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BULGARIA COVID-19 TRACKER (last updated at 18:00 on 15 April 2020) Key legal measures affecting business in relation to COVID-19 in Bulgaria GENERAL MEASURES ....................................................................................................................................................................................................2 RETAIL, SERVICES, TRAVEL, LEISURE AND HOSPITALITY ...........................................................................................................................10 TRANSPORT ....................................................................................................................................................................................................................13 EMPLOYMENT................................................................................................................................................................................................................18 TAX AND ACCOUNTING ..............................................................................................................................................................................................21 PHARMACEUTICALS ....................................................................................................................................................................................................27 JUDICIAL, ADMINISTRATIVE AND ENFORCEMENT PROCEEDINGS............................................................................................................29 PUBLIC PROCUREMENTS AND STATE GRANTS ..................................................................................................................................................33 MISCELLANEOUS ..........................................................................................................................................................................................................36

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Page 1: BULGARIA COVID-19 TRACKER (last updated at …...2020/04/15  · BULGARIA COVID-19 TRACKER (last updated at 18:00 on 15 April 2020) Key legal measures affecting business in relation

BULGARIA COVID-19 TRACKER (last updated at 18:00 on 15 April 2020)

Key legal measures affecting business in relation to COVID-19 in Bulgaria

GENERAL MEASURES .................................................................................................................................................................................................... 2

RETAIL, SERVICES, TRAVEL, LEISURE AND HOSPITALITY ........................................................................................................................... 10

TRANSPORT .................................................................................................................................................................................................................... 13

EMPLOYMENT................................................................................................................................................................................................................ 18

TAX AND ACCOUNTING .............................................................................................................................................................................................. 21

PHARMACEUTICALS .................................................................................................................................................................................................... 27

JUDICIAL, ADMINISTRATIVE AND ENFORCEMENT PROCEEDINGS............................................................................................................ 29

PUBLIC PROCUREMENTS AND STATE GRANTS .................................................................................................................................................. 33

MISCELLANEOUS .......................................................................................................................................................................................................... 36

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Page 2 of 37

No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

GENERAL MEASURES

1. [Supplemented] General

social distancing

measures1

Order No. РД-01-124 dated

13 March 2020 issued by the

Minister of Health

Order No. РД-01-131 dated

17 March 2020 issued by the

Minister of Health

Order No. РД-01-139 dated

19 March 2020 issued by the

Minister of Health

Order No. РД-01-143 dated

20 March 2020 issued by the

Minister of Health

Order No. РД-01-144 dated

22 March 2020 issued by the

Minister of Health

Order No. РД-01-154 dated

26 March 2020 issued by the

Minister of Health

Order No. РД-01-195 dated

On 13 March 2020, Bulgaria declared a state of

emergency for one month until 13 April 2020. The

state of emergency and the general social distancing

measures wеre further extended until 13 May 2020.

The following general restrictions were introduced:

• Business suspension measures [see below].

• All educational activities, including

extracurricular activities (excursions, study

halls, educational gatherings, etc.) are

suspended in schools, universities2 and other

educational institutions and organizations,

including kindergartens and nurseries.

• Any social events, including sports activities,

cultural events (cinemas, theaters, museums,

conferences, symposiums, sports and SPA

centers, gymnasiums, etc.) are suspended.

• Visits to parks, city gardens, sports and

children playgrounds are suspended (effective

00:00 on 21 March 2020).

Effective 13 March 2020.

Amendment effective 17

March 2020.

Amendment effective 19

March 2020.

Amendment effective

00:00 on 21 March 2020.

Amendment effective 22

March 2020.

Amendment effective 26

March 2020.

Amendment effective 10

April 2020.

Amendment effective 11

April 2020.

1 Under the State of Emergency Act, the Minister of Health will be entitled to introduce subsequent temporary anti-epidemic measures, including suspension of work

of public use facilities and mobility restrictions. 2 Except for specific classes related to the state of emergency that are held at the Academy of the Ministry of Interior (effective 2 April 2020).

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

10 April 2020 issued by the

Minister of Health

Order No. РД-01-197 dated

11 April 2020 issued by the

Minister of Health

• Wearing of protective masks or other face

coverings is mandatory in open and closed

public places, e.g. public transport, parks,

churches, bus stations, etc. (effective 12 April

2020 until 26 April 2020).

Persons below 60 years of age are barred

from visiting food stores and pharmacies

between 8:30 and 10:30 a.m. (effective 00:00

on 21 March 2020).

Persons in contact with those infected with

COVID-19 are placed under mandatory

quarantine for 14 days and are not allowed to

leave their homes. [See exception in item 67

below]

National Information System against spread

of COVID-19 is launched by the Ministry of

Health. The system aims at receiving

information on the health status of the

population. (effective 6 April 2020)

2. Mobility restrictions for

regional centers

Order No. РД-01-143 dated

20 March 2020 issued by the

Minister of Health

Order No. РД-01-153 dated

25 March 2020 issued by the

Minister of Health

Order No. РД-01-167 dated

Checkpoints are to be set up at the entry and exit

points of each of the 27 regional centers of Bulgaria

(including Sofia) and of the town of Bansko. Travel

through the checkpoints is only allowed for urgent

reasons, related to (i) work in the relevant settlement,

(ii) health reasons of the traveler or his/her close

relatives, оr when taking care of them, (iii) buying

essential supplies from food stores and pharmacies

Effective 00:00 on 21

March 2020.

Amendment effective 25

March 2020.

