Annual Individual Management Report
Corporate Governance Statement
Independent Auditors’ Report
Annual Separate Financial Statements
Bulgarian Energy Holding EAD
31 December 2024
Translation from Bulgarian
Corporate Governance Statement
Independent Auditors’ Report
Annual Separate Financial Statements
Bulgarian Energy Holding EAD
31 December 2024
Translation from Bulgarian
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Contents
Annual Separate Activity Report ................................................................................................................................... i
Corporate Governance Statement ................................................................................................................................. ii
Independent Auditors’ Report ...................................................................................................................................... iii
Annual Separate Financial Statements ......................................................................................................................... iv
Separate Statement of Profit or Loss ............................................................................................................................. 1
Separate Statement of Comprehensive Income ............................................................................................................. 2
Separate Statement of Financial Position ...................................................................................................................... 3
Separate Statement of Changes in Equity ..................................................................................................................... 5
Separate Statement of Cash Flows ................................................................................................................................ 7
Notes to the Separate Financial Statements .................................................................................................................. 8
1. General information and scope of activity ......................................................................................................... 8
3. Changes in the accounting policy .................................................................................................................... 10
4. Material Accounting Policy Information ......................................................................................................... 11
5. Dividend income .............................................................................................................................................. 28
6. Revenues from contracts with customers......................................................................................................... 29
7. Other income ................................................................................................................................................... 29
8. Impairment expenses ....................................................................................................................................... 30
9. Expenses for materials ..................................................................................................................................... 30
10. Hired services expenses ................................................................................................................................... 30
11. Audit services remuneration ............................................................................................................................ 31
12. Personnel expenses .......................................................................................................................................... 31
13. Other expenses ................................................................................................................................................. 31
14. Financial income .............................................................................................................................................. 31
15. Financial expenses ........................................................................................................................................... 32
16. Income tax expenses ........................................................................................................................................ 32
17. Earnings per share and dividends .................................................................................................................... 32
18. Investments in subsidiaries, associates and joint ventures ............................................................................... 33
19. Property, plant and equipment ......................................................................................................................... 36
20. Intangible assets ............................................................................................................................................... 37
21. Deferred tax assets ........................................................................................................................................... 38
22. Trade and other receivables ............................................................................................................................. 39
23. Receivables from Toplofikatsia Sofia EAD..................................................................................................... 39
24. Financial assets at fair value through other comprehensive income ................................................................ 41
25. Cash ................................................................................................................................................................. 41
26. Share capital and reserves ................................................................................................................................ 42
27. Issued bonds .................................................................................................................................................... 43
28. Loan from the European Investment Bank ...................................................................................................... 44
29. Reconciliation of liabilities arising from financial activities ........................................................................... 45
30. Liabilities related to employee’ retirement income ......................................................................................... 46
31. Trade and other payables ................................................................................................................................. 48
32. Related party disclosures ................................................................................................................................. 48
33. Non-cash transactions ...................................................................................................................................... 57
34. Commitments, lease and contingent liabilities ................................................................................................ 57
35. Financial Risk Management Objectives and Policy......................................................................................... 60
36. Fair value measurement ................................................................................................................................... 67
37. Capital management policies and procedures .................................................................................................. 68
38. Events after the reporting period...................................................................................................................... 68
Contents
Annual Separate Activity Report ................................................................................................................................... i
Corporate Governance Statement ................................................................................................................................. ii
Independent Auditors’ Report ...................................................................................................................................... iii
Annual Separate Financial Statements ......................................................................................................................... iv
Separate Statement of Profit or Loss ............................................................................................................................. 1
Separate Statement of Comprehensive Income ............................................................................................................. 2
Separate Statement of Financial Position ...................................................................................................................... 3
Separate Statement of Changes in Equity ..................................................................................................................... 5
Separate Statement of Cash Flows ................................................................................................................................ 7
Notes to the Separate Financial Statements .................................................................................................................. 8
1. General information and scope of activity ......................................................................................................... 8
3. Changes in the accounting policy .................................................................................................................... 10
4. Material Accounting Policy Information ......................................................................................................... 11
5. Dividend income .............................................................................................................................................. 28
6. Revenues from contracts with customers......................................................................................................... 29
7. Other income ................................................................................................................................................... 29
8. Impairment expenses ....................................................................................................................................... 30
9. Expenses for materials ..................................................................................................................................... 30
10. Hired services expenses ................................................................................................................................... 30
11. Audit services remuneration ............................................................................................................................ 31
12. Personnel expenses .......................................................................................................................................... 31
13. Other expenses ................................................................................................................................................. 31
14. Financial income .............................................................................................................................................. 31
15. Financial expenses ........................................................................................................................................... 32
16. Income tax expenses ........................................................................................................................................ 32
17. Earnings per share and dividends .................................................................................................................... 32
18. Investments in subsidiaries, associates and joint ventures ............................................................................... 33
19. Property, plant and equipment ......................................................................................................................... 36
20. Intangible assets ............................................................................................................................................... 37
21. Deferred tax assets ........................................................................................................................................... 38
22. Trade and other receivables ............................................................................................................................. 39
23. Receivables from Toplofikatsia Sofia EAD..................................................................................................... 39
24. Financial assets at fair value through other comprehensive income ................................................................ 41
25. Cash ................................................................................................................................................................. 41
26. Share capital and reserves ................................................................................................................................ 42
27. Issued bonds .................................................................................................................................................... 43
28. Loan from the European Investment Bank ...................................................................................................... 44
29. Reconciliation of liabilities arising from financial activities ........................................................................... 45
30. Liabilities related to employee’ retirement income ......................................................................................... 46
31. Trade and other payables ................................................................................................................................. 48
32. Related party disclosures ................................................................................................................................. 48
33. Non-cash transactions ...................................................................................................................................... 57
34. Commitments, lease and contingent liabilities ................................................................................................ 57
35. Financial Risk Management Objectives and Policy......................................................................................... 60
36. Fair value measurement ................................................................................................................................... 67
37. Capital management policies and procedures .................................................................................................. 68
38. Events after the reporting period...................................................................................................................... 68
BULGARIAN ENERGY HOLDING EAD
ANNUAL INDIVIDUAL MANAGEMENT REPORT
31 December 2024
ANNUAL INDIVIDUAL MANAGEMENT REPORT
31 December 2024
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
1
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Board of Directors as at the date of publication of the Separate Financial Statements
Veselina Lachezarova Kanatova-Buchkova
Kalin Boyanov Filipov
Valentin Aleksiev Nikolov
Diyan Atanasov Ivanov
Ivo Ivanov Todorov
Address
Bulgaria
District, Sofia 1000
Oborishte district
16 Veslets str.
Auditor
DZZD Audit BEH with participants audit firms Grant Thornton OOD and Zaharinova Nexia EOOD, registered
respectively under reg. № 032 and Reg. № 138 in the Register of Registered Auditors
Annual Individual Management Report
31 December 2024
1
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Board of Directors as at the date of publication of the Separate Financial Statements
Veselina Lachezarova Kanatova-Buchkova
Kalin Boyanov Filipov
Valentin Aleksiev Nikolov
Diyan Atanasov Ivanov
Ivo Ivanov Todorov
Address
Bulgaria
District, Sofia 1000
Oborishte district
16 Veslets str.
Auditor
DZZD Audit BEH with participants audit firms Grant Thornton OOD and Zaharinova Nexia EOOD, registered
respectively under reg. № 032 and Reg. № 138 in the Register of Registered Auditors
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
2
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Annual Individual Management Report
This annual management report of Bulgarian Energy Holding EAD (BEH EAD) as of 31.12.2024 presents a
commentary and analysis of the separate financial statements and other essential information concerning the financial
position and the results of the Company’s activities covering the period from 1 January 2024 to 31 December 2024.
The report has been prepared in accordance with Art. 39 of the Accountancy Act, Art. 187e, Art. 247, para. 1, 2, and
3 of the Commerce Act.
1. Company Information
Company name BULGARIAN ENERGY HOLDING EAD (BEH EAD)
UIC 831373560
Sole owner The Bulgarian State through the Ministry of Energy
Address Bulgaria
District, Sofia 1000
Oborishte district
16 Veslets str.
Scope of Business
Activity
Acquisition, valuation and sale of participations in commercial companies carrying out
business activities in the fields of production, extraction, transmission, transit, storage,
management, distribution, sale and/or purchase of natural gas, electricity, thermal power,
coal, as well as all types of energy and raw materials for the production and participation
in the management of such companies, their financing, acquisition, valuation, issuance
and sale of bonds, acquisition, valuation and sale of patents, assignment of licenses for
use of patents to the above companies, as well as carrying out own production or
commercial activities.
Directors As of 31 December 2024, the Company is managed by a Board of Directors (BOD) with
members:
Veselina Lachezarova Kanatova-Buchkova
Chairperson of the BD
Kalin Boyanov Filipov
Vice-Chairperson of the BD
Valentin Aleksiev Nikolov
Member of the BD and Executive Director
Galina Tsvetanova Todorova
Member of the BD and Executive Director
Ivo Ivanov Todorov
Member of the BD
Auditor DZZD Audit BEH with participants audit firms Grant Thornton OOD and Zaharinova
Nexia EOOD, registered respectively under reg. № 032 and Reg. № 138 in the Register
of Registered Auditors
Basis for preparation of
financial statements
The Company prepares its separate financial statements in accordance with the
requirements of IFRS Accounting Standards, as adopted by the EU.
The Company also prepares consolidated financial statements in accordance with the
requirements of Art. 31 of the Accountancy Act. The annual financial statements of the
Company are published in the Commercial Register by 30 September of the following
year, according to Art. 38 of the Accountancy Act.
Bulgarian Energy Holding EAD operates in compliance with the Bulgarian legislation.
Annual Individual Management Report
31 December 2024
2
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Annual Individual Management Report
This annual management report of Bulgarian Energy Holding EAD (BEH EAD) as of 31.12.2024 presents a
commentary and analysis of the separate financial statements and other essential information concerning the financial
position and the results of the Company’s activities covering the period from 1 January 2024 to 31 December 2024.
The report has been prepared in accordance with Art. 39 of the Accountancy Act, Art. 187e, Art. 247, para. 1, 2, and
3 of the Commerce Act.
1. Company Information
Company name BULGARIAN ENERGY HOLDING EAD (BEH EAD)
UIC 831373560
Sole owner The Bulgarian State through the Ministry of Energy
Address Bulgaria
District, Sofia 1000
Oborishte district
16 Veslets str.
Scope of Business
Activity
Acquisition, valuation and sale of participations in commercial companies carrying out
business activities in the fields of production, extraction, transmission, transit, storage,
management, distribution, sale and/or purchase of natural gas, electricity, thermal power,
coal, as well as all types of energy and raw materials for the production and participation
in the management of such companies, their financing, acquisition, valuation, issuance
and sale of bonds, acquisition, valuation and sale of patents, assignment of licenses for
use of patents to the above companies, as well as carrying out own production or
commercial activities.
Directors As of 31 December 2024, the Company is managed by a Board of Directors (BOD) with
members:
Veselina Lachezarova Kanatova-Buchkova
Chairperson of the BD
Kalin Boyanov Filipov
Vice-Chairperson of the BD
Valentin Aleksiev Nikolov
Member of the BD and Executive Director
Galina Tsvetanova Todorova
Member of the BD and Executive Director
Ivo Ivanov Todorov
Member of the BD
Auditor DZZD Audit BEH with participants audit firms Grant Thornton OOD and Zaharinova
Nexia EOOD, registered respectively under reg. № 032 and Reg. № 138 in the Register
of Registered Auditors
Basis for preparation of
financial statements
The Company prepares its separate financial statements in accordance with the
requirements of IFRS Accounting Standards, as adopted by the EU.
The Company also prepares consolidated financial statements in accordance with the
requirements of Art. 31 of the Accountancy Act. The annual financial statements of the
Company are published in the Commercial Register by 30 September of the following
year, according to Art. 38 of the Accountancy Act.
Bulgarian Energy Holding EAD operates in compliance with the Bulgarian legislation.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
1.1. Establishment, management, and structure of the Company
1.1.1. Legal status
Bulgarian Energy Holding EAD is a sole-owner joint-stock company, established by Decision No. 1371/1990 of the
Sofia City Court, 100% state-owned.
The sole shareholder of the capital is the Republic of Bulgaria and the rights of a sole shareholder are exercised by
the Minister of Energy, who has the capacity of principal and is authorized to make all decisions within the competence
of the sole shareholder of the capital, in compliance with the law and the Company’s Articles of Association.
The Company is managed by a one-tier management system. The management bodies are:
• General Meeting – Sole Shareholder of the Capital;
• The Board of Directors.
1.1.2. History
Bulgarian Energy Holding EAD is the successor of the Neft i Gas (Oil and Gas) State Company, founded in 1973,
and renamed “Gasosnabdyavane” (Gas Supply) in December 1975. In accordance with the Decree on Business
Activities, in the beginning of 1990, the company was renamed “Bulgargaz”. Bulgargaz was transformed into a sole-
owner joint-stock company by order of the Council of Ministers of 12 May 1993.
At the end of 2004, the Company established the subsidiary Bulgartel EAD with scope of business activity:
construction, use and maintenance of telecommunications networks and information systems.
By a conversion plan of 27 October 2006 and its annexes, Bulgargaz EAD was converted into Bulgargaz Holding EAD
through the separation of two sole joint-stock companies – Bulgartransgaz EAD and Bulgargaz EAD under the terms
of Article 262(d) of the Commercial Act. Bulgartransgaz EAD and Bulgargaz EAD are legal successors of the
respective portion of the property (rights and obligations) of Bulgargaz Holding EAD. The transformation was
registered in the court by decision No. 45 dated 15 January 2007 of the Sofia City Court.
With protocol No. RD-21-305 dated 18 September 2008 of the Minister of Economy and Energy the company name
was changed from Bulgargaz Holding EAD to Bulgarian Energy Holding EAD and the capital through was raised
through an in-kind contribution at par value of all shares of the capital of Natsionalna Elektricheska Kompania EAD,
NPP Kozloduy EAD, TPP Maritsa East 2 EAD and Mini Maritsa Iztok EAD.
In compliance with the requirements of the Third Energy Package, the Bulgarian legislator chose the independent
transmission operator model as the unbundling option applicable to the Bulgarian electricity transmission system
operator. By decision under Protocol No. 71-2013 / 11.12.2013 of the Board of Directors of BEH EAD and in
accordance with Decision P-205 of 18.12.2013 of the State Energy and Water Regulation Commission, restructuring
of NEK EAD was carried out by separation of ESO EAD. As a transmission system operator, ESO EAD remained
part of the vertically integrated undertaking, but detailed unbundling rules that comply with the European directives
and the national legislation were introduced and implemented.
By Protocol No. РД-21-27/18.09.2017, a decision was made to make a contribution in kind with the shares of Bulgartel
EAD – 50% of which were paid in as an increase of the capital of Bulgartransgaz EAD, and the remaining 50% – as
an increase of the capital of Electricity System Operator EAD.
At the time of preparation of the Annual Financial Statements, the State did not announce plans for full or partial
privatization of the Company. The assets united within the holding structure are of strategic significance for the
national security and therefore Bulgarian Energy Holding EAD was included in the so-called “prohibitive”
privatization list, according to Annex 1 to Art. 3, para.1 of the Privatization and Post-Privatization Control Act.
