Overall assessment

Updated December 2023

Amendments to the Law on Energy from Renewable Sources were finalised in October 2023. Thes amendments lay out requirements for the development of an enabling framework for both RECs and CECs, although most of these provisions simply replicate EU rules. As such, a national legal basis for an enabling framework for RECs exists, but concrete policies and measures to realise this framework still need to be put in place. Interestingly, the enabling framework for CECs is identical to that of RECs, which goes beyond the requirements of the Electricity Directive. This will allow for a coherent enabling framework to be created for both RECs and CECs together. The Ministry of Energy, involving other relevant Ministers has been given the duty to propose how to remove existing barriers based on an assessment of existing barriers and potential for the development of RECs prepared by AUER (SEDA, Sustainable Energy Development Agency). This assessment was already conducted, and proposals by the Ministry are in planned for the first half of 2024.

Detailed assessment

Assessment of obstacles and potential for development of ECs

The executive director of AUER (SEDA, Sustainable Energy Development Agency) prepares an assessment of the existing obstacles and the potential for the development of RECs.

Removal of unjustified regulatory & administrative barriers

Under the Law on Energy from Renewable Sources, the development of RECs and CECs is promoted through the removal of unreasonable regulatory and administrative obstacles. The Ministry plans to bring forward proposals in the first half of 2024.

Regarding obtaining a grid connection, a permit should be provided no longer than two years from the submission of the request. For production facilities with a total installed capacity of up to 150 kW, as well as in the case of reconstruction or modernization, this term is no longer than one year. This provision is not specific to energy communities.

DSO duties around cooperation with ECs and facilitation of energy sharing

Under the Law on Renewable Energy Sources, the relevant distribution network operator (electricity) and heat transfer company should ensure cooperation so RECs so they may transfer energy. However, there are no detailed provision on how to ensure DSOs cooperate. At the moment, national stakeholders report that DSOs are hesitant to install digital meters to allow virtual net metering.

Fair, proportionate, and transparent registration & licensing procedures

CECs and RECs must comply with the conditions defined in the Energy Act when selling energy and providing other energy services. The competent authorities are required to apply fair, proportionate and transparent administrative procedures, including registration and licensing. However, there are no detailed provisions on how to ensure regulations are applied proportionately to RECs or CECs.

Incentives connected to network tariffs based on a CBA

Competent authorities must ensure that regulated prices for network services are applied to all network users, which should contribute in an adequate, fair and balanced way to the distribution of total costs for the system in accordance with a transparent analysis of the costs and benefits of the distributed energy resources. However, no such analysis has been undertaken as of yet.

Non-discriminatory treatment as market participant

Under the Law on Renewable Energy Sources, the development of RECs and CECs is promoted through the application of non-discriminatory treatment to communities in relation to their activities, rights and obligations as end users, producers, suppliers, distribution system operators or as other market participants. However, there are no detailed provision on how to ensure non-discrimination of RECs and CECs.

Accessibility to low-income & vulnerable households

Under the Law on Renewable Energy Sources, the development of RECs and CECs is promoted through providing accessibility for all users to participate in communities, including low-income households or vulnerable clients However, there are no policies or measures to promote inclusiveness or to target low-income or vulnerable households.

Tools to access finance

Under the Law on Renewable Energy Sources, the development of RECs and CECs is promoted through facilitating access to financing. However, Bulgaria has not applied for EU funding regarding energy communities and there are currently no plans for how to provide RECs or CECs with access to financing.

Tools to access information

Under the Law on Renewable Energy Sources, the development of RECs and CECs is promoted through facilitating access to information. It will be mandatory for all municipalities to provide on-stop-shops under the Law, which will serve as local administrative and info centers. However, there are currently no measures being proposed to ensure that local authorities will the resources (financial, human) to meet this obligation. AUER(SEDA) also aims to prepare guidance for citizens and investors on how to start renewables projects.

Regulatory capacity building for public authorities

Under the Law on Renewable Energy Sources, the development of RECs and CECs is promoted through providing regulatory support and assistance to build the capacity of public authorities in facilitating and creating renewable energy communities and in facilitating their direct participation. However, as mentioned above, one-stop shops must be set up by municipalities but without any dedicated support so far.

NECP reporting on enabling frameworks

Under the Law on Renewable Energy Sources, information on the incentives provided for RECs and CECs is presented with reports on the progress and updating of the Integrated Plan in the field of energy and climate of the Republic of Bulgaria in accordance with Regulation (EU) 2018/1999.

Support Scheme adapted for RECs

There are no provisions addressing energy communities in the context of accessing support schemes. However, an assessment of the effectiveness of support schemes for renewable electricity and its impact on different user groups and on investments must be prepared. It will be important to ensure that energy communities are one of the groups considered in this assessment.