Online Store Terms and Conditions in Bulgaria (2026)

Terms and conditions for a Bulgarian online store are not merely a footer page. They must match the product page, checkout, payment flow, order email, delivery practice, returns process, and complaint handling. A polished document cannot repair a checkout that hides charges or uses the wrong order button.

This guide focuses on distance sales to consumers. For broader questions about incorporation, individually negotiated agreements, and terms used between businesses, see our separate guide to general terms and conditions in Bulgaria.

Consumer, e-commerce, data, tax, and product rules change. This guide is general information as at 1 August 2026, not legal, tax, accounting, or technical advice for a particular store.

Online Store Terms in Bulgaria at a Glance

Treat the Terms as Part of the Sales System

The Bulgarian Electronic Commerce Act requires permanent, direct access to core supplier information. It also requires the technical steps, error-correction tools, available contract languages, and contract-storage position to be explained before an electronic order. The terms and contract content must be available in a form the customer can store and reproduce, and receipt of the order must be acknowledged electronically without undue delay. These duties appear in the Ministry of Economy's current Electronic Commerce Act.

For a consumer sale, the Consumer Protection Act adds extensive pre-contract information. Before commitment, the customer should see:

• the goods' or services' main characteristics
• the trader's legal identity and effective contact and complaint channels
• the total price, including taxes, and all delivery or other unavoidable costs
• payment, performance, delivery territory, delivery timing, and complaint rules
• withdrawal instructions, the model form, return-cost allocation, and any valid exception
• the statutory conformity guarantee, plus any separate commercial warranty
• contract duration, minimum commitment, renewal, and termination mechanics
• deposits and relevant functionality, compatibility, and interoperability
• applicable out-of-court dispute options and any personalised-pricing disclosure

The Ministry's current Consumer Protection Act also requires this information in Bulgarian for covered distance contracts.

Design a Checkout That Forms a Valid Order

Immediately before a paid order, display the main characteristics, total price, contract duration, and minimum commitment clearly beside the final control. The button must say “order with obligation to pay” or use an equally unambiguous formulation. A generic “continue,” “confirm,” or “register” label can fail to make the payment consequence clear. If this rule is not met, the consumer is not bound by the order.

Do not preselect paid extras. Let the buyer correct the basket, delivery address, quantity, and payment method before submission. State delivery restrictions and accepted payment methods by the start of ordering.

After the order, send an email or another durable record containing the contract information—unless it was already supplied on a durable medium—and identify the version accepted. A robust evidence pack retains the order number, timestamp, material checkout screens, terms version, acceptance event, and confirmation sent. A footer link alone is weak evidence that a particular customer had the terms before buying.

Draft Prices, Delivery, and Payment Clauses From Operations

The advertised and checkout price should include VAT where applicable and disclose delivery and other mandatory charges before commitment. Subscription terms should state the charge for each billing period, renewal date, minimum term, and a workable cancellation method. If automated decision-making personalises a price, that fact must be disclosed before the distance contract.

As at 1 August 2026, euro is Bulgaria's legal tender, but the Consumer Protection Commission confirms that prices must remain displayed in both euro and lev through 8 August 2026. Storefront, promotion, basket, and checkout templates should be reviewed again when that temporary dual-display period ends. A price-reduction announcement generally uses the lowest price applied during at least the preceding 30 days as its previous price; do not manufacture a discount by first increasing the reference price.

Terms should reflect who dispatches, permitted territories, delivery times, failed-delivery handling, and when risk passes. The National Revenue Agency's current guidance also shows that disclosure of an e-shop to the NRA under Ordinance N-18 depends on accepting payments for which a fiscal receipt is required. It is not a universal duty for every website. Check the payment setup against the NRA's e-shop requirements before trading; terms do not replace fiscal or VAT compliance.

Build the 14-Day Withdrawal Process Correctly

The usual withdrawal period is 14 days. For goods, it generally runs from receipt; special rules cover split deliveries, lots, and regular deliveries. For services and digital content not supplied on a tangible medium, it normally runs from contract conclusion. A customer may use the statutory model form or any other unambiguous statement. Requiring one exclusive method is risky.

If the trader fails to give the prescribed withdrawal information, the period can extend to one year and 14 days. If proper information is supplied during that extra year, a 14-day period runs from its receipt. Once notified, the consumer normally has another 14 days to send goods back.