Amendment effective 30

March 2020.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

30 March 2020 issued by the

Minister of Health

Order No. РД-01-196 dated

10 April 2020 issued by the

Minister of Health

where not otherwise available at the place of current

or permanent residence, (iv) return to the place of

current or permanent residence, or to another

temporary address, if different. Depending on the

reasons, the travel must be evidenced by: (i) office

certificate (служебна бележка), office pass; (ii)

medical document; (iii) personal ID document or (iv)

a form declaration for the reason necessary for the

travel.3. A copy of the declaration (if requested) must

be kept by the authorities every time the person

passes through the checkpoints.

Truck drivers and drivers of cash collection vehicles

(инкасо автомобили) can provide only personal ID

documents and the office certificate or the working

identification card. Specific rules also apply to

passage of agricultural workers through the

checkpoints (Effective 10 April 2020).

Some employees or suppliers, e.g., of food and

medicinal products, employees of electricity and

water utility providers, etc., have priority when

traveling through the checkpoints

Amendment effective 10

April 2020.

3. Entry ban for arriving

passengers from high-risk

countries

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

Non-Bulgarian nationals, arriving from Italy, Spain,

France, the UK and Northern Ireland, Germany,

the Netherlands, Switzerland, Austria, Belgium,

Iceland, Lichtenstein, Luxembourg are to be

Effective 6 April 2020

3 The Bulgarian Ministry of the Interior published on its website a form of the declaration. The form is available here.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

refused entry into Bulgaria.

Exceptions:

- Bulgarian nationals, foreign nationals with

permanent, temporary or long-term residence

in Bulgaria, and members of their families.

- Medical staff, medical investigators, and

geriatric care specialists.

- Transport personnel engaged in the

transportation of goods, aircraft crew

members engaged in air transport and other

transport personnel, as necessary.

- Diplomatic staff, foreign officials (Heads of

States, members of governments) and

members of their delegations, staff of

international organizations, military and

humanitarian personnel, in performance of

their duties.

- Persons travelling for humanitarian reasons.

- Third country nationals, EU and Schengen

nationals (including nationals of San Marino,

Andorra, Monaco and the Vatican) directly

engaged in the construction, maintenance and

safety of strategic and critical infrastructure

of Bulgaria.

- Border workers and agricultural workers.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

[See general ban for entry for non-EU and non-

Schengen nationals below]

[See exceptions for truck drivers below]

4. Quarantine4 for all

arriving passengers

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

All passengers not included in the entry ban (see 3

above)5, arriving from abroad (regardless of

whether a COVID-19 case has been registered in

that country or not), are to be placed under

mandatory quarantine for 14 days.6 The arriving

passengers must inform border health authorities

about the address where they will be quarantined.7

[See exceptions for truck drivers below]

Effective 6 April 2020

5. General ban for entry of

all non-EU and non-

Schengen nationals

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

The entry of all non-EU and non-Schengen nationals

into the territory of Bulgaria is prohibited through all

border checkpoints regardless of the type of transport

– air, maritime, railway or road transport.

The exceptions for arriving passengers from high-risk

countries also apply to non-EU and non-Schengen

Effective 6 April 2020

4 Аccording to Order No. РД-01-217 dated 14 April 2020 issued by the Minister of Health the village of Panicherevo, Gurkovo Municipality, Stara Zagora Region, is

fully quarantined for 14 days. Entry to the village of persons having permanent or temporary residence in Panicherevo is permitted until 20:00 on 15 April. All

persons located in the village are quarantined for 14 days and cannot leave their homes except to buy food or medicinal products, or to use the services of banks, or to

seek medical help. Exceptions apply to certain medical, police, fire department, and other essential services personnel. Extensive restrictions to commercial activities

apply. The measure enters into force on 00:00 on 15 April 2020. 5 The categories of medical staff, diplomatic staff and foreign officials, transport personnel, in item 3 above, are exempted from this mandatory quarantine. 6 Art. 355, Para. 2 of the Criminal Code, provides imprisonment of until five years and a fine of BGN 10,000 to BGN 50,000 for failure to observe quarantine. 7 GUIDE/RULE/INSTRUCTION/PRECEPT FOR PLACEMENT UNDER A QUARANTINE is handed to all arriving passengers by the border health authorities.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

nationals.

[See full list of the exceptions in item 3 above]

[For transit through the country see item 6 below]

6. Transit through Bulgaria

to the country of residence

or establishment

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

Transit is permitted only in cases when the immediate

departure from the country is guaranteed. Foreign

nationals, for whom transit is allowed (see below),

must notify their respective diplomatic or consular

mission in Bulgaria in advance, in order for the

specific transit route to be set by the Bulgarian

authorities.

Transit through the Bulgarian territory to the country

of residence or establishment is allowed to the

following persons:

- EU and Schengen nationals (including

nationals of San Marino, Andorra, Monaco

and the Vatican) and members of their

families.

- Third country nationals having long-term

residence in an EU or Schengen Member

State (including in San Marino, Andorra,

Monaco and the Vatican) and members of

their families.

- Nationals of Serbia, the Republic of Northern

Macedonia, Montenegro and Turkey.

Effective 6 April 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

- Transport personnel engaged in the

transportation of goods, aircraft crew

members engaged in air transport and other

transport personnel, as necessary.8

[See specific rules in Transport section below]

7. General suspension of the

effects of default on

payments based on

financial agreements by

private persons and

entities

State of Emergency Act Until the end of the state of emergency, the effects of

default on payments based on financial agreements,

e.g. loans, leases, etc., of private persons and entities,

are suspended.9 The payments affected by the

suspension can be owed to financial institutions

(banks, lease companies, etc.) or to third parties in

case of assignment of the receivable. Suspension of

the effects of default on payments includes the

accrual of interest and penalties for delay,

acceleration, and the right to rescind a contract and

repossess assets.

