Bulgaria's Cadastre and Property Register Act (ЗКИР) 2026

Bulgaria's Cadastre and Property Register Act (ЗКИР) 2026

Pravko14 July 202612 min

Analysis of the ЗКИР after ДВ No. 95/2025 (in force 9 February 2026): cadastre, Property Register, the two-way link, cadastral errors, registrations.

The Cadastre and Property Register Act (Закон за кадастъра и имотния регистър, ЗКИР) is the normative backbone of the system for immovable property in Bulgaria, and in November 2025 it was amended and supplemented again by State Gazette (ДВ) No. 95 of 7 November 2025, in force from 9 February 2026. The changes mainly affect the provision of services (Chapter Seven) and the regime under Art. 52, Art. 55 and Art. 56, that is, the digitalisation of administrative services. This article systematises the whole regulation for property lawyers, notaries, registry judges, surveyors and cadastral engineers, carefully distinguishing what is in force from what is new and stressing one frequently underestimated point: a technical error in the cadastre and a substantive dispute over ownership are resolved by two different procedures.

❓What does the Cadastre and Property Register Act regulate?

✅The ЗКИР regulates the organisation, financing, creation, keeping and use of two related systems: the cadastre (data on the location, boundaries and dimensions of properties) and the Property Register (имотен регистър: the files of properties and the registration of deeds of ownership and other property rights). The two systems are tied together by a two-way link through the cadastral identifier.

Source: ЗКИР, Art. 1(1)

Legal framework and structure of the ЗКИР

The Act was promulgated in ДВ No. 34 of 25 April 2000 and has been in force since 1 January 2001, and the version that governs today is the one after the amendments by ДВ No. 95 of 2025. When working with legal databases it is important to cite precisely the current consolidated version: the official publication of the Geodesy, Cartography and Cadastre Agency (Агенция по геодезия, картография и кадастър, АГКК) and the text on lex.bg cross-confirm the same version.

Cadastre and Property Register Act (ЗКИР)

Art. 1(1)

The subject matter of the Act covers the whole life cycle of the two systems. Use includes the provision of services, the regime of which was reworked by ДВ No. 95/2025.

Official Bulgarian text

„Този закон урежда организацията, финансирането, създаването, воденето и ползването на кадастъра и имотния регистър.“

Structurally the ЗКИР is built in five parts: General provisions (Art. 1-9), Cadastre, Property Register, Long-term and annual programme, and Administrative-penal provisions (Art. 96-98). This five-part logic is not an end in itself: it reflects the division between the technical system (the cadastre, kept by the АГКК under the Ministry of Regional Development and Public Works, МРРБ) and the legal system (the Property Register, kept by the Registry Agency under the Minister of Justice).

Cadastre and Property Register: the two systems and the two-way link

The distinction between the two systems is fundamental. The cadastre answers the question of what the property is: its location, boundaries and dimensions. The Property Register answers the question of whose the property is and what burdens it carries. The cadastre contains the basic data under Art. 2(1), as well as additional categories of data under para. 2, including data on property rights and on restriction zones.

Cadastre and Property Register Act (ЗКИР)

Art. 2

Art. 2(1) defines the cadastre as a body of basic data on the location, boundaries and dimensions of immovable properties; para. 2 lists the additional categories of data. The data in the cadastre has evidential value for the circumstances to which it relates, until proved otherwise.

The Property Register, for its part, consists of the files of individual properties, in which deeds of ownership and of other property rights, distraint orders, mortgages and other circumstances subject to registration are entered. The link between the two systems is two-way and works through the cadastral identifier.

Cadastre and Property Register Act (ЗКИР)

Art. 6

Art. 6 regulates the two-way link between the cadastre and the Property Register through the identifier and the exchange of data. The cadastre supplies the basic data on the property, and the Property Register the data on ownership and property rights, with the identifier as the common key.