The trader must refund all payments, including the least expensive standard outbound delivery it offered, within 14 days after receiving the withdrawal notice. It may withhold a goods refund until the goods or proof of dispatch is received, whichever happens first. Refund by the original payment method unless the consumer expressly agrees otherwise without incurring a fee. The consumer bears direct return costs only if informed in advance. Liability for diminished value is limited to handling beyond what was needed to establish the goods' nature, characteristics, and functioning.

Exceptions must be used narrowly, not as a blanket “sale items cannot be returned” rule. Examples include personalised or perishable goods, unsealed hygiene-protected products, and specified unsealed software. A paid service loses the right only after full performance begun with the required express request and acknowledgement. Paid digital content not supplied on a tangible medium requires express prior consent to immediate supply, acknowledgement that withdrawal will be lost, and the prescribed confirmation. A withdrawal exception never removes remedies for non-conformity.

Keep Withdrawal and the Legal Guarantee Separate

Withdrawal lets a consumer exit an eligible distance contract without proving a defect. Conformity remedies apply when the product does not match the contract or the objective legal standard. The latter are governed by Bulgaria's Digital Content, Digital Services and Sale of Goods Act, updated in February 2026.

For goods, the seller generally answers for non-conformity that existed on delivery and appears within two years. A lack appearing within the first year is presumed to have existed on delivery unless the seller proves otherwise or the presumption is incompatible with the goods or defect. Repair or replacement must be free and completed within the statutory framework; price reduction or termination becomes available in the specified cases. A commercial warranty is additional—it cannot shorten statutory rights.

Digital content, digital services, and goods with digital elements need more tailored clauses. State functionality, compatibility, supply period, and necessary updates, including security updates. For continuous supply lasting more than two years, relevant liability may run for the contractual supply period. Do not reserve an unlimited right to remove features or modify a paid service: the law regulates permissible changes, notice, continued access, and termination rights.

Address Reviews, Subscriptions, Marketplaces, and Dark Patterns

If reviews are displayed, explain how they are verified and moderated, whether all types are published, and whether sponsorship affects them. Buying or submitting fake reviews, or claiming verification without reasonable checks, creates unfair commercial-practice risk. Search and marketplace interfaces may also need to explain the main ranking parameters and whether a third-party seller is acting as a trader.

A marketplace must clearly allocate which party sells the product and which party handles payment, fulfilment, withdrawal, guarantees, and complaints. The EU Digital Services Act adds trader-traceability and compliance-by-design duties for covered online platforms, subject to its scope and exemptions. It does not automatically turn every direct-to-consumer webshop into an online platform.

Avoid interface pressure even where a specific DSA platform rule does not apply. Hidden recurring charges, pre-ticked extras, false countdowns, visually buried refusal choices, and making cancellation materially harder than signup may breach consumer, data-protection, or platform rules. The sales journey and the legal text should tell the same story.

Do Not Use the Terms as a Privacy or Cookie Notice

Terms regulate the sale. A privacy notice explains who processes personal data, why, on which legal basis, with whom it is shared, how long it is kept, international transfers, rights, complaints, and any relevant automated decision-making. The CPDP's business guidance summarises these GDPR transparency duties.

Cookie controls are another layer. Article 4a of the Electronic Commerce Act requires information and a refusal opportunity for storage or access on a user's device, subject to exceptions for communications and a service expressly requested by the user; GDPR applies where personal data are involved. Keep contract acceptance separate from marketing or analytics choices. Refusing an optional tracker should not prevent a customer from accepting the sale terms.

Remove the Obsolete EU ODR Link but Retain Real Complaint Routes

Many inherited templates still say that online traders must link to the European ODR platform. That instruction is obsolete. EU Regulation 2024/3228 stopped complaint submissions on 20 March 2025, discontinued the platform, and repealed its founding regulation from 20 July 2025. Remove the dead ODR clause.

Keep a working internal complaint address, the information needed to trace an order, and a documented response process. Where applicable, explain access to the Bulgarian general or sectoral conciliation commissions. The CPC states that a consumer normally must first refer the dispute directly to the trader before applying for conciliation; proceedings are document-based and voluntary. Use the CPC's current conciliation application guidance, while noting that some CPC pages still contain legacy references to the closed EU platform.