[See item 8 for more information]

Effective 24 March 2020,

retroactively from 13

March 2020

Amendment effective 9

April 2020

8. [New] Terms and

procedures of payment

moratorium on financial

loans provided by banks

Decision dated 10 April 2020

adopted by the Bulgarian

National Bank (“BNB”)

In compliance with the Guidelines on legislative and

non-legislative moratoria on loan repayments applied

in the light of the COVID-19 crisis of the European

Banking Authority (“EBA”), the BNB adopted

respective local directions on terms and procedures of

Effective 10 April 2020

8 This category of foreigners who are allowed transit through the country, are exempted from the obligation to notify their respective diplomatic or consular mission

in advance. 9 For the period from 13 March 2020 until 8 April 2020, the general suspension of the effects of default on payments applies to all delayed payments of private

persons and entities regardless of the type of the obligations, i.e., it is not necessary for them to be based on financial agreements for this period.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

payment moratorium on financial loans provided by

banks and their subsidiaries. The directions include

various mechanisms of reliefs for the borrowers, e.g.,

temporarily postponement of capital and/or interest

payments on the loan without further amending the

terms and conditions. Eligibility criteria in respect of

the borrowers apply.

9. Extension of payment

periods

State of Emergency Act The periods for payment of electricity bills by

household customers are extended from 10 to 20 days

and may be extended further by the Minister of

Energy.

Effective 24 March 2020,

retroactively from 13

March 2020

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Page 10 of 37

No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

RETAIL, SERVICES, TRAVEL, LEISURE AND HOSPITALITY

10. Closing of public access to

non-essential retail outlets

and services

Order No. РД-01-124 dated

13 March 2020 issued by the

Minister of Health

Order No. РД-01-144 dated

22 March 2020 issued by the

Minister of Health

Order No. РД-01-154 dated

26 March 2020 issued by the

Minister of Health

Order No. РД-01-179 dated 6

April 2020 issued by the

Minister of Health

Order No. РД-01-195 dated

10 April 2020 issued by the

Minister of Health

Order No. РД-01-199 dated

11 April 2020 issued by the

Minister of Health

Order No. РД-01-218 dated

15 April 2020 issued by the

Minister of Health

Visits to all casinos and entertainment halls, bars,

discos, restaurants, fast food restaurants, cafés,

commercial centers (i.e., Malls), except for bank and

payment service providers offices, insurance offices,

grocery stores and pharmacies on their territory, are

suspended until 13 May 2020.

Fast food outlets and food stores in the territories of

gas stations should not allow consumption on the

spot. (Effective 22 March 2020)

The work of cooperative and flower markets will be

suspended from 17 April 2020 until 19 April 2020.

Separate food stores and pharmacies on the territory

of the markets are allowed to remain open. (Effective

15 April 2020).

Takeaway services are not affected.

Online retail is not affected.

Farmers’ markets are allowed to be open observing

strict sanitary requirements introduced by the local

municipalities. (Effective 6 April 2020)

All other retail trade and services are not affected,

except as stated below, but must continue under strict

sanitary requirements.

Effective 13 March 2020.

Amended 22 March

2020.

Amendment effective 26

March 2020.

Amendment effective 6

April 2020.

Amendment effective 10

April 2020.

Amendment effective 11

April 2020.

Amendment effective 15

April 2020.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

11. Sanitary requirements for

retail outlets which

remain in operation

Order No. РД-01-139 dated

19 March 2020 issued by the

Minister of Health

All retail outlets, the operation of which is not

suspended by the prohibition above, should operate

so as to ensure that not more than two adults above

the age of 60 are located in their premises and the

adjacent open areas at the same time, and should

instruct patrons to keep a distance of at least 1-1.5 m.

[See also prohibition for shoppers below the age of

60 in food stores and pharmacies between 8:30 and

10:30 a.m. in item 1 above.]

Effective 19 March 2020

12. [Expected] Obligation for

food retail chains10 to offer

Bulgarian products from

local agriculture

producers

Decree No. 70 dated 14 April

2020 on providing of main

group of foods in food retail

chains produced on the

territory of Bulgaria

According to draft Decree No. 70 dated 14 April

2020 on providing in food retail chains of the main

group of foods produced in the territory of Bulgaria11,

retailers having food stores in more than three

administrative regions in the country will be obliged

to offer and to allocate specific store locations for

Bulgarian products from local agriculture producers

within their stores, e.g. milk and dairy products,

honey, some fruit and vegetables12, etc.

[expected to come into

force on 21 April 2020]

13. Suspension of all tourism

visits

Order No. T-РД-16-76 dated

17 March 2020 issued by the

Minister of Tourism

All tourism visits and ancillary tourism services in

Bulgaria of persons having permanent residence in

the country and foreigners are suspended. Organized

tourism travels abroad and the related travel

Effective 17 March until

13 May 2020

10 Based on official announcement of the Minister Agriculture, Food and Forestry, the obligation refers to chains having at least 10 food stores on the territory of the

country. 11 The final wording of the draft Decree is not published yet. 12 Local producers of fruit and vegetables can be further supported by means of short-term loans granted by the State Fund Agriculture.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

Order No. T-РД-16-120

dated 10 April 2020 issued

by the Minister of Tourism

arrangements are also suspended. Based on an

unofficial statement by the Ministry of Tourism, the

hotels within the country should not accommodate

visitors.

