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Registration of a transport company in Bulgaria and the EU
Registration of a transport company
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The registration of a transport company in Bulgaria and the European Union is a process that raises many questions among the interested parties. Often they ask: “How much does an international transport license cost?”, “What are the requirements for a transport company with buses?” or “Are special documents required for a license to carry goods?”. These issues reveal the complexity of the regulatory framework and administrative procedures involved in starting or expanding a transport activity.

It is key to understand whether the activity will be national or international, as this determines the type of license — for example, a license for the transport of goods up to 3.5 tons or an international license for transport. At the same time, training questions and requirements for professional competence of the head of the transport activity, as well as tests for professional qualifications are often asked by future entrepreneurs.

Management of a transport company requires planning the subject of activity, ensuring financial stability, and keeping accounting in accordance with legal requirements. Many people are interested in “profit from a transport company” or what are the best practices when “appointing a transport activity manager”.

We at Elan Consulting can offer professional assistance in the entire process — from planning the activity to obtaining the necessary licenses and registration, both for Bulgaria and the European Union. In this article, we will consider in detail the steps and requirements for registration of a transport company, including documents related to obtaining a license for the carriage of goods, and answer questions related to management and profit from such activity.

What is an international transport company registered in Bulgaria according to the law?

An international transport company registered in Bulgaria is an entity that carries out transportation of passengers or cargo between different countries, in accordance with the provisions of Bulgarian legislation and European regulations. The main legal norms that regulate this activity are the Law on Road Transport and Ordinance No. 11 of 31.10.2002 on International Carriage of Passengers and Freight by Road.

What are the requirements for registration of a transport company?

In order to operate as an international transport operator, the company must hold a Community licence issued by the Minister for Transport or by an authorised person. The license is granted only to traders who meet the following basic requirements:

  1. Reliability (good reputation)— transport operators must not have a valid conviction for an intentional crime of a general nature or be deprived of the right to engage in a transport activity. Also, they should not be sanctioned for serious infringements in any EU Member State.
  2. Professional competence— the head of the transport activity must have a certificate of professional competence, which is issued after successfully passing an exam organized by the Executive Agency “Automobile Administration”. The certificate is indefinite.
  3. Financial stability— the transport company must have a minimum capital in the BGN equivalent of 9000 euros for the first car and 5000 euros for each subsequent one. In addition, it is necessary that there are no public obligations, as evidenced by financial documents, insurance contracts or bank guarantees.
  4. Establishment on the territory of Bulgaria— the company must have its own or hired service center for the service of trucks and offices for storing documents necessary for the performance of the activity.

International transport is carried out in accordance with the rules of Regulation (EC) No 1071/2009, which lays down the general conditions for the exercise of the occupation of road transport operator. Licensed companies can only use vehicles with Bulgarian registration, for which certified copies of the license have been issued.

In addition, all vehicles must undergo regular technical inspections, and drivers must hold relevant qualifications, including a driver qualification card issued by the Minister of Transport.

According to these requirements, an international transport company is characterized as a professional and reliable economic entity that follows a strict legal regime and participates in the global transport market.

What is the position of “head of transport activity”?

The position of “head of transport activity” is a key position in the management of transport companies related to strategic planning and control of operational activities. According to the Law on Road Transport and Ordinance No. 11 of 31.10.2002, the head of the transport activity is responsible for compliance with the legal requirements related to the performance of transport activities in Bulgaria and the European Union.

First of all, the head of the transport activity must have certificate of professional competenceissued by a competent authority, such as the Executive Agency “Automobile Administration”. This certificate is obtained after successful passing of an exam that covers a wide range of topics, including transport legislation, financial and human resource management, road safety and vehicle technical condition. In the event that the supervisor already holds a certificate from an EU Member State, it is recognized in Bulgaria according to the provisions of European law.

The head of the transport activity is obliged to effectively and constantly manage the activities of the company. This includes control over the planning and execution of transportations, optimization of routes, fleet management and ensuring compliance with all regulatory requirements. According to Regulation (EC) No 1071/2009, the person must be appointed under an employment contract or be an owner, partner or shareholder in the company.

