Bulgaria: Investment Funds Update - April 2026

Drawing on insights from our Asset Management and Financial Services Regulation team in Bulgaria, this update highlights significant national reforms alongside important EU‑level regulatory and supervisory developments. It is designed to help fund managers, asset managers and financial institutions stay informed and prepared for an increasingly complex regulatory environment.

Key themes covered in this edition include:

• Bulgarian legislative reforms – including the introduction of the multi‑fund pension framework, marking a major structural reform of Bulgaria’s second pillar pension system, and its implications for investment strategy, governance and asset allocation
• AIFMD II transposition in Bulgaria – covering the public consultation on draft legislation, with a focus on loan‑originating AIFs, liquidity management tools, delegation and supervisory enhancements
• EU regulatory and supervisory developments – summarising ESMA’s latest reports, principles and guidelines, including risk‑based supervision, cross‑border distribution of funds and expectations around marketing communications
• Sustainability and ESG developments – including ESMA’s thematic note on ESG strategies in sustainability claims and progress on SFDR 2.0 reform proposals
• Market integrity, risk and liquidity management – with updates on ESMA’s Guidelines on Liquidity Management Tools, EMIR 3.0 active account requirements and supervisory priorities for algorithmic trading
• AML and governance reforms – highlighting AMLA’s 2026–2028 priorities, draft RTS on customer due diligence and broader efforts to strengthen supervisory convergence across the EU

Our analysis is intended to support stakeholders across the investment funds and pensions sector as they navigate ongoing national reforms and significant EU regulatory change in 2026 and beyond.

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