Category Archives: Events



Mr Emil Karanikolov,


Subject: Draft Ordinance on the terms and conditions for keeping a register of the persons conducting economic activities related to oil and petroleum products (URBRDDIDNPNP)

Dear Mr. Karanikolov,

Bulgarian Industrial Capital Association (BICA) has the following


On the draft Ordinance on the terms and conditions for keeping a register of persons engaged in economic activities related to petroleum and petroleum products (UNDP):

Procedural – the reference to an exceptional case within the meaning of Art. 26, para. 4 of the LPA for the public deliberation for us is unjustified and for unconvinced reasons as even if the 30-day period does not hinder the project to be adopted in due time, given the entry into force of the law from 28.01.2019. Given the controversial nature of a number of norms and their impact on the fuel business, we think it would be appropriate to postpone the entry into force of the Law on the Administrative Regulation of Economic Activities Related to Oil and Petroleum Products (ZARISNNPNP). The same applies to the draft regulation under discussion.

We use the occasion to reiterate the principle that we follow in principle to support all measures aimed at curbing the gray economy, which is among the declared basic goals of the law. In our view, however, the achievement of such a goal is incompatible with the restriction of real competition, which is seriously disturbed by many operators in the industry.

After a thorough analysis of the draft Ordinance, we find:

1. The project reproduces the norms of the Law on the Administrative Regulation of Economic Activities Related to Oil and Petroleum Products, with obvious observance of its manifest contradictions with Art. 19 of the Constitution of the Republic of Bulgaria with regard to the free economic initiative, creation and guarantee of equal legal conditions for economic activity, prevention of abuse of monopoly, unfair competition, consumer protection, investment and economic activity;
2. As correctly noted on page 2 of the Report of the Interdepartmental Working Group established by Order No. РД-16-1053 / 11.09.2018 of the Minister of Economy (for drafting a draft Ordinance, which sets the terms and conditions for keeping a register of persons engaged in economic activities related to petroleum and petroleum products) “The draft Ordinance does not introduce texts of European legislation”. However, the fact that this project violates the norms of Community acts such as:

  1. Directive 2006/123 / EC of the European Parliament and of the Council of 12 December 2006 on services in the internal market (Preamble (52) – Simplification of administrative procedures and formalities, Preamble (69) Where requirements are discriminatory or objective justified by imperative reasons of public interest or where they are disproportionate, they must be removed or amended, “Preamble (99)” The insurance or guarantee should be adequate to the nature and extent of the risk “, Preamble (110) For Member States and it should be impossible to circumvent the rules laid down in this Directive, including the provision on the freedom to provide services, by carrying out inspections, inspections or investigations which are discriminatory or disproportionate. “Article 5 Simplification of procedures Article 10 Conditions for granting authorization, Article 14 Prohibited requirements, paragraph 7, etc.).
  2. Directive (EU) 2015/1535 of the European Parliament and of the Council of 9 September 2015 laying down a procedure for the provision of information in the field of technical regulations and rules on Information Society services (Preamble (2)) – the prohibition of quantitative restrictions the movement of goods and measures having the same effect is one of the fundamental principles of the Union “, Preamble (7)” The aim of the internal market is to create an environment conducive to the competitiveness of enterprises “).
    and above all
  3. The Small Business Act, proclaiming the European Competitiveness Principle – “Think about the little ones first”.
    A major flaw in the draft of the URBRDDIDNPNP is that no legal delegation exists for many of the prescribed norms. Such is provided in the IRISPNPN, Art. 4, para. 4 in relation to Art. 16, para. 1. The Delegation shall require the Minister of Economy to issue an ordinance defining only the terms and conditions for keeping a register of persons engaged in economic activities related to oil and petroleum products. This is not the decision in the draft Ordinance:
    In Art. 14, para. 1 (4) introduces a requirement for the submission of property documents certifying the existence of real or bond rights for the activities under Art. 2, para. 1, item 1-6 of the Law;
  4. In Art. 16, para. 1, item 4 and Art. 17, para. 1, item 6 a requirement for submission of explanatory notes by the respective applicant is introduced;
  5. In Art. 19, para. 1, item 4 and in Art. 21, para. 1, item 1 introduces a requirement for submission of a document of ownership;
  6. In Art. 35, para. 1 deposit in cash shall be provided for a period of not less than one year and six months from the date of submission of the application to the termination of the registration or the replacement of the bank deposit with a bank guarantee. In Art. 10, para. 3 of the Law, the time limit is limited to one year and six months from the submission of the application, without any additional restriction.

