Debt Recovery · 25 June 2026 · 9 min read

Cross-Border Debt Recovery in the EU: Enforcing Foreign Judgments in Bulgaria

For creditors based in EU Member States who hold judgments against Bulgarian debtors, or who seek to pursue debtors located in Bulgaria, the EU's harmonised civil procedure instruments provide a framework for cross-border enforcement that has substantially reduced the procedural burden compared to the pre-accession era. This article examines the principal EU instruments applicable to cross-border debt recovery in Bulgaria — the Brussels I Recast Regulation, the European Enforcement Order, and the European Order for Payment Procedure — together with the practical steps required to enforce a foreign judgment against assets held in Bulgaria.

I. The Brussels I Recast Framework

Regulation (EU) 1215/2012 (Brussels I Recast) establishes a system for the automatic recognition and enforcement of judgments in civil and commercial matters issued by courts of EU Member States. Under the Regulation, a judgment given by a court of one Member State is recognised in all other Member States without any special procedure being required, and is enforceable in another Member State upon the production of a standard form certificate issued by the court of origin.

To enforce a Brussels I Recast judgment against assets held in Bulgaria, the judgment creditor must present the judgment and the standard form certificate (Annex I to the Regulation) to the competent Bulgarian enforcement agent or, where the judgment requires an act other than the payment of money, to the competent regional court. The Bulgarian enforcement agent will treat the foreign judgment as equivalent to a domestic enforceable title and may proceed immediately to enforcement measures — attachment of bank accounts, attachment of salary, seizure of movable assets, or forced sale of real property — without any prior authorisation from a Bulgarian court.

II. The European Enforcement Order

For uncontested monetary claims — claims that the debtor has not contested, has explicitly acknowledged, or that have resulted in a default judgment — Regulation (EC) 805/2004 provides for the certification of the judgment as a European Enforcement Order (EEO) by the court of origin. An EEO certificate may be sought where the claim was uncontested throughout the proceedings in the Member State of origin, the debtor was duly served with the claim, and the debtor was informed of the procedural steps available to contest the claim.

An EEO certificate, once issued, allows the judgment to be enforced directly in Bulgaria without any exequatur or recognition proceeding, on the same basis as the Brussels I Recast mechanism. The creditor presents the judgment and the EEO certificate, together with a translation into Bulgarian where required, to the enforcement agent or competent court, and enforcement proceeds in the same manner as for a domestic judgment.

III. The European Order for Payment Procedure

Where the creditor does not yet hold a judgment but has a liquidated, uncontested monetary claim against a debtor domiciled in Bulgaria, Regulation (EC) 1896/2006 provides for the European Order for Payment Procedure. The creditor files a standardised application form with a court having jurisdiction under the Brussels I Recast framework — typically the courts of the creditor's Member State or the Member State where the debtor is domiciled — and the court issues the order without hearing the debtor. The order is served on the debtor, who has thirty days to lodge a statement of opposition. If no opposition is lodged, the order is declared enforceable and may be enforced in Bulgaria as described above.

IV. Practical Enforcement Steps in Bulgaria

Once the creditor holds an enforceable EU title — whether a Brussels I Recast judgment, an EEO, or an EOPP declared enforceable — the enforcement procedure in Bulgaria follows the domestic enforcement rules described in the companion article on debt collection and enforcement. The creditor must identify the competent private enforcement agent based on the debtor's domicile or the location of the assets, present the enforceable title with a Bulgarian translation, and instruct the agent to initiate enforcement measures. The enforcement agent's fees are regulated by statute and are ultimately borne by the debtor as part of the enforcement costs.

A preliminary asset tracing exercise — identifying the debtor's Bulgarian bank accounts, real property holdings, and registered vehicles before commencing enforcement — substantially improves the efficiency of the process. Bulgarian bank account information may be requested by the enforcement agent from all licensed banks operating in Bulgaria under Article 508 of the Civil Procedure Code; real property can be searched in the Property Register by owner name; and registered vehicles can be traced through the Ministry of Interior's traffic register. For debtors who are Bulgarian commercial entities, the Commercial Register provides information on any enforcement orders or attachments already registered against the company's assets.

V. Limitation Periods and the Risk of Delay

The limitation period applicable to the enforcement of a final court judgment in Bulgaria is five years, running from the date the judgment becomes final and enforceable. A creditor who delays in initiating enforcement — whether through lack of awareness of the Bulgarian assets or simply through inaction — may find that the limitation period has expired and that the judgment is no longer enforceable in Bulgaria, even though it remains valid in the Member State of origin. Creditors holding judgments against Bulgarian debtors should therefore act promptly upon obtaining an enforceable title and should not rely on the debtor to comply voluntarily with the judgment.

Disclaimer: This article is intended as general legal information only and does not constitute legal advice. Readers are encouraged to seek independent legal counsel tailored to their specific circumstances.

Frequently asked

I have a judgment from another EU country — must a Bulgarian court recognise it first?

No. Under Brussels I Recast a judgment given in one Member State is recognised in all the others without any special procedure. You present the judgment and the standard form certificate issued by the court of origin, in Annex I to the Regulation, to the competent Bulgarian enforcement agent, or to the regional court where the judgment requires an act other than payment of money. Enforcement may then begin immediately.

The debtor is in Bulgaria and has never disputed the invoice — can I avoid full litigation?

Yes, through the European Order for Payment Procedure, which covers liquidated, uncontested money claims against a debtor domiciled in Bulgaria. You file a standardised application with a court having jurisdiction under Brussels I Recast — typically your own Member State's courts or those where the debtor is domiciled — and the order issues without the debtor being heard. The debtor then has thirty days to oppose; absent opposition, the order is declared enforceable.

How long can I sit on a judgment before enforcing it in Bulgaria?

Five years, running from the date the judgment became final and enforceable. Creditors who wait — often because they only later discover Bulgarian assets — can find the period has run out and the judgment can no longer be enforced here, even though it remains perfectly valid in the Member State where it was given. Acting promptly, rather than waiting for voluntary payment, is the point.

The debtor never contested my claim — is there a quicker certificate than the usual route?

For claims the debtor never contested, explicitly acknowledged, or that ended in a default judgment, the court of origin can certify the judgment as a European Enforcement Order. Certification requires that the claim was uncontested throughout, that the debtor was duly served, and that the debtor was informed how to contest it. The certified judgment is then enforced directly in Bulgaria with no exequatur or recognition proceeding.

Who ends up paying the Bulgarian enforcement agent?

The enforcement agent's fees are regulated by statute rather than negotiated, and they are ultimately borne by the debtor as part of the enforcement costs. You choose the competent private enforcement agent by reference to the debtor's domicile or the location of the assets, present the enforceable title with a Bulgarian translation, and instruct the agent to initiate enforcement measures.

I have no idea what the debtor owns in Bulgaria — can anything be traced?

Quite a lot can be established before you start. The enforcement agent may request account information from all licensed banks operating in Bulgaria under Article 508 of the Civil Procedure Code. Real property can be searched in the Property Register by owner name, and registered vehicles traced through the Ministry of Interior's traffic register. For corporate debtors, the Commercial Register shows attachments already registered against the company's assets.

About the author

Lachezar Vesov — Attorney at Law, Sofia

Admitted to the Sofia Bar Association in 2016 (reg. no. 1400697210). Practises in civil, corporate, administrative, banking and criminal matters, advising Bulgarian companies and municipal enterprises alongside foreign founders, investors and property buyers. Member of the Board of Directors of the National Palace of Culture, Sofia, and Chairman of the Appellate Commission of the Bulgarian Football Union’s Sofia Zonal Council.

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