Bulgaria is emerging as one of the most dynamic markets for energy investment in South-East Europe, driven by ambitious EU decarbonisation targets, a rapidly expanding renewable energy sector, and a regulatory environment that, whilst complex, is progressively aligning with international standards. For investors seeking to develop, finance, or acquire energy assets in Bulgaria, a clear understanding of the legal landscape is essential — not only in relation to energy regulation itself, but also across the interconnected disciplines of project financing, real estate and zoning, foreign direct investment screening, and mergers and acquisitions. This guide brings together five perspectives on doing business in Bulgaria, each addressing a distinct area of law that is critical to the successful implementation of energy and infrastructure projects. Together, they offer a comprehensive overview of the opportunities, challenges, and legal considerations that shape the Bulgarian market for energy sector participants.
Chapter 1: Overview of The Energy Sector
Bulgaria’s energy sector is undergoing a significant transformation driven by EU decarbonisation policies and increased renewable energy deployment. Recent legislative reforms and policy initiatives are aimed at accelerating the energy transition and improving investment conditions.
Market trends and policy direction
Bulgaria has experienced rapid growth in renewable energy capacity, particularly in solar photovoltaics, with installed capacity exceeding 4.7 GW and continuing to expand at pace. This growth reflects both EU-driven targets and domestic efforts to diversify the energy mix and reduce reliance on fossil fuels.
The government’s updated National Energy and Climate Plan (NECP) sets ambitious targets – 34.96% share of renewable energy in the gross final energy consumption. In the power sector specifically, Bulgaria targets a 49.34% share of renewables in gross final electricity consumption. Achieving this level will require an expansion of renewable generation, primarily through new wind and solar capacity. At the same time, policy discussions increasingly focus on grid modernisation, energy storage integration, and the development of new technologies such as hydrogen and digital infrastructure.
Despite these positive trends, structural challenges remain. Bulgaria’s electricity system is under pressure from rapid renewable integration combined with an ageing grid infrastructure, requiring significant investment in transmission and distribution networks.
Grid connection: evolving regulatory framework
Grid connection remains one of the most critical issues for renewable energy investors in Bulgaria. The regulatory regime is governed primarily by the Energy Act and Ordinance No. 6 dated 28 March 2024 for connection to the electricity grids (Grid Connection Ordinance).
The Grid Connection Ordinance allows greater flexibility in initiating grid connection procedures. Notably, developers may apply for grid connection based on preliminary agreements for land acquisition rights or decisions of the municipal council granting construction rights, rather than requiring full ownership at the outset. Further, a new amendment of the Grid Connection Ordinance is expected, which will regulate the possibility of joint use of transmission capacity by several network users, the development of co-located electricity storage facilities when the connected capacity of the production facility does not change and the connection of production facilities when they are planned to include different types of generating capacities.
At the same time, financial guarantees (bank guarantee or deposit) for grid access have been introduced in the amount of EUR 25,565 per MW of requested capacity. This measure is intended to deter speculative grid access applications and ensure that reserved grid capacity is utilised by viable projects.
Acceleration areas for wind projects
In March 2026, the Ministry of Environment and Water published a draft Plan for the development of accelerated areas for wind energy. The Plan emphasises that the accelerated areas represent a strategic tool for optimising the permitting procedures in territories with low environmental risk. The Plan also states that the acceleration areas do not exclude the possibility of developing wind farms outside the territories included in the accelerated areas, provided that all requirements of the applicable legislation are complied with. In terms of grid connection, the accelerated areas have 463 MW of capacity under preliminary contracts, as well as 1,615 MW of potential for new connections. The total capacity for all zones amounts to 2,078 MW.
Energy storage
Energy storage, especially battery energy storage systems (BESS), is emerging as a central component of Bulgaria’s energy transition. As recently as 2024, Bulgaria had no utility-scale BESS; however, the sector has since undergone rapid development, with over 10 GW of projects currently in the pipeline. This growth is driven not only by the availability of subsidies, but also by streamlined permitting procedures and investment-friendly regulatory conditions. Permitting timelines are typically under one year, enabling projects to progress from concept to commissioning in less than two years. Notably, electricity storage activities are not subject to licensing requirements, and double charging of grid fees does not apply. The regulatory framework also allows BESS operators to participate in wholesale electricity markets and provide ancillary services to the transmission system operator. At the same time, the expansion of solar generation capacity has significantly reduced daytime electricity prices, increasing the importance of BESS for arbitrage and system balancing.
