The CPC’s 2026 annual enforcement priorities

The Bulgarian competition commission has announced its annual enforcement priorities for 2026

The Bulgarian Commission for Protection of Competition (CPC) has published its annual enforcement priorities for 2026, outlining the key areas where the regulator will focus its investigative resources throughout the year. These areas are the following:

• food;
• pharmaceuticals;
• fuels;
• energy;
• financial sector;
• telecommunications;
• digital economy and e-commerce; and
• sustainability.

Priority sectors for antitrust enforcement in 2026

The CPC’s annual enforcement priorities report identifies:

• the economic sectors and areas that will receive heightened scrutiny for potential antitrust infringements and unfair trading practices; and
• The types of proceedings that the CPC will prioritise when allocating its enforcement capacity, namely cartels and bid rigging cartels, abuses of dominant position and the special forms of unfair trading practices in the food supply chain.

These priorities offer an insight into where attention to competition compliance will be most critical for businesses operating in Bulgaria. In each of the prioritised sectors, the CPC has already launched initiatives that signal its emerging competition concerns and enforcement direction. Businesses active in these areas should therefore expect increased regulatory scrutiny throughout 2026 and take proactive steps to ensure their compliance frameworks are robust and up to date.

Food sector

With a strong recent track record of activity in the food sector, the sectors top positioning in the CPC’s annual priorities is unsurprising. The intensified activity forms part of the CPC’s ongoing in-depth sector inquiry proceedings. In the second half of last year the CPC shared preliminary findings from its inquiry relating to the markets for essential food products, including eggs, dairy, meat, flour, bread, sunflower oil and others. The preliminary findings pinpoint specific issues across the value chain relating to structural issues, market imbalances and pricing practices that affect suppliers and consumers. These findings have led to a targeted deepening of the research, including through on‑site inspections into alleged bid‑rigging of public tenders for the supply of food to hospitals and other institutions.

Against this backdrop the Commission has announced that, as a priority in 2026, it will further its inquiry focusing on:

• pricing practices and commercial terms between suppliers and retailers;
• retail market structure in economically vulnerable regions; and
• production, processing and trading of milk and dairy products, including follow‑up on the previously approved concentration on the dairy market.

Pharmaceutical sector

The pharmaceutical sector is another area on which the Commission has placed particular emphasis since the start of its mandate, last year. The Commission has launched an extensive sector inquiry to review the entire value chain of the supply of medicinal products for human use. The purpose of the inquiry is to evaluate whether any of the structural issues, particularly shortages of key medicines and increased prices on the Bulgarian market, may stem from anti‑competitive conduct.

In 2026, the CPC has announced that it will actively monitor all behaviour of market participants, with key priorities including:

• practices in the supply of medicines that may lead to distortions in the supply process or restrict competition across the value chain
• the examination of vertically integrated structures along the medicinal products supply chain (manufacturing/import – wholesale – retail), which may lead to unequal treatment of pharmacies by wholesalers;
• the investigation of parallel exports of medicinal products that could contribute to shortages of medicines in the country; and
• abuse of dominant position.

Fuels sector

The mass‑market fuel segments – A95 petrol and diesel – have consistently been a focus of the CPC given their importance in cost formation and their systemic relevance for the national economy. Most recently, the CPC has expressed market concerns arising from the escalating geopolitical tensions in the Middle East, which have the potential to exert pressure on supply chains and pricing dynamics. To this end the CPC has issued recommendations to the government suggesting that it facilitate its position in the management of the dominant supplier Lukoil to ensure uninterrupted access to the key fuel import infrastructure and to take actions to discourage speculative price setting and the retention of fuel quantities in storage.

The CPC is also carrying an ongoing monitoring of the retail prices of diesel and petrol for any indications of non‑competitive or parallel pricing behaviour. Concurrently, the Commission is running an investigation into alleged abusive practices by the dominant Lukoil group in relation to restrictions affecting fuel imports and the functioning of the wholesale fuels market in the country. This investigation follows the substantial sanctions imposed on Lukoil in 2023 for margin squeeze and refusal to provide access to key fuel import infrastructure.

In view of this, businesses should expect increased regulatory scrutiny of pricing developments and a continued focus on Lukoil’s market position throughout 2026.

