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A Bulgarian transport ordinance in force on 31 August 2026 makes AI Act conformity a build-and-operate condition binding on developers and maintenance contractors, not only on the public authority deploying the system
Bulgaria still has no national AI Act implementing law. It has just imposed AI Act conformity on software vendors anyway, through an ordinary transport ordinance that nobody filed under AI regulation.
Bottom line: A ministerial ordinance, binding, in force 31 August 2026. Article 44 point 4 requires that components using artificial intelligence conform to Regulation (EU) 2024/1689. The duty falls on system administrators, developers and maintenance contractors alike.
Who this affects: Transport technology vendors and systems integrators selling into Bulgarian public transport, municipal and regional transport authorities, ticketing and journey-planning software developers, and procurement and IT counsel on either side of those contracts.
Issue date: The ordinance carries its own date of 19 August 2026 and was promulgated in State Gazette issue 77 of 25 August 2026 at page 40. It enters into force on 31 August 2026.
What changed: AI Act conformity became a standing condition of construction, maintenance and use of Bulgaria's public transport information systems, sitting alongside accessibility, electronic identification and use of the e-government integration layer.
Analysis: The interesting move is the class of persons bound. The AI Act allocates duties by role, mostly provider and deployer. This ordinance binds administrators, developers and the persons entrusted with maintenance in a single sentence, which pushes a conformity duty down the supply chain by way of national transport law rather than AI law.
Primary sources: Naredba No. H-7, State Gazette issue 77 of 25 August 2026 (BG)
- Instrument (EN)
- Ordinance No. H-7 of 19 August 2026 on the information systems for planning and managing public transport
- Authority
- Ministry of Transport and Communications; signed by Minister Georgi Peev
- Jurisdiction
- Bulgaria
- Status
- Ministerial ordinance, promulgated in the State Gazette
- Bindingness
- Binding. Issued under article 13(7) of the Law on Public Transport per final provision 4.
- Issue date / next deadline
- Own date 19 August 2026, promulgated 25 August 2026, in force 31 August 2026. Systems already in operation must have their go-live date announced by 31 August 2026.
- AI provision
- Article 44 point 4: conformity of components that use artificial intelligence with the requirements of Regulation (EU) 2024/1689
- Later deadlines
- Static data to be supplied by 1 January 2027. Developers and operators of ticketing systems have 12 months from entry into force to bring their systems into conformity.
- Editorial Note
- Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
- Primary source
- https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=245514
The provision
Article 44 sets four conditions that must be satisfied in the construction, the maintenance and the use of the information systems the ordinance covers. It binds three classes of person to them at once: the system administrators, the developers, and the persons entrusted with maintenance.
The four are accessibility for persons with disabilities and reduced mobility under the national accessibility statute; electronic identification of users under applicable law; use of the e-government integration layer under the Law on Electronic Government; and, at point 4, conformity of the components that use artificial intelligence with the requirements of Regulation (EU) 2024/1689.
That is the whole of the AI content. There is no separate AI chapter, no risk classification exercise, no national register and no reference to any Bulgarian AI supervisory body. Point 4 is one item in a list of four, and it works by incorporating the AI Act wholesale rather than by restating any part of it.
Why a transport ordinance is the interesting route
Bulgaria has not enacted a national law implementing the AI Act. The market surveillance architecture, the notifying authority and the penalty regime that Regulation 2024/1689 expects each member state to stand up are still outstanding, and our earlier reporting on the scheduled implementing law covers that gap.
This ordinance does not fill it. What it does instead is make AI Act conformity operative inside one sector by ordinary means, as a condition of building and running a class of public systems. A vendor that would otherwise be waiting to see how Bulgaria sets up its AI supervision now has a conformity obligation written into the rules governing the systems it sells.
For practitioners tracking how the AI Act actually arrives in national law, this is worth noting as a pattern rather than as a Bulgarian curiosity. Sectoral instruments that never appear in AI legislation trackers can carry AI Act conformity duties, and they reach parties that the AI Act's own role definitions may not obviously capture.
Who carries the duty, and what happens if they do not
The three bound classes matter because two of them are contractors. A developer building a journey-planning or fleet-management component, and a firm holding a maintenance contract for one, are named in the same breath as the administrator of the system. The obligation attaches during maintenance and use, not only at the point of construction, so it does not expire at handover.