Against this backdrop, a notable emerging trend is the co-location of BESS with data centres, driven by the rapid growth in electricity demand from digital infrastructure. Storage enables data centres to secure reliable, 24/7 power supply, manage peak demand, and mitigate grid connection constraints, which are becoming a key bottleneck for new developments. The Bulgarian legislation already contains specific regulations for data centres. In 2025 the Energy Efficiency Act introduced the obligation for operators of data centres with a capacity exceeding 500 kW to publicly disclose data related to the energy efficiency of the facility on an annual basis.
To conclude, Bulgaria offers significant opportunities for renewable energy and digital infrastructure investors, supported by EU funding, growing electricity demand, and an evolving regulatory framework.
Key opportunities include:
- Expansion of solar and wind capacity;
- Development of battery storage and hybrid projects;
- Co-location of renewable assets with industrial consumers and data centres.
At the same time, investors must navigate a complex and evolving regulatory environment, particularly in relation to grid access, permitting, and environmental compliance.
Overall, whilst challenges remain, Bulgaria is positioning itself as an increasingly attractive market for energy transition investments, particularly for developers capable of managing regulatory complexity and adopting integrated, multi-technology solutions.
Chapter 2: Project Financing
The rapid expansion of renewable energy capacity and the emergence of BESS as a distinct asset class, described in the preceding chapter, have been accompanied by a significant deepening of the project finance market in Bulgaria. The structures, participants, and documentation employed in financing these projects are critical to their viability and to investor confidence. This chapter examines the key features of renewable energy project financing in Bulgaria.
Transaction Structuring
The typical ownership structure in Bulgarian renewable energy projects is built around a special purpose vehicle model that will be familiar to international project finance practitioners. At its core sits the project company, a local legal entity established specifically and solely for the construction and operation of the project. In the majority of cases, this entity takes the form of a limited liability company, though it may also be structured as a joint-stock company with registered shares. The project company owns all project assets, including the land or in the majority of cases only the building rights over the land on which the project is constructed and, where required, the renewable energy production licence. It also serves as the principal borrower under the project financing arrangements and acts as the counterparty under the main project documents.
Above the project company sits the direct shareholder, whose role in the financing structure is to provide additional funding, typically in the form of subordinated shareholder loans or equity contributions. Further up the ownership chain, the sponsor, usually an indirect shareholder or ultimate beneficiary of the project company, plays a critical role. The sponsor is expected to possess sufficient expertise, financial resources and experience in the implementation and operation of the project. Whilst the sponsor may also contribute additional financing through subordinated loans, its function as a guarantor for the overall success of the project is of paramount importance in securing lender confidence. Depending on the ownership structure, other affiliates of the project company may also be engaged as security or guarantee providers.
The documentation employed in Bulgarian renewable project financings is to a large extent adopted from internationally recognised standards. Large-scale transactions typically feature a facilities agreement under which one or more types of facility are made available, such as term and revolving loans, letters of credit and bank guarantees. These are complemented by security and hedging agreements, equity contribution and subordination arrangements, and a suite of project documents required for the development and operation of the renewable asset, including grid connection and access agreements, EPC and O&M contracts, balancing agreements and power purchase agreements. The tenor of project finance debt varies depending on the scale and type of the renewable project, but financing is generally provided for a period of no less than ten to twelve years. Lenders take careful account of the time necessary for the full development of the project and its long-term viability when determining the appropriate debt maturity profile.
Market Participants
Commercial banks are the most active participants in Bulgaria’s project finance market, with development banks, predominantly international institutions, following closely behind. Even where development banks do not act as principal lenders, they very often participate in transactions as guarantors, providing an additional layer of credit support. Investment funds have also entered the market, primarily offering financing in the form of secured bonds. A noteworthy development in recent years has been the increasingly active involvement of Bulgarian commercial banks as lenders. Historically, the largest renewable energy projects were financed primarily by international commercial or development banks. The growing participation of domestic institutions has inevitably deepened the project finance expertise within the Bulgarian banking sector and made the market more accessible for local and smaller-scale renewable energy developers.