Control Unfair Clauses and Cross-Border Sales

Bulgarian consumer terms must be clear and in good faith. A pre-formulated term that creates a significant imbalance to the consumer's detriment may be non-binding. High-risk wording includes unilateral price or service changes without a proper basis and exit route, disproportionate penalties, exclusions of statutory remedies, exclusive trader interpretation, forced unlawful arbitration, and shifting a legal burden of proof to the consumer. Transparency does not rescue a substantively unfair term. Our guide to the Bulgarian penalty clause explains why a stated charge still requires proportionate, legally supportable drafting.

Choosing Bulgarian law does not always end the cross-border analysis. Under Article 6 of Rome I, a choice-of-law clause cannot deprive a targeted EU consumer of non-derogable protection under the law that would otherwise apply in the consumer's habitual residence. Delivery countries, local-language marketing, currencies, domains, advertising, and customer support can help show where activities are directed. Before opening another market, check local consumer information, product, packaging, accessibility, VAT, and dispute rules rather than relying on one Bulgarian template.

An Implementation Checklist

1. Map each product type, customer group, delivery territory, payment route, subscription, digital element, and third-party platform.
2. Draft the legal terms from those facts and create separate withdrawal, privacy, cookie, complaint, warranty, and delivery materials where needed.
3. Reconcile every product page, promotion, basket, and checkout control with the terms; test mobile as well as desktop.
4. Add affirmative acceptance, error correction, a payment-obligation button, a durable confirmation, and versioned evidence.
5. Train customer support and fulfilment teams on returns, refunds, complaints, non-conformity, and escalation rather than leaving compliance to the website.
6. Re-audit when products, prices, payment providers, countries, laws, or the interface change—and promptly after the dual-price period ends.

Breach can trigger CPC administrative sanctions and corrective orders, CPDP action for privacy failures, NRA consequences for fiscal breaches, and DSA enforcement for covered platforms. Separately, an order may fail to bind, a withdrawal period may extend, or an unfair clause may be ineffective. The exact sanction depends on the offence, entity, and recurrence. Evidence and operational alignment matter.

Put the Store on a Defensible Legal Footing

Lion Consult can review the full online-sales journey, prepare tailored terms, and align checkout, withdrawal, warranty, privacy, and complaint materials with your actual operating model. Contact our team before launch or before expanding the store into another product or EU market.

This publication provides general information only and is not legal advice. Consumer and e-commerce compliance depends on the products, customers, interface, payment model, territories, and facts of each business. Obtain specific Bulgarian and, for cross-border sales, destination-market advice.

Frequently Asked Questions

Are terms and conditions mandatory for a Bulgarian online store?

Bulgarian law does not simply prescribe one document with a fixed title, but online traders must provide extensive supplier, contract, price, delivery, withdrawal, guarantee, and complaint information before a consumer is bound. A tailored, storable terms document is the usual way to organise part of that information, but the product page and checkout must also comply.

How should a customer accept online-store terms?

Present the terms before commitment, use an affirmative acceptance mechanism, let the buyer correct input errors, and label the final button with 'order with obligation to pay' or equally unambiguous wording. Keep the accepted version and send the contract information on a durable medium.

Does every online purchase have a 14-day return right?

Fourteen days is the usual rule for consumer distance contracts, but the start date varies and statutory exceptions apply to specified products and services, such as genuinely personalised or perishable goods and certain supplied digital content. An exception to withdrawal does not remove remedies for a defective or non-conforming product.

When must an online store issue a withdrawal refund?

The trader normally must refund all payments, including the least expensive standard outbound delivery offered, within 14 days after receiving the withdrawal notice. For goods, it may withhold the refund until it receives the goods or evidence of return dispatch, whichever occurs first.

How long is the Bulgarian legal guarantee for goods?

The seller generally answers for non-conformity that existed on delivery and appears within two years. Separate rules govern digital content, digital services, and goods with digital elements, including update duties and continuous-supply periods. A commercial warranty cannot replace or shorten statutory rights.

Must a Bulgarian online store still link to the EU ODR platform?

No. Complaint intake ended on 20 March 2025, the platform was discontinued, and its founding regulation was repealed from 20 July 2025. Stores should remove obsolete ODR clauses while keeping accurate internal complaint and applicable Bulgarian ADR information.

Must every Bulgarian online store be declared to the NRA?

No. Current NRA guidance ties the Ordinance N-18 disclosure duty to online sellers that accept payment types for which a fiscal receipt is required. The payment and reporting model should be reviewed before trading; where disclosure applies, it is made before activity and changes are generally reported within seven days.