CriterionCadastreProperty Register
Main questionWhat the property isWhose the property is and what burdens it
ContentLocation, boundaries, dimensions (Art. 2)Files, deeds, property rights, burdens (Art. 3)
Kept byАГКК under the МРРБRegistry Agency under the Ministry of Justice (МП)
Common keyCadastral identifierCadastral identifier
Legal effectEvidence until proved otherwiseRegistration with a publicity and protective effect

Cadastre and Property Register: the functional distinction

Authorities: the АГКК and the Registry Agency

The institutional duality follows the division of the two systems. The cadastre is entrusted to the Geodesy, Cartography and Cadastre Agency (АГКК) under the Minister of Regional Development and Public Works, which acts through the local Geodesy, Cartography and Cadastre Services (СГКК). The Property Register is kept by the Registry Agency (Агенция по вписванията).

Cadastre and Property Register Act (ЗКИР)

Art. 5

Competence over the Property Register lies with the judicial administration, not the cadastral one. This distinction matters for jurisdiction and for the route of appeal.

Official Bulgarian text

„Имотният регистър се води и съхранява от Агенцията по вписванията към министъра на правосъдието.“

A key procedural figure is the registry judge (съдия по вписванията). The judge is not part of the АГКК but acts at the relevant district court and orders the registrations in the files of the properties in their judicial district.

Cadastre and Property Register Act (ЗКИР)

Art. 3(3)

The provision is new with ДВ No. 36 of 2004 and is in force. It designates the registry judge as the authority that orders the registration, which also explains the later procedure for challenging it under Art. 88 ЗКИР.

Official Bulgarian text

„Съдията по вписванията разпорежда вписванията в партидите на недвижимите имоти, които се намират на територията на съответния съдебен район.“
AspectАГКК (cadastre)Registry Agency (Property Register)
MinistryМРРБMinistry of Justice
Local unitsСГККRegistry offices at the district courts
Key figureHead of the СГККRegistry judge
Main actOrder amending the cadastral mapOrder for registration
Route of appealAdministrative court under the АПКChallenge under Art. 537 ГПК

Competent authorities under the ЗКИР

Ask Pravko and get an answer with citations from the law.

Content of the cadastral map and the cadastral identifier

The cadastral map and the cadastral registers give material form to the basic data on properties. Every plot of land, building and separate unit in a building receives a unique cadastral identifier, which serves as the basis of the two-way link with the Property Register. The identifier makes it possible to refer every registered deed unambiguously to the specific property, which in practice removes ambiguity in the description of the property in notary deeds (нотариални актове).

In administrative servicing, licensed cadastral practitioners (правоспособни лица по кадастър) can assist the offices, which was extended by the latest amendments.

Cadastre and Property Register Act (ЗКИР)

Art. 56

Licensed cadastral practitioners, whether traders or self-employed professionals, may assist the СГКК in administrative servicing: accept applications and provide sketches, diagrams and certificates. Under the new para. 3 (2025) they can also submit applications for amendment on the basis of a written power of attorney. The amendment is by ДВ No. 95/2025.

What a lawyer should check in the cadastral extract before a transaction

The cadastral identifier and its match with the description in the deed of ownership

The area, boundaries and permanent land use of the property according to the cadastral map

The buildings and separate units shown on the plot of land

Whether there are restriction zones on the property

The match between the data in the cadastre and the file in the Property Register

Gaps and errors in the cadastre: correction under Art. 51-54

The cadastral map is kept up to date, and the grounds for amending it are set out in Art. 51. They include gaps or errors, a manifest factual error, new or demolished buildings and other changes in the data. The amendments by ДВ No. 95/2025 added to Art. 51 new paragraphs on notification and appeal under the Administrative Procedure Code (АПК).

Cadastre and Property Register Act (ЗКИР)

Art. 51

Art. 51 sets out the grounds for amending the cadastral map: gaps or errors, a manifest factual error, changes brought about by newly built or demolished buildings. With ДВ No. 95/2025 the provision was supplemented with new paragraphs on notification and appeal under the АПК.

Cadastre and Property Register Act (ЗКИР)

Art. 52

Art. 52 regulates the issuing by the СГКК of a draft sketch (скица-проект) or draft diagram (схема-проект) for a property that is not shown, or is shown inaccurately, in the cadastral map. Item 2 has been repealed, and items 3 and 5 were amended by ДВ No. 95/2025 in the context of electronic servicing.