1.1.3. Structure
Bulgarian Energy Holding EAD carries out its business activities by operating in different market segments through
its subsidiaries. The company does not have any branches.
The Company does not carry out any R&D activities.
Annual Individual Management Report
31 December 2024
3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
1.1. Establishment, management, and structure of the Company
1.1.1. Legal status
Bulgarian Energy Holding EAD is a sole-owner joint-stock company, established by Decision No. 1371/1990 of the
Sofia City Court, 100% state-owned.
The sole shareholder of the capital is the Republic of Bulgaria and the rights of a sole shareholder are exercised by
the Minister of Energy, who has the capacity of principal and is authorized to make all decisions within the competence
of the sole shareholder of the capital, in compliance with the law and the Company’s Articles of Association.
The Company is managed by a one-tier management system. The management bodies are:
• General Meeting – Sole Shareholder of the Capital;
• The Board of Directors.
1.1.2. History
Bulgarian Energy Holding EAD is the successor of the Neft i Gas (Oil and Gas) State Company, founded in 1973,
and renamed “Gasosnabdyavane” (Gas Supply) in December 1975. In accordance with the Decree on Business
Activities, in the beginning of 1990, the company was renamed “Bulgargaz”. Bulgargaz was transformed into a sole-
owner joint-stock company by order of the Council of Ministers of 12 May 1993.
At the end of 2004, the Company established the subsidiary Bulgartel EAD with scope of business activity:
construction, use and maintenance of telecommunications networks and information systems.
By a conversion plan of 27 October 2006 and its annexes, Bulgargaz EAD was converted into Bulgargaz Holding EAD
through the separation of two sole joint-stock companies – Bulgartransgaz EAD and Bulgargaz EAD under the terms
of Article 262(d) of the Commercial Act. Bulgartransgaz EAD and Bulgargaz EAD are legal successors of the
respective portion of the property (rights and obligations) of Bulgargaz Holding EAD. The transformation was
registered in the court by decision No. 45 dated 15 January 2007 of the Sofia City Court.
With protocol No. RD-21-305 dated 18 September 2008 of the Minister of Economy and Energy the company name
was changed from Bulgargaz Holding EAD to Bulgarian Energy Holding EAD and the capital through was raised
through an in-kind contribution at par value of all shares of the capital of Natsionalna Elektricheska Kompania EAD,
NPP Kozloduy EAD, TPP Maritsa East 2 EAD and Mini Maritsa Iztok EAD.
In compliance with the requirements of the Third Energy Package, the Bulgarian legislator chose the independent
transmission operator model as the unbundling option applicable to the Bulgarian electricity transmission system
operator. By decision under Protocol No. 71-2013 / 11.12.2013 of the Board of Directors of BEH EAD and in
accordance with Decision P-205 of 18.12.2013 of the State Energy and Water Regulation Commission, restructuring
of NEK EAD was carried out by separation of ESO EAD. As a transmission system operator, ESO EAD remained
part of the vertically integrated undertaking, but detailed unbundling rules that comply with the European directives
and the national legislation were introduced and implemented.
By Protocol No. РД-21-27/18.09.2017, a decision was made to make a contribution in kind with the shares of Bulgartel
EAD – 50% of which were paid in as an increase of the capital of Bulgartransgaz EAD, and the remaining 50% – as
an increase of the capital of Electricity System Operator EAD.
At the time of preparation of the Annual Financial Statements, the State did not announce plans for full or partial
privatization of the Company. The assets united within the holding structure are of strategic significance for the
national security and therefore Bulgarian Energy Holding EAD was included in the so-called “prohibitive”
privatization list, according to Annex 1 to Art. 3, para.1 of the Privatization and Post-Privatization Control Act.
1.1.3. Structure
Bulgarian Energy Holding EAD carries out its business activities by operating in different market segments through
its subsidiaries. The company does not have any branches.
The Company does not carry out any R&D activities.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
4
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
As of 31 December 2024, the BEH group comprises the following companies:
Information under Art. 187e and Art. 247, para. 2 of the Commercial Act
1.1.4. Share capital
As of 31 December 2024, the share capital of the Company amounts to BGN 3,463,941,744 divided into 3,463,941,744
ordinary registered voting shares with a nominal value of BGN 1 each. The entire amount of the Company capital is
subscribed and fully paid-up. The Company shares are ordinary, registered, non-privileged, with voting rights.
The Company does not possess any own shares. In 2024, the Company did not acquire or transfer its own shares.
Annual Individual Management Report
31 December 2024
4
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
As of 31 December 2024, the BEH group comprises the following companies:
Information under Art. 187e and Art. 247, para. 2 of the Commercial Act
1.1.4. Share capital
As of 31 December 2024, the share capital of the Company amounts to BGN 3,463,941,744 divided into 3,463,941,744
ordinary registered voting shares with a nominal value of BGN 1 each. The entire amount of the Company capital is
subscribed and fully paid-up. The Company shares are ordinary, registered, non-privileged, with voting rights.
The Company does not possess any own shares. In 2024, the Company did not acquire or transfer its own shares.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
5
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
1.1.5. Board of Directors
Information about the remuneration of the members of the Board of Directors of Bulgarian Energy Holding EAD
under management and control contracts:
BGN’000 31 December
2024
31 December
2023
Short-term remunerations, including: BGN’000 BGN’000
Remuneration 542 519
Social security contributions 18 21
Social costs 121 157
Unused annual leave and related social security expenses 18 19
Tantièmes - 154
Total remuneration 699 870
Information about the shares and bonds of the Company acquired, held and transferred by the members of
the Board of Directors of BEH EAD
The members of the Board of Directors of Bulgarian Energy Holding EAD do not own shares or bonds of the
Company. They do not have privileges or exclusive rights to acquire shares and bonds of the Company. All shares are
owned by the Bulgarian state.
Information on the participation of the members of the Board of Directors in commercial companies as
unlimited liability partners, ownership of more than 25 percent of the share capital of another company, as
well as their participation in the management of other companies or cooperatives as procurators, managers or
board members for the period 01.01.2024 - 31.12.2024:
Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors of Bulgarian Energy Holding
EAD as of 31.12.2024. She does not have any participation as an unlimited liability partner, does not own more than
25 percent of the share capital of another company, and does not participate in the management of other companies
or cooperatives as procurator, manager or board member.
Kalin Boyanov Filipov – Vice Chairperson of the Board of Directors of Bulgarian Energy Holding EAD and as of
31.12.2024. He does not have any participation as an unlimited liability partner, does not own more than 25 percent
of the share capital of another company, and does not participate in the management of other companies or
cooperatives as procurator, manager or board member.
Valentin Alexiev Nikolov - Executive Director of Bulgarian Energy Holding EAD and member of the Board of
Directors since 04.07.2024 and as of 31.12.2024. He owns more than 25 percent of the capital of the following
company:
SUZVEZDIE LUV OOD, UIC: 202787168 – sole owner of the capital until 10.01.2024 and partner with 49 percent
participation in the capital from 10.01.2024 to the present;
MDV CONSULT OOD, UIC: 203320833 – Partner with 50 percent participation in the capital until the present
moment.
Until 04.07.2024, he participated in the management as Executive Director and member of the Board of Directors of
the following company:
Kozloduy NPP EAD, UIC: 106513772.
Galina Tsvetanova Todorova – Executive Director of Bulgarian Energy Holding EAD and member of the Board of
Directors from 04.07.2024 and as of 31.12.2024. She does not have any participation as an unlimited liability partner,
does not own more than 25 percent of the share capital of another company, as well does not participate in the
management of other companies or cooperatives as procurator, manager or board member.
Ivan Todorov Andreev – Executive Director of Bulgarian Energy Holding EAD and member of the Board of
Directors until 04.07.2024. He participates as a member of the Supervisory Board of the following company:
Annual Individual Management Report
31 December 2024
5
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
1.1.5. Board of Directors
Information about the remuneration of the members of the Board of Directors of Bulgarian Energy Holding EAD
under management and control contracts:
BGN’000 31 December
2024
31 December
2023
Short-term remunerations, including: BGN’000 BGN’000
Remuneration 542 519
Social security contributions 18 21
Social costs 121 157
Unused annual leave and related social security expenses 18 19
Tantièmes - 154
Total remuneration 699 870
Information about the shares and bonds of the Company acquired, held and transferred by the members of
the Board of Directors of BEH EAD
The members of the Board of Directors of Bulgarian Energy Holding EAD do not own shares or bonds of the
Company. They do not have privileges or exclusive rights to acquire shares and bonds of the Company. All shares are
owned by the Bulgarian state.
Information on the participation of the members of the Board of Directors in commercial companies as
unlimited liability partners, ownership of more than 25 percent of the share capital of another company, as
well as their participation in the management of other companies or cooperatives as procurators, managers or
board members for the period 01.01.2024 - 31.12.2024:
Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors of Bulgarian Energy Holding
EAD as of 31.12.2024. She does not have any participation as an unlimited liability partner, does not own more than
25 percent of the share capital of another company, and does not participate in the management of other companies
or cooperatives as procurator, manager or board member.
Kalin Boyanov Filipov – Vice Chairperson of the Board of Directors of Bulgarian Energy Holding EAD and as of
31.12.2024. He does not have any participation as an unlimited liability partner, does not own more than 25 percent
of the share capital of another company, and does not participate in the management of other companies or
cooperatives as procurator, manager or board member.
Valentin Alexiev Nikolov - Executive Director of Bulgarian Energy Holding EAD and member of the Board of
Directors since 04.07.2024 and as of 31.12.2024. He owns more than 25 percent of the capital of the following
company:
SUZVEZDIE LUV OOD, UIC: 202787168 – sole owner of the capital until 10.01.2024 and partner with 49 percent
participation in the capital from 10.01.2024 to the present;
MDV CONSULT OOD, UIC: 203320833 – Partner with 50 percent participation in the capital until the present
moment.
Until 04.07.2024, he participated in the management as Executive Director and member of the Board of Directors of
the following company:
Kozloduy NPP EAD, UIC: 106513772.
Galina Tsvetanova Todorova – Executive Director of Bulgarian Energy Holding EAD and member of the Board of
Directors from 04.07.2024 and as of 31.12.2024. She does not have any participation as an unlimited liability partner,
does not own more than 25 percent of the share capital of another company, as well does not participate in the
management of other companies or cooperatives as procurator, manager or board member.
Ivan Todorov Andreev – Executive Director of Bulgarian Energy Holding EAD and member of the Board of
Directors until 04.07.2024. He participates as a member of the Supervisory Board of the following company:
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
6
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
ALLIANZ BULGARIA PENSION COMPANY AD, UIC: 121050885. Since 04.07.2024, he has participated in the
management as Executive Director and member of the Board of Directors of the following company: Kozloduy NPP
EAD, UIC: 106513772.
Diyan Stanimirov Dimitrov - Member of the Board of Directors of Bulgarian Energy Holding EAD until 04.07.2024.
Since 04.07.2024 he has participated in the management as Executive Director and Member of the Board of Directors
of the following company: TPP Maritsa East 2 EAD, UIC: 123531939.
Ivo Ivanov Todorov – Member of the Board of Directors of Bulgarian Energy Holding EAD since 31.12.2024. He
does not have any participation as an unlimited liability partner, does not own more than 25 percent of the share capital
of another company, as well does not participate in the management of other companies or cooperatives as procurator,
manager or board member.
Information on contracts pursuant to Art. 240b of the Commercial Act
The Company has not entered into contracts with members of the Board of Directors, other than management and
control contracts, as well as with parties related to them.
1.1.6. Personnel
As of 31 December 2024, the total number of employees of the Company under employment contracts is 101 people,
allocated in the following categories:
Total number of employees 31 December
2024
31 December
2023
Total employees under an employment relationship, including 101 101
Executives 26 28
Analytical specialists 64 61
Associate professionals 2 2
Support staff 6 7
Drivers 3 3
1.1.7. Related parties
Bulgarian Energy Holding EAD is the owner of an economically related group, which includes the following direct
subsidiaries as of 31 December 2024:
Company Country of
incorporation Share 31 December 2024
% BGN’000
Subsidiaries
Bulgartransgaz EAD Bulgaria 100.00% 934,569
Bulgargaz EAD Bulgaria 100.00% -
NEK EAD Bulgaria 100.00% 1,051,427
Kozloduy NPP EAD Bulgaria 100.00% 1,601,716
TPP Maritsa East 2 EAD Bulgaria 100.00% 673,916
Mini Maritsa-Iztok EAD Bulgaria 100.00% 65,000
ESO EAD Bulgaria 100.00% 96,103
National Energy Operator EAD Bulgaria 100.00% 30,000
Minproekt EAD Bulgaria 100.00% 1,000
Total equity interest in subsidiaries 4,453,731
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31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
ALLIANZ BULGARIA PENSION COMPANY AD, UIC: 121050885. Since 04.07.2024, he has participated in the
management as Executive Director and member of the Board of Directors of the following company: Kozloduy NPP
EAD, UIC: 106513772.
Diyan Stanimirov Dimitrov - Member of the Board of Directors of Bulgarian Energy Holding EAD until 04.07.2024.
Since 04.07.2024 he has participated in the management as Executive Director and Member of the Board of Directors
of the following company: TPP Maritsa East 2 EAD, UIC: 123531939.
Ivo Ivanov Todorov – Member of the Board of Directors of Bulgarian Energy Holding EAD since 31.12.2024. He
does not have any participation as an unlimited liability partner, does not own more than 25 percent of the share capital
of another company, as well does not participate in the management of other companies or cooperatives as procurator,
manager or board member.
Information on contracts pursuant to Art. 240b of the Commercial Act
The Company has not entered into contracts with members of the Board of Directors, other than management and
control contracts, as well as with parties related to them.
1.1.6. Personnel
As of 31 December 2024, the total number of employees of the Company under employment contracts is 101 people,
allocated in the following categories:
Total number of employees 31 December
2024
31 December
2023
Total employees under an employment relationship, including 101 101
Executives 26 28
Analytical specialists 64 61
Associate professionals 2 2
Support staff 6 7
Drivers 3 3
1.1.7. Related parties
Bulgarian Energy Holding EAD is the owner of an economically related group, which includes the following direct
subsidiaries as of 31 December 2024:
Company Country of
incorporation Share 31 December 2024
% BGN’000
Subsidiaries
Bulgartransgaz EAD Bulgaria 100.00% 934,569
Bulgargaz EAD Bulgaria 100.00% -
NEK EAD Bulgaria 100.00% 1,051,427
Kozloduy NPP EAD Bulgaria 100.00% 1,601,716
TPP Maritsa East 2 EAD Bulgaria 100.00% 673,916
Mini Maritsa-Iztok EAD Bulgaria 100.00% 65,000
ESO EAD Bulgaria 100.00% 96,103
National Energy Operator EAD Bulgaria 100.00% 30,000
Minproekt EAD Bulgaria 100.00% 1,000
Total equity interest in subsidiaries 4,453,731
Bulgarian Energy Holding EAD
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31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The Company has direct participation in joint ventures and associates as of 31 December 2024, as follows:
Company Country of
incorporation Share 31 December 2024
% BGN’000
Joint ventures
ICGB AD Bulgaria 50.00% 57,991
South Stream Bulgaria AD Bulgaria 50.00% 10,130
Total joint ventures 68,121
Associated companies
ZAD Energy Bulgaria 0.32% 21
Total associated companies 21
Total shareholding 4,521,873
The following table presents summarized financial information based on the financial statements of the associated and
joint ventures of the Company as of 31 December 2024.
