When it comes to national and international license for public passenger transport in Bulgaria, we often get questions from our clients who are looking for clarity and guidance on issuing permits for transporting passengers by buses and cars with a capacity of 7+1, 8+1, and 9+1 seats and up. Some of them are interested specifically in the procedure for issuing a license for the carriage of passengers and what documents are needed to cover all legal requirements. Others are asking about licenses for the carriage of passengers on their own account and how they differ from licenses for casual transport. Among the most frequent questions are those related to the verification of existing licenses for the carriage of passengers and the requirements of Ordinance 33 on public transport of passengers.
Customers are often consulted about the “necessary documents for a license for the international carriage of passengers” or for issuing a license for the carriage of goods on their own account, these issues are important for both new and already established carriers. In addition, some entrepreneurs are interested in specialized transportation of children and schoolchildren, asking us questions about the “requirements for the carriage of passengers” and the ordinance for the carriage of children and schoolchildren, which are essential to comply with regulatory requirements.
Elan Consulting offers assistance to clients not only in Sofia, but also in Burgas, Pomorie, Karnobat, Sunny Beach, Aytos, Nessebar, Sozopol, Primorsko and throughout Bulgaria, providing expert advice for obtaining the necessary licenses and permits for public transport of passengers, as well as for compliance all legal and administrative requirements. We will consider all these issues in more detail in the following sections, striving to meet the specific needs and requirements of each of our customers.
The term “public transport of passengers” is defined in the Law on Road Transport in Bulgaria and covers any activity related to the carriage of passengers for a fee, carried out by persons holding the necessary licenses and documents. According to Art. 2, para. 1 of the Road Transport Act, this type of transport applies to both domestic and international passenger transport performed with vehicles owned by Bulgarian or foreign carriers.
According to Article 6, paragraph 1, carriage of passengers may be carried out by persons who have a licence to carry out public transport of passengers or goods on the territory of Bulgaria, as well as for international carriage of passengers — a Community licence. The legislator requires that, in order for this transport to be legal, the carriers have a license to carry out this activity, the registration and control of the execution being carried out by the Executive Agency “Automobile Administration”.
It is important to note that public passenger transport includes all forms of transport in which passenger transport is carried out for remuneration, regardless of the form of payment, whether direct or indirect. This also includes occasional transport, where fixed routes and schedules are not followed, as well as specialised transport, in which specific categories of passengers, such as students or tourists, are transported. Ordinance No. 33 defines the requirements for this type of transport, emphasizing the importance of safety and regularity of the activity.
According to Article 7, paragraph 1, the license to operate public passenger transport is issued to traders who meet the requirements of reliability, professional competence and financial stability. These requirements ensure that the carrier is able to provide safe and reliable passenger transport while complying with all regulatory requirements.
Thus, public passenger transport covers any organized transport carried out for commercial purposes, including buses, taxis and other means of transport that provide transport services for a fee. This means that any person engaged in passenger transportation, whether within Bulgaria or internationally, must hold the necessary licenses and comply with the legal requirements set out in the Road Transport Act and the relevant regulations.
The difference between public passenger transport and taxi transport is based on a number of key aspects that are regulated in the Road Transport Act and its additional provisions. First of all, public passenger transport covers a wide range of transport services carried out with vehicles of different capacities. This includes buses, minibuses and other means of transport that are designed to carry a larger number of passengers, and there is no narrow restriction in the law (e.g. public transport would also be one with a car of 5+1 seats, 6+1 seats and above). Public passenger transport is subject to a strict licensing regime and is regulated by regulatory enactments that require the possession of a license to carry out this activity. In this context, public transport includes both domestic and international transport, organised on regular lines or occasional journeys.
On the other hand, taxi transport is defined as the transport of passengers carried out with motor vehicles with a capacity of up to 6+1 seats, including the driver. According to § 1, item 7 of the Supplementary Provisions of the Road Transport Act, taxi transport is characterized by the individual nature of the service, in which passengers are transported according to their choice of route and time, for an agreed fee, and the service is provided to an unspecified circle of persons. It is important to note that taxi transportation is carried out by means of transport that cannot carry more than 6 passengers plus the driver, which distinguishes it from public transport, where the capacity of vehicles can be significantly larger.