The central provision for correcting a gap or error is Art. 54. This is also where the most common practical mistake is made, so the provision deserves a careful reading. It is important to note that the current Art. 54 does NOT require the consent of the interested persons: that was the regime before the amendment by ДВ No. 57/2016. Today’s procedure is administrative: approval by an order of the head of the СГКК and notification under the АПК.

Cadastre and Property Register Act (ЗКИР)

Art. 54

The correction is made on the basis of written evidence and a draft amendment (para. 1). The amendment is approved by an order of the head of the СГКК, accompanied by a draft sketch, and is notified under the АПК (para. 4); the order is appealed under the АПК before the administrative court for the location of the property (para. 6). Where, however, there is a dispute on a substantive right, the gap or error is removed only after the dispute has been resolved through the courts (para. 2).

Correcting a gap or error under Art. 54 ЗКИР

1

Application and written evidence

The interested person submits an application with written evidence and a draft amendment of the cadastral map under para. 1.

2

Check for a dispute on a substantive right

The СГКК assesses whether there is a dispute on a substantive right. If there is, the amendment waits until the dispute is resolved through the courts (para. 2).

3

Order of the head of the СГКК

If there is no dispute, the amendment is approved by an order of the head of the СГКК, accompanied by a draft sketch (para. 4).

4

Notification under the АПК

The order is notified to the interested persons under the Administrative Procedure Code.

5

Appeal to the administrative court

The order can be appealed under the АПК before the administrative court for the location of the property (para. 6).

A technical error or an ownership dispute: two different procedures

This is the key distinction under Art. 54. A technical error in the cadastre (a mismatch between the map and the actual situation on the ground) is removed administratively by an order of the head of the СГКК. A dispute on a substantive right over the property (who the owner is, how far the boundaries of the right of ownership extend) can NOT be resolved by amending the cadastral map: it is resolved through the courts, and only then is the cadastre brought into line. Mixing up the two situations is a frequent cause of rejected applications and lost time.

The practice on errors in the cadastre and on the boundaries between the administrative route and the court-action route is rich, but it should be checked in each specific case against current case law of the administrative and civil courts, since the situations depend on the facts.

Registrations, challenges and deletion in the Property Register

In the Property Register, a registration has a publicity effect and, in certain cases, protects the person who registered as against third parties. Challenging and correcting registrations follows the procedure of the Civil Procedure Code (ГПК), to which the ЗКИР refers. It is important here to distinguish three different institutions: a challenge, correction of an obvious factual error, and deletion.

Cadastre and Property Register Act (ЗКИР)

Art. 88

Challenging a registration follows the procedure for challenging an act issued in non-contentious proceedings (охранителен акт): where the act affects the rights of third parties, the civil-law dispute is resolved by a court action against those who benefit from the act.

Official Bulgarian text

„Всяко вписване в имотния регистър може да бъде оспорено по реда на чл. 537, ал. 2 и 3 от Гражданския процесуален кодекс.“

Cadastre and Property Register Act (ЗКИР)

Art. 89

An obvious factual error is a technical mismatch in the registration itself, not a dispute on the merits. It is corrected by the registry judge by a ruling under the procedure of Art. 247 ГПК.

Official Bulgarian text

„Очевидна фактическа грешка на вписването в имотния регистър се поправя по реда на чл. 247 от Гражданския процесуален кодекс с определение на съдията по вписванията.“

Cadastre and Property Register Act (ЗКИР)

Art. 90

Deletion is the most serious consequence and presupposes a finding by court action of inadmissibility, invalidity or non-existence. It cannot be achieved administratively.

Official Bulgarian text

„Вписването в имотния регистър се заличава, когато по исков ред се установи недопустимост или недействителност на вписването, както и несъществуване на вписаното обстоятелство.“
InstitutionGroundProcedureCompetent authority
Challenge (Art. 88)Affecting the rights of third partiesArt. 537(2) and (3) ГПК, court actionCourt
Correction of an obvious factual error, ОФГ (Art. 89)Obvious factual errorArt. 247 ГПК, rulingRegistry judge
Deletion (Art. 90)Inadmissibility, invalidity, non-existenceCourt actionCourt

Three institutions for correcting a registration

An obvious factual error is not a dispute on the merits

The distinction between Art. 89 and Art. 90 is of real practical importance. An obvious factual error (for example a technical inaccuracy when data was transferred) is corrected quickly by the registry judge under Art. 247 ГПК. If, however, it is claimed that the registration itself is invalid or that the registered circumstance does not exist, the route is a court action and ends with deletion under Art. 90. Choosing the wrong institution makes the request inadmissible.