14. Refund offered by the

companies providing

tourism services for

cancelled travel

State of Emergency Act Companies providing tourism services (tour

operators) can offer a voucher instead of refunding

the amount paid for cancelled travel. If the traveler

does not accept the voucher, the tour operator must

refund the amount within one month as of the end of

the state of emergency.

Effective 9 April 2020

15. Exemption from rental

payments to public

authorities

State of Emergency Act The respective authority, in its capacity as a lessor, is

entitled to reduce the rental price or to exempt from

the entire rental price, or part of it, the lessees, whose

work was suspended or restricted due to the state of

emergency.

Effective 9 April 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

TRANSPORT13

16. Measures for Bulgarian

truck drivers arriving

from countries where a

case of COVID-19 has

been registered

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

Bulgarian nationals – truck drivers, arriving from

countries where a COVID-19 case has been

registered, must remain quarantined at home for 14

days. During this period, truck drivers are allowed to

go through the country, load and unload goods, drive

the truck and leave the country before expiry of the

period of the quarantine.

[For the truck drivers passing through the country,

see item 17 below]

Effective 6 April 2020

17. Measures for foreign

truck drivers – third

country nationals or

arriving from high-risk

countries

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

Non-Bulgarian nationals – truck drivers, who are

third country nationals, or arriving from, or have

passed through Italy, Spain, France, the UK and

Northern Ireland, Germany, the Netherlands,

Switzerland, Austria, Belgium, Iceland,

Lichtenstein, Luxembourg, may enter the country

in order to deliver the loaded goods and then leave

Bulgaria immediately, or, in case of transporting

goods intended for other countries – transit through a

route set in advance by the Bulgarian Road

Infrastructure Agency (green corridor).

Effective 6 April 2020

13 On 1 April 2020, the Council of Ministers defined the border points on Bulgarian territory through which unobstructed transit of goods will be ensured, i.e. so-

called “green corridors”.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

Truck drivers, whether Bulgarian nationals or not,

who go through the country, must obtain a

document14 issued by the Bulgarian Road

Infrastructure Agency which sets the latest possible

date and time, and the exact border checkpoint, for

leaving the country. (the time spent in Bulgaria

cannot exceed 24 hours).

If the transit through the border checkpoint

determined by the Bulgarian authorities is banned by

а neighboring country, the Bulgarian authorities will

determine a parking place where the driver and the

truck must remain until the ban is lifted.

[Truck drivers who are non-EU and non-Schengen

nationals are exempted from the general entry ban –

see item 3 above.]

18. Measures for aircraft

crew members arriving

from non-EU and non-

Schengen countries or

from high-risk countries

Order No. РД-01-183 dated 6

April 2020 issued by the

Minister of Health

The following applies to aircraft crew members

arriving from non-EU and non-Schengen countries,

or from Italy, Spain, France, the UK and

Northern Ireland, Germany, the Netherlands,

Switzerland, Austria, Belgium, Iceland,

Lichtenstein, Luxembourg:

i. Aircraft crew members are not to be

quarantined if they did not spend time on

the territory of any of the above countries

(except within the airport) and the time spent

Effective 6 April 2020

14 An English form of the document issued by the Road Infrastructure Agency is available here, page 15.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

within the airport was only for pre-flight

preparation of the aircraft;

ii. Aircraft crew members arriving from any of

the above countries are permitted to enter

into Bulgaria if they do not leave the aircraft

(except for the mandatory pre-flight

preparation of the aircraft) and the time for

the next takeoff does not exceed the

permitted flight duty period (“FDP”), but not

more than 12 hours.

iii. Aircraft crew members, nationals of any of

the above countries, arriving in Bulgaria for

delivering an aircraft for technical service,

are permitted to enter the country if they do

not leave the aircraft (except for the

mandatory pre-flight preparation of the

aircraft) and the time for the next takeoff

does not exceed the permitted flight duty

period (“FDP”), but not more than 12 hours.

iv. If a passenger on an aircraft landing on

Bulgarian territory shows symptoms of

COVID-19, the cabin crew who took part in

the particular flight must not plan their next

flight and must be put under mandatory 14-

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

day quarantine, as per the instructions of the

state health authorities.

19. Sanitary requirements for

air travel Order No. 45-01-156 dated

17 March 2020 issued by the

Director General of DG CAA

Airport and ground handling operators, companies

providing aircraft technical services and all air

carriers transporting passengers, cargo and mail from

and to the airports within the country must take strict

sanitary measures according to Safety Directive No.

SD-2020-01 dated 13 March 2020 issued by the

European Union Aviation Safety Agency15.

Effective 17 March 2020

20. Sanitary requirements for

maritime transport and

mandatory quarantine for

ships arriving from high-

risk countries

Measures adopted and

enforced by the Bulgarian

Maritime Administration

(“BMA”)16

Ships having on board one or more persons (crew

members or passengers) infected with COVID-19

must stay at anchorage quarantine area for 14 days.

Ships arriving from high-risk countries (not listed

by the BMA) for dry dock/ships repair shall also stay

at anchorage quarantine area for the same period.

Ships arriving from high-risk countries for cargo

operations are inspected by health inspectors. The

crew is placed under quarantine for 14 days on board,

cargo operations are to be carried out.

Effective 20 March 2020

21. Requirements for railway

transport

Measures adopted by the

Bulgarian State Railways

All cross-border trains to/from the country are

suspended (effective 17 March 2020).

