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Bulgaria completes Digital Services Act implementation
Nearly two years after the Digital Services Act (“DSA”) became applicable across the EU and amidst discussions on the “Digital Omnibus” simplification package announced by the European Commission, Bulgaria has finally aligned its national framework with DSA provisions. On 6 November 2025, the Bulgarian parliament adopted amendments to the Electronic Communications Act (“ECA”), confirming the designation of the Communications Regulation Commission (“CRC”) as the Digital Services Coordinator, vesting it with supervisory powers and the authority to certify out-of-court dispute settlement bodies and award trusted flagger and vetted researcher status, while also introducing comprehensive enforcement architecture.
Regional Competition Law Update – Q3 2025
Kinstellar’s Competition & FDI team is pleased to present the Q3 2025 update to our Regional Competition Review. This latest edition provides a snapshot of recent enforcement activity, legislative changes, and emerging trends across Austria, Bulgaria, Croatia, Czech Republic, Romania, Turkey and Ukraine. Key highlights include the introduction of new “call-in” powers in Bulgaria, as well as proposed and newly implemented FDI regimes in Croatia and Ukraine, alongside a range of developments that are reshaping competition and FDI control across the region, such as: Austria – Enforcement and energy market focus Czech Republic – Merger remedies, sector inquiries, and cartel fines Romania
GDPR x AI: When privacy meets machine intelligence
As Europe moves ahead with the AI Act, the European Commission has made clear that there will be “no stop the clock, no grace period, and no pause”, despite calls from major tech players such as Google, Meta, Mistral, and ASML to delay implementation. The timeline remains firm: core provisions apply from February 2025, general-purpose model rules from August 2025, and high-risk AI obligations from August 2026. The message is clear: the Commission intends to keep its ambitious AI timeline on track, while it looks to streamline other digital obligations for companies. Against this backdrop, the GDPR may also be entering a new chapter. Nearly seven years after its adoption, a leaked draft of the Digital Omnibus package
Stop-the-Clock directive: transposition progress in Central and Eastern Europe
The Stop-the-Clock Directive (Directive (EU) 2025/794), which postpones the application of certain provisions of the EU's Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD), giving companies breathing room and time to prepare for new sustainability reporting and due diligence requirements, is to be transposed by 31 December 2025. It has been gradually transposed across Central and Eastern Europe. Here’s a short overview of its transposition status: Country Status Austria Not yet transposed
Corporate and M&A: Key Bulgarian legal developments
Over the past months, Bulgaria has adopted and implemented several important legislative changes affecting foreign investment screening, merger control, corporate reorganisations, and company transparency. In addition, the country is preparing for euro adoption on 1 January 2026, which will bring adjustments to corporate governance and registration procedures. Courts have also issued significant rulings clarifying directors’ duties in insolvency, the validity of detrimental transactions, and shareholder rights. Our overview provides detailed information about these updates and outlines their implications for businesses and transactions. Update on Bulgarian legislation 1. Foreign Direct Investment
EBA consults new SREP Guidelines: Revisions reflect regulatory developments, including DORA and ESG, as well as lessons learned
On 24 October 2025, the European Banking Authority (“EBA”) published a consultation paper on revised guidelines on common procedures and methodologies for the supervisory review and evaluation process (“SREP”) and supervisory stress testing (EBA/CP/2025/21). The consultation period will last three months, until 26 January 2026. The revised SREP Guidelines are expected to apply from 1 January 2027. New SREP Guidelines will integrate recent legislative changes and address lessons learned Since the issuance of the initial SREP Guidelines in 2014 and its subsequent revisions in 2017 and 2021, the European regulatory framework has significantly advanced. Mainly, the CRR III/CRD IV banking package, the Digital
Bulgaria’s Merger Control Update: Below the thresholds but not below the radar
On 23 October 2025, Bulgaria adopted changes to its Competition Protection Act, introducing below-threshold merger filings. The legislator and the competition protection authority cited the following reasons for the changes: fast-paced technology developments and innovation, a growing number of “killer acquisitions”, as well as more legal certainty for investors. The changes become effective on the day of their promulgation – expected in first week of November. 1. Background Following the ECJ judgment in the Illumina/Grail case in 2024, it became clear that EU Member States may not refer below-threshold transactions to the European Commission if none of the EU Member States has jurisdiction
EU adopts 19th sanctions package against Russia
On 23 October 2025, following a European Commission proposal issued on 19 September 2025 and extended negotiations among Member States, the Council of the EU adopted its 19th sanctions package against Russia in response to its ongoing aggression against Ukraine. The latest package reinforces existing restrictions targeting Russia’s military-industrial complex, energy sector and financial system, building on the measures introduced under the 18th package. It further strengthens the EU’s efforts to combat circumvention, including by designating additional entities and individuals located in third countries. In parallel, the EU has adopted additional sanctions against Belarus, including trade-related measures
Follow the rules or face the consequences: Bulgaria’s Arbitration Reform
On 1 August 2025, Bulgaria introduced significant changes to its arbitration law, the title of which is now the Arbitration Act. The changes aim at promoting transparency and trust in arbitration proceedings. While some amendments were welcomed by practitioners in the field, others may raise questions, including of practical nature, related to excessive formality, administrative burdens and threat to the confidentiality. 1. Who is affected arbitration institutions with seat in Bulgaria; international arbitration institutions with seat outside of Bulgaria – when the place of the arbitration proceedings is in Bulgaria; ad hoc international arbitration tribunals – when the place of
AI awareness: Safeguarding your brand in an era of AI-generated content
The way we consume information is changing at an incredible pace, and we wanted to share a quick insight into a shift that may have real implications for your business. Recently, several clients have reached out to us with concerns about articles that are evidently AI-generated, potentially damaging their brand image and reputation. Unfortunately, this isn't an isolated issue, but it is part of a larger shift in the digital landscape. For the first time, more than half of all the visual and text-based content on the internet is now AI-generated. This means that the data your company relies on and the data it feeds into AI carries significant risks, demanding proactive strategies to remain compliant. What
Alternative distribution models in the automotive sector: Contractual law issues
The European automotive industry is in the midst of a profound transformation. Traditional dealership networks are being redefined, with manufacturers increasingly weighing direct-to-consumer, agency, or hybrid sales models. While such innovations can enhance brand control and customer engagement on the part of manufacturers, they also raise complex contractual law issues related to commercial and legal sustainability. At the centre of these challenges is the reality that altering hitherto existing distribution models requires substantial changes to existing contractual relationships. After all, most dealership agreements contain detailed provisions on exclusivity, termination rights, and non-compete obligations. Failure
EU FDI Screening: Insights from the Commission’s 5th Annual Report and what they mean for CEE
The European Commission published its fifth annual report on the screening of foreign direct investment (FDI) into the EU accompanied by a Staff Working Document. The report covers developments during 2024 and provides an overview of FDI screening across the EU, the evolution of national screening mechanisms, and emerging investment trends highlighting both the EU’s ongoing openness to foreign investors and its efforts to strengthen safeguards for security and public order. While the EU-27 continued to attract significant investment FDI inflows slowed in 2023 and 2024 due to a decline in greenfield investments, even as mergers and acquisitions began to recover unevenly across Member States and sectors. By the end of