The class does not raise the price yet.
Its absence already lowers it.
Since 1 January 2025 the appraiser records a class even when there is no certificate, and assumes it from the year and the construction.
Three documents everyone confuses and none of them is “for my apartment”
Three documents get mixed up in almost every conversation. An energy performance certificate for a new building (сертификат за енергийни характеристики) is issued on the basis of the design before the building is put into service. A certificate for a building in use is issued after an actual on-site survey. The energy passport is part of the technical passport under the Spatial Planning Act (ЗУТ) and is a third, separate document.
Which leads to the most important sentence on the subject: the certificate belongs to the building, not to the apartment. When a separate unit is sold, the seller provides a certified copy of the building's certificate. There is no such thing as a “certificate for my apartment” that the owner can get on their own in two weeks, because there is nothing to survey separately from the building.
A second clarification, this time of a widespread misreading. Under Art. 38(1) of the Energy Efficiency Act (ЗЕЕ), mandatory survey and certification applies to public service buildings with a gross floor area over 250 sq m and, separately, to buildings in use. The threshold applies only to the first group: if it applied to all, the exception in the same article for detached buildings of up to 50 sq m would be meaningless. This wording has been in the law since the end of 2016. So the common claim that “a certificate is only needed for buildings over 250 square metres” is wrong, and a 60 sq m villa lived in all year round is also covered.
“Valid for ten years”
Only if the building is class A
The law sets the ceiling: a certificate for a building in use is valid for up to 10 years. The Ordinance sets the actual period, and it depends on the class.
10 years for class A and for nearly zero-energy buildings. 8 years for class B. 6 years for class C. And 4 years for classes D, E, F and G.
So the typical unrenovated block that falls into class E has a certificate valid for four years, not ten. The poor building pays more often. Almost every publication in Bulgaria says “valid for ten years”, and that very line is why an owner shows a document from 2019, sincerely convinced it is valid, when it actually expired back in 2023. And once it expires, the obligation does not lapse; it is renewed.
And a new survey is a cost for the condominium (етажна собственост) that requires a decision of the general meeting, while the deal runs on the deadlines of the preliminary contract. In this scenario, time costs more than the document. How such decisions are made and why they also bind the new owner is covered in Condominium Ownership.
Seven classes, not nine and the boundaries are not absolute
The current scale has seven steps, from G to A, based on specific annual primary energy consumption in kWh per square metre per year. For multi-family residential buildings, class A is below 90, class B up to 180, class C up to 235, class D up to 290, class E up to 363, class F up to 435 and class G above 435. For single-family houses the boundaries are lower.
The verbal definitions in the Ordinance are surprisingly blunt. Class D is described as a building with unsatisfactory energy efficiency, class E as poor, class F as the worst. So the average Bulgarian block of flats is officially described as unsatisfactory to poor.
Two caveats that are rarely made. First, the scale is not absolute. The boundaries are set by the cost-optimal method, that is, against reference points for the Bulgarian building stock, so class C in Bulgaria and class C in Germany are not the same number. Second, scales with A+ are no longer in force: the one in force since 2022 has seven classes, from A to G, and websites that write about nine are quoting repealed rules.
Separately, the Ordinance requires all existing buildings not occupied by public authorities to have consumption of at least class B, with class C allowed where this is proven unfeasible. The requirement exists. Enforcing it is another matter.
The penalty that never comes
There is almost no fine for a residential building
Here something reverses the usual expectation. The Energy Efficiency Act expressly penalises the owner of a public service building who fails to meet the survey and certification obligation: from BGN 10,000 to 30,000 for an individual. For a residential condominium without a certificate there is no specific offence.
What remains is the general provision on “other obligations provided for in this Act”, which carries the lowest amounts in the entire law: €255.65 to €766.94 for an individual and €511.29 to €5,112.92 for a company, our conversion from BGN 500 to 1,500 and from BGN 1,000 to 10,000.
By comparison, a certificate issued without an actual survey is punished with a fine of BGN 50,000 to 100,000 and a financial penalty of up to BGN 300,000. A fictitious certificate is treated ten times more severely than a missing one.
The conclusion, however, is not “so there is nothing to fear”, but exactly the opposite: the obligation exists, and the pressure does not come from the fine. It comes from the appraiser and from the buyer's bank. There is one more obligation with the same weak penalty: once a certificate has been issued for the building, the kWh/m² figure must be stated in all listings. Not in the contract and not at the viewing, but in the listing. Renovated blocks already have certificates, yet listings for apartments in them mostly do not show the figure. This is an obligation of the agent and the landlord, not of the buyer.