On consequences, the ordinance is silent, and this is the part most likely to be reported wrongly. We searched the full promulgated text for administrative-penalty language and found none: no sanctions chapter, no fines, no property sanctions, no administrative-penalty provisions of any kind. Article 44 is drafted as a condition, not as an offence.
The practical bite is therefore contractual and procedural rather than punitive. Transitional provision 3(1) ties a system's entry into service to an announcement made by the Minister after successful acceptance testing, which is where a non-conforming component would be expected to surface. Separately, the AI Act's own enforcement chain continues to run in parallel and is unaffected by the ordinance's silence.
The dates that follow
The ordinance enters into force on 31 August 2026 under final provision 5. For any system already in operation on that date, the Minister must announce the date of entry into service by 31 August 2026, which is the same day.
Data submitters have until 1 January 2027 to supply the current static data through the relevant system in the form the annexes require. Developers and operators of ticketing, sale and inspection systems, the class identified in article 34(3), have 12 months from entry into force to bring their systems into conformity with the ordinance, and the ordinance is explicit that this period does not displace the separate interoperability deadline in the Law on Public Transport.
The ordinance also states that it gives effect to Delegated Regulation (EU) 2017/1926 on EU-wide multimodal travel information services, which is the instrument the data obligations are built around.
What we did not verify
We fetched the promulgated text from the State Gazette ourselves and read it in full. The bytes decode strictly as UTF-8 with no replacement characters, which we checked rather than assumed, and article 44 point 4 was located and matched against the source.
We did not open the Law on Public Transport, so we have not independently confirmed the scope of the enabling power in article 13(7) beyond the ordinance's own citation of it. We did not open the national accessibility statute or the Law on Electronic Government.
We did not verify whether any Bulgarian transport information system currently in operation actually contains an AI component, and the ordinance names none. Nothing here should be read as a finding that a specific system is or is not conforming.
We will not say what sanction follows a breach of article 44 point 4. We searched the promulgated text and it provides none. Any consequence would have to come from contract, from the acceptance process, or from the AI Act's own enforcement route, and we did not trace those.
If you build or maintain software for Bulgarian public transport, your AI Act exposure changed on 31 August 2026 and it did not arrive through AI legislation. Conformity of any AI component is now a condition of construction, maintenance and use, and it binds you as developer or maintenance contractor rather than resting solely with the authority that deployed the system. Check your acceptance criteria and your maintenance contracts before the 12-month ticketing deadline, because the ordinance provides no fine and the pressure will come through acceptance and contract instead.
Source File
https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=245514
Open the State Gazette page for issue 77 of 25 August 2026 and confirm three things: the heading Naredba No. H-7 of 19 August 2026, the text of article 44 point 4 requiring conformity of components using artificial intelligence with Regulation (EU) 2024/1689, and final provision 5 stating that the ordinance enters into force on 31 August 2026.
4. съответствие на компонентите, които използват изкуствен интелект, с изискванията на Регламент (ЕС) 2024/1689 (Bulgarian original. In English: 4. conformity of the components that use artificial intelligence with the requirements of Regulation (EU) 2024/1689.) Naredba No. H-7, article 44, State Gazette issue 77 of 25 August 2026
FAQ
What does Bulgarian Ordinance H-7 require about AI?
Article 44 point 4 requires that components using artificial intelligence conform to the requirements of Regulation (EU) 2024/1689, the EU AI Act. The requirement applies during the construction, maintenance and use of the public transport information systems the ordinance covers.
Who is bound by it?
Article 44 binds three classes together: the administrators of the systems, the developers, and the persons entrusted with maintenance. Two of those are typically contractors rather than the public authority deploying the system.
When does it take effect?
The ordinance enters into force on 31 August 2026 under final provision 5. Systems already in operation must have their entry-into-service date announced by that same date. Developers and operators of ticketing systems have 12 months from entry into force to conform, and static data is due by 1 January 2027.
What is the penalty for non-conformity?
The ordinance provides none. We searched the promulgated text and found no sanctions chapter, no fines and no administrative-penalty provisions. Article 44 is written as a condition of building and operating the systems, so the practical consequence runs through acceptance testing and contract, with the AI Act's own enforcement operating separately.
Does this mean Bulgaria has implemented the AI Act?
No. Bulgaria has not enacted a national AI Act implementing law, and this ordinance does not create one. It makes AI Act conformity operative within one sector by incorporating the Regulation as a condition, without establishing supervisory authorities or penalties.
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