Waste collection fee applicable to non-residential properties owned by businesses

This Client Alert is also available in Bulgarian.

The deadline for choosing a waste collection fee regime for 2026 is from 1 October to 30 November 2025.

According to the current version of the Ordinance on the Determination and Administration of Local Fees and Prices of Services Provided by the Sofia Municipality (the Ordinance), companies that own non-residential properties have the right to choose how the waste collection fee for 2026 will be calculated. This choice can be made between 1 October and 30 November of this year by submitting the relevant declaration to the Mayor of Sofia Municipality through the Directorate of Economy and Trade.

The options for selection, according to the current version of the Ordinance and the budget plan for 2025 adopted by the Sofia Municipal Council, are as follows:

• Option 1 –based on the amount of waste, as declared by the obligated person, the type and number of containers for its storage and the frequency of waste collection:
  
  -3.5 cubic metre / 4 cubic metre container per 1 container per year with a collection frequency of once a week: BGN 10,400 for 2025.
  
  +
  
  -Fee for maintaining the cleanliness of public areas: 3.7 ‰ of the book value of the properties

• Option 2 – through direct negotiation with companies providing waste collection and disposal services:
  
  -Fee for disposal of waste in landfills or other facilities: 2.6 ‰ of the book value of the properties
  
  +
  
  -Fee for maintaining the cleanliness of public areas: 3.7 ‰ of the book value of the properties
  
  
• Option 3 – proportionally in per milleif Option 1 or Option 2 is not selected.
  
  -9 ‰ of the book value of the properties

Upcoming legislative changes regarding the basis for determining the waste collection fee

We would like to remind you that, according to the Local Taxes and Fees Act, from 1 January 2026 all municipalities in Bulgaria must switch to a completely new principle for calculating the waste collection fee, shifting from a percentage of the tax valuation (or book value for non-residential properties of companies) to the “polluter pays” principle.

To prepare for the new calculation method, at the beginning of this year the Sofia Municipality published samples of the three declarations that citizens and businesses could complete to provide the administration with information for deciding how the waste collection fee will be determined from 2026 onwards.

The deadline for submitting the declarations expired on 30 September 2025. Submission was not mandatory but purely informative, so whether or not a declaration was submitted will not affect the amount of the fee for 2026.

Despite the legislator’s intention to switch to this new principle for calculating the waste collection fee, the draft Law on the State Budget of the Republic of Bulgaria for 2026, submitted to the National Parliament, provides for amendments to the Local Taxes and Fees Act, according to which the deadline for introducing the new basis for determining waste collection fees is extended until January 1, 2027. In this regard, on 17 November 2025, the Sofia Municipal Council opened a public consultation procedure on a draft municipal account plan for 2026, which proposes that the bases, options and parameters for calculating the waste collection fee applicable for 2025 be retained for the coming year.

Will the legislative changes providing for the postponement of the transition to the “polluter pays” principle until 1 January 2027 will be finally adopted and what the legal consequences of this further postponement – which conflicts with EU law – will be, are questions that still need to be clarified.