31 December 2024 Total assets Total
liabilities
Revenues Net profit
/(loss)
BGN’000 BGN’000 BGN’000 BGN’000
ICGB AD 601,173 448,389 68,954 32,393
South Stream Bulgaria AD (unaudited data) 20,306 38 6 (261)
ZAD Energy 33,940 6,517 15,589 7,469
655,419 454,944 84,549 39,601
ICGB AD Joint Venture
BEH EAD is a shareholder in ICGB AD – a company with an equal participation of BEH EAD and IGI Poseidon (a
company with an equal participation of DEPA S.A. and Edison SpA), registered in 2011 in the Republic of Bulgaria
with the purpose of building and becoming the owner and operator of IGB gas interconnection network.
In 2022, ICGB AD built the gas interconnector between Greece and Bulgaria with a capacity of up to 3 billion m3 per
year from Komotini to Stara Zagora with a length of 182 km.
The company holds a license and a certificate for a transmission network operator under the "independent transmission
operator" model and carries out natural gas transmission activities via the gas interconnection through which all
quantities of contracted Azeri gas are transported to Bulgaria. ICGB AD generates revenue from the provision of the
natural gas transmission services (currently approximately 1.5 billion m 3 /year).
The reporting year 2024 is the second full year since the start of the operation of the gas pipeline.
South Stream Bulgaria Joint Venture AD
The South Stream project, whose realization was terminated, covered the construction of a new gas system for natural
gas transportation from Russia to the European market through Bulgaria, with a technical capacity of the 900 km
Black Sea section of 63 billion m3 per year. Shareholders with equal interest in the joint venture on the Bulgarian
territory (which is no longer operating) are Bulgarian Energy Holding EAD and Gazprom Krasnodar. Due to the
termination of the South Stream Project, the activities of the South Stream Bulgaria AD project company have been
reduced to an absolute minimum.
A decision on the liquidation of the project company and its erasure from the Commercial Register is yet to be
assessed. In the liquidation process, if such a decision is made, the remaining assets – land properties, should be cashed
out.
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31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The Company has direct participation in joint ventures and associates as of 31 December 2024, as follows:
Company Country of
incorporation Share 31 December 2024
% BGN’000
Joint ventures
ICGB AD Bulgaria 50.00% 57,991
South Stream Bulgaria AD Bulgaria 50.00% 10,130
Total joint ventures 68,121
Associated companies
ZAD Energy Bulgaria 0.32% 21
Total associated companies 21
Total shareholding 4,521,873
The following table presents summarized financial information based on the financial statements of the associated and
joint ventures of the Company as of 31 December 2024.
31 December 2024 Total assets Total
liabilities
Revenues Net profit
/(loss)
BGN’000 BGN’000 BGN’000 BGN’000
ICGB AD 601,173 448,389 68,954 32,393
South Stream Bulgaria AD (unaudited data) 20,306 38 6 (261)
ZAD Energy 33,940 6,517 15,589 7,469
655,419 454,944 84,549 39,601
ICGB AD Joint Venture
BEH EAD is a shareholder in ICGB AD – a company with an equal participation of BEH EAD and IGI Poseidon (a
company with an equal participation of DEPA S.A. and Edison SpA), registered in 2011 in the Republic of Bulgaria
with the purpose of building and becoming the owner and operator of IGB gas interconnection network.
In 2022, ICGB AD built the gas interconnector between Greece and Bulgaria with a capacity of up to 3 billion m3 per
year from Komotini to Stara Zagora with a length of 182 km.
The company holds a license and a certificate for a transmission network operator under the "independent transmission
operator" model and carries out natural gas transmission activities via the gas interconnection through which all
quantities of contracted Azeri gas are transported to Bulgaria. ICGB AD generates revenue from the provision of the
natural gas transmission services (currently approximately 1.5 billion m 3 /year).
The reporting year 2024 is the second full year since the start of the operation of the gas pipeline.
South Stream Bulgaria Joint Venture AD
The South Stream project, whose realization was terminated, covered the construction of a new gas system for natural
gas transportation from Russia to the European market through Bulgaria, with a technical capacity of the 900 km
Black Sea section of 63 billion m3 per year. Shareholders with equal interest in the joint venture on the Bulgarian
territory (which is no longer operating) are Bulgarian Energy Holding EAD and Gazprom Krasnodar. Due to the
termination of the South Stream Project, the activities of the South Stream Bulgaria AD project company have been
reduced to an absolute minimum.
A decision on the liquidation of the project company and its erasure from the Commercial Register is yet to be
assessed. In the liquidation process, if such a decision is made, the remaining assets – land properties, should be cashed
out.
Bulgarian Energy Holding EAD
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31 December 2024
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ZAD Energy Affiliated Company
BEH EAD owns directly 0.32% of the share capital of ZAD Energy. The equity investment is accounted for as an
investment in an associate due to additional indirect participation in the capital of ZAD Energy through other
subsidiaries, resulting in a total direct and indirect equity participation of 48.08%.
2. Main results for 2024
2.1. Strategic projects
Interconnection Greece-Bulgaria – IGB project
The Greece-Bulgaria Gas Interconnector project (IGB project) was implemented in pursuance of the policy of the
Republic Bulgaria, aimed at increasing the security of natural gas supplies by providing infrastructure for access to
alternative sources and routes for supply of natural gas and ensuring the country's physical connectivity with the
Southern Gas Corridor.
With this project, commisioned on 1 October 2022, the construction of a gas pipeline with a capacity of 3 billion m3
per year, from Komotini to Stara Zagora, with a length of 182 km, 151 km of which on Bulgarian territory, was carried
out.
The licensed and certified operator of the gas pipeline is the ICGB AD joint company with equal interest of BEH EAD
and IGI Poseidon (with equal interest of DEPA International Projects and Edison International Holding N.V). The
company is the owner and operator of the gas pipeline, licensed and certified to carry out the transmission service,
distribute the transport capacity of the gas pipeline and receive the revenues from the transmission of natural gas.
Through the construction and commissioning of the IGB gas pipeline, Bulgaria is now connected to the Trans Adriatic
Pipeline for natural gas supplies from the Azerbaijani Shah Deniz field, Phase 2, and the Greek gas transmission
system, which has a functioning re-gasification LNG terminal, Revithoussa, and is connected through a functioning
gas interconnection with Turkey (TGI) for natural gas imports from the Caspian region and the Middle East. The IGB
gas pipeline ensures the long-term supply of the agreed 1 billion m3 per year for the Bulgarian market for 25 years
from Shah-Deniz field, Phase 2, coming from the Trans Adriatic Gas Pipeline.
With the commissioning of the IGB gas pipeline, Bulgaria and Greece are now able to respond effectively to supply
disruptions from external sources or seasonal peaks in the consumption of natural gas. This is infrastructure that
ensures transit transmission, and also ensures crisis supplies and covers peak usage in the months of increased
consumption.
Currently, the gas pipeline operates with a transmission capacity of 3 billion m3 per year, which, with additional
investment, can reach 5 billion m3 per year depending on the market interest.
2.2. Financial results for 2024
Bulgarian Energy Holding EAD operates as a financial holding company and the companies within its structure retain
their operational independence and autonomy. The Company is the largest holding company in Bulgaria in terms of
total assets and annual turnover generated. This allows the company to achieve economies of scale through the
application of efficient management practices in the financial management of the group companies. Through its
participation in the capital markets, BEH EAD has been able to secure external financing for the Group at competitive
interest rates, with the funds raised being used to financially stabilize the Group companies and to implement projects
of strategic importance for the future development of the energy sector in Bulgaria.
As a financial holding, the main revenues that the Company realizes are the income from dividends, interest income
received on loans granted, and revenues related to the services provided for the management of the subsidiaries
through the concluded holding agreements. The services provided to the subsidiaries are in the areas of financial
management, project management, corporate governance and business planning, legal and regulatory affairs, public
relations and communication. These activities ensure the application of a unified approach within the group regarding
Annual Individual Management Report
31 December 2024
8
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
ZAD Energy Affiliated Company
BEH EAD owns directly 0.32% of the share capital of ZAD Energy. The equity investment is accounted for as an
investment in an associate due to additional indirect participation in the capital of ZAD Energy through other
subsidiaries, resulting in a total direct and indirect equity participation of 48.08%.
2. Main results for 2024
2.1. Strategic projects
Interconnection Greece-Bulgaria – IGB project
The Greece-Bulgaria Gas Interconnector project (IGB project) was implemented in pursuance of the policy of the
Republic Bulgaria, aimed at increasing the security of natural gas supplies by providing infrastructure for access to
alternative sources and routes for supply of natural gas and ensuring the country's physical connectivity with the
Southern Gas Corridor.
With this project, commisioned on 1 October 2022, the construction of a gas pipeline with a capacity of 3 billion m3
per year, from Komotini to Stara Zagora, with a length of 182 km, 151 km of which on Bulgarian territory, was carried
out.
The licensed and certified operator of the gas pipeline is the ICGB AD joint company with equal interest of BEH EAD
and IGI Poseidon (with equal interest of DEPA International Projects and Edison International Holding N.V). The
company is the owner and operator of the gas pipeline, licensed and certified to carry out the transmission service,
distribute the transport capacity of the gas pipeline and receive the revenues from the transmission of natural gas.
Through the construction and commissioning of the IGB gas pipeline, Bulgaria is now connected to the Trans Adriatic
Pipeline for natural gas supplies from the Azerbaijani Shah Deniz field, Phase 2, and the Greek gas transmission
system, which has a functioning re-gasification LNG terminal, Revithoussa, and is connected through a functioning
gas interconnection with Turkey (TGI) for natural gas imports from the Caspian region and the Middle East. The IGB
gas pipeline ensures the long-term supply of the agreed 1 billion m3 per year for the Bulgarian market for 25 years
from Shah-Deniz field, Phase 2, coming from the Trans Adriatic Gas Pipeline.
With the commissioning of the IGB gas pipeline, Bulgaria and Greece are now able to respond effectively to supply
disruptions from external sources or seasonal peaks in the consumption of natural gas. This is infrastructure that
ensures transit transmission, and also ensures crisis supplies and covers peak usage in the months of increased
consumption.
Currently, the gas pipeline operates with a transmission capacity of 3 billion m3 per year, which, with additional
investment, can reach 5 billion m3 per year depending on the market interest.
2.2. Financial results for 2024
Bulgarian Energy Holding EAD operates as a financial holding company and the companies within its structure retain
their operational independence and autonomy. The Company is the largest holding company in Bulgaria in terms of
total assets and annual turnover generated. This allows the company to achieve economies of scale through the
application of efficient management practices in the financial management of the group companies. Through its
participation in the capital markets, BEH EAD has been able to secure external financing for the Group at competitive
interest rates, with the funds raised being used to financially stabilize the Group companies and to implement projects
of strategic importance for the future development of the energy sector in Bulgaria.
As a financial holding, the main revenues that the Company realizes are the income from dividends, interest income
received on loans granted, and revenues related to the services provided for the management of the subsidiaries
through the concluded holding agreements. The services provided to the subsidiaries are in the areas of financial
management, project management, corporate governance and business planning, legal and regulatory affairs, public
relations and communication. These activities ensure the application of a unified approach within the group regarding
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
9
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
the future development of the energy companies, which is in line with the directions set out in the Energy Strategy of
Bulgaria.
The values of the main financial indicators characterizing the activities of the company for 2024 and their change
compared to 2023 are presented in the table below:
Financial results 31 December
2024
31 December
2023 Change 2024/2023
BGN’000 BGN’000 BGN’000 %
Revenue from operating activity 634,762 857,194 (222,432) (25.95%)
Operating costs (excluding depreciation,
impairment and financial income) (16,817) (13,967) (2,850) (20.41%)
EBITDA 617,945 843,227 (225,282) (26.72%)
EBIT 554,546 962,369 (407,823) (42.38%)
Earnings before taxes (EBT) 673,878 1,105,772 (431,894) (39.06%)
Net profit 669,451 1,080,629 (411,178) (38.05%)
EBITDA margin 97.35% 98.37% (1.02) p.p. -
Return on equity 14.82% 26.19% (11.37) p.p -
Return on assets 9.28% 15.88% (6.60) p.p. -
Registered number of staff 101 101 - -
Financial position 31 December
2024
31 December
2023 Change 2024/2023
BGN’000 BGN’000 BGN’000 %
Total assets 7,214,163 6,805,834 408,329 6.00%
Working capital (323,861) 548,138 (871,999) (159.08%)
Equity 4,516,034 4,125,576 390,458 9.46%
Cash 313,041 220,012 93,029 42.28%
The financial position of its subsidiaries is the primary factor that directly affects the revenue amount of BEH EAD.
This is because the dividend received by BEH EAD from its subsidiaries is determined based on the net financial
result reported by the subsidiaries from their operations. In 2024, the reported dividend and participation income
(including income from interest on arrears) amounts to BGN 632,297 thousand compared to BGN 855,113 thousand
of dividend and participation income received in 2023. The most significant part of them is the dividend income from
Bulgartransgaz EAD in the amount of BGN 257,251 thousand, followed by dividend income from NPP Kozloduy
EAD and ESO EAD in the amount of BGN 241,673 thousand and BGN 123,503 thousand, respectively. The reported
dividend income in 2024 is lower on an annual basis, since in accordance with item 4 of Order No. 1 of the Council
of Ministers of 27 March 2024, NEK EAD does not distribute or pay a dividend in favor of BEH EAD in 2024 for the
company's profit for 2023. In comparison, in 2023 the reported dividend from NEK EAD was in the amount of BGN
449,314 thousand.
In 2024, the dividend distribution rate from state-owned commercial companies was maintained in accordance with
Order No. 1 of the Council of Ministers of 27 March 2024 on the establishment and payment to the State of deductions
from the profits of state-owned enterprises and state-owned commercial companies, dividend deductions were set at
50% of the net profits of the companies, after deduction of uncovered losses from previous years and deductions for
the Reserve Fund.
In 2024, the company's operating expenses, excluding depreciation and amortization and net financial income,
amounted to BGN 16,817 thousand, representing a growth of 20.4% on an annual basis, the main reason for which
was the costs for external services in the amount of BGN 5,007 thousand in 2024 compared to BGN 2,309 thousand
in 2023. The increase is mainly attributable to the increase in costs related to legal services rendered in connection
with BEH's legal representation in Case COMP/B1/AT.39849 – BEH Gas. With regard to administrative expenses,
Annual Individual Management Report
31 December 2024
9
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
the future development of the energy companies, which is in line with the directions set out in the Energy Strategy of
Bulgaria.
