One apartment,
five different prices.
Asking, market, bank, tax and transaction price. Five numbers, five different laws, and none of them is binding on the others.
The seller sees the first. The buyer with a loan runs into the third. And the only one that really is the price of the property is the last, and it exists only after the deal has happened.
Who produces them and what they are for
The asking price is set by the seller, serves to attract a call and costs nothing. The market valuation is the opinion of an independent appraiser certified under the Independent Appraisers Act (ЗНО) on value as at a specific date; on the open market it costs about €150 for an apartment of up to 150 sq m, ready in 3 to 5 days.
The bank valuation is made by an appraiser approved by the bank and serves as the basis for the loan, not for the price: €120.15, non-refundable. The tax assessment (данъчна оценка) is set by an official of the municipal administration using a formula from the law, for taxes and notary fees; the certificate costs €7.67. The starting price at a public sale (публична продан) is set by an enforcement agent (съдебен изпълнител).
And the sixth: the transaction price, agreed between the two parties. It is the only number that is the price of the property, and it appears last.
“Licensed appraiser”
no longer exists.
Licences were issued until 2008. Under the Independent Appraisers Act the regime is different: a certificate of competence and entry in a public register, a personal seal (Art. 16(2)) and insurance for the professional activity (Art. 18(7)). Only a person entered in the register has the right to practise the profession (Art. 16(1)).
Competence, moreover, is granted by type. Art. 6(1) lists nine types of valuation, and a separate exam is taken for each. A certificate for machinery is no use for an apartment. The register is public, which does not mean anyone checks it.
“The opinion of the independent appraiser is not binding on the client” (Art. 6(3) ЗНО). A valuation is not a price and obliges no one to sell or buy at it.
When a valuation is poor, it is challenged before the Professional Ethics Committee (Комисия по професионална етика) within 14 days of its delivery for the purpose for which it was commissioned (Art. 42). The fine is from €51.13 to €1,533.88, loss of competence is from six months to a year, and three valuations with established breaches lead to removal from the register. A buyer who learns of the problem when the loan is refused a month later is already outside the deadline.
There is no public database of real transaction prices
The comparative method takes sales actually completed, or offers for similar properties, and adjusts them. The adjustments for each difference are the professional part. The problem is what it is fed with.
The Property Register (Имотен регистър) is public, but a search is by a specific property or a specific person, for a fee. Not by neighbourhood, not by type, not by period. No one can ask the question “all three-room apartments sold in Vladislavovo in the last six months, with prices”. The consequence is that the comparative method in Bulgaria is fed mainly by asking prices plus the appraiser’s personal knowledge of real deals.
Even the official statistics of the National Statistical Institute (НСИ), “Market prices of dwellings”, are not a register but a survey among firms that act as intermediaries in deals, in 27 regional cities, for one-room, two-room and three-room apartments, excluding new builds, houses and luxury homes. That is not wrong. It is simply something specific with clear limits, which is not “the price of property”.
And one definition from the Bulgarian Valuation Standards (Български стандарти за оценяване) that settles half the arguments: market value does not take into account advantages that have value for a particular owner or a particular buyer. The renovation to your taste and the view you love do not count.
The listings ask.
The properties are not worth it.
Our snapshot of the market from alo.bg, downloaded on 4 September 2026: €2,805 versus €1,562 per sq m between neighbouring parts of the same district, a 79.6% difference. On the left stands one listing, on the right ninety. The single listing is not wrong: a real property, a real person asking for that money. It is simply not a neighbourhood median.
Counted from the same file: of 185 cells for apartments, 93 rest on fewer than ten listings, and 26 rest on one, with 6,352 listings behind the whole table. For parking spaces, of 18 cells in the whole city only one has at least ten.
And the most common mistake on top of that: asked is not paid. According to a national survey by Address Real Estate (July 2026, methodology unpublished), 54% of sellers in the country have compromised on price over the last six months, by between 2 and 10%. Why else a property sits: the unsold property.
It is not a stricter market valuation. It is something else.
The requirements of Art. 229 of Regulation (EU) No 575/2013 call for the value to be set independently of the loan approval process, on prudent criteria that exclude expectations of price rises, with an adjustment for the possibility that the current market value is significantly above the value sustainable over the term of the loan, and for it not to exceed the market value.
Since 1 January 2025 the text has been rewritten: the two previous anchor concepts have been replaced by a value on prudent criteria, averaged back over six years for residential property. Put simply, the bank by law looks not at what the property is worth today, but at what it will be worth if today turns out to be the peak.
What this costs the buyer, from a public tariff and only to show the order of magnitude: valuation of an apartment €120.15, checking and analysing the collateral for a loan between €50,000 and €100,000 another €205. The fee is not refunded if the transaction is not approved, and the buyer does not choose the appraiser. On a refusal they have lost €325.15 for two numbers that are not theirs. How the whole process moves: The bank said yes. The clock is not yours.
A formula from the law,
not market observation.
TA = BV × Kl × Ki × Kc × Kh × Kd × A (Annex 2 to the Local Taxes and Fees Act (ЗМДТ), Art. 4). Base value, location, infrastructure, individual characteristics, height, depreciation, area. The location coefficient in Varna is between 88.9 and 28.1 depending on the zone.
