry into force in July 2025. Discussions centred on observations from the first transactions already subjected to screening, as well as on the evolving regulatory and institutional approach.

Opening remarks were delivered by Ivan Mihailov, Chief Executive Officer of AmCham Bulgaria, and Omourtag Petkov, Partner at DGKV, member of the Managing Board of Amcham and Co-Chair of AmCham’s Rule of Law and Legislative Reform Committee, who also moderated the discussion.

 

Legal & Regulatory Framework

The first session addressed the structure and scope of Bulgaria’s FDI screening regime.

Valentin Bojilov, Partner at DGKV, outlined the key features of the framework, including its application to non-EU investors and to EU-established entities under non-EU control, as well as its broader reach to certain strategic investments, expansions, and transactions affecting sensitive sectors.

Drawing on DGKV’s involvement in some of the first filings under the regime, Vladislav Antonov, Senior Associate, presented observations from initial cases, with a particular focus on transaction structuring, timing considerations, and risk allocation.

 

Institutional Perspective

The institutional perspective was provided by representatives of the Bulgarian Investment Agency and the Ministry of Innovation and Growth.

Angel Ivanov, Acting Executive Director of the Bulgarian Investment Agency, and Nataliya Kyoseva, Chief Expert at the Agency, addressed the administration’s approach to the screening process, including coordination mechanisms and key aspects of its practical implementation.

Mira Yosifova, Deputy Minister of Innovation and Growth, further outlined institutional priorities and expectations in relation to the effective functioning of the regime.

The panel discussion explored, inter alia, the interpretation of “control”, the scope of notifiable investments, and the interaction with parallel EU screening mechanisms—issues increasingly central to cross-border investment planning. The discussion also highlighted areas where further clarification and practical guidance would support the regime’s effective application.

 

Key Takeaways

Bulgaria’s FDI screening regime—fully operational since 23 July 2025 following amendments to the Regulation for Implementation of the Investments Promotion Act—is already having a tangible impact on investment execution.

Early engagement with the screening requirements, careful transaction planning, and alignment across legal, financial, and strategic considerations were identified as critical in managing the implications of the regime.

The event concluded with an open exchange, underscoring the importance of continued dialogue between public authorities and market participants as the framework continues to evolve in practice.