Taxi transport is strictly regulated and requires the issuance of specific certificates and licenses that ensure that the carrier meets the requirements of safety, professional competence and financial stability, as specified in Art. 12, para. 1, items 1-3 of the Road Transport Act. In addition, taxi transportation is regulated by special regulations that determine the order and conditions for the implementation of this type of transport, including tariffs and requirements for the technical condition of cars.
The difference between the two types of transport also concerns the type of service that is provided. Public transport is aimed at providing transportation for larger groups of people on predetermined routes and schedules, while taxi transport provides a personalized service in which the passenger has the freedom to choose the route and time of travel. These differences make taxi transport more flexible, but also more limited in the scope of its activities, compared to public passenger transport.
The main difference between public passenger transport and taxi transport relates not only to the capacity of the vehicles and the type of service, but also to the legal framework which determines when a passenger transport falls into the category of public transport or taxi transport. Any paid passenger transport service that does not meet the requirements for taxi transport - that is, if it is carried out with a vehicle that has more than 6+1 seats - automatically falls under the requirements for public passenger transport. However, this is not valid in the opposite direction — taxi transport cannot be carried out with a motor vehicle that has more than 6+1 seats.
The term “occasional carriage of passengers” refers to a type of transport service that is carried out irregularly, outside established routes and schedules, and is usually organized at the request of a specific client or group of customers. Casual transportation is different from regular bus lines and other forms of public transport, which follow fixed routes and schedules. According to § 1, item 10 of the Supplementary Provisions of the Road Transport Act, occasional passenger transport is one in which the route and timetable are not predetermined and are carried out at the request of a particular client or group of customers, most often used for organized trips of tourist groups, business transports or other special events.
Any carriage of passengers which is not carried out on a regular route, does not follow a pre-established route and is carried out on request shall be considered as occasional carriage. Examples of casual transportation include organized tourist trips, company trips, or transportation of participants to certain events. An important aspect of casual transport is that it is not carried out on a regular basis and is not intended to serve the general public on a particular route.
In order to carry out occasional passenger transportation, it is necessary to have a license for public passenger transport. According to Article 6 (1) (1) of the Road Transport Act, every carrier that carries out public passenger transport, including occasional transport, must hold the appropriate licence. The licence shall certify that the carrier meets the requirements of reliability, professional competence and financial stability necessary for the safe and lawful operation of this type of transport service. This means that even for occasional transport, which may seem like a less formalized service, there are strict legal requirements that must be followed.
Companies that deal with airport transfers generally fall into the category of “occasional passenger transportation,” when they perform on-demand transportation, in which the route and time of travel are determined by the customer. These services are carried out with vehicles of different capacities, depending on the needs of the customer. The type of license and the category of driver required to carry out such transportation directly depend on the number of seats in the vehicle.
For vehicles with a capacity of 5+1 and 6+1 seats, transportation usually falls into the category of taxi services if the service is offered as an individual transport for a fee. In this case, the driver must have a valid certificate of taxi transportation. The presence of category “D” in the driver is not required, but it is sufficient to have category “B”.
Where airport transfers are carried out by vehicles with a capacity of 7+1 and 8+1 seats, these services are already considered to be public passenger transport, outside the scope of taxi transport. For these vehicles, the driver must hold category “B” or “D1", if the carriage has more than 8 passengers, but less than 16. A license for public passenger transport is mandatory, since the transport falls under the regulation of public services, even if it is occasional transport.
For vehicles with a capacity of 9+1 seats and above, airport transfers fall into the category of public passenger transport with greater capacity, requiring special attention to safety and regulations. In this case, the driver must necessarily have a category “D” for driving motor vehicles designed to carry more than 8 passengers. Category “D” is necessary because the legislation requires specialized qualifications for driving such vehicles, which ensures the safety of passengers.
Issuance of a license and permit for the carriage of passengers only on the territory of Bulgaria is a process that involves several steps and requires the fulfillment of specific legal requirements defined in the Law on Road Transport and related by-laws. The process begins with the preparation of the necessary documents, continues with the submission of an application and ends with obtaining the license and certificate of registration of vehicles.