The Rise of BESS Financings
Perhaps the most significant recent development in the Bulgarian renewable energy financing landscape is the emergence of battery energy storage systems (BESS) as a distinct asset class attracting project finance attention. BESS projects are increasingly recognised as essential infrastructure for supporting the integration of intermittent renewable generation into the grid and for providing ancillary services such as frequency regulation and peak shaving. From a financing perspective, BESS projects in Bulgaria broadly follow the established project finance structures described above, with a dedicated project company, sponsor support and security packages modelled on those used for solar and wind developments. However, BESS financings present certain distinctive considerations. Revenue streams for storage projects may derive from a combination of energy arbitrage, capacity market participation and ancillary service contracts, creating a more complex revenue profile than a traditional renewable generation asset underpinned by a single power purchase agreement. Lenders must therefore undertake more nuanced due diligence on the bankability of these revenue sources and the technological risks associated with battery degradation and performance over the life of the financing.
The growing pipeline of BESS projects in Bulgaria reflects both the maturation of the country’s renewable energy market and the broader European trend towards energy storage as a critical component of the energy transition. As Bulgarian and international banks gain further experience in structuring and underwriting BESS transactions, the expectation is that this segment will continue to expand, attracting a wider pool of capital and further diversifying the country’s renewable energy financing market.
To conclude, Bulgaria’s renewable energy project finance market is at an inflection point. The combination of active greenfield development, deepening domestic banking expertise and the emergence of BESS as a financeable asset class suggests a market that is maturing rapidly. Whilst official data on the overall size of the renewable project finance market remains unavailable, the trajectory is clear: Bulgaria is positioning itself as an increasingly attractive destination for renewable energy investment in South-East Europe.
Chapter 3: Real Estate and Zoning
As noted in the preceding chapters, the project company typically holds building rights over the land on which the energy facility is constructed, and securing adequate land rights is a precondition for both grid connection and project financing. The real estate and zoning framework in Bulgaria is therefore of fundamental importance to the viability of any renewable energy or battery storage investment. This chapter examines the key considerations that developers must address in structuring their land position and navigating the planning process.
Whilst much attention is often given to licensing and grid connection, the success of any project depends heavily also on navigating real estate rights and zoning procedures — prerequisites for construction and key determinants of project timelines, financing, and overall bankability.
Rights over land
At the core of every RES or BESS project lies the need to secure adequate rights over proper land. Bulgarian law provides several mechanisms through which developers may structure their land position, most notably full ownership and the right to build (superficies right). In practice, developers frequently rely on the right to build, usually established for a fixed term (e.g. 35–45 years), allowing them to construct, own, and operate energy facilities on third-party land without acquiring full ownership. Upon expiry of the right to build, ownership of the facility passes to the landowner at no cost. This approach is particularly relevant in large-scale projects where land consolidation may be complex or costly.
The type of land also matters. Private land offers the greatest flexibility. It is not uncommon, however, that projects are developed also on municipal land, where authorities may grant building rights directly — often without a competitive tender — subject to compensation. Special attention is required for agricultural land, pastures, and land under Article 19 of the Agricultural Land Ownership and Use Act (“ALOUA”). These categories are frequently targeted for RES and BESS development but are subject to special legal regimes affecting the establishment of building rights, including pre-approval conditions and specific rules on disposal and encumbrance. Despite higher legal complexity, such lands remain attractive due to their availability and scale, though developers must factor in longer lead times compared to urbanised or industrial land.
Easements also play a central role in energy project development. Under the Energy Act, energy infrastructure benefits from a special easement regime allowing developers to construct and operate grid connection facilities and transmission lines across third-party land. These easements are not automatic: they require approval of a parcelling plan and payment of market-value compensation to affected landowners before taking effect, creating a structural dependency between zoning procedures and infrastructure development. Easements must also be registered in the Property Register to be enforceable against future owners.
Zoning
Zoning is governed by the Spatial Development Act (“SDA”), which establishes a hierarchical planning framework consisting of general development plans (GDPs) at the municipal level — setting the overall structure, predominant land use, and technical infrastructure parameters — and detailed development plans (DDPs) for specific projects, determining permitted use and building parameters. Where a GDP is in force, the DDP must be aligned with it; otherwise, a GDP amendment procedure must be initiated in parallel.
