€5,112.92.
And that very amount is a breach.
The threshold was not chosen in euros but converted from the lev, and the amount itself is already on the other side of the line, not a ceiling you can go up to.
The threshold is not a round number and that is exactly why it gets missed
The limit beyond which cash payment within the country is prohibited is €5,112.92. The number looks odd because it was not chosen. It is a remnant of the lev: the threshold in the Limitation of Cash Payments Act (Закон за ограничаване на плащанията в брой) used to be BGN 10,000, and 10,000 divided by the fixed rate of 1.95583 gives 5,112.9188.
Two details in this limit do more work than the number itself.
The first: the threshold is counted inclusively. So €5,112.92 is not a ceiling you can go up to, it is already on the other side of the line. Up to €5,112.91 can be paid in cash.
The second: the law does not ban banknotes, it bans cash payment between the parties. The text requires the payment to be made by transfer or by deposit into a payment account. A buyer who goes to a bank counter and deposits the amount into the seller’s account has complied with the law, even though they carried the money in an envelope. What matters is the operation and the trail it leaves, not the vehicle that carried the money.
The practical consequence is unpleasantly simple. The deposit (капаро) in a property deal is almost always around 10 per cent of the price. Above a price of around €51,000 the standard deposit is already over the threshold, which means almost the entire Varna market is there. And a parking space for €15,000, which feels like a small sum and rarely goes through a lawyer, is nearly three times over the limit.
“We’ll split it into three instalments”
the most expensive sentence on the subject
The law anticipates exactly this move. Besides payments above the threshold, it also covers payments below the threshold when they are part of related payment operations on one and the same basis whose total value reaches the threshold.
The test is not the amount but the basis. One contract is one basis. Three instalments of €5,000 under one preliminary contract (предварителен договор) are not three payments below the threshold. They are one payment of €15,000, made in cash.
The effect is twofold. First, the base for the penalty becomes the whole amount. Second, splitting adds something that is evidence in itself: three instalments that stopped just below the threshold, under one contract, look exactly like what they are.
Where the line of “related” runs is not defined in the law. It is drawn case by case, and the revenue administration has given opposite answers for different situations: for a lease agreement the value for the term of the contract is added up, while for a dividend distributed by separate decisions each payment is treated on its own. The difference is again the basis: one contract against two separate decisions.
So the most important part of the rule is not in the text of the law but in its interpretation. That is why this topic is not for self-service. How the deposit itself is structured is described in The preliminary contract.
The fine is calculated on the whole payment not on the excess
The penalty is a percentage, and people usually assume the percentage applies to the amount above the threshold. It does not.
Individual: a fine of 25 per cent of the total amount of the payment made. Legal entity: a financial penalty of 50 per cent. For a repeat offence, 50 and 100 per cent respectively. Penalty decrees are issued by the National Revenue Agency (НАП).
€20,000 paid in cash is not fined on the excess of nearly €15,000. It is fined on €20,000, which means €5,000. A deposit of €8,500 on a property for €85,000 carries a fine of €2,125 for the buyer.
And here comes the second thing that is rarely read to the end. The law punishes two acts: whoever makes or allows the payment to be made. These are two different kinds of conduct, not one. So the recipient of the money is also exposed, and if the seller is a company, the penalty for it is double as a percentage. In the same example: €2,125 for the buyer and €4,250 for the company seller, a total of €6,375 on a single instalment, for nothing.
Whether the recipient in particular will be penalised also depends on how the statement of offence was drawn up. There is case law holding that a penalty decree which does not specify which of the two forms is being charged suffers from a material procedural breach. But that is a defence in proceedings that have already started, not a reason to count on their outcome.
The more expensive half: you paid and you have nothing
The fine is predictable. It is calculated with a calculator and known in advance. The other risk is not, and that is exactly why it is the bigger one.
Art. 164(1), item 3 of the Civil Procedure Code (ГПК) does not admit witness testimony to establish contracts worth more than €2,556.46, except between spouses and close relatives. Item 4 does not admit it to prove the repayment of monetary obligations established by a written instrument, and item 6 to refute the content of a private document issued by the party. Testimony on these points is admissible only with the express consent of the opposing party, given before the court.