The stated (non-exhaustive) material defects justify our position against the draft Ordinance on the Terms and Conditions for keeping a register of the persons conducting economic activities related to oil and petroleum products (URBRDSDNPNP).



In the course of our actions as a responsible nationally representative employers’ organization on the issues we have signaled in the electricity market, we welcome the efforts to normalize tradable volumes and pricing of the platforms of Bulgarian Independent Energy Exchange EAD. We expect results for both the “day ahead” and the “bilateral contracts” segment – with particular attention being paid to this market from the perspective of industrial consumers.

We are confident that the adequate supply, as well as the responsible and committed behavior of the trading participants, will allow us to achieve reasonable balanced price levels.

Analyzing the volumes in the last week, we are convinced that there are still significant opportunities regarding the volumes offered for bilateral trade – both in TPP Maritsa East 2 AD and Kozloduy NPP covering the problematic winter period for the first quarter 2019, without affecting the volumes offered by those companies in the “day ahead” segment.



The Bulgarian Industrial Capital Association (BICA) welcomed more than 400 guests at the official celebration of its 22nd birthday. Among them were representatives of the executive and legislative branches, business, branch, trade union and non-governmental organizations, diplomats and others.


“During these little more than two decades, the Bulgarian Industrial Capital Association became not only the voice of the Bulgarian business but it has become a real advocate for the interests of small and large enterprises, public organizations and companies providing services of general interest. I can boldly say that we will continue to participate actively in the process of creating and updating the legal framework in the country and good administrative practices, “said BICA Managing Board Chairman Vasil Velev.

BICA pointed out the priorities for 2019. For the Association one of the main problems faced by the Bulgarian economy – the lack of a skilled labor force for key sectors, the implementation of a reform in the financing of higher education and the inclusion of more business representatives in the definition of plan-adopts for secondary education. The struggle with the gray economy, which has become a trademark of BICA, will also be among the priorities of the most representative employers’ organization in Bulgaria.



18The Bulgarian Industrial Capital Association (BICA) presented the fifth annual “Business to the rules” awards. The winners in the categories were selected by a special jury of over 100 prominent people by secret ballot. The awards were distributed at a ceremony in Sofia Hotel Balkan and guests were Prime Minister of Bulgaria Boyko Borisov, Deputy Prime Minister Valeri Simeonov, Finance Minister Vladislav Goranov, important government officials, Sofia Municipality, businesses, NGOs and social partners.

The National Council for Tripartite Cooperation took the prize in the category of “Normative act or administrative practice that leads to curbing the gray economy and improving the business environment”. The award was given to actively contribute to the drafting of the changes to the Labor Migration and Labor Mobility Act, which led to the facilitation of the legal hiring of third-country nationals and the communication of the positions of all stakeholders. Nominated in the category were the Ministry of Finance and the Energy Commission at the 44th National Assembly of the Republic of Bulgaria.

The Association of Organizations of the Bulgarian Employers won the distinction of “Person or organization that contributed to the limitation and prevention of the informal economy through an active position”. AOBE, which managed to combine employers’ positions on a record number of issues, received a nomination for the overall activity of an organization in the past year in the field of curbing and preventing the informal economy. The Active Users Association, the Bulgarian Association of Private Schools and the Chief Councilor of the Vivacom Managing Board Dr. Janet Zaharieva were the other nominees for the prize in the category.