Energy sector

The energy sector across electricity, natural gas and district heating remains one of the CPC’s key priority areas for monitoring and enforcement in 2026. Over the past year, the Commission issued two decisions in complex abuse‑of‑dominance cases, including matters involving the definition of the market for the supply of electricity to final customers at freely negotiated prices. One of the notable proceedings concerned allegations against one of the large electricity distribution companies, Elektrorazpredelenie Sever, with a regional dominant position, relating to claims of exclusionary practices and distortions in electricity trading and network access.

Last year, the Commission also announced that it is conducting a preliminary investigation in the sector following a submission to the Prosecutor General on suspicion of a hidden cartel exerting anti-competitive control over a significant part of the energy market in the country. The CPC will assess whether the alleged practices amount to infringements of competition law or whether they amount to sector-specific infringements under REMIT rules such as agreements for market manipulation and insider trading of information. Recently, the sector regulator – EWRC found a REMIT infringement, related to the allegations made before the CPC – establishing market manipulation on the wholesale energy market, concerning the sale of energy by Toplofikatsiya Sofia to a specific energy trader at below-market prices. As such factual patterns could, in principle, also raise issues under competition law, it remains to be seen whether and how the CPC will assess any broader competition concerns.

Financial and digital sector

In 2026, the CPC will continue to prioritise both the financial sector and the fast‑evolving digital and e‑commerce markets. While there are no investigations in financial services, the CPC emphasises its commitment to safeguarding effective competition and preventing market distortions. To this end, the CPC has committed to deepen its cooperation with the Bulgarian National Bank and the Financial Supervision Commission, with the aim of improving coordination on emerging issues, including inter alia in the context of the Euro currency adoption.

The CPC maintains a strong focus on the digital sector. The increasingly complex interaction between sector‑specific digital regulations, including the DMA, DSA, GDPR and the emerging rules on artificial intelligence and their impact on market dynamics. The CPC is closely following developments related to the conduct of DMA‑designated gatekeepers and is expected to scrutinise their commercial practices in Bulgaria in relation to both businesses and end‑users.

Telecommunication sector

In the last year, the Commission has opened two new proceedings, both against major market players. The case against Vivacom – one of the three largest telecom operators in the country – concerns allegations of a prohibited agreement under Art. 101 TFEU and Art. 15 LPC, with no further details disclosed publicly. The other case involves one of the most prominent TV and broadcasting companies, Nova TV, also without publicly available information at this stage. The CPC has stated in the annual priorities report that it will closely monitor the competitive conditions and market developments in the provision of voice services, internet and television access and their bundled offerings to end users.

The Commission has also announced that it will be initiating a sector inquiry into telecommunication services to address issues identified in the market inquiries of the national telecom regulator – the Communications Regulation Commission (CRC) – focusing in particular on areas where the CRC has identified concerns but lacks the regulatory powers to intervene directly.

Alongside enforcement, the CPC is also active in its advocacy function. The Commission has initiated work on a joint report with the CRC regarding the definition, analysis and assessment of the wholesale local access market, a market that plays a central role in shaping competitive conditions in electronic communications.

With the above actions, the authority signals an increased readiness to intervene where conduct may restrict competition or harm market openness.

Sustainability

The sustainability topic has consistently been identified as an important one by the Commission, although this has not always been clearly reflected in its enforcement practice. Last year, however, the Commission paid particular attention to a signal concerning a significant and simultaneous increase in eco‑fees prices applied by all licensed collective scheme operators. Subsequently, the Commission initiated a broader inquiry into the potentially affected market – the waste management sector for electronic and electrical equipment (EEE).

CPC enforcement – monitoring and investigation tools

A core instrument used by the CPC to deepen its market monitoring is the issuance of requests for information and cooperation to the relevant market participants. Businesses operating in the prioritised sectors should therefore anticipate being asked to provide data, documents and clarifications to support the Commission’s information‑gathering activities.

Where the CPC holds serious suspicions of an antitrust infringement, it may also conduct unannounced inspections (dawn raids) at company premises, as well as at the private premises of representatives or members of the company’s management bodies, as permitted under Bulgarian law. Since 2025, these inspections may be carried out not only by CPC officials but also with the involvement of authorised external experts, expanding the Commission’s investigative capacity.

In view of possible engagement with the CPC, companies should ensure that their internal compliance programmes remain robust, up to date and capable of responding to potential requests.

WT PG TEAM

Wolf Theiss’s competition team is closely following developments in competition law at both national and European level and stands ready to support clients in navigating any competition law compliance queries.