The certificate of professional competence for the head of a transport activity is mandatory according to Art. 5 of Ordinance No. 11 of 31.10.2002, which regulates the requirements for international road transport of passengers and cargo.According to Art. 5, para. 1 of the Ordinance, professional competence is demonstrable by acquiring knowledge and skills after passing specialized training and successfully passing a written exam organized by the Executive Agency “Automobile Administration”.

Where can I get the certificate?

According to Art. 7c, para. 1 of the Road Transport Act, training for the acquisition of professional competence is organized by licensed training centers that are registered with the Executive Agency “Automobile Administration”. These may include vocational high schools, higher education institutions and other accredited institutions.

Is the certificate mandatory?

According to Art. 7, para. 1, item 2 of the Road Transport Act, the certificate of professional competence is one of the requirements for issuing a Community license or a license to carry passengers and cargo on the territory of Bulgaria. Without this document, the transport company cannot carry out its activities.

What is the procedure for obtaining?

  1. Enrollment for training:Art. 7c, para. 1 of the Road Transport Act stipulates that training for the acquisition of professional competence must be organized by accredited institutions.
  2. Exam:According to Art. 5, para. 1 of Ordinance No. 11, applicants take a written exam, which is organized by the Executive Agency “Automobile Administration”. Successful passing of the exam is a mandatory condition for obtaining a certificate.
  3. Obtaining the certificate:According to Article 5, paragraph 2 of Ordinance No. 11, the successful person who has passed the exam receives a certificate of professional competence, which is permanent and is recognized in all Member States of the European Union.
  4. Periodic training:Art. 7c, para. 8 of the Law on Road Transport requires managers of transport activities to undergo periodic training to maintain their knowledge every five years.

According to Art. 5, para. 5 of Ordinance No. 11, applicants who wish to obtain a certificate of professional competence must have at least a secondary education, and also provide a criminal record and other documents certifying their reliability.

According to these provisions, the certificate of professional competence is the main document for proving the professional suitability of the head of the transport activity, ensuring that the transport company acts in accordance with legal requirements and ensures the safety and efficiency of its activities.

What are the necessary documents for registration of a transport company in Bulgaria and the EU? Where can they be taken out?

Registration of a transport company in Bulgaria and the EU involves the provision of numerous documents that certify compliance with the regulatory requirements for organization and management of transport activity. Here is a detailed description of all the necessary documents and requirements:

1. Registration in the Commercial Register

In order to be recognized as a legal entity, a transport company must register in Registry Agency. Required documents include:

  • Application for registration(model A4, A5 or other, depending on the legal form).
  • Constitutive Act(for sole proprietorships) or company contract(for Ltd., JSC, etc.).
  • Minutes of the Constituent Assemblywhich indicates the election of a manager.
  • Certificate of contributed capitalissued by a bank.
  • Declarationsfrom the governors that they are not bankrupt and agree to occupy the position.

2. Licensing documents

In order to carry out transportation activities, the company must obtain a transport license issued by Executive Agency “Automobile Administration”. According to Art. 6, para. 1 of the Road Transport Act, the following documents are mandatory:

2.1. Community licence or national licence

  • Application for the issuance of a license (by model).
  • Criminal recordto the head of the transport activity.
  • Certificate of Professional Competenceto the head of the transport activity.
  • Financial Stability Documents, including:
    • Annual financial statements certified by an auditor.
    • Bank guaranteeor insurance covering the minimum capital requirements (€9000 for the first car and €5,000 for each subsequent one).
  • Evidence of trustworthiness:
    • Documents confirming the absence of serious violations, according to Art. 5 of Ordinance No. 11.
  • Rental or leasing contract of vehiclesif they are not owned by the company.

2.2. Address and operation center

According to Art. 6a, para. 1 of Ordinance No. 11, the company must prove that it has:

  • Officefor management:
    • Lease agreement or document of ownership of the premises.
    • A statement that the address is used to store accounting documents, contracts and other administrative records.
  • Operation Center:
    • Lease or lease agreement on a technical basis.
    • Service maintenance contract with a licensed company that performs technical inspections and maintenance of vehicles.
    • Documents on the availability of parking facilities, if applicable.