To obtain a license to carry out public passenger transport, you must first submit an application to the Executive Agency “Automobile Administration”. The application must indicate details of the applicant, including name, legal form, registered office and address, as well as information on the vehicles that will be used to carry out the transport. This application must be accompanied by a number of documents proving that the applicant meets the legal requirements of trustworthiness, professional competence and financial stability.
Reliability is one of the key conditions that must be met in order to obtain a license to carry passengers. According to Art. 7, para. 4 of the Road Transport Act, trustworthiness is proved by certificates that the managers of the transport activity have not been convicted of intentional crimes of a general nature and have not been deprived of the right to engage in transport activities with a valid sentence. In addition, it must be demonstrated that the undertaking or the transport operator has not been sanctioned in a Member State of the European Union for serious infringements of Union rules that would lead to loss of reputation under Commission Regulation (EU) 2016/403.
Professional competence is the other important aspect that must be proven when applying for a license. Art. 7, para. 5 provides that the head of the transport activity must have a certificate of professional competence, which is issued after successfully passing a written examination. This exam covers topics related to the management of transport enterprises, traffic safety, legal requirements and other areas that are important for the implementation of the activity of public passenger transport. The Executive Agency “Automobile Administration” is the body that organizes and conducts these examinations, and issues the certificate of professional competence.
Financial stability is also an essential criterion that must be covered. According to Article 6, paragraph 1, financial stability is proved by providing evidence of the availability of sufficient financial resources to ensure the normal functioning of the transport enterprise. The legislation requires a minimum capital for the first vehicle, equal to the BGN equivalent of 9000 euros, and for each subsequent vehicle — 5000 euros. These amounts must be proven by documents that show the financial condition of the firm, including bank statements, balance sheets and other documents.
After all these documents have been prepared, the application is submitted to the Executive Agency “Automobile Administration”, which is responsible for its consideration. After the application is approved and the license is issued, the next step is the registration of the vehicles that will be used for public passenger transportation. Each vehicle must be registered and receive a registration certificate, which is part of the license and certifies that the vehicle meets all technical and legal requirements.
According to Art. 7a, para. 1, licensed carriers may carry passengers on the territory of Bulgaria only in motor vehicles for which public transport certificates have been issued. This certificate is issued for each vehicle individually and is valid only if certain conditions are met, such as periodic technical inspections, civil liability insurance and other requirements related to vehicle safety.
The license for public transport of passengers, which is issued only for the territory of Bulgaria, does not cover international transport. For the international carriage of passengers, a Community license is required, which requires additional conditions and documents. However, for domestic transportation, the license issued under the Road Transport Act is quite sufficient and covers all aspects of transportation within the country.
The issuance of a licence and permit for the carriage of passengers valid throughout the European Union requires a special procedure that begins with the preparation of documents and the fulfilment of specific requirements laid down in national legislation and European regulations. This licence, called a 'Community licence', is required for any transport company that plans to carry out international passenger transport within the European Union.
The first step in obtaining this license is the submission of an application to the Executive Agency “Automobile Administration.” The application must include information about the company, such as name, legal form, registered office and address of management, as well as details of the vehicles that will be used to carry out the transports. In addition, it is necessary to provide evidence that the company meets the requirements of trustworthiness, professional competence and financial stability.
Credibility is a key criterion, evidenced by the absence of convictions for intentional offences of a general nature for transport managers, as well as by the absence of penalties for serious infringements of the Union rules referred to in Regulation (EU) 2016/403. In addition, drivers must not be deprived by a valid sentence of the right to engage in transport activities, which is a requirement under Article 7, paragraph 4 of the Road Transport Act.
The professional competence of the head of the transport activity is another important aspect. To prove his competence, the manager must have a certificate of professional competence, issued after successfully passing an exam, which covers important aspects of the management of transport enterprises, including legal requirements and traffic safety. This examination is organised by the Executive Agency 'Automobile Administration', and the certificate of professional competence is compulsory for obtaining a Community licence.
Financial stability is essential for obtaining a Community licence. It must be proved that the company has funds that are sufficient to ensure the normal functioning of the transport enterprise. The legislation requires the capital to cover the amount needed for the first vehicle, which must be equivalent to 9000 euros, and for each subsequent vehicle, 5000 euros. These amounts must be certified by financial documents that prove the availability of these funds.