The values of the main financial indicators characterizing the activities of the company for 2024 and their change
compared to 2023 are presented in the table below:
Financial results 31 December
2024
31 December
2023 Change 2024/2023
BGN’000 BGN’000 BGN’000 %
Revenue from operating activity 634,762 857,194 (222,432) (25.95%)
Operating costs (excluding depreciation,
impairment and financial income) (16,817) (13,967) (2,850) (20.41%)
EBITDA 617,945 843,227 (225,282) (26.72%)
EBIT 554,546 962,369 (407,823) (42.38%)
Earnings before taxes (EBT) 673,878 1,105,772 (431,894) (39.06%)
Net profit 669,451 1,080,629 (411,178) (38.05%)
EBITDA margin 97.35% 98.37% (1.02) p.p. -
Return on equity 14.82% 26.19% (11.37) p.p -
Return on assets 9.28% 15.88% (6.60) p.p. -
Registered number of staff 101 101 - -
Financial position 31 December
2024
31 December
2023 Change 2024/2023
BGN’000 BGN’000 BGN’000 %
Total assets 7,214,163 6,805,834 408,329 6.00%
Working capital (323,861) 548,138 (871,999) (159.08%)
Equity 4,516,034 4,125,576 390,458 9.46%
Cash 313,041 220,012 93,029 42.28%
The financial position of its subsidiaries is the primary factor that directly affects the revenue amount of BEH EAD.
This is because the dividend received by BEH EAD from its subsidiaries is determined based on the net financial
result reported by the subsidiaries from their operations. In 2024, the reported dividend and participation income
(including income from interest on arrears) amounts to BGN 632,297 thousand compared to BGN 855,113 thousand
of dividend and participation income received in 2023. The most significant part of them is the dividend income from
Bulgartransgaz EAD in the amount of BGN 257,251 thousand, followed by dividend income from NPP Kozloduy
EAD and ESO EAD in the amount of BGN 241,673 thousand and BGN 123,503 thousand, respectively. The reported
dividend income in 2024 is lower on an annual basis, since in accordance with item 4 of Order No. 1 of the Council
of Ministers of 27 March 2024, NEK EAD does not distribute or pay a dividend in favor of BEH EAD in 2024 for the
company's profit for 2023. In comparison, in 2023 the reported dividend from NEK EAD was in the amount of BGN
449,314 thousand.
In 2024, the dividend distribution rate from state-owned commercial companies was maintained in accordance with
Order No. 1 of the Council of Ministers of 27 March 2024 on the establishment and payment to the State of deductions
from the profits of state-owned enterprises and state-owned commercial companies, dividend deductions were set at
50% of the net profits of the companies, after deduction of uncovered losses from previous years and deductions for
the Reserve Fund.
In 2024, the company's operating expenses, excluding depreciation and amortization and net financial income,
amounted to BGN 16,817 thousand, representing a growth of 20.4% on an annual basis, the main reason for which
was the costs for external services in the amount of BGN 5,007 thousand in 2024 compared to BGN 2,309 thousand
in 2023. The increase is mainly attributable to the increase in costs related to legal services rendered in connection
with BEH's legal representation in Case COMP/B1/AT.39849 – BEH Gas. With regard to administrative expenses,
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
10
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
the efforts of the management are focused on their optimization by applying a selection of best management practices
and approaches aimed at efficient utilization of available resources.
As a result of the observed dynamics of revenue and expenses, the company’s earnings before interest, taxes,
depreciation and amortization (EBITDA) in 2024 amounted to BGN 617,945 thousand and was BGN 225,282
thousand (or 26.7%) lower than the reported EBITDA in 2023 in the amount of BGN 843,227 thousand.
In 2024, BEH EAD generated earnings before interest and taxes (EBIT) in the amount of BGN 554,546 thousand,
reporting a decrease of BGN 407,823 thousand (or 42.4%) compared to the operating profit reported a year earlier in
the amount of BGN 962,369 thousand. During the period under review, the company's operating result deteriorated
mainly due to lower reported dividend income, as well as due to an accrued impairment charge of BGN 62,658
thousand, mainly related to impaired loans to related parties. In comparison, in 2023, impairment income on loans
receivable from related parties and on receivables from Toplofikatsiya Sofia EAD in the total amount of BGN 119,794
thousand was reintegrated.
At the level of profit before tax, the result reported in 2024 is BGN 673,878 thousand and is BGN 431,894 thousand
lower than the reported profit before tax in 2023 of BGN 1,105,772 thousand. This result is influenced by the reported
net financial income in 2024 of BGN 119,332 thousand (compared to net financial income of BGN 143,403 thousand
in 2023). A significant part of the company’s financial income came from interest on loans granted to its subsidiaries.
In 2024, the company's reported financial expenses amount to BGN 73,623 thousand. (BGN 74,617 thousand in 2023)
and mainly reflect accrued interest on BEH EAD's outstanding bond issues.
The working capital of BEH EAD for 2024 is negative and amounts to BGN 323,861 thousand, compared to a positive
working capital of BGN 548,138 thousand, reported in 2023. The main reason for the change in working capital on
an annual basis is the bond issue of BEH EAD maturing in June 2025, in connection with which a current liability on
issued bonds of BGN 1,206,731 thousand was recorded at the end of 2024. The company's total interest -bearing
liabilities as of the end of 2024 remain stable on an annual basis - in the amount of BGN 2,635,335 thousand, consisting
of two outstanding bond issues in the amount of BGN 2,378,371 thousand, a loan obligation to the European
Investment Bank in the amount of BGN 215,380 thousand as of 31.12.2024, as well as a loan obligation received from
NPP Kozloduy EAD in the amount of BGN 41,584 thousand. The company's cash balances increased by BGN 93,029
thousand on an annual basis and amounted to BGN 313,041 thousand at the end of 2024.
In connection with the adopted policy for the purchase of greenhouse gas emission allowances of BEH EAD and on
the basis of the contract concluded in July 2021 between BEH EAD as the seller and TPP Maritsa East 2 EAD as the
buyer, the Holding has purchased greenhouse gas emission allowances of the EUA type for securing the production
activity of the thermal power plant in 2021, 2022, 2023 and 2024. The Company's commitment obliges it to purchase
greenhouse gas emission allowances on an ongoing basis upon receipt of a request from TPP Maritsa East 2 EAD.
The allowances purchased are transferred to the account of the buyer once they have been paid in full by the latter.
The goal of this strategy is the optimization of the costs for carbon emissions by implementing a competitive principle
in buying them and thus reducing the brokerage commissions. The current purchase of the required emission
allowances allows their costs to be fully included in the price of the electricity sold, thus hedging the risk of rising
emission prices.
Principle – assumption of a going concern
The sole shareholder of the Company is the Bulgarian State through the Minister of Energy, in their capacity as
Principal. The functioning and the future development of the Company is entirely dependent on the future intentions
and strategy of the state regarding the continuation of its functions and activities within the energy sector in Bulgaria.
The management has analyzed the validity of the going concern assumption, taking into account the principal’s
intentions in the short and medium term. As a result, it has come to the conclusion that the use of the going concern
assumption is appropriate. Management has also taken into account the available information on the foreseeable
future, the above-described circumstances related to macroeconomic factors and the ongoing war between Russia and
Ukraine, the Bulgarian Recovery and Resilience Plan, approved by the EU, and the dynamics of the energy market
globally and in Bulgaria. In addition, as at 31 December 2024 current liabilities exceed current assets by BGN 323,861
thousand. Included in current liabilities is a liability of BGN 1,206,731 thousand for bonds issued, of which BGN
1,193,971 thousand is for a bond issue maturing on 28 June 2025. In accordance with the Company's adopted Business
Program, the Company will refinance the bond issue maturing on 30 June 2025 with a new bond issue in 2025. The
Board of Directors expects that the Company will have sufficient financial resources to continue in operation f or the
foreseeable future and will continue to apply the going concern basis in preparing the independent financial statements.
Annual Individual Management Report
31 December 2024
10
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
the efforts of the management are focused on their optimization by applying a selection of best management practices
and approaches aimed at efficient utilization of available resources.
As a result of the observed dynamics of revenue and expenses, the company’s earnings before interest, taxes,
depreciation and amortization (EBITDA) in 2024 amounted to BGN 617,945 thousand and was BGN 225,282
thousand (or 26.7%) lower than the reported EBITDA in 2023 in the amount of BGN 843,227 thousand.
In 2024, BEH EAD generated earnings before interest and taxes (EBIT) in the amount of BGN 554,546 thousand,
reporting a decrease of BGN 407,823 thousand (or 42.4%) compared to the operating profit reported a year earlier in
the amount of BGN 962,369 thousand. During the period under review, the company's operating result deteriorated
mainly due to lower reported dividend income, as well as due to an accrued impairment charge of BGN 62,658
thousand, mainly related to impaired loans to related parties. In comparison, in 2023, impairment income on loans
receivable from related parties and on receivables from Toplofikatsiya Sofia EAD in the total amount of BGN 119,794
thousand was reintegrated.
At the level of profit before tax, the result reported in 2024 is BGN 673,878 thousand and is BGN 431,894 thousand
lower than the reported profit before tax in 2023 of BGN 1,105,772 thousand. This result is influenced by the reported
net financial income in 2024 of BGN 119,332 thousand (compared to net financial income of BGN 143,403 thousand
in 2023). A significant part of the company’s financial income came from interest on loans granted to its subsidiaries.
In 2024, the company's reported financial expenses amount to BGN 73,623 thousand. (BGN 74,617 thousand in 2023)
and mainly reflect accrued interest on BEH EAD's outstanding bond issues.
The working capital of BEH EAD for 2024 is negative and amounts to BGN 323,861 thousand, compared to a positive
working capital of BGN 548,138 thousand, reported in 2023. The main reason for the change in working capital on
an annual basis is the bond issue of BEH EAD maturing in June 2025, in connection with which a current liability on
issued bonds of BGN 1,206,731 thousand was recorded at the end of 2024. The company's total interest -bearing
liabilities as of the end of 2024 remain stable on an annual basis - in the amount of BGN 2,635,335 thousand, consisting
of two outstanding bond issues in the amount of BGN 2,378,371 thousand, a loan obligation to the European
Investment Bank in the amount of BGN 215,380 thousand as of 31.12.2024, as well as a loan obligation received from
NPP Kozloduy EAD in the amount of BGN 41,584 thousand. The company's cash balances increased by BGN 93,029
thousand on an annual basis and amounted to BGN 313,041 thousand at the end of 2024.
In connection with the adopted policy for the purchase of greenhouse gas emission allowances of BEH EAD and on
the basis of the contract concluded in July 2021 between BEH EAD as the seller and TPP Maritsa East 2 EAD as the
buyer, the Holding has purchased greenhouse gas emission allowances of the EUA type for securing the production
activity of the thermal power plant in 2021, 2022, 2023 and 2024. The Company's commitment obliges it to purchase
greenhouse gas emission allowances on an ongoing basis upon receipt of a request from TPP Maritsa East 2 EAD.
The allowances purchased are transferred to the account of the buyer once they have been paid in full by the latter.
The goal of this strategy is the optimization of the costs for carbon emissions by implementing a competitive principle
in buying them and thus reducing the brokerage commissions. The current purchase of the required emission
allowances allows their costs to be fully included in the price of the electricity sold, thus hedging the risk of rising
emission prices.
Principle – assumption of a going concern
The sole shareholder of the Company is the Bulgarian State through the Minister of Energy, in their capacity as
Principal. The functioning and the future development of the Company is entirely dependent on the future intentions
and strategy of the state regarding the continuation of its functions and activities within the energy sector in Bulgaria.
The management has analyzed the validity of the going concern assumption, taking into account the principal’s
intentions in the short and medium term. As a result, it has come to the conclusion that the use of the going concern
assumption is appropriate. Management has also taken into account the available information on the foreseeable
future, the above-described circumstances related to macroeconomic factors and the ongoing war between Russia and
Ukraine, the Bulgarian Recovery and Resilience Plan, approved by the EU, and the dynamics of the energy market
globally and in Bulgaria. In addition, as at 31 December 2024 current liabilities exceed current assets by BGN 323,861
thousand. Included in current liabilities is a liability of BGN 1,206,731 thousand for bonds issued, of which BGN
1,193,971 thousand is for a bond issue maturing on 28 June 2025. In accordance with the Company's adopted Business
Program, the Company will refinance the bond issue maturing on 30 June 2025 with a new bond issue in 2025. The
Board of Directors expects that the Company will have sufficient financial resources to continue in operation f or the
foreseeable future and will continue to apply the going concern basis in preparing the independent financial statements.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
11
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2.3. External debt
Funds attracted from international capital markets
BEH EAD's external financial resources raised as of 31 December 2024 include two bond issues issued in 2018 and
2021.
In addition to the two bond issues mentioned above, BEH EAD has repaid in full the following bond issues:
- Eurobonds, issued in 2013 with a nominal value of EUR 500 million and an annual interest rate of 4.25%,
repaid on the maturity date – 7 November 2018.
- Eurobonds, issued in 2016 with a nominal value of EUR 550 million and an annual interest rate of 4.875%,
repaid on the maturity date – 2 August 2021.
Unpaid bond issues:
Bond issue 2018
On 28 June 2018, in the context of highly volatile financial markets as a result of a number of negative news from the
international political scene, Bulgarian Energy Holding EAD successfully sold its third issue of Eurobonds for EUR
400 million. As a result of an increased investor interest, the company recorded two increases in the bond issue –
respectively by EUR 150 million on 31 July 2018 and by EUR 50 million on 12 October 2018. The parameters of the
Eurobond are as follows:
- Total amount of the bond issue of EUR 600 million;
- Maturity 28 June 2025;
- Fixed interest rate of 3.5% per annum;
- the interest is payable once a year on 28 June, with a first payment due on 28 June 2019;
- ISIN code XS1839682116 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin) and the
Bulgarian Stock Exchange (BSE);
According to the Prospectus of the bond issue, BEH EAD undertakes to comply with the following financial
conditions:
• For as long as any Bond remains outstanding, the Issuer shall not, and shall not permit any of its
subsidiaries to, directly or indirectly, incur any financial indebtedness, provided, however, that the Issuer
and any larger subsidiary may incur Financial Indebtedness, if, after giving effect to the incurrence of
such Financial Indebtedness and the receipt and application of the proceeds therefrom: (1) no Event of
Default has or would have occurred and is or would be continuing; (2) the EBITDA Coverage Ratio
would be not less than 4.0 to 1.0; and (3) the Consolidated Leverage Ratio would not be more than 4.5
to 1.0.
• For as long as any Bond remains outstanding, in the event that NEK EAD is declared by a Bulgarian
court to be over-indebted within the meaning of the Bulgarian Commercial Act, the Issuer shall not, and
shall not permit (to the extent permitted by law) any of its subsidiaries to, directly or indirectly, incur
any financial indebtedness.
The proceeds from the issue are intended for general corporate purposes and refinancing of Eurobonds issued by the
company in 2013, with its maturity date in November 2018.
The first interest payment was made on 27 June 2019, the second interest payment on 24 June 2020, the third interest
payment on 25 June 2021, the fourth interest payment on 28 June 2022, the fifth interest payment on 26 June 2023
and the sixth interest payment on 25 June 2024. The annual interest for the bond issue is in the amount of EUR 21,000
thousand (BGN 41,072 thousand)
Bond issue 2021
On 15 July 2021, BEH EAD successfully placed its fourth bond issue in the amount of EUR 600 million at an annual
interest rate of 2.45%. Taken into account the extremely strong interest by the investors, the bond was re -subscribed
2.3 times, and the interest rate respectively is the lowest achieved by Bulgarian Energy Holding EAD since the
company participates on the international capital markets. The parameters of the Eurobond are the following:
- amount of the bond issue of EUR 600 million;
- maturity date on 22 July 2028;
- fixed interest rate 2.45% per annum;
- the interest is payable once a year on 22 July, with the first payment due on 22 July 2022;
Annual Individual Management Report
31 December 2024
11
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2.3. External debt
Funds attracted from international capital markets
BEH EAD's external financial resources raised as of 31 December 2024 include two bond issues issued in 2018 and
2021.