The changes by ДВ No. 95/2025 and the administrative-penal provisions

The amendments by ДВ No. 95 of 7 November 2025 (in force from 9 February 2026) are concentrated on the digitalisation of administrative servicing. They affect Chapter Seven on the provision of services, as well as Art. 52, Art. 55 and Art. 56. The emphasis is on electronic documents and electronic identification.

Cadastre and Property Register Act (ЗКИР)

Art. 55

Art. 55 (completely reworked by ДВ No. 95/2025) regulates the provision by the АГКК of administrative services through electronic documents, the making of amendments and electronic identification under the e-Governance Act (Закон за електронното управление). The electronic document contains an access code and a number, which makes it possible to verify its authenticity.

Scope of the amendment by ДВ No. 95/2025

The changes by ДВ No. 95/2025 concern the provision of services (Chapter Seven) and Art. 52, Art. 55 and Art. 56. They do not rewrite the substantive regime of the cadastre and of registrations. When relying on a specific provision, check the current consolidated version as at the date of the relevant act, since some of the new paragraphs enter into force only on 9 February 2026.

The administrative-penal provisions are in Art. 96-98. Fines are provided for natural persons, and pecuniary sanctions for legal entities and sole traders. Violations are established by an act of an official.

Cadastre and Property Register Act (ЗКИР)

Art. 98

The penalty decree (наказателно постановление) is issued by the relevant minister, and the proceedings follow the procedure of the Administrative Violations and Sanctions Act (Закон за административните нарушения и наказания, ЗАНН).

Official Bulgarian text

„Нарушението се установява с акт на длъжностно лице, определено от министъра на регионалното развитие и благоустройството, съответно от министъра на правосъдието.“

100 - 5000 BGN

Fines for natural persons and officials under Art. 96 (in leva, per the consolidated text)

1000 - 10,000 BGN

Pecuniary sanctions for legal entities and sole traders under Art. 96 and Art. 97 (in leva, per the consolidated text)

Penalty amounts: dual denomination from 1 January 2026

The amounts of the fines and pecuniary sanctions under Art. 96-98 appear in the АГКК’s consolidated text in leva, and were last amended by ДВ No. 49/2014; the amendment by No. 95/2025 does not change them. From 1 January 2026, however, by virtue of the Euro Introduction Act (Закон за въвеждане на еврото), the sums apply denominated in euro at the fixed rate of 1.95583 leva to 1 euro, even though the published text still writes them in leva. When relying on a specific amount, check the current version and the applicable denomination as at the date of the violation.

Practical conclusions for the lawyer

Working with the ЗКИР requires constantly keeping in mind the two distinctions that follow from the architecture of the Act itself: the cadastre versus the Property Register as two systems, and the administrative route versus the court-action route for corrections. A technical error in the cadastre is removed by an order of the head of the СГКК and appealed before the administrative court, whereas a dispute over ownership and the invalidity of a registration go through the courts by court action. For the property-law context of the deeds that are entered in the Property Register, our analysis of the Property Act is also useful, and for practical lookups, the user guides on a Property Register extract, a free property check in the cadastre and ordering a cadastral sketch.

For quick orientation in the current version and structure of the Act you can use the official publication of the АГКК, the full text on lex.bg, the Cadastral and Administrative Information System КАИС and the portal of the Registry Agency.

Legal information, not legal advice

Pravko provides legal information but does not replace consultation with a lawyer. For a specific case on applying the ЗКИР, correcting an error in the cadastre or challenging a registration, consult a licensed lawyer.

⚠️ Important

Pravko provides legal information, but it does not replace advice from a lawyer. For important legal matters, consult a licensed lawyer.

#ЗКИР#cadastre Bulgaria#Property Register#АГКК#Registry Agency#registrations#cadastral errors#Bulgarian property law

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