For her “Read the Label” column, Biljana Gavasova won the Journalist or Media Prize, who contributed to changing public attitudes towards intolerance to an informal economy. The bTV journalist struggled to compete with the economic department of Sega newspaper, Europe television and the reporters of “Lords of the Air” Boris Vaklinov, Vladi Vassilev and Dimitar Varbanov.

Nominations for the awards were made through a broad public consultation among members of the Bulgarian Industrial Capital Association, all social partners, members of the Public Council for Limiting and Prevention of the Informal Economy, composed of representatives of a number of state institutions and the media.

The competition aims to highlight and reward leading institutions and individuals with an active position and contribution to curbing gray practices. Thus, for another consecutive year, BICA promotes active action in the fight against the informal economy and promotes the constructive role of business in society in improving the socio-economic environment.

For the past year, the composite index “Business to the rules”, by which BICA measures the light bulk of the Bulgarian economy, has risen to a record 3.07 points to 74.78. The association reported a clear trend of accelerating the shrinking dynamics of the “gray” economy over the past three years, dropping to 25% in 2017.

BICA developed innovative instrumentary to increase to increase the attractiveness of keywords professions for bulgarian economy


“There is a devaluation of higher education – a large quantity, low quality and inconsistency of a plan – accepting needs,” said Vasil Velev, chairman of the Bulgarian Industrial Capital Association (BICA), which developed tools to increase the attractiveness of important for Bulgarian professions. As part of it, BICA prepared a strategy and plan with specific measures and pilot models to enhance the attractiveness of professions in the Mechanical and Metal Processing, Electrical and Electronics, Transport and Spedition and Beauty and Health Medicine and Services sectors, , a module for promoting mobility, and a model for objective assessment of labor productivity. “The problem with human resources is very acute and comes first in business surveys as barriers to investment, growth in sales and a staple of economic growth as a whole, hence of living standards,” Mr. Velev stressed. The aim of the developed instruments is to solve one of the main problems on the labor market – the lack of skilled persons for key areas of the Bulgarian economy such as machine building, electronics and electrical engineering, healthcare, etc. This became clear today after a working meeting between representatives of AICB, the European Commission, the Ministry of Labor and Social Policy, the Employment Agency, the National Agency for Vocational Education and Training and representatives of industry employers’ and trade union federations from the four pilot sectors.

The toolkit was developed under project BG05M9OP001-1.011 – 0002 “Achieving sustainable and quality employment by improving the attractiveness of professions with low labor market supply in key sectors for the development of the Bulgarian economy”. More than 80 experts took part in its development.

The main measure to solve the problems of the labor market were the active inclusion of employers in the improvement of the quality of education at secondary vocational schools and higher education institutions. Representatives of the business believe that by annually updating curricula, improving the structure of the plan-adopting, increasing the practical applicability of the education system, and providing scholarships, they will be able to create and develop a lasting interest in the majors of the economy.

Among the factors which influence the attractiveness of professions and motivation were flexible working hours, proximity to work, pay, vocational trainings, topicality of the profession, working conditions, stability and security of employment, social prestige of the profession, etc. In order to improve the attractiveness of the deficit professions, state institutions, employers and trade unions will have to develop practical tools and measures as soon as possible.


“The link between business and education for us is very important. However, targeting children to vocational education should not only be a task for employers’ organizations but for our society as a whole. We must break our thinking and appreciate the work, as each profession has its place and meaning for the country’s economic development. We hope that the Ministry of Education and Science will support the proposed mirror project in the field of education, which will implement the measures outlined in the other target groups – students and their families, “said Milena Angelova, the Project leader.

The Chairwoman of the National Agency for Vocational Education and Training Emiliana Dimitrova has expressed her readiness to consider the possibility of incorporating some of the models and measures for enhancing the attractiveness of the professions in the State Educational Standards as well as their use in their future work.