In addition to the two bond issues mentioned above, BEH EAD has repaid in full the following bond issues:
- Eurobonds, issued in 2013 with a nominal value of EUR 500 million and an annual interest rate of 4.25%,
repaid on the maturity date – 7 November 2018.
- Eurobonds, issued in 2016 with a nominal value of EUR 550 million and an annual interest rate of 4.875%,
repaid on the maturity date – 2 August 2021.
Unpaid bond issues:
Bond issue 2018
On 28 June 2018, in the context of highly volatile financial markets as a result of a number of negative news from the
international political scene, Bulgarian Energy Holding EAD successfully sold its third issue of Eurobonds for EUR
400 million. As a result of an increased investor interest, the company recorded two increases in the bond issue –
respectively by EUR 150 million on 31 July 2018 and by EUR 50 million on 12 October 2018. The parameters of the
Eurobond are as follows:
- Total amount of the bond issue of EUR 600 million;
- Maturity 28 June 2025;
- Fixed interest rate of 3.5% per annum;
- the interest is payable once a year on 28 June, with a first payment due on 28 June 2019;
- ISIN code XS1839682116 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin) and the
Bulgarian Stock Exchange (BSE);
According to the Prospectus of the bond issue, BEH EAD undertakes to comply with the following financial
conditions:
• For as long as any Bond remains outstanding, the Issuer shall not, and shall not permit any of its
subsidiaries to, directly or indirectly, incur any financial indebtedness, provided, however, that the Issuer
and any larger subsidiary may incur Financial Indebtedness, if, after giving effect to the incurrence of
such Financial Indebtedness and the receipt and application of the proceeds therefrom: (1) no Event of
Default has or would have occurred and is or would be continuing; (2) the EBITDA Coverage Ratio
would be not less than 4.0 to 1.0; and (3) the Consolidated Leverage Ratio would not be more than 4.5
to 1.0.
• For as long as any Bond remains outstanding, in the event that NEK EAD is declared by a Bulgarian
court to be over-indebted within the meaning of the Bulgarian Commercial Act, the Issuer shall not, and
shall not permit (to the extent permitted by law) any of its subsidiaries to, directly or indirectly, incur
any financial indebtedness.
The proceeds from the issue are intended for general corporate purposes and refinancing of Eurobonds issued by the
company in 2013, with its maturity date in November 2018.
The first interest payment was made on 27 June 2019, the second interest payment on 24 June 2020, the third interest
payment on 25 June 2021, the fourth interest payment on 28 June 2022, the fifth interest payment on 26 June 2023
and the sixth interest payment on 25 June 2024. The annual interest for the bond issue is in the amount of EUR 21,000
thousand (BGN 41,072 thousand)
Bond issue 2021
On 15 July 2021, BEH EAD successfully placed its fourth bond issue in the amount of EUR 600 million at an annual
interest rate of 2.45%. Taken into account the extremely strong interest by the investors, the bond was re -subscribed
2.3 times, and the interest rate respectively is the lowest achieved by Bulgarian Energy Holding EAD since the
company participates on the international capital markets. The parameters of the Eurobond are the following:
- amount of the bond issue of EUR 600 million;
- maturity date on 22 July 2028;
- fixed interest rate 2.45% per annum;
- the interest is payable once a year on 22 July, with the first payment due on 22 July 2022;
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
12
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- ISIN code XS2367164576 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin);
According to the Prospectus of the bond issue, BEH EAD undertakes to comply with the following financial
conditions:
• For as long as any Bond remains outstanding, the Issuer shall not, and shall not permit any of its
subsidiaries to, directly or indirectly, incur any financial indebtedness, provided, however, that the Issuer
and any larger subsidiary may incur Financial Indebtedness, if, after giving effect to the incurrence of
such Financial Indebtedness and the receipt and application of the proceeds therefrom: (1) no Event of
Default has or would have occurred and is or would be continuing; (2) the EBITDA Coverage Ratio
would be not less than 4.0 to 1.0; and (3) the Consolidated Leverage Ratio would not be more than 4.5
to 1.0.
• For as long as any Bond remains outstanding, in the event that NEK EAD is declared by a Bulgarian
court to be over-indebted within the meaning of the Bulgarian Commercial Act, the Issuer shall not, and
shall not permit (to the extent permitted by law) any of its subsidiaries to, directly or indirectly, incur
any financial indebtedness.
The proceeds from the bond issue are used to refinance the Company second bond issue with a face value of EUR 550
million, sold in 2016, at an annual interest rate of 4.875%, with a maturity date 2 August 2021, as well as for general
corporate purposes, except of coal-related activities.
The first interest payment was made on 22 July 2022, the second interest payment was made on 21 July 2023 and the
third interest payment was made on 19 July 2024. The annual interest payable on the bond issue is EUR 14,700
thousand (BGN 28,751 thousand).
Loan from the European Investment Bank
In October 2019, Bulgarian Energy Holding EAD and the European Investment Bank concluded a Financing
Agreement for the construction of the IGB gas pipeline worth EUR 109.9 million with a state financial guarantee
security from the Republic of Bulgaria, the Guarantee Agreement for which is ratified by the National Assembly. The
loan is provided to Bulgarian Energy Holding EAD as a shareholder in ICGB AD. For its part, BEH EAD transfers
the loan financing of the project company through a Shareholder Loan Agreement in the same amount, under the same
financial conditions set in the agreement with the European Investment Bank and without additional margin for
Bulgarian Energy Holding EAD. The repayment of the loan granted by the European Investment Bank will be carried
out with the use of a grace period for the repayment of the principal of the tranches drawn down, which, according to
the Agreement with the Bank, may have a duration of up to 7 years from the date of utilization of a tranche.
The first tranche amounting to EUR 30 million was utilized on 17 August 2020 under the following terms: interest
payment every six months at an annual interest rate of 0.259%, a five-year grace period for principal payments, bi-
annual principal payments with the last payment due on 17 August 2045.
The second tranche amounting to EUR 30 million was utilized on 18 January 2021 under the following terms: payment
of interest twice a year in the amount of 0.237% annual interest rate, five-year grace period for principal payments,
payment of principal twice a year, the last installment being due on 18 January 2046.
On 1 December 2021, the third tranche of EUR 30 million was utilized under the following conditions: payment of
interest twice a year in the amount of 0.612%, annual interest rate, five-year grace period for principal payments,
payment of principal twice a year, the last installment being due on 1 December 2046.
On 29 September 2022, the final, fourth tranche of EUR 19.9 million was drawn down under the following conditions:
payment of interest twice a year in the amount of 2.888% annual interest rate, five-year grace period for principal
payments, payment of principal twice a year, the last installment being due on 29 September 2047.
As at 31 December 2024 the liability to the European Investment Bank amounts to BGN 215,380 thousand, including
BGN 214,946 thousand principal and BGN 434 thousand interest (31 December 2022: BGN 215 ,380 thousand). The
obligation shall be serviced in a timely manner.
Annual Individual Management Report
31 December 2024
12
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- ISIN code XS2367164576 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin);
According to the Prospectus of the bond issue, BEH EAD undertakes to comply with the following financial
conditions:
• For as long as any Bond remains outstanding, the Issuer shall not, and shall not permit any of its
subsidiaries to, directly or indirectly, incur any financial indebtedness, provided, however, that the Issuer
and any larger subsidiary may incur Financial Indebtedness, if, after giving effect to the incurrence of
such Financial Indebtedness and the receipt and application of the proceeds therefrom: (1) no Event of
Default has or would have occurred and is or would be continuing; (2) the EBITDA Coverage Ratio
would be not less than 4.0 to 1.0; and (3) the Consolidated Leverage Ratio would not be more than 4.5
to 1.0.
• For as long as any Bond remains outstanding, in the event that NEK EAD is declared by a Bulgarian
court to be over-indebted within the meaning of the Bulgarian Commercial Act, the Issuer shall not, and
shall not permit (to the extent permitted by law) any of its subsidiaries to, directly or indirectly, incur
any financial indebtedness.
The proceeds from the bond issue are used to refinance the Company second bond issue with a face value of EUR 550
million, sold in 2016, at an annual interest rate of 4.875%, with a maturity date 2 August 2021, as well as for general
corporate purposes, except of coal-related activities.
The first interest payment was made on 22 July 2022, the second interest payment was made on 21 July 2023 and the
third interest payment was made on 19 July 2024. The annual interest payable on the bond issue is EUR 14,700
thousand (BGN 28,751 thousand).
Loan from the European Investment Bank
In October 2019, Bulgarian Energy Holding EAD and the European Investment Bank concluded a Financing
Agreement for the construction of the IGB gas pipeline worth EUR 109.9 million with a state financial guarantee
security from the Republic of Bulgaria, the Guarantee Agreement for which is ratified by the National Assembly. The
loan is provided to Bulgarian Energy Holding EAD as a shareholder in ICGB AD. For its part, BEH EAD transfers
the loan financing of the project company through a Shareholder Loan Agreement in the same amount, under the same
financial conditions set in the agreement with the European Investment Bank and without additional margin for
Bulgarian Energy Holding EAD. The repayment of the loan granted by the European Investment Bank will be carried
out with the use of a grace period for the repayment of the principal of the tranches drawn down, which, according to
the Agreement with the Bank, may have a duration of up to 7 years from the date of utilization of a tranche.
The first tranche amounting to EUR 30 million was utilized on 17 August 2020 under the following terms: interest
payment every six months at an annual interest rate of 0.259%, a five-year grace period for principal payments, bi-
annual principal payments with the last payment due on 17 August 2045.
The second tranche amounting to EUR 30 million was utilized on 18 January 2021 under the following terms: payment
of interest twice a year in the amount of 0.237% annual interest rate, five-year grace period for principal payments,
payment of principal twice a year, the last installment being due on 18 January 2046.
On 1 December 2021, the third tranche of EUR 30 million was utilized under the following conditions: payment of
interest twice a year in the amount of 0.612%, annual interest rate, five-year grace period for principal payments,
payment of principal twice a year, the last installment being due on 1 December 2046.
On 29 September 2022, the final, fourth tranche of EUR 19.9 million was drawn down under the following conditions:
payment of interest twice a year in the amount of 2.888% annual interest rate, five-year grace period for principal
payments, payment of principal twice a year, the last installment being due on 29 September 2047.
As at 31 December 2024 the liability to the European Investment Bank amounts to BGN 215,380 thousand, including
BGN 214,946 thousand principal and BGN 434 thousand interest (31 December 2022: BGN 215 ,380 thousand). The
obligation shall be serviced in a timely manner.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
13
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2.4. Financial policy
In 2024, the financial policy of Bulgarian Energy Holding EAD for improving the financial position and managing
the liquidity of the subsidiaries was implemented through the following activities:
o Pursuant to a framework agreement for the purchase and sale of greenhouse gas emission allowances between
BEH EAD and TPP Maritsa East 2 EAD dated 16 July 2021, (as amended by Supplementary Agreements No. 2
of 17.07.2023 and No. 3 of 22.12.2023), in the calendar year 2024 BEH EAD purchased and transferred to the
account of TPP Maritsa East 2 EAD in the National Greenhouse Gas Emission Allowance Trading Register a
total of 1,701,207 tonnes of greenhouse gas emissions to cover the company's obligations;
o For ensuring the required liquid funds for securing the operational activity of the companies from the holding
structure, the following were signed:
- Loan agreement dated 12 February 2024, whereby BEH EAD provides Minproekt EAD with a short -term
credit line (loan) with a limit of BGN 3,000 thousand for operational needs with a term of 12 months from
the date of signing the agreement;
- Loan agreement dated 16 February 2024 in the amount of BGN 224,657 thousand, which offsets NEK EAD's
dividend obligations representing 50% of the balance of the company's retained earnings for 2022. The
dividend was determined by the minutes of the Board of Directors of BEK EAD dated 20 December 2023 in
connection with the implementation of Order No. 7/14.12.2023 of the Council of Ministers.
- Framework agreement for financing of the business activities of Maritsa East Mines EAD of 28 June 2024
in the amount of BGN 100,000 thousand. In accordance with the terms of the agreement, the following three
loan agreements were concluded for the purpose of payments to personnel, social security funds, the state
budget and contractors, as follows:
• Loan agreement dated 16 August 2024, in the amount of BGN 28,000 thousand, valid until 30 November
2025;
• Loan agreement dated 18 September 2024, in the amount of BGN 28,000 thousand, valid until 31
December 2025;
• Loan agreement dated 17 October 2024, in the amount of BGN 44,000 thousand, valid until 31 January
2026.
- Second framework agreement for financing the business activities of Maritsa East Mines EAD dated 17
October 2024, in the amount of BGN 100,000 thousand. Under the terms of the agreement, a short-term credit
line (loan) agreement was signed on 17 December 2024, whereby BEH EAD provides Maritsa East Mines
EAD with targeted financing for the payment of staff, social security funds, the state budget and other
operational needs, in the amount of BGN 50,000 thousand, with a term of 12 months from the date of the
first drawdown under the loan. On 18 December 2024, Maritsa East Mines EAD drew down funds in the
amount of BGN 10,000 thousand.
- Agreement dated 9 December 2024 to reschedule the 2021 and 2022 dividend payable by Bulgartransgaz
EAD to BEH EAD in the amount of BGN 257,251 thousand in three annual installments payable in December
2025, December 2026 and December 2027.
o Given the seasonal, irregular nature of natural gas consumption in the country, as well as taking into account the
delay in payments by customers during the autumn-winter season, in particular the district heating companies,
the liquidity of Bulgargas EAD was reduced, which necessitated rescheduling of the Company's liabilities to
BEH EAD by concluding the following contracts:
- Agreement dated 2 August 2024 for extension of the loan agreement (short-term credit line) granted by BEH
EAD to Bulgargas EAD in the amount of BGN 60,000 thousand until 6 July 2025;
- Agreement dated 26 June 2024 for the extension of the loan agreement (short-term credit line) granted by
BEH EAD to Bulgargas EAD in the amount of BGN 200,000 thousand until 26 June 2027.
o In the process of seeking a sustainable solution to reduce the amount of receivables from Toplofikatsia Sofia EAD
and in order to guarantee the financial interest of the holding company, an annex to the Tripartite Agreement of
2023 between Bulgarian Energy Holding EAD, Toplofikatsia Sofia EAD and the Electricity System Security
Fund was signed on 28 June 2024, extending its validity for the price period from 01 July 2024 to 30 June 2025.
As of 31 December 2024, BEH EAD's receivables under loans granted to related parties amounted to BGN 1,856,369
thousand, of which non-current loans amounted to BGN 1,537,117 thousand and current loans amounted to BGN
Annual Individual Management Report
31 December 2024
13
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2.4. Financial policy
In 2024, the financial policy of Bulgarian Energy Holding EAD for improving the financial position and managing
the liquidity of the subsidiaries was implemented through the following activities:
o Pursuant to a framework agreement for the purchase and sale of greenhouse gas emission allowances between
BEH EAD and TPP Maritsa East 2 EAD dated 16 July 2021, (as amended by Supplementary Agreements No. 2
of 17.07.2023 and No. 3 of 22.12.2023), in the calendar year 2024 BEH EAD purchased and transferred to the
account of TPP Maritsa East 2 EAD in the National Greenhouse Gas Emission Allowance Trading Register a
total of 1,701,207 tonnes of greenhouse gas emissions to cover the company's obligations;
o For ensuring the required liquid funds for securing the operational activity of the companies from the holding
structure, the following were signed:
- Loan agreement dated 12 February 2024, whereby BEH EAD provides Minproekt EAD with a short -term
credit line (loan) with a limit of BGN 3,000 thousand for operational needs with a term of 12 months from
the date of signing the agreement;
- Loan agreement dated 16 February 2024 in the amount of BGN 224,657 thousand, which offsets NEK EAD's
dividend obligations representing 50% of the balance of the company's retained earnings for 2022. The
dividend was determined by the minutes of the Board of Directors of BEK EAD dated 20 December 2023 in
connection with the implementation of Order No. 7/14.12.2023 of the Council of Ministers.
