Internet service providers operating in Bulgaria are facing an expanding set of legal obligations for restricting access to illegal online content. While the bill amending the Bulgarian Electronic Communications Act (ECA), which implements the EU’s Digital Services Act (DSA), remains under parliamentary review, several targeted content-blocking measures have already been adopted or proposed for adoption this summer.

Under Article 9 of the DSA, internet service providers are required to act when receiving an order from a competent judicial or administrative authority. Such orders mandate the restriction or removal of illegal content, which under local legislation may include:

Unlicensed gambling platforms;
Terrorist propaganda or instructional content;
Pornographic material, particularly involving minors;
Unauthorised crypto-asset services;
Investment services offered without proper authorisation;
Copyright-infringing content.
Trade mark infringing digital interfaces may soon fall within the scope of illegal content specifically addressed under local legislation.

The obligation to act is triggered upon receipt of a valid order that meets the criteria set forth in the DSA. These criteria include a clear legal basis, identification of the issuing authority, a reasoned explanation of illegality, precise location of the content (e.g. URL) and information regarding redress mechanisms and territorial scope.

Where applicable, failure to comply with such orders may result in administrative fines of up to 6% of the provider’s annual global turnover for the preceding financial year.

The Communications Regulation Commission (CRC) serves as the designated Digital Services Coordinator in Bulgaria. It is responsible for overseeing compliance with the DSA and coordinating enforcement actions across the sector.

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