“The project has a very broad partner base and this is its strongest side. One of the main European objectives is to make vocational education the first choice for children. Among the problems we have to deal with is the high percentage of Roma children who drop out of the education system – 67%, and then about ¼ of the Roma drop out of the labor market. The role of the European Social Fund is extremely important for the realization of precisely such projects, which are of great importance for the improvement of the social and economic situation in Bulgaria, “said European Commissioner Dora Krumova.

The Bulgarian Industrial Capital Association has set as its main priority the coping with the shortage of qualified personnel. So far, BIC has made a number of proposals to the Ministry of Education and Science for a complete reform of the way of financing higher education and reform in the preparation of plan-adopters in secondary vocational education, introducing into the legal framework a methodology for creating a list of specialties from professions, for which there is an expected shortage, etc.







Subject : Take the necessary steps for applying for accession of Bulgaria into the ERM – II / ERM II /


Dear Mr. Borisov,
DEAR MR Radev,

Conducted numerous public debates in connection with the Bulgarian presidency of the European Council reaffirmed the need to immediately initiate all necessary procedures for accession of Bulgaria to the ERM II, and accelerate all preparatory steps for subsequent accession to the Eurozone.

As you informed on these issues nationally represented employers and trade unions have expressed their categorical common positions, incl. in November 2014, in the accepted opinion of the Economic and Social Council of December 2017 and other self-declarations.

In a letter to you on 14.06.2018, the social partners proposed holding an emergency meeting on repeatedly stated commitments to quickly join the ERM II. The busy schedule of the Bulgarian presidency of the European Council clearly hampered the timely holding of this meeting and full discussion in our proposed format.

Insofar as these matters are highly attractive both for our members and for the whole society, the institutions of legislative and executive power, banking and actions in key areas of responsibilities exercised policies, hereby reiterate strong support of all social partners in the face of nationally representative organizations of workers and employers in Bulgaria, a Bulgarian official presentation of the candidacy to join the ERM II, immediately after etc. Key Bulgarian presidency of the European Council in the first week of. July 2018

In this regard, we express again the expectations of the social partners to take all necessary steps immediately within the responsibilities and powers of the Government and National Bank, and requested preliminary positions.









AOBE position on the resumption of the project “Belene”





Dear Ladies and Gentlemen,

In recent days, public opinion in Bulgaria is very excited by the proposal for a “reset” of NPP “Belene”. On June 7, 2018 pending the National Assembly to take a very responsible decision on the return of this project on the agenda of the Bulgarian energy sector and under what conditions to do this or, respectively – to continue the moratorium.

Association of Bulgarian Employers (AOBE) has repeatedly expressed its position is regarding the development and implementation of new energy projects – this is acceptable under the explicit condition to be entirely on market principles, without commitments for guaranteed quantities and the discounted prices.

Petkov announced that the project “Belene” will be performed at “market conditions” but as such it made public so far only two requirements:

no state guarantees for the project;

no long-term contracts for the purchase of electricity produced.

Not openly stated publicly express prohibition on:

preferential pricing;

possible additional payment of price differences and / or written;

corporate guarantees from state-owned companies in the energy sector, for example, Bulgarian Energy Holding, National Electric Company, Kozloduy NPP.

In fact, the above requirements hardly exhaust the possible non-market ways of defrauding taxpayers – corporate and individuals. Therefore, relying on the goodwill of both the legislative and the executive, we insist on a clear and unambiguous statement that will be traversed all possibilities “Innovation” and implementing schemes for non-market revenue.

Transparency, marketability, economic consistency – these are basic principles that can ensure long-term sustainability of a project. Considering these principles, the investments made to date and the scale of the project “Belene”, a successful scenario for implementation may include the following steps:

State retrieve a public company existing tangible and intangible assets, including engineering, licensing rights, playground, performed works, and all received or intended to be received equipment, which Bulgaria is the legal owner;

Make a prospectus for public offering of shares of this public company on the stock exchange in volume, securing raising sufficient capital to implement the investment program – so in the most transparent manner and the market will be assessed the economic solvency of the project;

The public company, which after the capital increase involving relevant investors – strategic, institutional, and perhaps smaller ones (if the business audience really believes that the project is profitable) completes the construction site NPP “Belene” and is likely be necessary commitment and debt;

As an investor and operator of the plant “Belene” public company realized electricity produced energy market – from the first to the last megawatt of market prices.

