BESCO

BESCO – Bulgarian Startup Association’s position regarding proposed amendments to the Tourism Act submitted by Ms. Menda Stoyanova and Mr. Valeri Simeonov

BESCO – the Bulgarian Startup Association firmly supports maintaining the possibility for short-term rental of apartments in Bulgaria. We support the need for better regulation of this type of service and express our willingness to participate in improving the legal framework. However, we express strong concern that the proposed amendments to the Tourism Act would cause serious harm to businesses, related industries, and a significant number of people in Bulgaria. Our position is based on the following reasons:

1. Equal treatment of different providers of tourism services. The issue lies in the certification procedures for tourist sites

The categorization procedure is cumbersome, not digitalized, involves extensive documentation, and requires attempts to meet with a commission that is already overloaded. We personally know members of the commission—they are competent professionals—but categorizing 2,000 properties in Sofia within 3 months is impossible.

A more serious issue lies in the Ordinance on requirements for accommodation establishments and the Tourism Act itself, which contain outdated requirements. Examples include:

Requirement to display signs near the entrance with “company name, registered address, and management address” and “name of the manager with contact phone” (Art. 114, para. 3 of the Tourism Act). Under the proposed changes, individuals who are not traders may provide accommodation services. This would require posting personal data of individuals in residential buildings.
Requirement for a “price list displayed in a visible place near reception” (Art. 115, para. 1). Apartments do not have receptions, and prices on platforms change daily. This creates confusion and mistrust among guests.
Requirements for TVs and landline phones—obsolete in 2019.
Requirement for information boards with brochures (like a printed TripAdvisor).
Requirement for daily cleaning—unreasonable and disruptive.
Mandatory signage with star ratings, which increase regulatory burden and taxes without clear benefit.

2. Undemocratic mechanisms for restricting global platforms

The proposed control mechanisms shift responsibility from Bulgarian authorities (Ministry of Tourism and Consumer Protection Commission) to platforms.

Within 3 months, platforms like Booking.com would have to verify thousands of properties—unrealistic. If just 3 non-compliant listings exist, access to the platform in Bulgaria may be blocked.

This could also affect Airbnb, Facebook, and others. A likely scenario is banning Airbnb, which users would bypass via VPNs—while Bulgarians lose access abroad.

3. Short-term rental platforms are not purely tourism platforms

Platforms like Airbnb and Imot.bg provide the same core service—connecting landlords and tenants.

Many Airbnb users are:

employees, clients, and partners of companies
film crews, universities, students
diplomatic staff, NGOs, public administration

These users often do not meet the legal definition of “tourists,” so their accommodation should not be classified as a “tourist service.”

4. Unclear definition of “occupying one’s own property” and risks to private property rights

Many owners rent out their homes temporarily while living elsewhere. The proposed law does not define “occupancy” clearly.

Restricting property use may violate the constitutional protection of private property (Art. 17, para. 3 of the Constitution).

5. Incorrect assumptions behind the proposed amendments

Too many tourists: Unlike cities like Venice or Barcelona, Sofia actually lacks sufficient tourists. Tourism is key for Bulgaria’s economy, and short-term rentals support it.
Housing shortage and rent increases: In Sofia, Airbnb listings (~3,000) are far fewer than in cities like London (57,000). There are many vacant properties and new constructions.
Tax evasion: Airbnb income is traceable via bank transfers and taxed. Traditional rentals are more often undeclared.
Consumer protection: Platforms like Airbnb and Booking.com offer far more effective review systems than paper complaint registers.

6. Concerns about lack of transparency

The issue is extremely important and could cause serious economic and social harm. Making such changes during budget discussions raises concerns about transparency.

Many young people rely on Airbnb income to repay mortgages. A ban could lead to financial collapse for thousands.

Short-term rental platforms attract foreign spending—key for GDP growth. Restricting them risks damaging Bulgaria’s economy and global image.

BESCO proposals:

Withdraw the proposed amendments to avoid long-term negative consequences;
Simplify regulations for accommodation providers and enable full digital processes;
Introduce an API from the Ministry of Tourism for automatic registration via platforms like Airbnb;
Create a working group including government, legal experts, platforms, and users to develop a balanced legal framework;

Final remarks

People use Airbnb not to avoid rules, but because existing rules are outdated and inefficient.

If regulations are clear, logical, and easy to use, the “Airbnb case” will become merely a technical matter.

Economic data:

2,775 properties in Sofia
Average monthly income per property: €460
Total monthly Airbnb turnover in Sofia: €1,276,500
Expected tourist tax revenue: BGN 300,000–400,000

Sofia generates approximately one-third of Bulgaria’s short-term rental turnover → total monthly turnover ≈ €3.8 million.

According to National Statistical Institute (NSI):

January 2018: 1,894 accommodation establishments
56.2k rooms, 113.5k beds
+5.4% increase in establishments, +3.7% beds
Total overnight stays: 910,000 (+13.5% YoY)
Revenue: BGN 50 million (+20.2% YoY)
- Foreign visitors: +21.8%
- Bulgarian visitors: +18.0%

Position on the Airbnb case