The blow that is already a fact The appraiser since 1 January 2025
This is the most important part for Bulgarian buyers and sellers in 2026, and it is explained almost nowhere.
The Chamber of Independent Appraisers (Камарата на независимите оценители) and the Chamber of Professional Appraisers (Камарата на професионалните оценители), together with the Sustainable Energy Development Agency (АУЕР), adopted guidelines for appraisers on reflecting the certificate, which took effect on 1 January 2025. What they require: the certificate is among the mandatory documents when a valuation is commissioned; the class must be stated; where there is no certificate, the appraiser must state an assumed class, derived from the type of construction, the year of construction and the climate region; the report must include a market coefficient for energy performance; and a budget for upgrading the class to at least class B must be stated.
The guidelines themselves also publish the table for this budget. From class G to class B: BGN 240/sq m, that is €122.71/sq m, our conversion. From class E to class B: BGN 195/sq m, that is €99.70/sq m. From class C to class B: BGN 152/sq m, that is €77.72/sq m.
The worked example in the guidelines is the shortest possible explanation of the mechanism. Market value after all other adjustments: €2,650/sq m. Cost of upgrading from class C to class B: €77/sq m. Market coefficient: one minus 77 divided by 2,650, that is 0.97. Valuation: 2,650 times 0.97, that is €2,570/sq m.
This is the real price of a missing certificate in Bulgaria, and it is not a fine. Without a certificate, the appraiser does not leave the field blank. The appraiser assumes the class from the year and the construction, and a panel block from 1978 does not get a good assumption. From there, an explicit budget up to class B goes into the valuation and lowers the value. And that valuation goes straight to the buyer's bank. What the construction means on its own is covered in Panel Block or New Build.
The bill that lands at the valuation stage
€8,589 on 70 square metres
Take the most ordinary Varna case. A 70 sq m apartment in an unrenovated block, a buyer with a mortgage, a seller without a certificate.
The appraiser is obliged to state an assumed class. If the approximation reaches class G, the budget up to class B is BGN 240/sq m, which for 70 sq m comes to BGN 16,800, or about €8,589, our conversion. This amount goes into the valuation report as an explicit cost.
From here the arithmetic is familiar. The Bulgarian National Bank (БНБ) cap is 85% of the valuation, not of the price. The valuation drops, the bank lends less, and the buyer has to cover the difference in cash, or the deal falls apart at the valuation stage. The seller usually finds this out two weeks after already committing under a preliminary contract. The full caps are in The BNB Tightened Lending, and the mechanics of the loan in Mortgage Loan Step by Step.
What the certificate itself costs, for comparison. The market quotes per square metre of gross floor area: from €0.70/sq m for large buildings to €1.50 for small ones. An average panel block entrance of 4,000 sq m comes to about €2,800, which matches the published estimate of €2,000 to €3,000 for a whole residential building. Divided by forty apartments, that is about €70 per apartment.
So the document that can cost the seller eight and a half thousand euros in the valuation costs seventy euros per household. The problem is not the price. The problem is that you cannot buy it on your own: the cost is shared, the benefit is individual, and the decision belongs to the general meeting.
The cost a new-build buyer inherits Between the third and the sixth year
New build looks clean on this front. It is not.
Under Art. 33(1) of the Energy Efficiency Act, the developer obtains a certificate for a new building before it is put into service, meaning the document must exist even before Act 16 (Акт 16). The owners are entitled to a copy of the original, which is kept by a person they have authorised. If the developer has gone bankrupt, changed company or does not respond, the copy is sought from the “authorised person”, who often does not exist, and the building pays again for a survey the law had already required to be issued and paid for.
And the second part, which is a time bomb. Under Art. 39(2) of the Energy Efficiency Act, owners of new buildings obtain a certificate for a building in use no earlier than three and no later than six years after it is put into service. So a buyer of an apartment in a building with Act 16 from 2023 is also buying an on-site survey that falls due by around 2029. For the whole building it costs €2,000 to €3,000. The buyer of a “new build” also buys this cost without having seen it in the price.
There is also the reverse, positive link, which we only note here: validity under the Energy Efficiency Act runs from the date of issue, and in cases under the Local Taxes and Fees Act (ЗМДТ) from the beginning of the following year, so a certificate with a good class can bring an exemption from building tax. Under Art. 24(1), items 18 and 19 of the Local Taxes and Fees Act, a building from before 2005 with class A is exempt for 6 years, and a nearly zero-energy building for 10 years, in total no more than 10 years (para. 6). For the tax itself, see Building Tax and Waste Fee.