That is where the finding comes from. The same hypothetical two-room apartment, physically identical, has a tax assessment that differs 3.16 times depending only on which zone caught it. And the zone boundaries are set by a decision of the municipal council, that is, by an administrative line on a map.
For Sofia, two independent publications from summer 2026 give a gap of between five and nine times against the real price, and report that a working group at the Ministry of Finance is preparing the first substantial reform in over 20 years.
The tax assessment does, however, rule in three places, and there it cannot be overridden: the tax base on acquisition is the higher of the agreed price and the tax assessment (Art. 46(2)(1) ЗМДТ), the starting price at a public sale cannot be below it, and a certificate issued before 30 June is valid only until that date. More on the municipal bills: The waste fee costs more than the tax itself.
The median describes a neighbourhood. The deal happens with an apartment.
The floor. The law has an opinion and it is a weak one: the whole difference between the first floor and the third under Table 6 is 8.4%, and the top floor loses more. The market measures the same feature differently. The number from the law is useful precisely because it shows how differently the same feature weighs in the two systems.
The noise. Here there is a standard and it is specific. Under Ordinance No 6 of 26 June 2006 (Наредба № 6), residential zones tolerate 55 dB(A) during the day, and zones affected by rail transport 65. Ten decibels is roughly a doubling of perceived loudness. The same neighbourhood lawfully tolerates both, depending on which way the windows face.
The act. It is not cosmetic but access to money: banks finance about 60 to 70% at Act 14 (Акт 14), 70 to 80% at Act 15 and 85 to 90% at Act 16. Two physically identical apartments in one building have a different circle of buyers. In detail: Act 14, 15 and 16.
The denominator. The same home gives a different number of euros per square metre depending on whether we divide by the built-up area (застроена площ) or by the gross area including the undivided shares (идеални части). The number is not comparable if you do not know what it was divided by: built-up area, gross floor area and the common parts.
Four scenarios
with specific numbers.
Pricing off someone else’s listing. A neighbour lists a property and its number enters the aggregate table as the median for the locality. A seller who lines up with a row that has one listing behind it, without seeing the property type, can go out with a price 84% above their own estimate. The cost of the mistake has been measured: demand peaks by the 14th day after going on the market, and if there are no enquiries by then, the price has been set wrongly (Daniela Grozeva, National Real Estate Association, НСНИ, 3 April 2026).
The valuation comes in below the agreed price. At a price of €96,645 and a valuation of €87,000, the maximum loan at 85% falls from €82,148 to €73,950. The buyer has to find €8,198 on top, usually within two to three weeks.
Expired valuations. Updating a bank valuation from the last six months costs half the fee, which means that after six months it is done again from scratch. A tax assessment certificate issued before 30 June is valid only until that date. A deal dragged out over the summer can end up without a valid bank valuation and without a valid tax assessment, for two different reasons and in different weeks.
Declaring at the tax assessment. It does not work. The base is the higher of the two, the parties declare in the notarial deed (нотариален акт) itself that the recorded sum is the actual payment, in case of eviction by a third party (евикция) the buyer gets back only the declared price, and on resale the tax is calculated from the understated acquisition. A published example: €100,000 declared against a real €200,000, and a later sale for €230,000, gives tax due of €11,700 instead of €2,700.
Frequently asked questions
Who is allowed to value a property in Bulgaria?
Only a person entered in the register of the Chamber of Independent Appraisers and holding a certificate of competence under Art. 7 of the Independent Appraisers Act. The term “licensed appraiser” is outdated: licences have not been issued since 2008. Competence is granted by type, and a separate exam is taken for each type, so a certificate for machinery is no use for an apartment. The appraiser must have a personal seal and insurance for their professional activity.
Is the valuation binding on the price of the deal?
No. Under Art. 6(3) of the Independent Appraisers Act, the opinion of the independent appraiser is not binding on the client. A valuation is an opinion of value as at a specific date, for a specific purpose and under the conditions of a specific market. In an ordinary sale between two people the law does not require a valuation at all.
Why is the bank valuation lower than the price we agreed?
Because by law it is a different thing. The requirements of Art. 229 of Regulation (EU) No 575/2013 call for the value to be set on prudent criteria that exclude expectations of price rises, and for it not to exceed the market value. Since 1 January 2025 the value for residential property is averaged back over six years. The bank looks not at what the property is worth today, but at what it will be worth if today turns out to be the peak.
Why is the tax assessment so much lower than the market price?
Because it is calculated by a formula from Annex 2 to the Local Taxes and Fees Act, not by market observation. For Sofia, publications from summer 2026 give a gap of between five and nine times. The same apartment can have a tax assessment that differs 3.16 times depending only on which zone it falls into, and the zone boundaries are set by a decision of the municipal council. A working group at the Ministry of Finance is preparing the first substantial reform in over 20 years.
Look at how many listings
Before you set a price from an aggregate table, open the row for your neighbourhood and see how many listings stand behind the number. Under ten is not a neighbourhood price. It is a one-minute check, and it saves the conversation that otherwise comes after the fourteenth day.
Send us the address, the floor area and the floor. We send back which median applies to your property, how many listings stand behind it, and where the bank valuation usually stops.
This material is not a property valuation and is not legal advice. A valuation is commissioned from an independent appraiser with a certificate of competence.
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