Bulgaria
(a) What is the NIS2 implementation status?
The bill of amendment to the Cybersecurity Act transposing NIS2 has been promulgated in the State Gazette on 13 February 2026 and has entered into force on 17 February 2026.
(b) What is the envisaged NIS2 implementation timeline?
The amendments to the Bulgarian Cybersecurity Act implementing NIS 2 are currently in force.
(c) What does the NIS2 mean for other national cybersecurity legislation?
The Bulgarian Cybersecurity Act, as amended, provide for adoption of new underlying legislation on its application. Drafts of the new underlying legislation have not been published to date.
(d) Who will be the supervisory authority and how are they preparing the market?
The primary supervisory authority remains the Ministry of e-Government but cybersecurity compliance will be also monitored by an expanded list of authorities competent in the public sectors, including among others, national security, transport and health.
(e) What should you be doing/on the lookout for?
Clients must conduct internal analysis on their business activities to identify whether they can be classified as “essential” or “important” entities under the amended Cybersecurity Act and, accordingly, determine whether they fulfil their obligations under the Cybersecurity Act, as amended. Clients should be also aware of the increased amount of the administrative sanctions reaching the higher of EUR 10,000,000 or 2% of the total worldwide annual turnover for the entities classified as “essential” and EUR 7,000,000 or 1.4% of the total worldwide annual turnover for the entities classified as “important”.
Contact
Victoria Marincheva E: victoria.marincheva@eversheds-sutherland.bg
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