Bulgaria's public procurement rules (ППЗОП): 2026 analysis

The Public Procurement Act (ЗОП) sets the principles and the framework, but it is the Rules for the Implementation of the Public Procurement Act (ППЗОП) that turn those principles into workable procedures, deadlines and documents. Lawyers in the public sector and compliance specialists know that whether an award is lawful is often decided not at the level of the act but in the detail of the rules.

The latest amendment of the ППЗОП, in State Gazette (ДВ) No. 62 of 23 July 2024, introduced new rules on observers in procedures and reorganised the regime of external ex-ante control by the Public Procurement Agency (АОП). This analysis looks at the status of the rules, their scope by chapter, how they differ from the ЗОП, electronic awarding through the ЦАИС ЕОП (the central e-procurement platform) and the current changes from 2024.

What the ППЗОП is and what its status is

The ППЗОП is a piece of secondary legislation within the meaning of the Normative Acts Act. It was adopted by the Council of Ministers with Decree No. 73 of 5 April 2016 (ПМС № 73), promulgated in the State Gazette (ДВ) No. 28 of 8 April 2016 and has been in force since 15 April 2016, that is, in parallel with the current version of the ЗОП. As an implementing act, the rules cannot contradict the act and cannot regulate matters outside the limits it sets.

It is important to note the current state of both acts. The rules were last amended and supplemented by ДВ No. 62 of 23 July 2024 (the amendment was introduced by Council of Ministers Decree No. 257 of 22 July 2024). The ЗОП itself has undergone later amendments, and its consolidated text ends with ДВ No. 16 of 10 February 2026. Be careful with sources: the pages of individual authorities do not always reflect the most recent amendment of the act.

Subject matter: what the ППЗОП regulates

The scope of the rules is listed exhaustively in Art. 1, items 1-12 of the ППЗОП. It covers the full life cycle of an award: from planning and preparation, through the conduct of the procedures and the design contest, to the content of the participation documents, the manner of submitting and receiving them, the work of the committees and control.

Two of the items in Art. 1 deserve special attention, because they reflect how the regime has developed in recent years. Item 6 introduces electronic awarding, and item 12 (new since 2024) adds observers as a separate subject of regulation.

ЗОП versus ППЗОП: the what and the how

For a practising lawyer the distinction between the two acts is not theoretical but practical. The ЗОП answers the question of what must be complied with: the principles, the parties, the types of procedure and the value thresholds. The ППЗОП answers the question of how: within what deadlines, with what content of the documentation, by what procedure the committees work and how control is exercised.

The practical consequence is that checking whether a procedure is lawful necessarily involves both acts. A contracting authority (възложител) that has formally complied with the act but breached a procedural rule in the regulations (for example on how tenders are received) is exposed to the risk of an appeal and of financial corrections.

Electronic awarding through the ЦАИС ЕОП

Electronic awarding is among the most significant changes in the public procurement regime in recent years. Item 6 of Art. 1 ППЗОП (new, ДВ No. 17/2019) ties the rules to awarding through the centralised electronic platform under Art. 39а(1) ЗОП, the system known as the ЦАИС ЕОП (Centralised Automated Information System “Electronic Public Procurement”).

The ЗОП itself uses the wording “centralised electronic platform”, and the ЦАИС ЕОП is the brand name of the same system. The platform provides for the electronic exchange of documents, the electronic submission of tenders and the publicity of procedures, which ensures transparency, traceability and equal treatment of bidders.

Estimated value, options and renewals

Chapter Two of the ППЗОП, titled “Subject and estimated value of the public contract”, covers Art. 3-7 and sets out in detail how the estimated value is determined. This is a practically critical section, because the estimated value determines the type of procedure that applies and the relevant value thresholds.

Art. 5 ППЗОП regulates options and Art. 6 regulates renewals; both legal figures are based on Art. 21(1) ЗОП (the same paragraph) and must be included in the estimated value. Art. 7 regulates lots (обособени позиции) under the conditions of Art. 21(6) ЗОП. Leaving an option or a renewal out of the estimated value is a common cause of choosing the wrong procedure.

External ex-ante control by the АОП

External ex-ante control is a mechanism by which the АОП checks the lawfulness of certain procedures before they are carried out. Item 10 of Art. 1 ППЗОП (supplemented by ДВ No. 62/2024) expressly includes the exercise of this control and the exchange of information in connection with it in the scope of the rules.

The powers of the executive director of the АОП are regulated in Art. 229(1) ЗОП. Gaps found during ex-ante control can lead to suspension of the procedure, and in later checks to financial corrections on projects financed with EU funds.

The changes from ДВ No. 62/2024: what is new

The amendment and supplement from ДВ No. 62/2024 (in force since 23 July 2024) is the latest significant change to the rules. It introduces three practically important novelties that every contracting authority and bidder should know.

Who the ППЗОП matters to: practical application

The ППЗОП is the benchmark of lawfulness for three categories of stakeholders: contracting authorities (state bodies, municipalities, ministries, bodies governed by public law), bidders (companies, construction firms, suppliers, consortia) and the legal and audit units that review procedures. The practical value of the rules shows precisely when the documentation is prepared: a mistake here leads to exclusion or correction.

Analysing a specific provision often requires comparing the text of the rules with the provision of the act it refers to and checking the amendment markers. This is where Pravko can be useful: as an AI legal assistant that covers all Bulgarian acts, codes, rules and ordinances (including the ППЗОП), Pravko gives answers with citations to specific provisions on lex.bg and can analyse a situation you describe. The database is updated once a month, so for the most recent amendments always check against the primary source.

For the full framework of the act that the rules implement, see also our analysis: Public Procurement Act: full legal analysis.