3. Additional requirements for specific transport

  • Carrier Liability Insuranceto cover damage related to transport activities.
  • Documents relating to the carriage of dangerous goods (ADR certificates for drivers and vehicles).
  • Evidence of compliance with driving and rest time requirements for drivers (tachographs and data management software).

4. Documents for registration in the EU

If the company carries out international transport, a Community licence is required, according to Regulation (EC) No 1071/2009:

  • Application for a Community licence.
  • Certificate of trustworthiness.
  • Certificate of professional competence.
  • Documents proving the presence of an EU management address and a service centre.

5. Where are the documents issued from?

  • Commercial register: Registration of the company and submission of constituent documents.
  • Executive Agency “Automobile Administration”: Issuance of licenses and certificates of professional competence.
  • Banks and insurers: Issuance of bank guarantees and insurance.
  • Licensed Centers: Conducting training for professional competence.
  • Local municipalities: Approval for address and technical bases.

These documents and procedures ensure that the transport company meets all legal requirements for starting and operating in Bulgaria and the EU.

What are the requirements for the personnel of the transport company?

The requirements for the personnel of a transport company are strictly regulated by national and international legislation, including the Road Transport Act, Ordinance No. 40 on the carriage of dangerous goods and the European Convention on the Work of Crews (AETR). These requirements cover drivers, transport managers and other employees involved in the logistics and management of the company.

Drivers of vehicles must meet specific qualification and training requirements. According to Article 5, paragraph 1 of the AETR, the minimum age for drivers is 18 years for vehicles with a permissible maximum mass of up to 7.5 tons and 21 years for all other vehicles. For drivers of vehicles carrying dangerous goods, an additional ADR certificate is required, issued after successfully completed a course and examination, in accordance with Art. 23 of Regulation No. 40.

Managers of transport activities must have a certificate of professional competence issued by the Executive Agency “Automobile Administration”. According to Art. 7a of the Road Transport Act, the manager is responsible for the compliance of the company with the requirements for the technical condition of vehicles, the management of driving and rest time of drivers, as well as for the safety of the cargo.

According to Art. 6 of the AETR, the driving time of drivers is limited to 9 hours a day, with the possibility of extending up to 10 hours twice a week. Drivers must have at least 45 minutes of rest after 4.5 hours of driving, divided into two parts of at least 15 and 30 minutes. Employers are obliged to organize schedules in such a way as to ensure compliance with these restrictions, in accordance with Article 11 (1) of the AETR.

Personnel responsible for loading and unloading operations must also be qualified and familiar with safety requirements. According to Art. 4 of Ordinance No. 40, persons involved in the handling of dangerous goods must undergo training in working with the specific types of cargo, including measures to prevent accidents.

Companies are obliged to keep records of drivers' working hours, according to Art. 12 of the AETR, using tachographs and hand-held records. Violations of these provisions can lead to penalties that affect both the employer and drivers.

In addition to the above requirements, Art. 14 of the Road Transport Act obliges transport companies to provide their personnel with regular instruction and training related to transportation safety. This includes not only drivers, but also other persons involved in the logistics, loading, unloading and management of the company. The employer is obliged to keep records of the trainings conducted and ensure that employees are aware of innovations in legislation and technologies related to transport activity.

According to Art. 6, para. 3 of Ordinance No. 40, companies carrying out transportation of dangerous goods must appoint a safety consultant who is responsible for complying with the requirements of ADR and developing emergency action plans. The consultant must undergo a specialized training course and hold a certificate of competence issued by the Executive Agency “Automobile Administration”. Art. 7 of the regulation requires the consultant to conduct regular inspections of the company's activities and prepare an annual safety report, which is provided to the management of the company and kept for a period of at least five years.

In addition, according to Article 8 of the AETR, companies operating international transport are obliged to provide their personnel with access to current rules and regulations for international transport, including the specific requirements of the countries through which the goods pass. This also includes knowledge of customs requirements, restrictions on the movement of heavy goods vehicles in certain zones or times and security measures when transporting valuable or dangerous goods.