Does the class affect the price
The honest answer, without imported numbers
There is no Bulgarian study with a published methodology that measures a price premium by energy class. The search did not return one, and claims of a “15 to 20% premium in Bulgaria” appear in marketing publications with no methodology and no sample. That is why there is no such number here.
There is a European review from 2025 of 68 studies which finds a premium of up to 13.3% for homes in classes A and B compared with class C, and a discount for F and G. This is a Western European result, from markets with twenty years of certificate history. It does not carry over as a Bulgarian number.
The only Bulgarian mechanism that really turns class into money is the appraisal. And it is not a premium for a good class, but a deducted budget for a poor one. So the precise wording is this: in Bulgaria the class does not raise the price yet; its absence already lowers it, and it does so in the valuation.
What is coming. The 2024 European directive on the energy performance of buildings requires for the housing stock not a ban, but a national trajectory for gradual renovation, with average consumption falling by at least 16% compared with 2020 by 2030. Minimum standards with thresholds exist only for non-residential buildings. Bans on renting out the worst classes are national decisions of individual countries, the best known being the French one, and they do not apply in Bulgaria.
Bulgaria has not yet transposed this directive into law: on 15 July 2026 the European Commission opened infringement procedures with letters to all 27 member states, and on 24 July 2026 the Ministry of Energy (Министерството на енергетиката) published for public consultation a draft amendment to the Energy Efficiency Act, which closed on 23 August 2026. Its explanatory memorandum contains no new regime for residential certificates in transactions. What the media described in July as “a new bill obliges owners to certify their homes before sale” has been law in force since 2016; it simply is not enforced.
One thing, however, will catch out even the well prepared. The scale under the new directive is built differently: class A corresponds to a zero-emission building, class G to the worst in the national stock. So the boundaries move, and today's class is not tomorrow's class for the same building.
Frequently asked questions
Is an energy performance certificate mandatory when selling an apartment?
Yes, but the obligation is on the building, not on the apartment. Under Art. 41 of the Energy Efficiency Act, when a separate unit is sold, the seller provides the buyer with a certified copy of the building's energy performance certificate, and when it is rented out, the landlord provides a copy to the tenant. Separately, if a certificate has been issued for the building, the kWh/m² figure must be stated in all listings. The obligation is not new: it has been in the law since 2015 and was extended from the end of 2016, not from 2025, as is often claimed.
How many years is an energy certificate valid?
It depends on the class, and it is not always ten years. Under the Ordinance, validity is ten years for class A and for nearly zero-energy buildings, eight years for class B, six years for class C and four years for classes D, E, F and G. So the typical unrenovated block in class E has a certificate valid for four years. Once validity expires, the owner is obliged to obtain a current one, and the new survey itself is a cost for the condominium and requires a decision of the general meeting.
What happens in a transaction if there is no certificate?
A fine hardly ever follows: the law expressly penalises only the owner of a public service building, and for a residential condominium only the general offence remains, with the lowest amounts in the law, from €255.65 to €766.94 for an individual. The real cost comes from elsewhere. Since 1 January 2025, the guidelines for appraisers require that, where there is no certificate, the appraiser states an assumed class based on the construction, the year and the climate region, and must enter a budget for upgrading to at least class B. For class G this is about €122.71 per square metre, or about €8,589 for a 70 square metre apartment, and this amount weighs on the valuation that goes to the buyer's bank.
How much does an energy certificate cost and who issues it?
It is issued only by firms entered in the public register of the Sustainable Energy Development Agency, with energy efficiency consultants who meet the requirements for education, experience and qualification. The price is quoted per square metre of gross floor area, from about €0.70 for large buildings to about €1.50 for small ones, so an average panel block entrance of 4,000 sq m comes to about €2,800, or about €70 per apartment across forty units. The problem is not the price, but that the document cannot be bought individually: the cost is shared, the benefit is individual and the decision is taken by the general meeting of the condominium.
Buying or selling
in Varna?
Tonight, check whether the listing shows a figure in kWh/m². If the building has been renovated or is a new build and the figure is missing, the document either does not exist or nobody has looked at it. If the seller shows a certificate, look at the date of issue and the class: for class E, validity is four years, not ten.
Send us the link to the listing, the year of the building and a photo of the certificate, if there is one. We send back an assessment of which class the appraiser will most likely assume if there is no document, what budget up to class B will go into the valuation report, and how this affects the amount the bank will lend.
The assessment is commercial and practical, not an appraisal report and not an energy efficiency survey. Amounts in BGN have been converted at the fixed rate of 1 EUR = 1.95583 BGN.
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