After all the documents have been prepared and the application has been submitted, the Executive Agency “Automobile Administration” examines the application and checks whether the company meets all legal requirements. If all the conditions are met, the agency issues a Community licence that allows the company to carry out international passenger transport within the European Union.
The Community licence shall be valid for five years, after which it must be renewed. During this period, the company must maintain all the conditions that were necessary for the initial issuance of the license. This includes maintaining the reliability, professional competence and financial stability of the company.
In addition to the licence, any motor vehicle to be used for the international carriage of passengers must be registered and obtain a certified copy of the Community licence. This certified copy certifies that the vehicle meets all technical requirements and is fit for international transport. Certified copies are issued by the Executive Agency “Automobile Administration” for each vehicle that will be used under the license.
For the process to be successful, the company must maintain compliance with all regulatory requirements throughout the entire period of validity of the license. This includes conducting regular technical inspections of vehicles, compliance with legislation on drivers' working hours, and providing appropriate insurance. In case of violations, the license may be revoked or suspended, which would terminate the company's right to carry out international passenger transportation.
The issuance of a license for national and international passenger transportation is a process that requires the submission of a set of documents that certify that the applicant meets all legal requirements. These documents are the main way of proving the reliability, professional competence and financial stability of the carrier, as well as the suitability of the vehicles that will be used for transportation. The documents required for issuing a license for national and international passenger transportation include the following categories:
After all these documents have been prepared and submitted to the Executive Agency “Automobile Administration,” a process of consideration of the application follows. The Agency shall verify that all requirements have been met and that the documents submitted are valid and up to date. If all is well, the agency issues a license for national and/or international passenger transportation, which allows the carrier to legally carry out its activities. The license is valid for a certain period and must be renewed before its expiration, again providing the necessary documents proving that the carrier continues to comply with all legal requirements.
The process of issuing a license for public passenger transport, both for national and international transport, includes clear deadlines and fees, which are regulated in the relevant regulatory documents.
First, the license for public passenger transport is issued within 30 days from the date of submission of all necessary documents to the Executive Agency “Automobile Administration.” This is the standard period during which the agency considers the application, checks that all conditions are met, and then issues the license. However, if there are irregularities in the submitted documents or the need for additional checks, the period may be extended, but not more than two months from the date of submission of the application.
Regarding the state fees that are paid for the issuance of licenses for national and international passenger transport, they are defined in Tariff No. 5, which regulates the fees collected in the system of the Ministry of Transport and Communications. For the issuance of a license for national passenger transport, the fee is BGN 500. This fee includes the issuance of the licence and the certified copy of the licence for each motor vehicle that will be used to carry out the transports.
For the international carriage of passengers, the issue of a Community licence is accompanied by a higher fee of BGN 1000. In this case, a fee for issuing certified copies of the Community licence for each vehicle to be used for international transport shall be added to the licence fee. Certified copies are required to certify that the vehicle is legitimate and meets all requirements for international transportation.
The fees for certified copies of the license vary depending on the type of transport and the number of vehicles. For example, for each additional certified copy of the license for international transport, an additional fee of BGN 50 is paid. These fees are paid once upon issuance of the license and are included in the total amount to be paid to the Ministry of Transport.
The license for national and international passenger transport is issued for a period of five years. This means that once the license is issued by the Executive Agency “Automobile Administration”, it remains valid for a period of five years, during which the carrier has the right to carry out public passenger transport in accordance with the terms of the license.
After the expiration of the five-year period, the license must be renewed. The renewal procedure requires the re-submission of an application and the provision of the necessary documents proving that the carrier continues to meet the requirements of reliability, professional competence and financial stability, as well as all other requirements established by law.
This five-year period is valid for both national passenger transport licences and international passenger transport licences, the conditions for renewal of the licence being the same for both types of transport.
Carrying out public passenger transport without an issued license is a serious violation, which entails significant penalties, both administrative and criminal. The Law on Road Transport and the Criminal Code provide for various measures against persons who carry out such an activity without the necessary permission.
First of all, according to the Criminal Code, a person who carries out public passenger transportation without the appropriate license or permission is subject to criminal liability. According to Art. 234d, para. 1 of the Criminal Code, for carrying out public transport of passengers without permission, registration or license, a penalty of imprisonment of one to three years is provided. In cases where the act is committed by two or more persons who have agreed in advance, or through the use of false documents, the punishment is imprisonment from two to five years and a fine of two to ten thousand leva (Art. 234, para. 2).