- Framework agreement for financing of the business activities of Maritsa East Mines EAD of 28 June 2024
in the amount of BGN 100,000 thousand. In accordance with the terms of the agreement, the following three
loan agreements were concluded for the purpose of payments to personnel, social security funds, the state
budget and contractors, as follows:
• Loan agreement dated 16 August 2024, in the amount of BGN 28,000 thousand, valid until 30 November
2025;
• Loan agreement dated 18 September 2024, in the amount of BGN 28,000 thousand, valid until 31
December 2025;
• Loan agreement dated 17 October 2024, in the amount of BGN 44,000 thousand, valid until 31 January
2026.
- Second framework agreement for financing the business activities of Maritsa East Mines EAD dated 17
October 2024, in the amount of BGN 100,000 thousand. Under the terms of the agreement, a short-term credit
line (loan) agreement was signed on 17 December 2024, whereby BEH EAD provides Maritsa East Mines
EAD with targeted financing for the payment of staff, social security funds, the state budget and other
operational needs, in the amount of BGN 50,000 thousand, with a term of 12 months from the date of the
first drawdown under the loan. On 18 December 2024, Maritsa East Mines EAD drew down funds in the
amount of BGN 10,000 thousand.
- Agreement dated 9 December 2024 to reschedule the 2021 and 2022 dividend payable by Bulgartransgaz
EAD to BEH EAD in the amount of BGN 257,251 thousand in three annual installments payable in December
2025, December 2026 and December 2027.
o Given the seasonal, irregular nature of natural gas consumption in the country, as well as taking into account the
delay in payments by customers during the autumn-winter season, in particular the district heating companies,
the liquidity of Bulgargas EAD was reduced, which necessitated rescheduling of the Company's liabilities to
BEH EAD by concluding the following contracts:
- Agreement dated 2 August 2024 for extension of the loan agreement (short-term credit line) granted by BEH
EAD to Bulgargas EAD in the amount of BGN 60,000 thousand until 6 July 2025;
- Agreement dated 26 June 2024 for the extension of the loan agreement (short-term credit line) granted by
BEH EAD to Bulgargas EAD in the amount of BGN 200,000 thousand until 26 June 2027.
o In the process of seeking a sustainable solution to reduce the amount of receivables from Toplofikatsia Sofia EAD
and in order to guarantee the financial interest of the holding company, an annex to the Tripartite Agreement of
2023 between Bulgarian Energy Holding EAD, Toplofikatsia Sofia EAD and the Electricity System Security
Fund was signed on 28 June 2024, extending its validity for the price period from 01 July 2024 to 30 June 2025.
As of 31 December 2024, BEH EAD's receivables under loans granted to related parties amounted to BGN 1,856,369
thousand, of which non-current loans amounted to BGN 1,537,117 thousand and current loans amounted to BGN
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
14
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
319,252 thousand.
According to the information presented above, BEH EAD continued to provide active financial support to the
subsidiaries within the holding structure in 2024, which enabled the Group companies to overcome the challenges in
the energy sector without any shocks.
2.5. Information on transactions with related parties
In 2024 and 2023, the following business transactions were carried out between BEH EAD and its subsidiaries and
companies under joint control:
BGN’000 31 December 2024 31 December 2023
Purchases 227,929 1,530,015
Sales 230,374 305,602
Trade receivables 282,398 8,676
Trade liabilities 0 0
2.6. Commitments, contingent liabilities and other significant events
Litigation and claims arise in the Company’s normal course of activity. According to the Company’s Management,
the costs required to resolve these disputes and claims will not have a material impact on the financial position and
cash flows in future financial periods.
Proceedings by the European Commission against Bulgarian Energy Holding EAD
Case COMP/B1/АТ.39849 – BEH gas
The case concern a possible violation of Article 102 TFEU in connection with alleged actions of BEH EAD and its
subsidiaries – Bulgargaz EAD and Bulgartransgaz EAD, aimed at:
• preventing their competitors from gaining access to key gas infrastructure (gas transmission network and natural
gas storage facility) in Bulgaria, explicitly or implicitly denying access to third parties or causing delays;
• preventing competitors from receiving access to a main gas import transmission network by reserving a
capacity, which remains unused.
The proceedings were instituted in 2013 with a view to adopting a decision under Chapter 3 (Articles 7 to 10) of
Regulation 1/2003.
On 23 March 2015, the EC issued a Statement of Objections. Bulgarian Energy Holding EAD and its gas subsidiaries
submitted their respective responses to the European Commission on 9 July 2015 (Bulgargaz EAD), 10 July 2015
(Bulgarian Energy Holding EAD) and 17 July 2015 (Bulgartransgaz EAD).
On 24 November 2017, the 44 th National Assembly (NA) of the Republic of Bulgaria adopted a decision to take the
necessary action to bring Case COMP/B1/AT.39849 - BEH Gas to a close, whereby the NA supports the closure of
the case under Article 7 of Regulation (EC) No 1/2003 without admitting the alleged infringements and without
accepting liability for them, by fulfilling the obligations arising from a possible prohibition order, including a possible
financial penalty. Currently, the European Commission has not made any official decision to close the case, including
regarding the possible amount of the financial sanction.
On 26 July 2018, a decision was adopted by the 44 th National Assembly (NA) of the Republic of Bulgaria for taking
actions for termination of Case COMP/B1/AT.39849 – BEH Gas pursuant to Art. 9 of Regulation (EC) No. 1/2003
by entering into commitments by the Bulgarian side and reaching an agreement with the European Commission. The
second decision of the National Assembly is jusitified by the development of case COMP/B1/AT.39816 between the
EC and Gazprom, where on 24 May 2018 the Commission announced that an agreement had been reached and it was
terminated pursuant to Art. 9 of Regulation (EC) No. 1/2003 without a financial penalty.
On 17 December 2018, the European Commission notified the adoption of Decision C(2018)8806 under Case
AT.39849 BEH-Gas, whereby the European Commission imposed a fine on Bulgarian Energy Holding EAD (BEH),
its subsidiary for gas supply – Bulgargaz EAD – and its subsidiary – Bulgartransgaz EAD (BEH Group) – in the
amount of EUR 77,068,000 for preventing competitors from accessing key gas infrastructure in Bulgaria in breach of
EU antitrust rules. The decision was received in the offices of the three companies on 19 December 2018, which set
Annual Individual Management Report
31 December 2024
14
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
319,252 thousand.
According to the information presented above, BEH EAD continued to provide active financial support to the
subsidiaries within the holding structure in 2024, which enabled the Group companies to overcome the challenges in
the energy sector without any shocks.
2.5. Information on transactions with related parties
In 2024 and 2023, the following business transactions were carried out between BEH EAD and its subsidiaries and
companies under joint control:
BGN’000 31 December 2024 31 December 2023
Purchases 227,929 1,530,015
Sales 230,374 305,602
Trade receivables 282,398 8,676
Trade liabilities 0 0
2.6. Commitments, contingent liabilities and other significant events
Litigation and claims arise in the Company’s normal course of activity. According to the Company’s Management,
the costs required to resolve these disputes and claims will not have a material impact on the financial position and
cash flows in future financial periods.
Proceedings by the European Commission against Bulgarian Energy Holding EAD
Case COMP/B1/АТ.39849 – BEH gas
The case concern a possible violation of Article 102 TFEU in connection with alleged actions of BEH EAD and its
subsidiaries – Bulgargaz EAD and Bulgartransgaz EAD, aimed at:
• preventing their competitors from gaining access to key gas infrastructure (gas transmission network and natural
gas storage facility) in Bulgaria, explicitly or implicitly denying access to third parties or causing delays;
• preventing competitors from receiving access to a main gas import transmission network by reserving a
capacity, which remains unused.
The proceedings were instituted in 2013 with a view to adopting a decision under Chapter 3 (Articles 7 to 10) of
Regulation 1/2003.
On 23 March 2015, the EC issued a Statement of Objections. Bulgarian Energy Holding EAD and its gas subsidiaries
submitted their respective responses to the European Commission on 9 July 2015 (Bulgargaz EAD), 10 July 2015
(Bulgarian Energy Holding EAD) and 17 July 2015 (Bulgartransgaz EAD).
On 24 November 2017, the 44 th National Assembly (NA) of the Republic of Bulgaria adopted a decision to take the
necessary action to bring Case COMP/B1/AT.39849 - BEH Gas to a close, whereby the NA supports the closure of
the case under Article 7 of Regulation (EC) No 1/2003 without admitting the alleged infringements and without
accepting liability for them, by fulfilling the obligations arising from a possible prohibition order, including a possible
financial penalty. Currently, the European Commission has not made any official decision to close the case, including
regarding the possible amount of the financial sanction.
On 26 July 2018, a decision was adopted by the 44 th National Assembly (NA) of the Republic of Bulgaria for taking
actions for termination of Case COMP/B1/AT.39849 – BEH Gas pursuant to Art. 9 of Regulation (EC) No. 1/2003
by entering into commitments by the Bulgarian side and reaching an agreement with the European Commission. The
second decision of the National Assembly is jusitified by the development of case COMP/B1/AT.39816 between the
EC and Gazprom, where on 24 May 2018 the Commission announced that an agreement had been reached and it was
terminated pursuant to Art. 9 of Regulation (EC) No. 1/2003 without a financial penalty.
On 17 December 2018, the European Commission notified the adoption of Decision C(2018)8806 under Case
AT.39849 BEH-Gas, whereby the European Commission imposed a fine on Bulgarian Energy Holding EAD (BEH),
its subsidiary for gas supply – Bulgargaz EAD – and its subsidiary – Bulgartransgaz EAD (BEH Group) – in the
amount of EUR 77,068,000 for preventing competitors from accessing key gas infrastructure in Bulgaria in breach of
EU antitrust rules. The decision was received in the offices of the three companies on 19 December 2018, which set
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
15
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
the start of the appeal period of the EC Decision (two months and ten days after notification of the Decision to the
parties), and for payment of the fine (three months after the notification of the Decision to the parties) set therein.
Appealing the decision does not delay payment of the fine.
On 18 March 2019, ING Bank NV issued two unsecured bank guarantees in favor of the EU with a total amount equal
to the amount of the fine of EUR 77,068,000, as follows:
- a bank guarantee in the amount of EUR 51,379 thousand, covering 2/3 of the total amount of the fine, securing
the obligations of Bulgarian Energy Holding EAD and Bulgargaz EAD;
- bank guarantee in the amount of EUR 25,689 thousand, which guarantees the liability of Bulgartransgaz
EAD for the imposed sanction.
On 4 July 2019, the Bulgarian state, through the Ministry of Foreign Affairs, filed an application to intervene in the
case in support of BEH EAD and its gas subsidiaries.
On 26 August 2019, the European Commission presented before the General Court its Defense in response to the
complaint lodged by Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD.
On 29 November 2019, Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD filed an
Opposition against the European Commission Defense.
On 20 February 2020, the Republic of Bulgaria filed through the Ministry of Foreign Affairs, within the period
specified by the General Court of the European Union, the official position of the Republic of Bulgaria on Case Т -
136/19, submitted by the Ministry of Energy and the Ministry of Foreign Affairs whereby the State intervened in
support of Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD against the European
Commission before the General Court of the European Union. The General Court examined additional documents and
requested information in order to clarify all the circumstances involved in the case. By letter of 14 March 2022, the
Court requested the European Commission to provide non-confidential versions of the documents listed by the Court.
On 29 September 2022, the Court session ended with oral hearings under the BEH Gas case, within which the parties
summarized their positions and the court asked questions that were addressed by the parties.
On 25 October 2023, the Court of First Instance rendered a decision in favor of Bulgarian Energy Holding EAD,
Bulgartransgaz EAD and Bulgargaz EAD, with which it completely annulled the fine imposed by the European
Commission on the three BEH-group companies in the amount of EUR 77,068,000.
On 11 January 2024, the European Commission filed an appeal against the decision of the Court of First Instance,
requesting the annulment of the Decision of the General Court in its entirety. Based on the appeal, case C -14/24 R
was initiated before the Court of Justice of the European Union – European Commission against BEH and others.
On 29 March 2024 BEH Group filed a response to the complaint of the European Commission to the Court of Justice
of the European Union.
On 22 July 2024, the European Commission submitted a reply to the Court of Justice of the European Union.
On September 30 2024, BEH Group provided a rejoinder.
On 25 October 2023, the General Court of the European Union annulled in its entirety the Decision of the European
Commission in Case AT.39849 - BEH Gas, by which the Commission had imposed a fine on BEH EAD, Bulgargas
EAD and Bulgartransgaz EAD with a fine of EUR 77,068,000 for abuse of a dominant position preventing access to
the Bulgarian gas infrastructure in the period from 30.07.2010 to 01.01.2015.
The Bulgarian state is also an interested party in the case. On 11 January 2024, the European Commission filed an
appeal against the decision of the court of first instance. To date, replies have been filed by BEH EAD, Bulgartransgaz
EAD and Bulgargas EAD and the Republic of Bulgaria against the European Commission's appeal in Case C-14/24
before the Court of Justice of the European Union.
The Bulgarian side has also submitted a request for the Court to allow oral proceedings as at first instance. Oral
proceedings in the case are expected in the second quarter of 2025.
Lease contracts
The lease liabilities of the Company are as follows:
Annual Individual Management Report
31 December 2024
15
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
the start of the appeal period of the EC Decision (two months and ten days after notification of the Decision to the
parties), and for payment of the fine (three months after the notification of the Decision to the parties) set therein.
Appealing the decision does not delay payment of the fine.
On 18 March 2019, ING Bank NV issued two unsecured bank guarantees in favor of the EU with a total amount equal
to the amount of the fine of EUR 77,068,000, as follows:
- a bank guarantee in the amount of EUR 51,379 thousand, covering 2/3 of the total amount of the fine, securing
the obligations of Bulgarian Energy Holding EAD and Bulgargaz EAD;
- bank guarantee in the amount of EUR 25,689 thousand, which guarantees the liability of Bulgartransgaz
EAD for the imposed sanction.
On 4 July 2019, the Bulgarian state, through the Ministry of Foreign Affairs, filed an application to intervene in the
case in support of BEH EAD and its gas subsidiaries.
On 26 August 2019, the European Commission presented before the General Court its Defense in response to the
complaint lodged by Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD.
On 29 November 2019, Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD filed an
Opposition against the European Commission Defense.