Read the last sentence once more. To prove the payment with witnesses, the buyer needs the seller’s consent. A seller who denies the payment will not give it.
What remains is the receipt. It is a private document, and the other party can challenge the authenticity of the signature, which leads to proceedings under Art. 193 of the Civil Procedure Code, a handwriting examination, adjournments and costs. The bank statement is incomparably stronger, because it is a document of a third party with no interest in the dispute, and the payment reference turns “received money” into “received this money for this”.
The asymmetry is the whole topic: a cash payment leaves nothing against the seller and everything on the buyer, because the buyer is the one who has to prove they paid. If the deal falls apart and it comes to a claim for the return of the deposit or for double its amount, the first step is not the dispute on the merits but proving that anything was paid at all.
One word with two meanings and its price has five digits
In the everyday language of the market, “cash” means without a mortgage, that is, with one’s own funds. Legally, “in cash” means banknotes. The two meanings diverge, and most breaches are born exactly in that gap.
A seller hears “the buyer is paying cash”, understands “bringing the money”, and they agree on a handover in cash. Nobody meant to break anything. A buyer with a budget of €40,000 in own funds who really pays in banknotes faces a fine of €10,000, plus no proof of payment, plus a declaration of the origin of funds that has to explain where €40,000 in cash came from.
The problem with words does not end here. The exceptions where the law does not apply at all are listed exhaustively and there are seven: withdrawals and deposits from one’s own accounts, the same for accounts of persons lacking legal capacity, spouses and relatives in the direct line, foreign currency transactions carried out as a business, operations with the Bulgarian National Bank (БНБ), exchange of damaged banknotes, wages under the Labour Code (Кодекс на труда), guaranteed deposits.
None of them covers a property deal. There is no exception “between relatives”, no “between private individuals”, no “this is only a deposit, not the deal itself”. The item on relatives covers deposits and withdrawals from a relative’s account, not payment of a price under a contract.
The most harmless monthly payment on the market
Rent of €490 a month is far below the threshold and nobody sees it as a problem. Over a year, however, it comes to €5,880, which is above the threshold.
According to the revenue administration’s interpretation, the value of a lease agreement is assessed for its term, and for an open-ended agreement for one year. Once the total value reaches the threshold, every monthly payment has to go through a bank, even though the monthly instalment is far below it. On this reading, a tenant who paid by hand for a whole year is looking at a base of €5,880 and a fine of €1,470, which is three times the monthly rent.
Here it is important to be honest: this is an interpretation, not the letter of the law. It depends on the term of the contract and on its wording. And that is exactly why it is a good example: the most ordinary payment on the market can be a breach, and the answer depends on a document the tenant has never read carefully, and on administrative practice that is not in the law.
A cash payment does not disappear from view it remains unexplained
An agent in property transactions is an obliged entity under the Measures Against Money Laundering Act (Закон за мерките срещу изпирането на пари). This is not a passing formality: identification by an official document, establishing the beneficial owner, customer due diligence for an occasional transaction of €15,000 or more, and for a cash payment of €5,000 (Art. 11(1), item 3 of that Act, from 1 January 2026), a declaration on politically exposed persons, a declaration of the origin of funds, reporting on suspicion, and keeping the file for five years after the end of the relationship.
The declaration of origin asks for specifics, not the word “savings”: for an inheritance, the year of acquisition and details of the deceased; for savings, the period and the source; for income from an activity, the period and the counterparty. It is signed with an expressly stated criminal liability for declaring false circumstances.
And here is the link that makes a cash payment more expensive than it looks. Buying a property is exactly the event that makes the mismatch visible. The property is registered, declared at the municipality, and enters the tax profile. If a person’s assets do not match the declared income, the revenue administration can carry out an audit under the special procedure, and there the findings in the audit report are deemed true until proven otherwise. It is not the administration that proves the money is unexplained, it is the person who proves it is explained.