Drivers engaged in the carriage of goods of class 1 (explosive) and class 7 (radioactive) are subject to additional specialized training, according to Art. 23, para. 2 of Ordinance No. 40. This training includes the recognition of the risks associated with cargo, methods for their safe transportation and actions in the event of emergency situations. At the same time, Art. 8b of the same regulation requires drivers to have specific personal protective equipment and equipment, such as fire extinguishers, spill protection and other tools necessary to minimize the risk during transportation.

Employers are obliged to provide healthy and safe working conditions for all personnel, including suitable rest bases and recovery conditions during long routes. Art. 14, para. 1 of the Law on Road Transport emphasizes that transport companies must establish internal rules for managing driving and rest time of drivers, in accordance with the requirements of the AETR and Ordinance No. 41 on the working time of drivers.

What are the requirements for registration of a forwarding company according to the law?

Forwarding activity, as a specific service in the transport sector, includes the organization of cargo transportation and logistics services. According to Bulgarian legislation, the registration of a forwarding company requires the fulfillment of certain legal and administrative requirements.

According to The Road Transport Act(Art. 6, para. 1), the forwarding activity, if it involves the direct performance of transports, is subject to licensing. A public transport licence is not required to carry out forwarding services that involve the management of means of transport or the engagement of transport capacity from third parties. However, the forwarding company must be registered as a trading company within the meaning of the Commercial Law.

The main requirement is that the company be registered under The Law on the Commercial Register and the Register of Non-Profit Legal Entities, for which an application must be submitted to the Commercial Register. Documents such as a memorandum of association, a decision on registration, a list of partners and others are required depending on the legal form of the company.

If the shipping company is involved in international transportation, it must meet the licensing requirements under Ordinance No. 11 of 31.10.2002for the international carriage of passengers and cargo by road. This includes the presence of a Community licence if the company provides transport services with its own vehicles. Otherwise, when the activity is limited only to intermediation and organization of transportation, a transport license is not mandatory.

In addition, the company must guarantee financial stability, which is usually certified by financial statements or bank guarantees, as specified in Art. 6 of Ordinance No. 11. The head of the forwarding company does not necessarily have to have a certificate of professional competence if the company does not carry out direct transport activities, but it is advisable to have one for optimal management of the activity.

Other specific requirements include compliance with personal data protection standards under General Data Protection Regulation (GDPR), especially if the company works with international partners. In addition, it must be ensured that contracts with subcontractors and transport companies comply with Bulgarian and international legislation.

Finally, the forwarding company must provide “Freight Forwarder Liability” insurance, which covers the risks associated with non-performance or delay of the contracted services. This is standard industry practice that inspires confidence in customers and partners.

These requirements are part of the framework that ensures the lawful functioning of freight forwarding companies in Bulgaria and ensures that they provide quality services to their customers.

What are the requirements for registration of a transport company for the carriage of dangerous goods?

According to the provisions of Ordinance No. 40 of 14.01.2004 on the conditions and procedure for the carriage of dangerous goods by road, the registration and operation of a transport company for the transportation of dangerous goods require strict compliance with a number of regulatory requirements. According to Art. 1, para. 1 of the Ordinance, the duties of the safety consultant, the order of training of persons engaged in the transportation of dangerous goods, the duties of drivers and the requirements for road vehicles (TSO) are determined. The same provision also regulates the obligations of the participants in the carriage, the requirements for loading and unloading, as well as the control mechanisms for the implementation of the transports. Article 1, paragraph 2, stipulates that the transport of dangerous goods must be carried out in accordance with ADR (European Convention for the International Carriage of Dangerous Goods by Road).

Any enterprise that plans to carry out transportation of dangerous goods must have a license for transport activities issued by the Executive Agency “Automobile Administration”. According to Art. 6, para. 1, companies engaged in the transportation of dangerous goods are obliged to have a safety consultant to ensure compliance with safety requirements. The consultant may be a person employed under an employment or civil contract, the head of the enterprise or another competent person. Article 6 (4) provides for an exception for enterprises operating with quantities below the values specified in ADR, to which the obligation to consult does not apply.

