Off-Plan in Bulgaria: Act 14 / Act 15 / Act 16 (New-Build Stages)

What exactly are Act 14, Act 15, and Act 16?

Act 14 (Образец 14) — “Structural completion (shell & core)”

• Confirms the structure is completed in line with the approved design; compiled by the structural designer, builder, and supervisor, where applicable. Often called the “shell & core” milestone.

Act 15 (Образец 15) — “Handover for acceptance”

• A declaratory handover from the builder to the investor, confirming that the construction is complete according to the approved designs. It serves as the basis for the final report from the construction supervision (where required) and is a prerequisite for commissioning.

Act 16 (Образец 16) — “Protocol for suitability for use”

• For Category I–III builds, Act 16 is a protocol that establishes suitability for use and proposes the issuance of a Use Permit by DNCC (ДНСК) – the National Construction Control in Bulgaria. After Act 16, DNCC issues the Use Permit.

Use Permit vs. UVE (Certificate for Commissioning)

• Use Permit (Разрешение за ползване) → required mainly for Category I–III constructions; issued by DNCC (the National Construction Control Directorate) after the Act 16 process.
• UVE (Удостоверение за въвеждане в експлоатация) → applies to Category IV–V constructions; issued by the authority that issued the building permit (usually the municipality/chief architect). No Act 16 is drawn up for these categories.

Reference point: Categories are defined in Art. 137 ZUT. In practice, residential buildings are often categorized as III–V, depending on their height/complexity, which determines whether a Use Permit (DNCC) or a UVE (municipality) is required. Always check the category on the building permit.

Can I move in with Act 14 or Act 15 only?

No. Bulgarian law prohibits the use of a building (or parts of it) before it is commissioned (i.e., before the Use Permit or UVE is issued for the applicable category). This is outlined in ZUT and the Commissioning Ordinance No. 2/2003.

What documents are typically checked at commissioning?

Authorities require a set of documents—examples include:

• Final report from the licensed construction supervision (for IV category and above, where applicable),
• Building permit, ownership/right-to-build documents,
• Act 14 & Act 15, executive (as-built) documentation, protocols for 72-hour tests for installations, and utility connection documents.
  Municipal portals (such as the Sofia Municipality Portal) and the national eGov portal publish the exact checklist for each category.

Who signs and issues each document?

• Act 14: signed by the structural designer, builder, and the technical person for structures (and supervision where applicable).
• Act 15: signed by investor, builder, designer(s), supervision (or technical lead for Cat. V) — handover for acceptance.
• Act 16: protocol by a state commission (for Cat. I–III) establishing suitability for use; DNCC then issues the Use Permit. For Cat. IV–V, no Act 16; the municipality issues a UVE.

Typical buyer timeline (off-plan)

1. Act 14 → structure complete; request a full document pack (permit, right-to-build, design set, supervision contract).
2. Act 15 → completion & handover; ensure executive drawings, test protocols, and the supervision final report are on track.
3. Commissioning:
   • Cat. I–III → Act 16 then Use Permit (DNCC).
   • Cat. IV–V → UVE from municipality (no Act 16).

Do not move in or connect as a regular occupant before commissioning; it’s unlawful use.

Safe payment logic for off-plan (best practice)

• Milestones: tie payments to objective stages: e.g., X% at Act 14, Y% at Act 15, balance after commissioning (Use Permit or UVE, as applicable).
• Escrow: use a bank escrow or notary/client account with clear release conditions (e.g., “release only upon registration of commissioning document”).
• Clauses you want: remedies for delay, long-stop dates, penalties, and a mechanism if commissioning is refused or materially delayed.

(Milestone/escrow setup is a market-proven risk control; pair it with independent legal review.)

Buying/selling before Act 16 or UVE: is it possible?

• Sales can occur at earlier stages (many off-plan deals close with deferred possession), but occupancy and everyday use require commissioning.
• Mortgages/insurance: many lenders and insurers set minimum stage requirements (often commissioning). Confirm your bank’s rules in writing as soon as possible.

(These are practical/market constraints; the legal prohibition is about use before commissioning, not about concluding a sale itself.)

What should I ask the developer to show me?

• Building Permit (category visible), right-to-build/land title, and the design approvals.
• Act 14, Act 15 (once issued), and the supervision final report.
• Executive (as-built) documentation and test protocols (e.g., 72-hour tests).
• For commissioning: confirm who the issuing authority is (DNCC vs. Municipality) and the expected timeline per Ordinance No. 2/2003/Art. 177 ZUT.

Common pitfalls & red flags

• Marketing says “ready in weeks,” but no Act 15 yet → insufficient to commission.
• Confusion between Act 16 and Use Permit/UVE → remember: Act 16 is a protocol leading to Use Permit (Cat. I–III); UVE is a municipal certificate (Cat. IV–V) without Act 16.
• Moving in with only Act 15 → not lawful; commissioning still pending.

Official references (for buyers who want to verify)

• Ordinance No. 3/2003 — forms and who signs Act 14 / Act 15 / Act 16 (official text + annexes/templates). MRRB
• Ordinance No. 2/2003 — commissioning rules; who issues Use Permit vs UVE (Certificate for Commissioning), minimum warranty periods. MRRB
• ZUT — Territorial Planning Act — legal basis incl. Art. 177 (commissioning) and the ban on use before commissioning (latest consolidated text). AGCC / Cadastre
• Municipal example (Sofia) — service page with document checklists for UVE (Categories IV–V). Sofia Municipality – “Issuance of Certificate for Commissioning (UVE) – Cat. IV & V” and Sofia Architecture and Urban Planning
  (Optional public register of issued UVE in Sofia: NAG Register, as well as Sofia Architecture and Urban Planning resource.
• Ministry site — quick primer that explains Act 14 → Act 15 → Act 16 → commissioning in plain language – BG overview Ministry of Economy and Industry, and EN overview Ministry of Economy and Industry
• DNSK / National Construction Control — official guidance on Act 16 protocol and Use Permit issuance workflow. DNSK – Commissioning page

Mini-FAQ

General Suggestions

• Pay by milestones: Act 14 → Act 15 → Commissioning (Use Permit/UVE).
• Use escrow with release conditions tied to documents.
• Get independent counsel to review the preliminary contract and payment schedule.

You May Also Find Useful:

• Buying Property in Bulgaria: Step‑by‑Step with Notary, Cadastre, Taxes & Hidden Costs
• Residential Property Market in Bulgaria
• Bulgarian Real Estate Market 2025: Outlook for Investors and Expats

Disclaimer: This text reflects regulations and municipal practices as of September 2025, and cites relevant Bulgarian official sources where applicable. This information is not intended as legal advice; for a specific deal, please confirm exact fees/taxes with your notary and municipality, and obtain tailored legal counsel.