The Bulgarian Industrial Capital Association (BICA) presented nine opinions on the legislative proposals included in the agenda of the National Council for Tripartite Cooperation (NCTC) for 23 October 2026. The Association supports measures aimed at reducing administrative burdens, encouraging investment and increasing transparency, but opposes proposals that create additional costs, legal uncertainty and unjustified burdens for law-abiding businesses.
Today's meeting is attended by Dobrin Ivanov, Executive Deputy Chairman of BICA, and Ivelin Zhelyazkov, Parliamentary Secretary and Director of Tripartite Cooperation at BICA.
A central focus of BICA's positions is the need for a consistent and predictable tax policy. The Association strongly opposes using the introduction of the euro as grounds for a de facto increase in administrative penalties. Several draft laws propose replacing the existing amounts of fines in Bulgarian leva with the same numerical amounts in euros, which would represent a 95.58% increase rather than a currency conversion.
BICA insists that penalties should be converted at the official fixed exchange rate and that any subsequent adjustment should be carried out separately, with clear justification, an impact assessment and due consideration of the severity of the violations.
Key Highlights of the Opinions:
1. Personal Income Taxes Act – Support for Working Families
BICA supports increasing tax relief for children and introducing a new tax allowance for documented expenditure on healthcare, education and sports activities. According to the Association, these measures encourage labour market participation, support families and promote investment in human capital. However, their implementation should be as straightforward as possible and should not create additional administrative obligations for employers.
2. Corporate Income Tax Act – Opposition to the Extraordinary Tax on "Excess Profits"
BICA does not support the proposed extraordinary sectoral tax at a rate of 33%, as it considers that such a measure could penalise enterprises for successful investments, business expansion and increased productivity. The Association also opposes limiting the annual deduction of tax losses to 70% of the positive taxable financial result.
At the same time, BICA supports accelerated depreciation for investments in artificial intelligence and high-performance technological infrastructure.
Regarding food vouchers, BICA welcomes the adoption of its proposal to maintain the tax-exempt amount of up to EUR 102.26, with the proposed 7% tax applying only to the amount exceeding this threshold.
3. Value Added Tax Act – A Higher Registration Threshold and Effective Electronic Invoicing
BICA calls for the mandatory VAT registration threshold to be increased to EUR 75,000 as early as 1 January 2027, rather than postponing the increase through a phased approach until 2029.
The Association supports the introduction of structured electronic invoicing, provided that the technical readiness of the systems is guaranteed, sufficient time is allowed for adaptation and enterprises are protected from penalties arising from technical problems beyond their control.
4. Local Taxes and Fees Act – Waste Collection Fees Based on Actual Waste Generation
BICA supports the gradual updating of property tax assessments but insists that this should not automatically lead to higher municipal waste collection fees.
The Association once again calls for the implementation of the "polluter pays" principle from 1 January 2027, so that enterprises pay fees based on the quantity of waste they generate rather than the value of their properties.
5. Excise Duties and Tax Warehouses Act – More Proportionate Rules and Fewer Administrative Burdens
BICA welcomes the fact that the Ministry of Finance has incorporated a substantial part of its proposals concerning the new excise duty on high-powered vehicles. The changes include exempting fully electric vehicles and taking into account only the power of the internal combustion engine in hybrid vehicles.
The Association also supports removing the possibility of imposing both a financial penalty and the sealing of a commercial establishment for the same violation. However, BICA opposes increases in penalties and certain excise duty rates presented as currency conversion measures.
6. Accountancy Act – Fewer Sustainability Reporting Obligations for Enterprises
BICA supports narrowing the scope of mandatory sustainability reporting and introducing more proportionate requirements, particularly for small and medium-sized enterprises.
The Association insists that large companies should not be allowed to transfer disproportionate reporting obligations to their suppliers. It also proposes an additional transitional period for enterprises that remain subject to mandatory reporting requirements.
7. Independent Financial Audit and Sustainability Assurance Act – Reducing Reporting Costs
BICA supports the transition to limited assurance in the verification of sustainability information. This would preserve independent oversight while ensuring more proportionate costs for enterprises.
The Association insists that the new rules should be aligned with the amendments to the Accountancy Act and that no additional national requirements should be introduced beyond those necessary under European legislation.
8. Gambling Act – More Effective Control and Prevention of Gambling Addiction
BICA supports measures to restrict gambling advertising, including indirect forms of promotion, as well as strengthening prevention efforts among young people.
The Association also welcomes the proposed automated submission of information to the National Revenue Agency (NRA) on bets placed and winnings paid out, as a tool for reducing undeclared turnover.
9. Minimum Wage for 2027 – Support for a Balanced Increase to EUR 660
BICA supports the proposed minimum wage of EUR 660 from 1 January 2027 as a balanced first implementation of the new mechanism.
According to the Association, sustainable income growth must take into account social needs, labour productivity and the capacity of the economy. Predictable minimum wage determination through genuine social dialogue is important for both employees and enterprises. Predictable rules are a prerequisite for investment and economic growth.
Through the opinions presented, BICA reaffirms its consistent position that fiscal stability and increased public revenue should be achieved by broadening the tax base, reducing the shadow economy, promoting digitalisation and improving tax collection efficiency, rather than imposing unpredictable and disproportionate burdens on law-abiding businesses.
The Association will continue to advocate for a transparent, fair and predictable regulatory environment that encourages investment, productivity, competitiveness and sustainable income growth.
The full texts of BICA's nine opinions are available at the following links:
- Opinion on the Draft Amendments to the Personal Income Taxes Act – HERE
- Opinion on the Draft Amendments to the Corporate Income Tax Act – HERE
- Opinion on the Draft Amendments to the Value Added Tax Act – HERE
- Opinion on the Draft Amendments to the Local Taxes and Fees Act – HERE
- Opinion on the Draft Amendments to the Excise Duties and Tax Warehouses Act – HERE
- Opinion on the Draft Amendments to the Accountancy Act – HERE
- Opinion on the Draft Amendments to the Independent Financial Audit and Sustainability Assurance Act – HERE
- Opinion on the Draft Amendments to the Gambling Act – HERE
- Opinion on the Draft Decree Determining the Minimum Wage for 2027 – HERE