In case a city/village is quarantined, the route of the

Various

15 Available here. See also Safety Directive SD No. 2020-02. 16 Full text of the measures is available here.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

trains will be adjusted, so that the trains do not stop at

the stations under quarantine (effective 24 March

2020).

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

EMPLOYMENT

22. Remote work. Sanitary

measures at the

workplace.

Order No. РД-01-124 dated

13 March 2020 issued by the

Minister of Health

All employers are instructed to transfer to remote

work mode for their employees, where possible.

Where not possible, they must ensure the introduction

of increased anti-epidemic measures, including

filters, disinfection and regular airing of the premises,

instructions to staff on personal hygiene, and must

not allow access for employees or visitors having

symptoms of acute contagious diseases.

On 13 March 2020, the General Labor Inspectorate

Executive Agency announced to the employers on its

website that they need to include the introduced anti-

epidemic measures in the risk assessment in

accordance with Ordinance No. 5 dated 11 May 1999

on risk assessment.

Effective 13 March 2020

until the end of the state

of emergency.

23. Remote and home-based

work State of Emergency Act Employers are allowed (depending on the nature of

the work and possibility for remote work or work

from home), to assign to employees, without their

consent, remote work or work from home

Effective 24 March 2020,

retroactively from 13

March 2020

24. Unilateral right of

employer to grant the use

of up to ½ of the annual

paid leave

State of Emergency Act The employer may unilaterally order its employees,

without their consent, to use up to one half of their

annual paid leave.

Effective 24 March 2020,

retroactively from 13

March 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

25. Suspension of work State of Emergency Act Any employer or a public authority may, by an order,

suspend work at the enterprise, part of it or of

individual employees until the end of the state of

emergency. Where a public authority has suspended

work, the employer is barred from allowing

employees to access their workplaces.

Effective 24 March 2020,

retroactively from 13

March 2020

26. Rights of the employer

during suspension of work

State of Emergency Act Where work is suspended during the state of

emergency (see above), the employer can enforce the

use of the unused annual paid leave of the employees.

Employers must pay 100% of the gross salary to all

employees during the period of suspension of work,

regardless of the reason for the suspension (whether it

is by decision of the employer or of a public

authority).

Effective 24 March 2020,

retroactively from 13

March 2020

27. Obligation to grant leave

to certain categories of

employees

State of Emergency Act Employers are obliged to allow the use of paid or

unpaid leave at the request of certain categories of

employees, such as pregnant employees, single

parents, employees under the age of 18, etc.

Effective 24 March 2020,

retroactively from 13

March 2020

28. Introducing part-time

working hours

State of Emergency Act Employers may introduce reduced working hours for

employees who work full-time for the entire duration

of the state of emergency.

Effective 24 March 2020,

retroactively from 13

March 2020

29. Extension of the possible

term for seasonal farm

employment contracts

State of Emergency Act An employer – registered farmer can conclude a

short-term seasonal farm employment contract for a

period longer than 1 day.

Effective 9 April 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

30. State aid for partially

covering salaries of

employees

State of Emergency Act For a period of up to 3 months, the National Social

Security Institute may transfer to an employer 60% of

the amount of the individual social insurance income

for January 2020 of certain employees, based on

criteria adopted by the Bulgarian government.

[See item 31 below for more information]

Effective 24 March 2020,

retroactively from 13

March 2020

31. Criteria for granting state

aid for partially covering

salaries of employees

Decree of the Council of

Ministers on the conditions

and procedure for paying

compensations to employers

for maintaining employment

of employees for the state of

emergency declared by the

National Assembly on 13

March 2020

According to a Decree of the Council of Ministers,

the possibility for companies to claim the support for

partial (60%) co-payment of salaries for a period of

up to 3 months during the state of emergency, is

available for:

i. employees whose work was suspended on the

basis of a government authority in relation to the state

of emergency;

ii. employees whose work was suspended on the

basis of an order of the employer in relation to the

state of emergency;

iii. employees whose working hours have been

reduced on the basis of an order of the employer in

relation to the state of emergency.

The availability of aid is subject to a number of

exceptions and conditions.

The state aid scheme was approved by the European

Commission of 14 April 2020.

Effective 1 April 2020,

retroactively from 13

March 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

TAX AND ACCOUNTING

32. Extension of the deadline

for publication of the

annual financial

statements

State of Emergency Act The deadline for publication of the annual financial

statements is extended until 30 September 2020. In

addition, dormant entities must submit a declaration

of dormancy by 30 June 2020.

Annual financial statements can be signed by

electronic signatures without further professional

stamps of the auditors or hand-written signatures.

Effective 24 March 2020

33. Extension of the deadline

for filing corporate

income tax returns

State of Emergency Act The deadline for submission of the Corporate Income

Tax (CIT) returns for 2019, as well as for payment of

the corporate income tax due, is extended until 30

June 2020.

If the company is required to make advance corporate

tax instalments for 2020, the instalments will have to

be reported by 15 April 2020. For this purpose, the

template of the CIT return only with the part for

advance instalments will have to be submitted by 15

April 2020.

[See more details about the advance instalments in

item 36 below.]

Effective 24 March 2020

34. Extension of the deadline

for declaration and

State of Emergency Act Entities obliged to pay alternative taxes instead of

general corporate income tax (e.g., entities Effective 24 March 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

payment of alternative

taxes under the Corporate

Income Tax Act

conducting vessels operations or ancillary and

auxiliary activities under the Gambling Act) will

have to submit their tax returns and pay the

alternative tax by 30 June 2020.

In addition, entities conducting ancillary and

auxiliary activities under the Gambling Act can also

submit their annual activity report by 30 June 2020.