Vehicles used for the transport of dangerous goods must meet the specific requirements of Annex B of the ADR, as specified in Art. 4 para. 1. This includes their technical serviceability, the presence of fire extinguishers, signal marking and other means of safety specified in the regulatory act. Documents for registration of vehicles must be accompanied by a certificate of their technical condition and suitability for the carriage of the specific dangerous goods for which they are intended.

Drivers of motor vehicles must undergo specialized training and hold a driver's license for the transport of dangerous goods. Art. 21, para. 1 requires these persons to pass an exam after completing courses organized by licensed training centers. According to Art. 23, paragraph 1, drivers who transport dangerous goods in tanks or of class 1 (explosive) and class 7 (radioactive) must undergo additional specialized courses.

The company is obliged to have insurance “Carrier Liability”, which covers the risks associated with the transportation of dangerous goods, as well as an accident action plan. According to Art. 7, para. 3, the safety consultant is obliged to develop an emergency plan and investigate incidents related to transport activities. An annual report on the activities of the enterprise for the transportation of dangerous goods is provided to the head of the enterprise and stored for five years, a certified copy of which is sent to the relevant regional unit of the Executive Agency “Automobile Administration” until the end of February of the following year.

According to Art. 8b, drivers of vehicles carrying dangerous goods must be familiar with fire extinguishers, prevent the use of inappropriate equipment, such as metal lamps that can cause sparks, and comply with strict parking and supervision requirements for vehicles when they carry dangerous goods.

Registration documents include an application for licensing, a lease or ownership agreement for an office, a contract for an operation center with appropriate infrastructure, insurance policies, vehicle roadworthiness certificates and driver's certificates. All these documents must be submitted to the competent authority - Executive Agency “Automobile Administration”.

In addition to the aforementioned requirements, the company must provide specific documentation and comply with administrative procedures that extend both to the organization of the activity and to the technical condition of the vehicles and the qualification of personnel. According to Art. 9, para. 1 of Ordinance No. 40 of 14.01.2004, carriers of dangerous goods are obliged to provide appropriate marking and labelling of the goods in accordance with ADR. This includes the affixing of clearly distinguishable UN number plates (UN numbers) to vehicles and containers in order to identify the type of cargo and the risks associated with it.

The company is obliged to have a service maintenance contract with a licensed service base, as required by Art. 4 para. 1. This ensures that all vehicles are maintained in good working order and are ready to carry out the transports safely. In addition, according to paragraph 2 of Article 7, the operating center from which the vehicles are operated must be equipped with facilities for regular inspection of cargoes, their safe storage and preparation of vehicles for carrying out transportation.

The company must also develop an internal safety management system for the transport of dangerous goods, which includes training of all personnel on the specific requirements of ADR and the development of standard procedures for handling cargo. This is regulated in Article 10, paragraph 3, which stipulates that all employees involved in the transport of dangerous goods — including unloaders, logistics coordinators and drivers — must undergo internal instructions and training on handling hazardous materials.

Special attention is paid to route planning. According to Article 11 (1) of Ordinance No. 40, carriers must avoid passing through high-risk areas (e.g. city centres, tunnels and bridges) unless absolutely necessary. Transport managers must ensure that routes are planned in advance in order to minimise the risk and possible impact in the event of an accident.

In the case of transportation of goods of class 1 (explosive) and class 7 (radioactive), according to Art. 23, para. 2 of the Ordinance, additional coordination is required with the local self-government bodies and the Ministry of Internal Affairs, which provide the relevant security measures. In addition, for transportation of these classes of cargo, drivers must undergo specialized additional training, certified by the relevant certificates.

Companies carrying out international transport of dangerous goods must also ensure compliance with customs regulations and the requirements of international agreements. This includes the preparation of transit documentation that complies with ADR and the local legislation of the countries through which the cargo passes. Art. 13, para. 2 of the Ordinance stipulates that any international carriage must be accompanied by a correctly completed bill of lading containing data on the type of cargo, its dangerous properties and safety measures.

Control over the compliance of the company with the requirements for the carriage of dangerous goods is carried out by the bodies of the Executive Agency “Automobile Administration”, as well as by the competent authorities for road traffic safety. According to Art. 15, para. 3, when carrying out inspections, inspectors may require all necessary documents, including licenses, safety certificates and risk management plans.