The heaviest combination is the classic one: an understated price in the notarial deed (нотариален акт) and the difference in an envelope. Four separate risks pile up at once, and the most expensive is not the fine. If the deal is rescinded, the buyer gets back the declared price, because the difference does not exist on paper. What is actually owed on a sale is described in When you pay tax on selling a property, and when you don’t.
And the new European ceiling will not help you
From 10 July 2027, a ban on cash payments of €10,000 or more will apply across the whole European Union. The number is already doing the rounds in the news, and it produces exactly the wrong conclusion.
Two things about it.
First, the Bulgarian threshold is and remains lower. €5,112.92 against €10,000. The European ceiling is a minimum standard, not a permission, and member states can introduce lower thresholds. The Netherlands, for example, has already gone down to €3,000 for physical goods.
Second, the scope of the European rule is narrower than the Bulgarian law. It applies when at least one party acts in the course of business, and it does not apply between private individuals. The Bulgarian law has no such limitation: it also covers a deal between two neighbours.
The buyer who heard on the news that “the limit in Europe is 10,000 euros and it does not apply between private individuals” is exactly the person who will pay a deposit in cash and then pay a fine.
This is also the essence of the whole topic. The threshold is one sentence, but around it stand an interpretation that is not in the law, a penalty calculated on the whole amount, and a rule of evidence that leaves the buyer alone. The choice of payment method is not a technical detail on the day of signing but a decision made before the contract.
Frequently asked questions
What is the maximum amount that can be paid in cash in a property deal?
Payments within the country are made only by transfer or by deposit into a payment account when their value is equal to or exceeds €5,112.92. So up to €5,112.91 can be paid in cash, and the amount of €5,112.92 itself is already a breach, not the limit. The threshold comes from the former BGN 10,000 at the fixed rate of 1.95583, which is why the number is not round. The law does not, however, ban banknotes as such: depositing the amount into the recipient’s account at a bank counter meets the requirement, because the operation goes through a payment account.
Can the amount be split into several instalments below the threshold?
No. Besides payments above the threshold, the law also covers payments below it when they are part of related payment operations on one and the same basis whose total value reaches the threshold. The test is not the size of the individual instalment but the basis: one contract is one basis. Three instalments of €5,000 under one preliminary contract are treated as one payment of €15,000, and the fine is calculated on the whole amount. Splitting does not reduce the risk and adds a circumstance that looks exactly like circumvention.
How large is the fine and on what amount is it calculated?
For an individual the fine is 25 per cent of the total amount of the payment made, and for a legal entity the financial penalty is 50 per cent. For a repeat offence the amounts become 50 and 100 per cent respectively. Penalty decrees are issued by the National Revenue Agency. The base is the whole amount paid in cash, not the excess over the threshold: with €20,000 in cash the fine for an individual is €5,000. The law punishes both the one who makes and the one who allows the payment, so both parties are exposed.
How is a cash payment proven?
With difficulty, and this is the more expensive half of the risk. Under Art. 164(1) of the Civil Procedure Code, witness testimony is not admissible to establish contracts worth more than €2,556.46, to prove the repayment of monetary obligations established by a written instrument, or to refute the content of a private document. Testimony in these cases is admissible only if the opposing party expressly agrees before the court, and the party that denies the payment will not agree. What remains is the receipt, whose authenticity can be challenged and lead to a handwriting examination. The bank statement is the strongest evidence, because it comes from a third party with no interest in the dispute, especially when the payment reference names the contract.
Is the deposit next week?
Check the basis, not the amount.
Open the preliminary contract and look at three things: which account the payment goes to, what the payment reference is, and whether there are other payments under the same contract that add up with this one. If the amount is split into instalments, add them together before deciding that you are below the threshold.
Send us the contract and the deposit amount. We come back with whether the payment falls within the threshold, which instalments add up on one basis, and what remains unproven if the payment does not go through an account. If the case is borderline, we will tell you that the answer needs a lawyer, not a calculator.
This material is general information as of December 2026, it is not legal or tax advice and does not replace a lawyer. Thresholds and penalties should be checked in the official text of the law as of the date of payment.
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