For agricultural land — common in RES projects — a mandatory change of designation to non-agricultural use is required under the Agricultural Land Protection Act. Recent legislative changes require a Ministry of Energy opinion to ensure alignment with national targets, whilst exemptions previously available for agrivoltaics were annulled by the Constitutional Court. The zoning and land designation change procedures involve environmental assessments, coordination with multiple authorities, and public consultations, making them both time-consuming and unpredictable. The role of municipalities cannot be overstated. Whilst many actively support RES investments, others have adopted a more cautious approach, adding further uncertainty.
Once zoning requirements are met, developers must obtain a building permit under the SDA, which requires approved zoning plans, secured land rights, and approved technical designs. The final step is commissioning — obtaining a use permit (Act 16) confirming that construction has been completed in accordance with applicable regulations and that the facility is safe for operation. Only after this permit is issued can the project begin commercial operations. Simplified procedures may apply to smaller installations, but large-scale projects must undergo the full inspection and approval process.
BESS Particularities
Battery storage projects follow largely the same real estate and zoning framework as RES projects. Although in some limited cases BESS may be considered as movable property benefitting from a less restrictive and time-consuming regime, BESS are treated as energy infrastructure and in general require a building permit and commissioning document following the same procedure as RES projects. If co-located with a solar or wind facility, BESS may be included in the same DDP and building permit. Stand-alone BESS projects outside regulated territory require a separate DDP.
Investors should pay particular attention to several recurring risks: fragmented ownership and existing encumbrances can complicate land acquisition; zoning procedures may be delayed by administrative bottlenecks or municipal resistance; and easement establishment often depends on the timely completion of zoning steps. These risks can directly affect project timelines and the validity of preliminary grid connection agreements. A well-structured approach to land acquisition, early engagement with local authorities, and strategic coordination of zoning and permitting processes are essential to unlocking the full potential of the Bulgarian energy market. In parallel with these challenges, Bulgaria is taking steps to align with EU requirements by introducing priority zones for renewable energy development (wind projects in particular). Although still being developed, the framework, once adopted, is expected to accelerate project timelines and offer greater certainty to investors.
Chapter 4: Foreign Direct Investment Screening
Foreign investors entering the Bulgarian energy market — whether through greenfield development, project acquisition, or the financing structures described in Chapter 2 — must also navigate Bulgaria’s foreign direct investment screening regime. Given that energy storage, critical infrastructure, and the supply of energy are all within the scope of the screening mechanism, the FDI framework is of particular relevance to energy sector participants. This chapter sets out the key features of the regime.
Occupying a strategically significant position that continues to attract the attention of foreign investors, Bulgaria has progressively aligned its legal and regulatory framework with EU standards. Bulgaria’s introduction of a foreign direct investment (“FDI”) screening mechanism represents its most consequential step in this respect. In 2024, the Bulgarian parliament adopted the final text of a bill to amend the Investment Promotion Act (the “Act”), implementing the screening mechanism outlined in Regulation (EU) 2019/452 (the “EU FDI Screening Regulation”). Whilst the Act entered into force on 12 March 2024, it became fully applicable on 22 July 2025, rendering the Bulgarian FDI screening regime fully operational since then. Any foreign direct investment, subject to screening under the Act, is to be approved by the newly established Interministerial Council for Screening of Foreign Direct Investments (the “Screening Council”).
General Screening Criteria
The Act borrows heavily from the EU FDI Screening Regulation, and requires prior screening of any foreign direct investment that directly or indirectly originates from a non-EU investor, as well as from an EU investor with ultimate non-EU control. More specifically, the status of a “foreign investor” in accordance with the Act attaches to (i) non-EU persons or entities but also (ii) EU entities, in which control is exercised directly or indirectly by one or more non-EU natural or legal persons, and (iii) EU entities, in which, by virtue of a contract or internal rules, one or more non-EU (natural or legal) persons have direct or indirect control over the specific investment, or where an FDI is made on the EU entity’s own name, but on behalf of a non-EU person or entity.
Apart from the “foreign” status of the investor, before the FDI screening regime comes into play, two conditions must be fulfilled cumulatively: (1) the investment must concern an activity or sector that falls within the prescribed scope of the legislation, and (2) the investment must reach the applicable financial threshold.