35. Extension of the deadline

for declaration and

payment of tax on

expenses under the

Corporate Income Tax

Act

State of Emergency Act The deadline for reporting and paying the one-off tax

on expenses is extended until 30 June 2020.

Effective 24 March 2020

36. Extension of the deadline

for filing tax returns

concerning corporate

income tax advance

contributions

State of Emergency Act The corporate income tax advance instalments in

2020 are made under the requirements of Chapter

XIV of the Corporate Income Tax Act considering

the following:

i. If the CIT return for 2019 has been filed

before the effective date of the State of

Emergency Act, the tax advance instalments

are to be made according to the income

declared in the tax return for 2019. Further

revising declaration under Art. 88 of the

Corporate Income Tax Act may be

submitted;

ii. If a tax return for 2019 has been filed by 15

Effective 24 March 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

April 2020, the tax advance instalments are

to be made according to the income declared

in the filed tax return;

iii. If a tax return for 2019 has not been filed by

15 April 2020, the tax advance instalments

have to be declared with the annual tax return

by 15 April 2020. The annual tax return has

to be filled in only in the sections concerning

the tax advance contributions.

37. Extension of the deadline

for filing personal income

tax returns for sole

traders

State of Emergency Act The deadline for submission of personal income tax

returns for 2019 and payment of the tax due for sole

traders is extended until 30 June 2020 with a discount

of 5% if tax is paid by 31 May 2020.

Otherwise, the deadline for submitting personal

income tax returns for 2019 and payment of the tax

due remains 30 April 2020, with a discount of 5% if

tax is paid by 31 March 2020.

Effective 24 March 2020

38. Extension of the deadline

for benefitting from

property tax discounts

State of Emergency Act The deadline for the discount of 5% in case of

prepayment of the real estate tax or the vehicle tax

for the whole year is extended until 30 June 2020.

Effective 24 March 2020

39. Suspension of procedural

deadlines and limitation

periods under the Tax

and Social Security

Procedure Code

State of Emergency Act The limitation periods for public (including tax)

liabilities are suspended until the end of the state of

emergency, except for limitation periods under Art.

172, Para. 1. of the Tax and Social Security

Procedure Code.

Effective 24 March 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

No new enforcement proceedings under the Tax and

Social Security Procedure Code are to be initiated

until the end of the state of emergency, subject to

limited exceptions.

All existing enforcement procedures are suspended,

subject to limited exceptions.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

FINANCIAL SECTOR17

40. Extension of time limits

for companies in the

financial sector

State of Emergency Act Certain time limits for the submission of regular

financial statements and for fulfillment of reporting

obligations18 by UCITS, alternative investment funds,

public companies and other issuers, etc., are

extended, as follows:

i. Under the Public Offering of Securities

Act

The deadline for submission of quarterly reports by

bond issuers is extended until 30 September 2020

The deadline for public disclosure of standalone and

consolidated financial statements by public issuers is

also extended until 30 September 2020. However,

each issuer is obliged to publish its annual financial

statement (“AFS”) by 31 July 2020. The issuers

must notify the Financial Supervision Commission

(FSC) if the initial deadlines will not be met and

information on the exact reasons for the delay must

be provided.

The annual general meetings of public companies can

Effective 24 March 2020,

retroactively from 13

March 2020

17 The local Financial Supervision Commission supports the European Securities and Market Authority’s (“ESMA”) views and recommendations for mitigating the

impact of COVID-19. A Public Statement by ESMA is available here. 18 See also ESMA's guidance on accounting implications of COVID-19.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

be held until 30 September 2020.

In addition, the time limit for the investment firms to

provide the information on the clients’ assets to the

FSC and to the Investor Compensation Fund is

extended until the end of the month, following the

reporting period.

ii. Under the Markets in Financial

Instruments Act (“MFIA”)

Investment firms and market operators can submit

their annual financial statements and reports to the

FSC until 31 July 2020.

iii. Under the Collective Investment Funds

and Other Undertakings for Collective

Investments Act (“Collective Investments

Act”)

Management companies and investment companies

need to submit their annual and ongoing reports

under Art. 60 and Art. 92 until 31 July 2020 for the

annual reports and until 31 July 20 for the ongoing

reports, respectively.

Some other facilitating measures have been adopted

as well.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

PHARMACEUTICALS19

41. Possible ban for exports

of medicinal products

State of Emergency Act The Minster of Health may prohibit exports of

medicinal products until the end of the state of

emergency.

Effective 24 March 2020,

retroactively from 13

March 2020

42. Extension of validity of

prescription protocols

State of Emergency Act The validity of prescription protocols for high value

treatment medicines, which expire during the period

of the state of emergency, is extended for that period

and an additional two months after that.

Effective 24 March 2020,

retroactively from 13

March 2020

43. Extension of support for

assisted reproduction

procedures validity

State of Emergency Act The validity of orders for support of assisted

reproduction procedures is extended for a period of

six months after the end of the state of emergency.

Effective 24 March 2020,

retroactively from 13

March 2020

44. Extension of validity of

TELK and NELK

decisions

State of Emergency Act The validity of the decisions of TELK (Expert Labor

Medical Commission) and NELK (National Expert

Medical Commission) for determining long-term

disability and its level is extended for the period of

the state of emergency and an additional two months

after that.

Effective 24 March 2020,

retroactively from 13

March 2020

45. Ban for export of

medicinal products based

Order No. РД-01-141 dated

20 March 2020 issued by the

The export of medicinal products having quinine as

raw material is prohibited.