What we think is realistic scheme that could implement the project “Belene” NPP – led by economic logic and pragmatism – without ideological, geopolitical interpretations pathetic phraseology and seeking political gain. At the same time, taking into account the stated official intentions to launch a procedure for selecting a strategic investor, we believe that the preconditions for negotiations with potential candidates should include as basic requirements – ensuring transparency, implementation of the project on market principles and other applicable conditions, some of which are listed above.

We believe that we need a public discussion involving all stakeholders, not disseminate false information – about the price of electricity produced by NPP “Belene”, the volume of future electricity demand, the lack of alternatives.

By arguing that such was the price of electricity produced by NPP “Kozloduy” in the public media space boldly comment on prices generated by the future nuclear power plant “Belene” power ranging between 25 and 50 euros per megawatt hour. Thesis, which we define as inconsistent and inadequate information available – in comparison, the project Hinkley Point C, Britain declared price of 92.50 pounds per megawatt hour, a contract for 35 years. In 2019 Belarus is expected to start operating new nuclear power plant, the prices of which range from 110 euros per megawatt hour. The project Akkuyu, Turkey assumes a price of 124 US dollars per megawatt hour, and estimates for the project of expansion with two new blocks Paksi, Hungary are in the upper range of 80-110 euros per megawatt hour.

The National Statistics Institute systematically develop and publish energy balances, including Overall energy balance, primary energy consumption, energy intensity of the economy. Their analysis shows unequivocally improve energy efficiency – for comparison, 0,470 tonnes of oil equivalent per 1000 euro GDP in 2012., The same indicator for 2016 is 0.423. The same conclusion can we do for electricity intensity – while in 2012 GDP for 1000 euros have been invested over 820 kwh in 2016, the electricity is 765 kwh. However, net electricity consumption in the country (taking into account net production and physical import deducting losses in the grid the need to regulate the electricity system and physical exports) in recent years is sustainable in the range of 31-32 TWh (data of ESO KEVR and NEC), at 3-4 percent economic growth annually. Naturally, there is considerable untapped potential for improvement in this regard.

There are alternatives – both in the field of energy, and in terms of energy consumption and energy efficiency. Examples – new generations renewables already generate electricity with significantly lower prices compared to the recent past, the growing consumption of natural gas will inevitably replace part of the consumed current electricity (trend among household subscribers), develop intelligent networking solutions that optimize bidirectional elektrosvarzanost , is a significant technological progress and possible solutions for efficient storage of electricity and balanced electricity, the voltage at optimal.

In realization of the project “Belene” should be eliminated all the risks associated with the dominant ‘ours’ understanding of quality control and performance, the product of corruption and political interference environment, including purely technical matters. With additional guarantees for the effective implementation of norms for procurement of high public importance and spending significant funds for high quality performance, an objective assessment of the technology of reactors and risk management at the highest achievable level acceptable to our society, our European partners and neighbors.

Last but not least, the vote on the resolution on the moratorium of the National Assembly should proceed in parallel with the discussion of the strategy for sustainable energy development until 2030, the drafting of which was entrusted to the Ministry of Energy.







ICCEU Supports Bulgaria’s Membership in OECD


The International Coordinating Council of Employers’ Unions (ICCEU) supported Bulgaria’s bid to become a member of the Organization for Economic Co-operation and Development (OECD). This was announced by the ICCEU Chairman Andrzej Malinovski at the General Assembly of the organization hosted by the Association of Industrial Capital in Bulgaria (BICA).

“As always, it is the business that paves the way for our country’s membership in significant international organizations. As you know, at the beginning of this year, the Association of Bulgarian Employers’ Organizations became an associate member of the OECD Advisory Committee on Business and Industry. Our country meets the requirements for membership in one of the most important economic organizations in the world, which signals to foreign investors that the economic situation in Bulgaria is good”, BICA’s Chairman Vasil Velev declared.

