October 2025 – On 23 October 2025,
Bulgaria adopted changes to its Competition Protection Act,
introducing below-threshold merger filings.
The legislator and the competition protection authority cited
the following reasons for the changes: fast-paced technology
developments and innovation, a growing number of "killer
acquisitions", as well as more legal certainty for
investors.
The changes become effective on the day of their promulgation
– expected in first week of November.
1. Background
Following the ECJ judgment in the Illumina/Grail case in 2024, it became
clear that EU Member States may not refer below-threshold
transactions to the European Commission if none of the EU Member
States has jurisdiction to review the transaction under its
national law.