Effective 20 March 2020

19 On 25 March 2020, the Council of Ministers decided to request from the European Commission to exempt the import of medicinal goods related to treatment of

COVID-19 from customs duties and VAT.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

on quinine Minister of Health

46. Ban for export of

protective medical

equipment

Decision No. 159 dated 8

March 2020 adopted by the

Council of Ministers

All export of disinfectants, protective medical

equipment, e.g., masks, medical gloves, shoe covers,

protective glasses, etc. is prohibited without prior

authorization under Regulation (EU) 2020/402 of 14

March 2020 issued by the Minister of Health, or an

authorized person.20

Effective 8 March 2020

47. Exemptions for

pharmacies

State of Emergency Act Until the end of the state of emergency, pharmacies

are allowed to dispense prescription medicines

without requiring a prescription, based on the latest

entries in the patient’s prescription book, subject to

rules and limits to be set by the National Health

Insurance Fund.

Effective 24 March 2020,

retroactively from 13

March 2020

48. Payments to healthcare

providers within the state

of emergency

State of Emergency Act Until the end of the state of emergency, the National

Health Insurance Fund and the Bulgarian Medical

and Dental Associations can conclude an Annex to

the respective National Framework Agreements in

order to determine terms and conditions for payments

to the medical healthcare providers within the state of

emergency.

Effective 9 April 2020

20 See also Commission Implementing Regulation (EU) 2020/402 of 14 March 2020 making the exportation of certain products subject to the production of an export

authorization.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

JUDICIAL, ADMINISTRATIVE AND ENFORCEMENT PROCEEDINGS

49. General suspension of

procedural time limits and

deadlines

State of Emergency Act Effective 13 March 2020 (retroactively) until the end

of the state of emergency:

Procedural time limits within pending litigation,

arbitration and enforcement procedures are

suspended.

However, an Annex to the State of Emergency Act

specifies and lists all exceptions where the time limits

will not be suspended. The Annex includes some

criminal, administrative and civil proceedings, e.g.,

interim measures proceedings; all court cases under

the Public Procurement Act and the Concessions Act;

cases on appeals against assessments of public

receivables; cases on appeals against administrative

acts issued due to the state of emergency, etc.

(Effective 9 April 2020)

Effective 24 March 2020,

retroactively from 13

March 2020

Amendment effective 9

April 2020

50. General suspension of

limitation periods

State of Emergency Act All limitation periods, whose expiry extinguishes or

creates rights for private persons and entities, are

suspended.21

Effective 24 March 2020,

retroactively from 13

March 2020

Amendment effective 9

21 Time limits and deadlines for fulfillment of instructions issued by an administrative authority, time barring rights or times giving rise to obligations subject to

suspension according to the initial wording of the State of Emergency Act continue to run again as of 17 April 2020.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

April 2020

51. Extension of time periods,

established by law, for

private persons and

entities

State of Emergency Act All other time periods, established by law, which

expire during the period of the state of emergency,

which are not suspended as per the above, and are

related to the exercise of rights or the fulfillment of

obligations by private persons and entities, are

extended until one month after the end of the state

of emergency.

Time limits for certain procedures, e.g. under the

Public Procurement Act, the Concessions Act, the

Spatial Development Act, the Protection of

Competition Act, etc., and under the related

secondary legislation, do not fall within the scope of

this general suspension. The exceptions come into

force on 17 April 2020.

Effective 24 March 2020,

retroactively from 13

March 2020

Amendment effective 17

April 2020

52. Extension of the validity of

expiring acts of the

administration

State of Emergency Act The validity of all acts of the administration, which

are time-limited, and expiring during the state of

emergency, is extended until one month after the

end of the state of emergency.

Effective 24 March 2020,

retroactively from 13

March 2020

53. Cancellation of court

hearings and other

procedural actions

Decision dated 15 March

2020 adopted by the

Supreme Judicial Council

Decision dated 7 April 2020

adopted by the Supreme

Judicial Council

All court hearings are suspended. Serving of court

papers is suspended.

Court judgments issued during the state of emergency

must be entered into the record book of the court and,

if possible, published on the website of the courts.

Statements of claim /applications/ appeals are

Effective 16 March 2020

until 13 April 2020

Amendment effective 7

April 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

registered upon filing with the court and new court

cases can be opened. Pending and new court cases

will be stayed and scheduled for new hearings.

(Effective 7 April 2020)

Exceptions apply.

54. Suspension of certain

enforcement actions and

notarial proceedings

State of Emergency Act Public enforcement sales and repossessions are

suspended. The relevant procedures must be initiated

anew after the end of the state of emergency.

The imposition of distraints on bank accounts of

individuals and hospitals, on salaries, on medical

equipment, as well as certain enforcement actions in

respect of real estates and movable assets of

individuals, are suspended. Exceptions apply.

Notary certifications are limited only to urgent cases.

Effective 24 March 2020

55. Holding of meetings via

remote access or

suspension of the meetings

of some authorities

State of Emergency Act

Order / Decision of the

respective authority

The State of Emergency Act permits public

authorities, state agencies, commissions, etc. (which

are not legal entities), to hold their meetings digitally

via remote access and to adopt their decisions in

absentia. (Effective 9 April) [See below for related

measures adopted by some authorities]

All meetings of the Commission for Protection

against Discrimination are suspended until 13 May

2020.

The National Council on Prices and Reimbursement

of Medicinal Products has not issued a special order

Various

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

but has suspended its regular meeting on 19 March

2020.

Тhe Commission for Personal Data Protection will

not hold its meetings in public.