Subject to all these requirements, the transport company can carry out activities in the transport of dangerous goods according to regulatory standards, guaranteeing safety for the public, the environment and workers in the sector. These stringent requirements not only ensure legality, but also significantly reduce the risks of accidents and accidents.

Why choose Elan Consulting for accounting of a transport company in Bulgaria?

The choice of “Elan Consulting” for the accounting services of a transport company in Bulgaria is justified by the in-depth knowledge of the specific requirements and regulations related to the transport activity, as well as by our experience in providing professional and reliable services. Financial management in the transportation sector requires not only standard accounting skills, but also an understanding of complex tax and regulatory requirements specific to the activity. We have the expertise that ensures correct and efficient management of all accounting aspects of your company.

Knowledge of legal requirements is a key factor in our work. The Elan Consulting team has detailed knowledge about the regulations in Bulgaria and the European Union, including the requirements of the Road Transport Act, Ordinance No. 40 on the Transport of Dangerous Goods and the applicable EU regulations. This allows us to provide customized accounting services to meet the specific needs of your transport company. Whether it is preparing financial statements, filing VAT returns, managing fleet maintenance costs or optimizing tax liabilities, we are ready to provide full support.

The transport sector is characterized by a significant volume of document flow and complexity in reporting, including the processing of expenditure documents for fuels, tolls and international transit. We at Elan Consulting understand these specifics and can ensure the smooth running of processes. Using modern software solutions, we ensure that your documents will be processed in a timely manner and in accordance with the requirements. In addition, our experts offer advice on cost structuring and financial management in order to improve profitability.

Another key advantage of Elan Consulting is our ability to provide up-to-date information and solutions in line with the dynamic changes in legislation. The transport sector is often subject to changes in local and international regulations that can have a serious impact on business. Our team regularly monitors these changes and informs our customers about the possibilities for optimization or avoidance of potential risks.

“Elan Consulting” offers services both nationally and internationally. This means that we can assist transport companies operating in Bulgaria and within the EU, focusing on the specifics of international regulations, including ADR and EU licensing requirements. With our help, your company will be fully prepared to meet the challenges of the international transport market.

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Frequently Asked Questions

What are the requirements for a transport activity manager in a transport company that is engaged in the transportation of goods up to 3.5 tons?

Pursuant to Article 3 (1) of the Road Transport Act, transport companies carrying goods up to 3.5 tonnes are exempted from the requirement for a Community licence. However, under Regulation (EC) No 1071/2009, the company must appoint a transport manager who is responsible for the proper management of the company. The person holding this position must have a certificate of professional competence, which is acquired after training and successful passing the exam. The requirements for financial stability are more relaxed compared to those for transport with heavier vehicles, but the manager is still responsible for respecting the driving and rest time of the drivers, the technical condition of the vehicles and the safety of the transports.

How is the minimum capital for financial stability of a transport company in Bulgaria calculated and what documents prove it?

According to Art. 7c, para. 3 of the Road Transport Act, the minimum capital for financial stability is calculated on the basis of the number of vehicles in the company. The capital required is 9000 euros for the first vehicle and 5000 euros for each subsequent one. Financial stability is proven by providing documents such as certified annual financial statements, bank guarantees or insurance. It is also permissible to use financial resources from partners or shareholders, if this is certified by a bank statement or other relevant financial documents.

What are the duties of a safety consultant in a transport company that carries out transportation of dangerous goods?

According to Art. 6 of Ordinance No. 40 of 14.01.2004, the safety consultant is obliged to ensure that all requirements of ADR are complied with in the framework of transport activities. This includes checking the compliance of vehicles with ADR requirements, training drivers and other personnel on safety, ensuring appropriate cargo labelling and developing emergency plans. The consultant must also draw up an annual safety report to be provided to the management of the company and to the Executive Agency “Automobile Administration”. In addition, in the event of accidents related to the transportation of dangerous goods, the consultant is responsible for analyzing the situation and drawing up recommendations to prevent similar cases in the future.

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