Opinion on Electronic Food Vouchers

TO

Ministry of Finance

Attention:

Ms. Lyudmila Petkova
Deputy Prime Minister and Minister of Finance

OPINION

Submitted by

Bulgarian Entrepreneurial Association (BESCO), registered in the Register of Non-Profit Legal Entities maintained by the Bulgarian Registry Agency, UIC 177239971, with its registered office and management address at: 117 Hristo Botev Blvd., Floor 2, Vazrazhdane District, Sofia 1303, Bulgaria, represented by its Chairman, Svetozar Georgiev Georgiev, acting through its Executive Director, Dobromir Georgiev Ivanov

Dear Ms. Petkova,

Dear Ladies and Gentlemen,

We are writing to you regarding the timely issue of electronic food vouchers.

While recognizing the undeniable benefits of food vouchers as an employee benefit, we would like to draw your attention to several existing and potential risks associated with the use of food vouchers in electronic form.

When accepting electronic food vouchers, merchants incur additional costs which, according to information provided by our members, range from 1% to more than 6%.

On the one hand, merchants pay a commission to the food voucher operator with whom they have concluded a contract.

On the other hand, the transition to electronic food vouchers increases merchants' costs due to the transaction fees charged when vouchers are redeemed.

The increase in fees is particularly significant when cards issued by international electronic food voucher providers are used, resulting in additional transaction costs of approximately 1.5% per transaction.

The financial burden falls most heavily on small and medium-sized enterprises, particularly small businesses. As economically weaker market participants compared to food voucher operators, they are often unable to negotiate lower commission rates, unlike large retail chains.

This situation creates a risk that fewer merchants will be willing to accept electronic food vouchers, thereby limiting consumers' choices.

Furthermore, there is an increased risk that merchants will raise the prices of goods in order to offset the higher costs associated with redeeming food vouchers.

In this regard, we would like to express our view that the State could play a key role in facilitating dialogue among the relevant stakeholders, helping them reach mutually acceptable solutions and minimizing the risks associated with the use of electronic food vouchers.

We would like to thank you in advance for taking the time to consider our position.

We believe that constructive cooperation and expert dialogue between the public sector and the business community are essential for developing solutions that safeguard the interests of the State while also protecting businesses and consumers.

We remain available to participate in meetings and discussions on this matter.

Date: 22 October 2024

Respectfully,

Dobromir Ivanov
Executive Director