Sectoral Scope
A mandatory FDI filing is triggered if the FDI targets any of the industries listed under Article 4, para 1 of the EU FDI Screening Regulation, including in particular (i) critical infrastructure, (ii) critical technologies and dual use items (such as AI, semiconductors, robotics, aerospace, defence, energy storage, quantum and nuclear technologies), (iii) supply of critical inputs, including of energy and raw materials, and including activities related to oil and petroleum products, as well as food security, (iv) access to sensitive information, including personal data, or the ability to control such information, and freedom and pluralism of the media. Notably, the FDI regime applies where the target engages in cross-border business into Bulgaria and the target is active in the relevant activities.
Financial Threshold
The second condition is for the investment to involve the acquisition of at least 10% of the capital of an enterprise operating in Bulgaria, or to exceed EUR 2 million in value.
Nature of the Investment
Drawing from the EU FDI Screening Regulation, the Bulgarian FDI regime covers any FDIs aimed at establishing or maintaining a lasting and direct link in order to carry on business in Bulgaria, including effective participation in the management or control of a company carrying on business in Bulgaria. In addition, it captures the expansion of an existing investment and “new” (greenfield) investments. The Act explicitly excludes purely passive (portfolio) investments from the scope of the FDI regime.
Specific Foreign Direct Investments Subject to Screening in All Cases
Certain investments, irrespective of the above conditions being met, trigger an FDI screening under the new regime in all cases. Subject to screening are all FDIs related to the production of petroleum energy products and petroleum products at facilities that are part of or adjacent to critical infrastructure, and all FDIs made by foreign investors from Russia and Belarus.
Low-Risk States
In addition to EU investors, the Act introduces certain non-EU states that are deemed “low risk” and included in a list to be adopted by the Bulgarian Parliament, along with investors from the United States of America, the United Kingdom of Great Britain and Northern Ireland, Canada, Australia, New Zealand, Japan, the Republic of Korea, the United Arab Emirates and the Kingdom of Saudi Arabia, the Swiss Confederation and any country that is a member of the Agreement on the European Economic Area (EEA) (collectively, “Low-risk states”). Whilst there is some uncertainty around this provision, it appears from practice that investors from these states are not exempt from a filing obligation (subject to the respective conditions being met), but they may benefit from a simplified or expedited review process.
Proceedings
An application is addressed to the Screening Council through the Invest Bulgaria Agency (“IBA”), acting as a screening body and formally reviewing the application. Upon receiving a complete application for the approval of a foreign direct investment, the Screening Council will have 45 calendar days to review the application in substance and issue a decision. The review period may be extended by an additional 30 days. The Screening Council may issue an unconditional clearance, issue a conditional clearance (i.e., subject to behavioural or structural measures), or prohibit the investment entirely. Notably, where no decision has been issued within the above review period, the FDI is considered to be tacitly approved.
Chapter 5: Mergers and Acquisitions
The FDI screening regime described above is most frequently engaged in the context of M&A transactions, where the acquisition of shares in a Bulgarian target company by a non-EU investor will typically trigger a filing obligation. More broadly, M&A activity is a principal route through which foreign capital enters the Bulgarian energy market, whether through the acquisition of operational assets, project companies at various stages of development, or portfolios of renewable energy projects. This chapter examines a key trend shaping the Bulgarian M&A landscape: the increasing adoption of English law concepts in deal documentation and the challenges this presents.
A Shift Towards English Law
Cross-border M&A deals involving Bulgarian targets are increasingly governed by English law, reflecting the growing internationalisation of the Bulgarian M&A market and the recognition of English law as the preferred governing law in cross-border deals. This trend has also driven the harmonisation of deal documentation, with English law standards being applied to transactions governed by Bulgarian law. Whilst this development is broadly welcomed by foreign investors who are familiar with English law agreements, it presents significant challenges for Bulgarian practitioners: concepts that are well-established under English law may have similar but subtly different, or even entirely different, meaning under Bulgarian law. The discussion below examines these divergences focusing on share purchase agreements (SPAs), but the issues discussed equally apply to asset purchase agreements.
Why English Law?
English law has long been the first choice of governing law in cross-border M&A transactions. Its appeal lies in the predictability and certainty it offers, underpinned by extensive case law and widely accepted market standards. SPAs governed by English law are standardised, which facilitates negotiations, and highly detailed. The level of detail is largely due to the limited statutory or common law protection available to parties in M&A transactions: English courts would generally enforce the written terms of an agreement without implying additional terms. It is therefore unsurprising that Bulgarian law SPAs often follow the structure and level of detail of an English law SPA, adopting the same terminology when drafted in English.