In addition, if the motor vehicle was used to commit such an offense, the law provides for its confiscation in favor of the state, regardless of whose ownership it is (art. 234g, para. 3). If the vehicle is missing or has been alienated, the law provides for the award of its equivalent. This is a serious measure that aims to prevent the repetition of illegal transportation in the same vehicle.
From the point of view of administrative sanctions, the Law on Road Transport also provides for fines for drivers who carry out passenger transportation without the necessary license. According to Article 93 (1) (1), a driver of a motor vehicle who carries out public transport of passengers without an issued public transport certificate or without a certified copy of a Community license is punished by a fine of BGN 2000 in the event of a first violation. If the same violation is committed again, the fine increases to BGN 4000 (Art. 93, para. 1, item. 2). For systemic violations, the fine reaches 6000 leva (Art. 93, para. 1, item. 3).
In addition to the main fines, the law provides for other penalties for related violations. For example, if the driver fails to submit to the control authorities the necessary documents, including a license or a certified copy of the license, the fine is BGN 100 (Art. 93, para. 2). In case of refusal by the driver to carry out an inspection, the fine is BGN 2000 (Art. 93, para. 4).
These legal provisions make it clear that carrying out the carriage of passengers without a license is an offense with grave consequences. The legislation not only imposes significant fines, but also provides for imprisonment and confiscation of vehicles in order to prevent illegal activity and ensure the safety of passengers. Compliance with these requirements is essential for all those who wish to carry out legal and safe passenger transport.
By trusting Elan Consulting for the registration of a transport company, accounting services and assistance with licenses for national and international passenger transport, you choose a partner with many years of experience and expertise in the field of transport business and regulatory requirements. Our team consists of highly qualified professionals who understand the details of the Bulgarian and European legislation related to the transport activity.
One of the main reasons to choose Elan Consulting is our ability to provide comprehensive solutions that cover all aspects of the transportation business — from company registration to ensuring compliance with all regulatory licensing requirements. We have the necessary knowledge and skills to guide you through the entire registration and licensing process, ensuring smooth and efficient execution of all necessary steps.
In addition, we offer a full range of accounting services that are fully tailored to the specifics of the transport business. Our accountants have experience in managing the finances of transport companies, which ensures that your business will be in full compliance with tax and accounting requirements, both nationally and internationally. This allows you to focus on running your business while we take care of the administrative and accounting issues.
We at Elan Consulting are committed to providing you with a personalized service, answering all your questions and supporting you at every stage of the development of your business. Our approach is focused on long-term partnerships, and our goal is to contribute to your success and sustainable growth. Whether you are a budding entrepreneur or an established firm, we are here to help you navigate the complex regulatory and business landscape with confidence and peace of mind.
By choosing Elan Consulting, you get a trusted partner who understands the needs of your business and is ready to offer flexible and efficient solutions for all your transportation and accounting requirements. Our experience combined with deep knowledge of the industry makes us your best choice for success at every step of your development as a transport company.
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The head of the transport activity must have a certificate of professional competence, which proves that he has the necessary knowledge and skills to manage a transport company. This certificate is obtained after successfully passing an exam organized by the Executive Agency “Automobile Administration.” In addition, the driver should not have convictions for intentional crimes and should not be deprived of the right to engage in motor activity. These requirements ensure that the manager can manage the activity in accordance with all legal and regulatory provisions.
The occasional carriage of passengers requires compliance with all regulatory safety requirements, including the maintenance of the technical condition of the vehicles used for the carriage. Carriers must ensure that all vehicles undergo regular technical inspections and that they are equipped with the necessary safety devices, such as seat belts and fire-fighting equipment. In addition, drivers of vehicles must have valid driving licenses for the relevant category of vehicles and follow all road safety rules.
Violation of the terms of the license for the international carriage of passengers can lead to serious consequences, including temporary or permanent withdrawal of the license. In addition, the carrier may be fined and subject to additional sanctions imposed by the competent authorities. Depending on the severity of the violation, the company may be deprived of the right to carry out international passenger transportation for a certain period, which could negatively affect the business activity and reputation of the company.
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