Act 14, 15 and 16:
what exactly you are buying
In just three months, permits for 1,316 new homes were issued in Varna region. Every one of them goes through the same three acts. They are not a schedule, but three different legal states of the same property.
You are buying walls and a roof.
The law leaves no room for interpretation. Under § 5, item 46 of the additional provisions of the Spatial Development Act (ЗУТ), “rough construction” (груб строеж) is a building or structure in which the enclosing walls and the roof have been completed, with or without varying degrees of finishing works. That is the entire list. Everything else you picture when you hear “apartment” is outside it.
The legal consequence, however, is serious and in the buyer’s favour. Under Art. 181(2) of the Spatial Development Act (amended, State Gazette No. 16 of 2021), once the building has been completed in rough construction, the building or individual units in it can be the subject of a transfer transaction. The completion itself is established by a record which, under the new paragraph 3, is drawn up by the person exercising construction supervision in the presence of the client, the builder, the designer and an official under Art. 223(2). This means the apartment already exists as a separate object of ownership and is transferred with a notarial deed (нотариален акт). Until that moment the subject of the transaction is a building right (право на строеж), not a home.
Until Act 16 (Акт 16) is issued, the building runs on an industrial electricity tariff, not a household one. The renovation you do before commissioning is paid for at the more expensive rate.
The visualisation is not part of the deal
The renders in the project brochure are marketing. What is binding is the approved investment design and the contract, and a mismatch between the design and what is actually built is also one of the typical reasons Act 16 is delayed. The pretty picture and the accepted structure are two different things, and the buyer rarely compares them.
We apply the same principle to our own listings. For two parking spaces in a building in rough construction we deliberately do not make a photorealistic image, but a branded diagram with the explicit caption “Diagram, not a photo”. A buyer who sees a photorealistic image assumes it was photographed. It is a small decision that saves a big disappointment.
The building is finished. Living in it is illegal.
Act 15 (Акт 15) is the record that establishes the construction is fit for purpose, with which it is handed over from the builder to the developer. It confirms that construction was carried out in accordance with the approved designs. The lift works, the plaster is on, the front door locks.
And this is exactly where the most misleading impression in the whole process appears: physical readiness is taken for legal readiness. Living in a building with only Act 15 remains prohibited. The building looks finished and legally cannot be used.
The bank values the property as it currently is, and as long as it cannot be used, the valuation is for an unfinished property. The buyer keeps covering the difference up to the full price.
The document that opens the door.
“Act 16” is the colloquial name for the use permit (разрешение за ползване). For construction of the first, second and third category it is issued by the Directorate for National Construction Control (Дирекция за национален строителен контрол). For the fourth and fifth category, the relevant authority issues a certificate of commissioning (удостоверение за въвеждане в експлоатация). Different categories are accepted by different authorities, and that also shifts the timeline.
Only after this document come lawful occupation, address registration and household electricity. After it is received, the property is declared to the municipality within two months.
The two estimates differ by more than a factor of two, and that is not a mistake by either of them. The law simply sets no deadline. The duration depends on the category of the construction and on how complete the documentation is, which means nobody can guarantee it to you in advance. A promise of a specific month in conversation is not a promise in a contract.
What holds up Act 16
Moving in “temporarily, until the act comes out” is common, and it is a violation. Under Art. 237(1) of the Spatial Development Act, using a construction without that use being permitted in the established manner carries a financial penalty for a legal entity or sole trader of BGN 1,000 to 10,000, which is about €511 to €5,113 at the fixed rate, plus an order prohibiting the use. On top of that, the bank may refuse the final disbursement of the loan, and the property becomes harder to resell, because it is harder to finance.
Each act shifts the weight.
Bank financing grows with each stage, because the collateral becomes more secure. The gap up to the full price does not disappear: the buyer covers it with their own funds, and the earlier the buyer enters the project, the earlier that money is needed.
Seen from the side of your own capital: the cap set by the Bulgarian National Bank (БНБ) for a housing loan is 85% of the valuation (in force since 1 October 2024), which means that even for a finished home at least 15% has to be your own money, and with rough construction the valuation is for an unfinished property.
A schedule that asks for 80 to 90% of the total value before Act 14 (Акт 14) has been described as extremely high risk (according to the Bulgarian News Agency, БТА, 2 June 2026). This is not a discount and not a sign of a confident developer. It is a transfer of the construction risk onto the buyer: you finance the build, and your guarantee is paper.
If the developer goes bankrupt before Act 16.
At that moment it does not matter how much you have paid. What matters is which document you hold.
You join the queue in the insolvency proceedings together with everyone else who has a claim against the company. There is no right in rem over a specific unit.
An incomparably better position. The unit is yours. But the building does not finish itself: the owners join forces and complete the project with additional personal funds.
That is why the real question for the developer is not “when will it be ready”. It is “what document will I hold if it isn’t”. The answer to that question lives in the preliminary contract (предварителен договор) and is settled before signing, not when the problem is already there.
And a little context, so that this does not sound like panic. In the second quarter of 2026, permits were issued in Varna region for 202 residential buildings with 1,316 homes and over 150,800 sq m of gross floor area. Actually started, however, were 150 buildings with 791 homes, with about 15% fewer residential buildings started than in the same quarter of 2025. A permit is not construction, and construction is not Act 16. The distance between the three is exactly where money is made and lost.
A note on accuracy: the penalty under Art. 237(1) of the Spatial Development Act is set in BGN and applies to legal entities and sole traders. It has been converted at the fixed rate of €1 = BGN 1.95583. The timelines for issuing Act 16 in this article are published estimates by practitioners, not a statutory deadline. The law sets no such deadline.
Looking at a property in rough construction?
The BulGhar Homes portfolio has exactly such a property: an apartment in Vladislav Varnenchik with Act 14 from March 2026. We know this stage from the inside, not from a brochure. Which document covers you and which does not is decided before signing.
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