On 20 February 2020, the Republic of Bulgaria filed through the Ministry of Foreign Affairs, within the period
specified by the General Court of the European Union, the official position of the Republic of Bulgaria on Case Т -
136/19, submitted by the Ministry of Energy and the Ministry of Foreign Affairs whereby the State intervened in
support of Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD against the European
Commission before the General Court of the European Union. The General Court examined additional documents and
requested information in order to clarify all the circumstances involved in the case. By letter of 14 March 2022, the
Court requested the European Commission to provide non-confidential versions of the documents listed by the Court.
On 29 September 2022, the Court session ended with oral hearings under the BEH Gas case, within which the parties
summarized their positions and the court asked questions that were addressed by the parties.
On 25 October 2023, the Court of First Instance rendered a decision in favor of Bulgarian Energy Holding EAD,
Bulgartransgaz EAD and Bulgargaz EAD, with which it completely annulled the fine imposed by the European
Commission on the three BEH-group companies in the amount of EUR 77,068,000.
On 11 January 2024, the European Commission filed an appeal against the decision of the Court of First Instance,
requesting the annulment of the Decision of the General Court in its entirety. Based on the appeal, case C -14/24 R
was initiated before the Court of Justice of the European Union – European Commission against BEH and others.
On 29 March 2024 BEH Group filed a response to the complaint of the European Commission to the Court of Justice
of the European Union.
On 22 July 2024, the European Commission submitted a reply to the Court of Justice of the European Union.
On September 30 2024, BEH Group provided a rejoinder.
On 25 October 2023, the General Court of the European Union annulled in its entirety the Decision of the European
Commission in Case AT.39849 - BEH Gas, by which the Commission had imposed a fine on BEH EAD, Bulgargas
EAD and Bulgartransgaz EAD with a fine of EUR 77,068,000 for abuse of a dominant position preventing access to
the Bulgarian gas infrastructure in the period from 30.07.2010 to 01.01.2015.
The Bulgarian state is also an interested party in the case. On 11 January 2024, the European Commission filed an
appeal against the decision of the court of first instance. To date, replies have been filed by BEH EAD, Bulgartransgaz
EAD and Bulgargas EAD and the Republic of Bulgaria against the European Commission's appeal in Case C-14/24
before the Court of Justice of the European Union.
The Bulgarian side has also submitted a request for the Court to allow oral proceedings as at first instance. Oral
proceedings in the case are expected in the second quarter of 2025.
Lease contracts
The lease liabilities of the Company are as follows:
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
16
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2024 31 December 2023
Minimum
lease
installments
Discounting
Present
value of the
installments
Minimum
lease
installments
Discounting
Present
value of the
installments
BGN’000 BGN’000 BGN’000 BGN’000 BGN’000 BGN’000
Within one year 281 (17) 264 487 (57) 430
Between one and five
years 503 (29) 474 981 (78) 903
Over five years 144 (4) 140 206 (8) 198
Total minimum lease
installments under lease
agreements
928 (50) 878 1,674 (143) 1,531
The Company has entered into the following lease agreements:
Bulgarian Energy Holding EAD has rented parts of a real estate property for administrative purposes for a period of
five years with an option for extension. The monthly installment under the rental contract is in the amount of BGN 5
thousand, excl. VAT. To determine the present value of the lease liabilities, Bulgarian Energy Holding EAD used a
discount rate of 2.45%, which is the interest rate received by the company when financing its activities in the last year
and corresponding to market levels. As of 31 December 2024, the present value of the liability is BGN 414 thousand.
The company has leased 10 motor vehicles under lease agreements. The term of the contracts is from 2 to 4.5 years.
The applicable annual interest rates for vehicle leases range from 0.98% to 24.05%. As of 31 December 2024, the
present value of the liability is BGN 463 thousand.
The assets are used exclusively by the Company and no sublease agreements have been concluded.
Amounts, recognized in the profit or loss statement:
- Depreciation expenses in the amount of BGN 455 thousand;
- The interest expenses amounting to BGN 41 thousand.
The total leasing cash flow in 2024 is as follows:
- Payments related to lease contracts – BGN 437 thousand.
Credit rating
• Moody’s Ratings
On 18 June 2018, Moody’s Ratings assigned a corporate family rating of Ba1 with a stable outlook to the Bulgarian
Energy Holding EAD Group and a Ba2 rating to the unsecured bonds issued by the Company.
On 12 July 2021, Moody’s Ratings assigned a Ba2 rating to the unsecured and non-subordinated bond issued by
Bulgarian Energy Holding EAD on 15 July 2021. The bond issue was placed on 15 July 2021 with a maturity date on
22 July 2028.
On 6 February 2023, Moody’s Ratings revised the credit outlook of Bulgarian Energy Holding EAD from stable to
positive, while affirming the Group’s long-term rating at Ba1 and the rating of the non-subordinated unsecured bond
issues at Ba2. The upgrade in the credit outlook was driven by improved financial indicators, progress in the
liberalization of the electricity market, and the structural advantages of the BEH Group, including its portfolio of
electricity generation and public supply of natural gas.
On 27 November 2024, Moody’s Ratings revised the credit outlook of Bulgarian Energy Holding EAD from positive
to stable, while reaffirming the Group’s long-term rating at Ba1 and the rating of its unsecured and non-subordinated
bond issues at Ba2. The change in outlook reflects the increased uncertainty associated with the planned construction
of two new nuclear units at the NPP Kozloduy site, which would significantly raise BEH’s risk profile due to the
inherent risks of implementing such large-scale projects.
• Fitch Ratings
On 26 February 2021 the long-term credit rating ‘BB’ in foreign and local currency was affirmed, while the outlook
was revised from stable to positive. This change reflects the improved credit rating outlook of the Republic of Bulgaria.
Annual Individual Management Report
31 December 2024
16
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2024 31 December 2023
Minimum
lease
installments
Discounting
Present
value of the
installments
Minimum
lease
installments
Discounting
Present
value of the
installments
BGN’000 BGN’000 BGN’000 BGN’000 BGN’000 BGN’000
Within one year 281 (17) 264 487 (57) 430
Between one and five
years 503 (29) 474 981 (78) 903
Over five years 144 (4) 140 206 (8) 198
Total minimum lease
installments under lease
agreements
928 (50) 878 1,674 (143) 1,531
The Company has entered into the following lease agreements:
Bulgarian Energy Holding EAD has rented parts of a real estate property for administrative purposes for a period of
five years with an option for extension. The monthly installment under the rental contract is in the amount of BGN 5
thousand, excl. VAT. To determine the present value of the lease liabilities, Bulgarian Energy Holding EAD used a
discount rate of 2.45%, which is the interest rate received by the company when financing its activities in the last year
and corresponding to market levels. As of 31 December 2024, the present value of the liability is BGN 414 thousand.
The company has leased 10 motor vehicles under lease agreements. The term of the contracts is from 2 to 4.5 years.
The applicable annual interest rates for vehicle leases range from 0.98% to 24.05%. As of 31 December 2024, the
present value of the liability is BGN 463 thousand.
The assets are used exclusively by the Company and no sublease agreements have been concluded.
Amounts, recognized in the profit or loss statement:
- Depreciation expenses in the amount of BGN 455 thousand;
- The interest expenses amounting to BGN 41 thousand.
The total leasing cash flow in 2024 is as follows:
- Payments related to lease contracts – BGN 437 thousand.
Credit rating
• Moody’s Ratings
On 18 June 2018, Moody’s Ratings assigned a corporate family rating of Ba1 with a stable outlook to the Bulgarian
Energy Holding EAD Group and a Ba2 rating to the unsecured bonds issued by the Company.
On 12 July 2021, Moody’s Ratings assigned a Ba2 rating to the unsecured and non-subordinated bond issued by
Bulgarian Energy Holding EAD on 15 July 2021. The bond issue was placed on 15 July 2021 with a maturity date on
22 July 2028.
On 6 February 2023, Moody’s Ratings revised the credit outlook of Bulgarian Energy Holding EAD from stable to
positive, while affirming the Group’s long-term rating at Ba1 and the rating of the non-subordinated unsecured bond
issues at Ba2. The upgrade in the credit outlook was driven by improved financial indicators, progress in the
liberalization of the electricity market, and the structural advantages of the BEH Group, including its portfolio of
electricity generation and public supply of natural gas.
On 27 November 2024, Moody’s Ratings revised the credit outlook of Bulgarian Energy Holding EAD from positive
to stable, while reaffirming the Group’s long-term rating at Ba1 and the rating of its unsecured and non-subordinated
bond issues at Ba2. The change in outlook reflects the increased uncertainty associated with the planned construction
of two new nuclear units at the NPP Kozloduy site, which would significantly raise BEH’s risk profile due to the
inherent risks of implementing such large-scale projects.
• Fitch Ratings
On 26 February 2021 the long-term credit rating ‘BB’ in foreign and local currency was affirmed, while the outlook
was revised from stable to positive. This change reflects the improved credit rating outlook of the Republic of Bulgaria.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
17
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
On 23 July 2021, a credit rating ‘BB’ (EXP) was assigned to a unsecured and non-subordinated bond issue by
Bulgarian Energy Holding EAD. The bond issue was placed on 15 July 2021 with a maturity date on 22 July 2028.
On 24 March 2023, Fitch Ratings upgraded the credit rating of Bulgarian Energy Holding EAD from BB to BB+ with
a stable outlook, as well as the rating of BEH EAD's non-subordinated, unsecured debt from BB to BB+. The rating
upgrade is the result of an improvement in the company standalone credit profile as a result of stable financial results,
a significant reduction in indebtedness, an improved regulatory framework and strong support from the sole owner –
the state.
On 20 March 2024, Fitch Ratings revised the outlook of Bulgarian Energy Holding EAD from stable to positive and
affirmed the issuer’s long-term foreign and local currency rating at ‘BB+’. The change in outlook is driven by the
company's improved business profile and increased profitability as a result of progress in the electricity market
liberalization process.
Environmental, Social and Governance (ESG) rating
As of 31 December 2024, BEH Group's ESG rating as determined by Sustainalytics is 35.5 points (“high risk”). BEH's
ESG Risk Score, which refers to the extent to which the company is exposed to various material risks related to
environmental, social, and governance aspects, is 53.8 points (“medium risk”). The governance score reflecting how
well the company manages these aspects is 36.8 points (“average performance”).
Program for compensation of consumers of electricity
For mitigating the economic effects resulting from the sudden instability of the prices on the energy market, a Program
was developed for compensation of the non-household end consumers of electrical energy, approved by Decision No.
739 of the Council of Ministers of 2021, amended and supplemented by further decisions of the Council of Ministers.
The proposed Program has a compensatory effect and supplements other temporary measures at national level for
raising the transparency and improving the functioning of the energy market, as well as for strengthening the
regulatory control.
By Council of Ministers Decision No. 294 of 23 April 2024, a Compensation Program for Non-Household End
Consumers for Electricity Costs was adopted for the period 1 January 2024 to 30 June 2024. The support under the
Program is targeted at a specific group of non-household end customers within the meaning of § 1, items 27d and 41b
of the Additional Provisions of the Energy Act (EA), which are exhaustively listed in § 3, para. 14 of the Transiti onal
and Final Provisions of the State Budget Act 2024 - nurseries, kindergartens, nursery groups in kindergartens, schools,
children's sports schools, community centers, prayer houses, temples and monasteries of registered religious
denominations. The compensation shall be calculated as the difference between the average price of the base load on
the Independent Bulgarian Energy Exchange EAD (IBEX), of the “Day -ahead” segment for the respective month and
the regulated price, approved by the Energy and Water Regulatory Commission, at which end suppliers sell electricity
to end household customers connected to the low-voltage electricity distribution network, the amount not including
VAT.
The indicative budget under the Program is BGN 30 million for the period from 01.01.2024 to 30.06.2024. The
compensations under the Program were paid by 30 September 2024.
By Decision No.546 of the Council of Ministers of 31 July 2024, a Program for Compensation of Non -Household
End Customers for Electricity Costs for the period from 1 July 2024 to 31 December 2024 was adopted, which was
updated by the subsequent Decision No.654 of the Council of Ministers of 18 September 2024. Support under the
Program is targeted at all non-household end customers, except for the persons listed in § 3, para. 14 of the
Transitional and Final Provisions of the State Budget Act 2024 and described in the above paragraph, for whom the
support measure was extended by Decision No.481 of the Council of Ministers of 4 July 2024. The amount of the
support provided under the Program shall be calculated as 100 per cent of the difference between the actual average
monthly exchange price for base load of the “Day -ahead” segment of the IBEX, for the relevant month of the period
01.07.2024 - 31.12.2024 and the base price of BGN 180/MWh, for non-household end-users, regardless of the
network to which they are connected. The Program shall also benefit the operators of the electricity transmission and
distribution networks for the purchase of the quantities of electricity consumed for technological costs for the period
from 1.07.2024 to 31.12.2024. The maximum amount of compensation for each individual month shall be determined
on the basis of the quantities of electricity for technological costs for the respective month, confirmed by the
Electricity System Security Fund (ESSF) by comparing with the quantities of active electricity based on the
Annual Individual Management Report
31 December 2024
17
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
On 23 July 2021, a credit rating ‘BB’ (EXP) was assigned to a unsecured and non-subordinated bond issue by
Bulgarian Energy Holding EAD. The bond issue was placed on 15 July 2021 with a maturity date on 22 July 2028.
On 24 March 2023, Fitch Ratings upgraded the credit rating of Bulgarian Energy Holding EAD from BB to BB+ with
a stable outlook, as well as the rating of BEH EAD's non-subordinated, unsecured debt from BB to BB+. The rating
upgrade is the result of an improvement in the company standalone credit profile as a result of stable financial results,
a significant reduction in indebtedness, an improved regulatory framework and strong support from the sole owner –
the state.
On 20 March 2024, Fitch Ratings revised the outlook of Bulgarian Energy Holding EAD from stable to positive and
affirmed the issuer’s long-term foreign and local currency rating at ‘BB+’. The change in outlook is driven by the
company's improved business profile and increased profitability as a result of progress in the electricity market
liberalization process.
Environmental, Social and Governance (ESG) rating
As of 31 December 2024, BEH Group's ESG rating as determined by Sustainalytics is 35.5 points (“high risk”). BEH's
ESG Risk Score, which refers to the extent to which the company is exposed to various material risks related to
environmental, social, and governance aspects, is 53.8 points (“medium risk”). The governance score reflecting how
well the company manages these aspects is 36.8 points (“average performance”).
Program for compensation of consumers of electricity
For mitigating the economic effects resulting from the sudden instability of the prices on the energy market, a Program
was developed for compensation of the non-household end consumers of electrical energy, approved by Decision No.
739 of the Council of Ministers of 2021, amended and supplemented by further decisions of the Council of Ministers.
The proposed Program has a compensatory effect and supplements other temporary measures at national level for
raising the transparency and improving the functioning of the energy market, as well as for strengthening the
regulatory control.
By Council of Ministers Decision No. 294 of 23 April 2024, a Compensation Program for Non-Household End
Consumers for Electricity Costs was adopted for the period 1 January 2024 to 30 June 2024. The support under the
Program is targeted at a specific group of non-household end customers within the meaning of § 1, items 27d and 41b
of the Additional Provisions of the Energy Act (EA), which are exhaustively listed in § 3, para. 14 of the Transiti onal
and Final Provisions of the State Budget Act 2024 - nurseries, kindergartens, nursery groups in kindergartens, schools,
children's sports schools, community centers, prayer houses, temples and monasteries of registered religious
denominations. The compensation shall be calculated as the difference between the average price of the base load on
the Independent Bulgarian Energy Exchange EAD (IBEX), of the “Day -ahead” segment for the respective month and
the regulated price, approved by the Energy and Water Regulatory Commission, at which end suppliers sell electricity
to end household customers connected to the low-voltage electricity distribution network, the amount not including
VAT.
