1. There is a set of challenges, (including new and unforeseen), concerning the development of the energy sector and the energy security, which need to be met adequately from now-a-days perspective with realism. This, however, should not jeopardize the cooperation at regional and EU level aiming at promoting the further liberalization of the market while taking due note of the climate changes. Market liberalization is to save costs and thereby for the benefit of all customers.
  2. There is necessity to continue the efforts for financial stabilization of the energy sector, including its electricity part, and take measures that will not allow the accumulation of new deficits.
  3. Transparency in all aspects of the energy market development is a must. At this stage there is deficiency of market transparency in some aspects, which should be overcome.
  4. Sustainable development of the energy sector can be achieved only by consistent and predictable regulatory framework and proper market monitoring. For this, however, the independence of the Regulator, incl. the financial one and the independence on other state bodies, should be further promoted.
  5. The business strongly supports the active development, transparent functioning and liquidity of the Independent Bulgarian Energy Exchange as a tool towards competitive wholesale electricity market, introducing the relevant trade platforms (day-ahead, bi-lateral and intra-day) and its cooperation with other markets.
  6. There is a vivid necessity for preparation of a long-term strategy for the energy sector.
  7. Improvement of the balancing market to achieve more transparency and competitiveness for efficient and economical electricity system operation. Closest to market production forecast shall be allowed the soonest.
  8. The state needs to further develop and implement policy to address energy poverty through proven institutional measures. However, the energy poverty should be considered rather in the context of the overall income poverty at national level than separately. In this relation, the social functions of the state should be clearly separated from the steps, which need to be undertaken as to develop actively the liberalized energy market; there is a common understanding that market prices guarantee energy security, which is important for everyone. On this ground, the consideration for introducing a “social tariff” is not assumed as appropriate as it contradicts the liberalization approach.
  9. The important role of the implementation of the EU energy efficiency policy is particularly noted.
  10. The business considers that a potential transformation of the “Single Buyer” model and the integration of the long term contracts of the independent electricity producers and the power purchase agreements of the producers, for whom preferential prices are applicable (feed-in tariffs), in the competitive wholesale market must be consensual. In this aspect it is of utmost importance that due note is taken of the legitimate interests of the investors and full preservation of their economic interests. This includes inter alia adequate consideration and respect of the sanctity of contracts’ approach
  11. Careful consideration should be given to the development of adequate mechanisms that ensure the security of electricity supply such as capacity remuneration mechanism (CRM). CRM mechanisms are well known and already implemented in other EU countries and development of a formal capacity market in Bulgaria will be a fundamental enabler of security of supply.
  12. The communication and common work between the state institutions and the business on the implementation of energy market liberalization should continue intensely – the underlined readiness in this aspect on behalf of the state is strongly welcomed. This concerns active engagement of stakeholders from the whole energy sector in energy policy and legislative initiatives formation. On the other side, there is necessity to improve the mechanisms for protection of investors throughout the energy chain, which should be combined with improving the overall investment climate.


The National Energy Chamber and the Energy Management Institute declare their readiness to actively participate in these processes as to support the efforts of the state institutions towards further improvement of the energy market in Bulgaria along the EU trends and rules.