During the General Assembly, the next ICCEU chair was also nominated. This is very likely to be the President of the Employers’ Association of Georgia, Elguja Meladze. ICCEU is expected to officially announce its decision at its next meeting, which will take place on 19-21 November this year in Krakow, Poland.

Among other topics discussed by the members of the International Coordinating Council of Employers’ Organizations were priorities of the G-20 Business Council. Those included the development of small and medium-sized enterprises, labour market and education, digital economy, etc. Information was also provided on the National Qualifications Framework of ICCEU, CIS and BRICS.

The official site of the organization was also presented to the participants in the General Assembly.

The Commission for Protection of Competition (CPC) Associates AOBE’s Signal to the Procedure of Analyzing Competitiveness on Local Electricity Market


The Commission for Protection of Competition (CPC) will join the AOBE’s signal to the formal procedure it has already started to conduct a sectoral analysis of the competitive environment on the electricity market. This becomes clear from CPC’s response to the AOBE‘s signal related to wholesale electricity prices on the market.

In its letter, CPC informs that in the framework of the proceedings of the Commission № CPC / 82/2018, a comprehensive and in-depth analysis of the competitive environment on the electricity market, as well as of AOBE statements, will be carried out in order to identify existing or possible anti-competitive agreements or practices. Within the framework of the analysis, CPC will define relevant markets, their characteristics and structure, barriers to exit, market participants, degree of market competition, regulatory framework, etc., and will draw conclusions on the state of the competitive environment.

“The implementation of a new sectoral analysis of the energy market will give CPC a detailed picture of the current market processes and the need for any additional measures by the Commission, under the provisions of the Law on Protecting Competition, to contribute to proper functioning of the market environment”, says the CPC’s letter to AOBE.

It is recalled that AOBE sent its signal to CPC on 25 January 2018. It stated that the promotion of open and fair competition on wholesale electricity markets to the benefit of end-users was the aim of Regulation (EC) No 1227 / 2011 of the European Parliament. CPC confirmed that it will do the checks requested by AOBE regarding:

  • coordinated behavior of Kozloduy NPP EAD and TPP Maritsa East 2 EAD as the main suppliers of electricity on the free market in Bulgaria when announcing initial auction prices;
  • pre-arranged cooperation between the two plants with certain electricity traders, applying different access to information on tendering procedures;
  • coordinated action by electricity traders in connection with a significant and unjustified increase in the price of active electrical energy offered to end-users.

PwC Starts a Campaign in Support of Bulgarian Students

PwC_25years_KeyVisual_25_en (2)

The initiative “Your 25 Reasons to Choose Bulgaria” will award 25 students with scholarships, internships and mentorship

PwC Bulgaria starts the campaign “Your 25 Reasons to Choose Bulgaria” in support of ambitious Bulgarian students. On the occasion of its 25th anniversary in the country PwC Bulgaria together with leading partner companies will support 25 students with:

  • one-year scholarships
  • internships in a prestigious company
  • mentorship

“Through the “Your 25 Reasons to Choose Bulgaria” project we aim to motivate Bulgarian students choose Bulgaria and develop successfully here, help them gain valuable experience, knowledge and advice on their personal and career development”, shared Bojidar Neytchev, Managing Partner, PwC Bulgaria.

The initiative is held under the patronage of the President of the Republic of Bulgaria Rumen Radev and with the support of the Ministry of Education and Science. Bulgarian students, aged 18-24, highly motivated to stay and develop here, could take part in the contest. The applicants should submit an essay on the topic “My 25 Reasons to Choose Bulgaria” until 10 February 2018. A jury of business leaders and experts will select the winners.

Leading Bulgarian and foreign companies that develop successful business in Bulgaria partner the campaign.

For more information on “Your 25 Reasons to Choose Bulgaria”, please visit the official website and the PwC Bulgaria Facebook and LinkedIn profiles.

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