Same Words, Different Meanings
The core challenge for Bulgarian practitioners lies in terminology. Several concepts that appear identical under English and Bulgarian law differ considerably in their legal effect. Three areas stand out: warranties and representations, indemnities, and limitation periods.
Warranties and Representations
Under English law, the principle of caveat emptor (buyer beware) governs share acquisitions: the law provides no statutory or common law protection for the buyer as to the assets and liabilities it acquires. Accordingly, buyers seek extensive warranties and representations both to extract information from the seller about the target company and to provide a mechanism for retrospective price adjustment through a claim for damages. English law draws a clear distinction between the two: warranties are contractual statements of facts, given by a seller irrespective of whether the buyer has entered into the transaction in reliance on them, whereas representations induce the buyer to enter into the transactions. The same contractual statement of fact, if untrue, may give rise either to a contractual claim for breach of warranty or a tortious claim for misrepresentation.
The remedies differ accordingly. Unless the SPA expressly provides otherwise, damages is the only available remedy for a warranty breach. Misrepresentation also allows for rescission, though this is typically excluded in the SPA, save in case of fraud. The measure of damages also differs between the two types of claim, although this may not necessarily result in a different amount being awarded. In warranty claims (unlike indemnity claims), damages are typically assessed by reference to the diminution in value of the target company and rarely agreed to be determined on an indemnity basis, i.e. on a pound-for-pound basis.
Under Bulgarian law, by contrast, warranties and representations are used interchangeably with the same remedies applicable in case of breach. The buyer benefits from limited statutory implied warranties as to title and quality of the target business. In the event of breach, the buyer has the following statutory remedies: (i) rescission (even if excluded in the SPA, such exclusion is arguably void), (ii) reduction of the purchase price, or (iii) the seller remedying the breach, plus damages on top of any of these three remedies. Damages are usually determined on an indemnity basis, i.e. on a euro-for-euro basis, disregarding any diminution in value of the business or any multiples used in the determination of the purchase price.
Indemnities
The English law indemnity is a promise to reimburse the buyer in respect of a particular type of liability should it arise. Damages are calculated on a pound-for-pound basis. The English law concept of indemnity has no direct equivalent under Bulgarian law and there is no case law on that point. The closest analogous concept is the liquidated damages clause. The only similarity, however, is that the buyer need not prove the amount of the damages suffered. The two concepts are often confused. A liquidated damages clause is designed to ensure the seller’s performance of the agreement, not to protect the buyer against a known potential liability. Furthermore, the amount payable under a liquidated damages clause is typically fixed or determinable at the outset, whereas the amount payable under an indemnity is, by definition, unknown at the time the SPA is signed.
Parties to a Bulgarian law SPA may nonetheless agree a compensation mechanism for a specified risk and label it an “indemnity.” However, absent a statutory framework, such a provision is likely to be treated as an ordinary contractual undertaking, breach of which would attract the standard statutory remedies for breach of contract.
Limitation Periods
Time limitations are standard SPA provisions intended to limit the seller’s liability. In an English law SPA, parties are free to agree contractual limitation periods for all types of claims. Bulgarian lawyers often follow the same approach, agreeing time limitations on the basis that they do not constitute statutory limitation periods. However, the enforceability of such clauses has not been tested in court. There is a credible argument that only limitation periods for warranty claims can be freely agreed by contract, whilst other claims remain subject to mandatory statutory limitation periods that cannot be excluded. Whether contractually agreed time limitations for non-warranty breach of contract claims will be upheld by Bulgarian courts remains an open question.
To conclude, the convergence of Bulgarian M&A practice towards English law is a positive development for deal efficiency and cross-border investment. However, it carries a significant risk that is often underestimated: importing English law concepts into a Bulgarian law framework without appreciating the underlying legal differences can produce unintended consequences. For practitioners advising on Bulgarian M&A, the practical takeaway is clear. Drafting SPAs that track English law precedents requires careful analysis of how each provision will be construed and enforced under Bulgarian law. This evolution reinforces the importance of dual-system literacy: a thorough understanding of Bulgarian corporate law and local M&A market specifics, combined with practical familiarity with English law M&A documentation and standards.