May 2017 marked the expiration of the transition period – set out in the Bulgarian Act on the Protection of Agricultural Land Plots – for agricultural land plots with changed designation to keep their urban status. This changing of designation was, among others, required prior to the commencement of construction works on the land. Investors, whose real estate projects in Bulgaria have been on hold due to the real estate crisis, will likely be affected.

Under the act, if construction works were not commenced on the converted land plot prior to May 2017, then the land will automatically revert to its agricultural designation. An exemption to this occurs when construction has commenced on one land plot which was re-designated as urban along with other plots during the same regulation proceeding (and by means of the same regulation order). In such cases, all land plots that were re-designated in the same order will retain their urban status.

Going forward, to obtain/realize a construction permit for agricultural land plots which has lost their urban status, it will be necessary to initiate re-designation proceedings again. In a best-case scenario (for land plots within the borders of residential areas), the proceeding will be completed upon payment of a fee (according to a special tariff). However, for land plots that are outside the urban borders, the administrative procedure change of designation must be carried out again. 

The Bulgarian agricultural authorities are currently in charge of undertaking all necessary actions to register the land as agricultural again and to make the necessary updates and amendments in the cadastre maps and in municipal administration. 

Despite the above, at present there are no legal obstacles for land owners/investors to undertake real estate transactions in Bulgaria. The above complications only apply when planning construction.