The Commission already raised its concerns in a reasoned opinion sent to Bulgaria in May 2025. The Commission considers that Bulgaria fails to fully comply with the DSA. Indeed, under the DSA, Member States must designate Digital Services Coordinators, national authorities responsible for enforcing the Regulation within their jurisdiction. The Digital Services Coordinators must be fully operational to give full effect to the provisions of the DSA in the territory of their Member State to ensure that users benefit from its rules and to create legal certainty for companies. Following the Commission's letter of formal notice and subsequent reasoned opinion, Bulgaria adopted legislation empowering one of the authorities acting as Digital Services Coordinators. The Commission considers that Bulgaria is still failing to comply by not designating and empowering the Personal Data Protection Commission and the Electronic Media Council, national authorities that would complete the national enforcement framework of the DSA. Moreover, it considers Bulgaria wrongfully implemented the powers to sanction foreseen by the DSA, as the law does not always respect the maximum fine limits, nor does it ensure that all penalties are effective, proportionate, and dissuasive, also in view of the distinct treatment of natural and legal persons, which is not established under the Regulation. Bulgaria now has two months to respond and address the shortcomings raised by the Commission. In the absence of a satisfactory response, the Commission may decide to issue an additional reasoned opinion.
Last update
1 October 2026