The Energy and Water Regulatory Commission will

hold its meetings, but will allow the presence of the

parties to the administrative proceedings only.

The Geodesy, Cartography and Cadastre Agency has

introduced some specific rules for review of

administrative procedures within its remit.

All authorities encourage the submission of all type

of documents electronically or by post.

56. Suspension of the deadline

for adoption of internal

rules under the Measures

Against Money

Laundering Act

(“MAMLA”)

State of Emergency Act The deadline for adoption of internal rules on

measures against money laundering and terrorist

financing is suspended until the end of the state of

emergency.

Non-profit legal entities obliged to draft a risk

assessment under the MAMLA must adopt their

internal rules within 4 months as of the end of the

state of emergency.

Some other time limits under the MAMLA are also

suspended.

Effective 9 April 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

PUBLIC PROCUREMENTS AND STATE GRANTS

57. Public procurement

exemption

Act to Amend and

Supplement the Health Act22

Purchasing of medical products and personal

protection equipment necessary to support health

measures in case of a state of emergency is permitted

without following a public procurement procedure.

Effective 14 March 2020

58. Public procurement

exemption

State of Emergency Act The following acquisitions are exempted from public

procurement rules:

1. Purchasing of sanitary materials,

disinfectants, medical devices and personal

protection equipment, needed for anti-

epidemic measures;

2. Purchasing of medical devices, medical and

laboratory equipment, needed for the

diagnostics and treatment of infected

patients, the consumables for them, as well as

associated implementation activities;

3. Utilization of pesticides and hospital waste

under Ordinance No. 1 on the requirements

for collection and treatment of waste on the

territory of the healthcare establishments

(SG, Issue 13 of 2015, as amended).

Effective 24 March 2020,

retroactively from 13

March 2020

22 State Gazette, Issue 23 of 14 March 2020.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

59. Public procurement

contracts extension

State of Emergency Act At the request of the sponsor, the duration of a public

procurement contract can be renegotiated, but [the

extension can apply] for no longer than the duration

of the state of emergency.

Effective 24 March 2020,

retroactively from 13

March 2020

60. Exemption from the rules

concerning procurement

of medical devices

State of Emergency Act Certain rules applicable to the procurement of

medical devices by the Ministry of Health, and

healthcare establishments of state and municipal

ownership, do not apply to purchases of medical

devices needed for anti-epidemic measures, for

treatment and diagnostics of infected patients.

Effective 24 March 2020,

retroactively from 13

March 2020

61. Direct award of grants by

the state

State of Emergency Act Grants can be awarded by the state, without prior

invitation for collecting offers, under reduced time

periods, with a simplified process for approval.

Effective 24 March 2020,

retroactively from 13

March 2020

62. Financial support for the

business through the

Bulgarian Development

Bank23

Decision dated 25 March

2020 adopted by the Council

of Ministers

The Council of Ministers decided to increase the

state’s share capital in the Bulgarian Development

Bank by BGN 700,000,000. The funds of the capital

increase are part of the government measures to

support the business in relation to the COVID-19

circumstances. The funds granted will be used for

issuance of portfolio guarantees in favor of

commercial banks24. The Fund Manager of Financial

Instruments in Bulgaria (“Funds of Funds”) wholly

Effective 25 March 2020

23 In addition, the Bulgarian National Bank announced а set of measures amounting to 9.3 billion BGN in relation to COVID-19 crisis for supporting the sustainability

and flexibility of the bank system. 24 Thе measure was approved by the European Commission under EU state aid rules on 8 April 2020 (see the Decision here).

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

owned by the state also announced similar measures

supporting business on 14 April 2020.

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

MISCELLANEOUS

63. Urgent checks by

healthcare establishments,

state institutions and

telecom operators

State of Emergency Act All healthcare establishments, state institutions and

companies in the telecommunications sector are

required to make urgent preventive checks of the

electricity supply systems and capacity they own,

within 7 days of entry of the State of Emergency Act

into effect. They must inform the Ministry of Energy

of the results, without delay.

Effective 24 March 2020

64. Measures for electricity

operators

State of Emergency Act All electricity transmission and electricity grid

operators should discontinue all planned maintenance

involving interruption of electricity transmission,

with the exception of emergency repairs.

Effective 24 March 2020

65. Extension of validity and

time limits

State of Emergency Act The time limits for validity of personal documents

(e.g. IDs, driving licenses, documents for residence

of foreigners) will be extended by 6 months. Other

administrative reliefs for Bulgarian nationals and

resident foreigners will be also available.

Effective 24 March 2020,

retroactively from 13

March 2020

66. Access to telecoms data

for the purposes of

enforcing anti-epidemic

measures

State of Emergency Act Access to data kept by electronic communications

operators for a period of 6 months under Art. 251б of

the Electronic Communications Act is granted to

enforcement authorities also for the purposes of

enforcing of the anti-epidemic measures, without the

requirement for a court warrant.

Effective 24 March 2020

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No. SUBJECT LEGAL BASIS DESCRIPTION EFFECTIVE

DATE/PERIOD

67. Providing market access

to agricultural producers

Order No. РД-01-179 dated 6

April 2020 issued by the

Minister of Health

Agricultural producers can have access to their

croplands and subsequent market access for selling

the production must be provided.

In addition, employees in good health –persons in

contact with those infected with COVID-19, and

employed in animal farms can continue their work for

taking care of the animals based on a self-declaration.

The employer must ensure specific working

conditions which do not endanger the health of the

rest of the employees.

Effective 6 April 2020