Energy: Bulgaria Introduces Licensing Regime For Natural Gas Traders

With a last-minute amendment of the Bulgarian Energy Act of 26 June 2020, natural gas trading becomes an activity subject to licensing by the Energy and Water Regulatory Commission (the "Energy Commission").

Currently, traders of natural gas may freely trade on the Bulgarian gas exchange or over-the-counter without a licence. As of 1 October 2021, natural gas trading may be performed only by licensed traders. For that purpose, as of 1 January 2021, traders may submit applications for a licence to the Energy Commission and follow a special licensing procedure.

The licensing procedure is set in an ordinance for licensing activities in the energy sector. Generally, a licence may be obtained by an entity that is registered under the Bulgarian Commercial Act or has an equivalent registration in another EU Member State. In addition, natural gas traders must meet certain technical, financial, material, human resources and organisational criteria. For example, applicants