The indicative budget under the Program is BGN 30 million for the period from 01.01.2024 to 30.06.2024. The
compensations under the Program were paid by 30 September 2024.
By Decision No.546 of the Council of Ministers of 31 July 2024, a Program for Compensation of Non -Household
End Customers for Electricity Costs for the period from 1 July 2024 to 31 December 2024 was adopted, which was
updated by the subsequent Decision No.654 of the Council of Ministers of 18 September 2024. Support under the
Program is targeted at all non-household end customers, except for the persons listed in § 3, para. 14 of the
Transitional and Final Provisions of the State Budget Act 2024 and described in the above paragraph, for whom the
support measure was extended by Decision No.481 of the Council of Ministers of 4 July 2024. The amount of the
support provided under the Program shall be calculated as 100 per cent of the difference between the actual average
monthly exchange price for base load of the “Day -ahead” segment of the IBEX, for the relevant month of the period
01.07.2024 - 31.12.2024 and the base price of BGN 180/MWh, for non-household end-users, regardless of the
network to which they are connected. The Program shall also benefit the operators of the electricity transmission and
distribution networks for the purchase of the quantities of electricity consumed for technological costs for the period
from 1.07.2024 to 31.12.2024. The maximum amount of compensation for each individual month shall be determined
on the basis of the quantities of electricity for technological costs for the respective month, confirmed by the
Electricity System Security Fund (ESSF) by comparing with the quantities of active electricity based on the
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
18
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
information available in the Fund and the value for each MWh, calculated as the difference between the average
monthly price of base load electricity on the “Day Ahead” market, according to the data provided by IBEX and the
estimated market price determined by the Energy and Water Regulatory Commission (EWRC), respectively for the
transmission system operator and for the electricity distribution system operators in Decision No. C-17 of 30.06.2024.
The indicative budget of the Program is BGN 549 million for the period from 1 July 2024 to 31 December 2024.
Compensation under the Program is scheduled to be paid by 31 March 2025. The funds under the program shall be
disbursed following a positive decision by the European Commission or an opinion that the disbursement of the funds
does not constitute state aid within the meaning of Article 107(1) of the Treaty on the Functioning of the European
Union (TFEU). As a result of the discussions held through the Ministry of Finance, a positive reply was received
from the Directorate General for Competition, based on which the measure is considered not to constitute state aid,
given that it is similar to the support measures applied since 2021.
Implementation of Regulation (ЕU) 2022/1854 of the Council of 6 October 2022
The transitional and final provisions (TFP) of the Act on the Application of Provisions of the 2022 State Budget of
the Republic of Bulgaria Act, the 2022 Public Social Insurance Budget Act and the 2022 National Health Insurance
Fund Budget Act (Prom. in SG No. 104 of 2022) cover the measures for the implementation of Regulation (ЕU)
2022/1854 of the Council of 6 October 2022 with regard to an urgent interference for dealing with the high energy
prices.
Pursuant to §8 of the TFP of the Act on the Application of Provisions of the 2022 State Budget of the Republic of
Bulgaria Act, the electricity producers with electricity production facilities with an installed capacity of more than 1
MW, whose market revenues are derived from the sale of electricity produced from sources under Art. 7 of Regulation
(EU) 2022/1854, and from energy produced from coal and hydroelectric plants according to Art. 8, para. 1, letters “c”
and “e” of Regulation (EU) 2022/1854, make targeted contributions to the Electricity System Security Fund,
representing the positive difference between market revenues without value added tax and the specified revenue
ceiling calculated by applying the values for the relevant type of producer, with a delivery period from 1 December
2022 to 30 June 2023, with the exception of transactions with balancing energy required for the balancing needs of
the electricity system by ESO EAD. The values used for calculating the revenue ceiling for the relevant type of
producer are determined by an act of the Council of Ministers.
The adopted State Budget Act of the Republic of Bulgaria for 2023 (promulgated, State Gazette, issue 66 of 1.08.2023,
in force from 01.01.2023) extends the period of operation of the applied measures for emergency intervention to deal
with high energy prices by setting price ceilings on market revenues for inframarginal producers with low marginal
costs from 1 July 2023 to 31 December 2023.
The State Budget Act of the Republic of Bulgaria for 2024 (promulgated, State Gazette, issue 108 of 30.12.2023, in
force from 01.01.2024) extended the period of operation of the measures until 31 December 2024, with the same
mechanism of operation, while the values used to calculate the revenue ceiling for the period January - June 2024 for
the respective type of producer were set by Decision of the Council of Ministers № 167 of 14 March 2024,
respectively:
a) for a producer of electricity from a nuclear power plant – BGN 150 per MWh;
b) for a producer of electricity from a coal-fired condensing power plant, including from lignite - BGN 300, increased
by the average monthly price per tonne of CO 2 emission allowances multiplied by 1.32 per MWh;
c) for a producer of electricity from coal with the addition of biomass fuel (solid or gaseous biomass fuels) and/or
waste and/or petroleum products and/or a combination thereof - BGN 300, multiplied by 0.9 of average monthly price
per tonne of CO 2 emission allowances, per MWh;
d) for a producer of electricity from renewable sources without a contract for compensation with premiums – BGN
300 per MWh;
e) for electricity from hydropower plants owned by National Electricity Company (NEK) EAD – BGN 200 per MWh.
The same, with the exception of the values for electricity from hydroelectric plants owned by NEK EAD, were
confirmed by Decision of the Council of Ministers No. 537 of 25 July 2024 for the period July - December 2024. For
this period, no separate value has been set to cap the revenues from NEK EAD's hydroelectric plants and the company
falls into the group of renewable electricity producers without a premium compensation contract with a revenue cap
of BGN 300 per MWh as of 1 July 2024.
Annual Individual Management Report
31 December 2024
18
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
information available in the Fund and the value for each MWh, calculated as the difference between the average
monthly price of base load electricity on the “Day Ahead” market, according to the data provided by IBEX and the
estimated market price determined by the Energy and Water Regulatory Commission (EWRC), respectively for the
transmission system operator and for the electricity distribution system operators in Decision No. C-17 of 30.06.2024.
The indicative budget of the Program is BGN 549 million for the period from 1 July 2024 to 31 December 2024.
Compensation under the Program is scheduled to be paid by 31 March 2025. The funds under the program shall be
disbursed following a positive decision by the European Commission or an opinion that the disbursement of the funds
does not constitute state aid within the meaning of Article 107(1) of the Treaty on the Functioning of the European
Union (TFEU). As a result of the discussions held through the Ministry of Finance, a positive reply was received
from the Directorate General for Competition, based on which the measure is considered not to constitute state aid,
given that it is similar to the support measures applied since 2021.
Implementation of Regulation (ЕU) 2022/1854 of the Council of 6 October 2022
The transitional and final provisions (TFP) of the Act on the Application of Provisions of the 2022 State Budget of
the Republic of Bulgaria Act, the 2022 Public Social Insurance Budget Act and the 2022 National Health Insurance
Fund Budget Act (Prom. in SG No. 104 of 2022) cover the measures for the implementation of Regulation (ЕU)
2022/1854 of the Council of 6 October 2022 with regard to an urgent interference for dealing with the high energy
prices.
Pursuant to §8 of the TFP of the Act on the Application of Provisions of the 2022 State Budget of the Republic of
Bulgaria Act, the electricity producers with electricity production facilities with an installed capacity of more than 1
MW, whose market revenues are derived from the sale of electricity produced from sources under Art. 7 of Regulation
(EU) 2022/1854, and from energy produced from coal and hydroelectric plants according to Art. 8, para. 1, letters “c”
and “e” of Regulation (EU) 2022/1854, make targeted contributions to the Electricity System Security Fund,
representing the positive difference between market revenues without value added tax and the specified revenue
ceiling calculated by applying the values for the relevant type of producer, with a delivery period from 1 December
2022 to 30 June 2023, with the exception of transactions with balancing energy required for the balancing needs of
the electricity system by ESO EAD. The values used for calculating the revenue ceiling for the relevant type of
producer are determined by an act of the Council of Ministers.
The adopted State Budget Act of the Republic of Bulgaria for 2023 (promulgated, State Gazette, issue 66 of 1.08.2023,
in force from 01.01.2023) extends the period of operation of the applied measures for emergency intervention to deal
with high energy prices by setting price ceilings on market revenues for inframarginal producers with low marginal
costs from 1 July 2023 to 31 December 2023.
The State Budget Act of the Republic of Bulgaria for 2024 (promulgated, State Gazette, issue 108 of 30.12.2023, in
force from 01.01.2024) extended the period of operation of the measures until 31 December 2024, with the same
mechanism of operation, while the values used to calculate the revenue ceiling for the period January - June 2024 for
the respective type of producer were set by Decision of the Council of Ministers № 167 of 14 March 2024,
respectively:
a) for a producer of electricity from a nuclear power plant – BGN 150 per MWh;
b) for a producer of electricity from a coal-fired condensing power plant, including from lignite - BGN 300, increased
by the average monthly price per tonne of CO 2 emission allowances multiplied by 1.32 per MWh;
c) for a producer of electricity from coal with the addition of biomass fuel (solid or gaseous biomass fuels) and/or
waste and/or petroleum products and/or a combination thereof - BGN 300, multiplied by 0.9 of average monthly price
per tonne of CO 2 emission allowances, per MWh;
d) for a producer of electricity from renewable sources without a contract for compensation with premiums – BGN
300 per MWh;
e) for electricity from hydropower plants owned by National Electricity Company (NEK) EAD – BGN 200 per MWh.
The same, with the exception of the values for electricity from hydroelectric plants owned by NEK EAD, were
confirmed by Decision of the Council of Ministers No. 537 of 25 July 2024 for the period July - December 2024. For
this period, no separate value has been set to cap the revenues from NEK EAD's hydroelectric plants and the company
falls into the group of renewable electricity producers without a premium compensation contract with a revenue cap
of BGN 300 per MWh as of 1 July 2024.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
19
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Other
The latest tax inspections of the Company were carried out by the tax administration as follows:
• Corporate tax – until 31 December 2022;
• VAT – until 31 October 2022;
• Personal income tax – check for the month of November 2022;
• Social security insurance – until 31 December 2008.
The Company Management does not consider that there are any significant risks as a result of the dynamic fiscal and
regulatory environment in Bulgaria, which would require adjustments to the financial statements for the year ending
on 31 December 2024.
2.7. Intangible resources
The Company has no specific and undisclosed intangible resources. Given its core business as a holding company, its
most important resources are investments in subsidiaries, details of which are disclosed in Note 18 of the annual
separate financial statements.
3. Risk factors
The main elements that pose a risk in the activity of the Company are trade and other receivables and payables, trade
and financial balances with related parties, cash and financial assets available for sale. The types of risks to which the
Company is exposed in the course of its business activity are:
Currency risk
The Company’s currency risk is related to the potential negative effect of a change in foreign exchange rates on the
realization of gains or losses from revaluation of assets and liabilities denominated in foreign currencies.
BEH EAD holds EUR securities of Transgaz SA, Romania, which were purchased at the initial public offering of
securities of the Romanian company and are presented in the statement of financial position of BEH EAD as available
or sale financial assets. The Company recognizes the assets at fair value measured at quoted prices on an active market.
The coupon payments to the bondholders of BEH EAD on the bond issues issued in 2018 and in 2021 are payable in
euros.
Given the fact that the Republic of Bulgaria is in the conditions of the Currency Board and the BGN Lev is fixed to
the European currency – the Euro, the currency risk may be mainly affected by fluctuations in the US Dollar. In 2024,
BEH EAD has no significant transactions in currencies other than BGN and EUR.
Liquidity risk
Liquidity risk, or the risk of financing, is related both to the possibility of difficulties in obtaining funds to meet
commitments and to the inability to quickly sell a financial asset at a value close to its fair value to cover short-term
liabilities.
In connection with liquidity risk management, the Company performs cash flow calculations and forecasts receivables
and payables and monitors its liquidity position on a daily basis in order to provide the necessary cash resources to
meet its current and non-current obligations in a timely manner.
Credit risk
Credit risk includes the risk of financial loss due to non-payment of the liabilities of the debtor under a contract or a
financial instrument.
To minimize credit risk, the Company monitors its receivables on an ongoing basis, monitors the behavior of its
counterparties and analyzes in detail the activities of its larger debtors.
The trade and financial relations of BEH EAD are mainly related to its subsidiaries. Accordingly, the credit risk for
the Company is related to the risk that any of the debtor companies will not be able to cover its liabilities and therefore
realize a financial loss. In this regard, control over the revenues, expenses and implementation of the subsidiaries is
carried out on a monthly basis.
With regard to receivables from third parties, the Company carries out ongoing monitoring of their size and maturity,
so that the Company can take timely actions to collect them.
Annual Individual Management Report
31 December 2024
19
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Other
The latest tax inspections of the Company were carried out by the tax administration as follows:
• Corporate tax – until 31 December 2022;
• VAT – until 31 October 2022;
• Personal income tax – check for the month of November 2022;
• Social security insurance – until 31 December 2008.
The Company Management does not consider that there are any significant risks as a result of the dynamic fiscal and
regulatory environment in Bulgaria, which would require adjustments to the financial statements for the year ending
on 31 December 2024.
2.7. Intangible resources
The Company has no specific and undisclosed intangible resources. Given its core business as a holding company, its
most important resources are investments in subsidiaries, details of which are disclosed in Note 18 of the annual
separate financial statements.
3. Risk factors
The main elements that pose a risk in the activity of the Company are trade and other receivables and payables, trade
and financial balances with related parties, cash and financial assets available for sale. The types of risks to which the
Company is exposed in the course of its business activity are:
Currency risk
The Company’s currency risk is related to the potential negative effect of a change in foreign exchange rates on the
realization of gains or losses from revaluation of assets and liabilities denominated in foreign currencies.
BEH EAD holds EUR securities of Transgaz SA, Romania, which were purchased at the initial public offering of
securities of the Romanian company and are presented in the statement of financial position of BEH EAD as available
or sale financial assets. The Company recognizes the assets at fair value measured at quoted prices on an active market.
The coupon payments to the bondholders of BEH EAD on the bond issues issued in 2018 and in 2021 are payable in
euros.
Given the fact that the Republic of Bulgaria is in the conditions of the Currency Board and the BGN Lev is fixed to
the European currency – the Euro, the currency risk may be mainly affected by fluctuations in the US Dollar. In 2024,
BEH EAD has no significant transactions in currencies other than BGN and EUR.
Liquidity risk
Liquidity risk, or the risk of financing, is related both to the possibility of difficulties in obtaining funds to meet
commitments and to the inability to quickly sell a financial asset at a value close to its fair value to cover short-term
liabilities.
In connection with liquidity risk management, the Company performs cash flow calculations and forecasts receivables
and payables and monitors its liquidity position on a daily basis in order to provide the necessary cash resources to
meet its current and non-current obligations in a timely manner.
Credit risk
Credit risk includes the risk of financial loss due to non-payment of the liabilities of the debtor under a contract or a
financial instrument.
To minimize credit risk, the Company monitors its receivables on an ongoing basis, monitors the behavior of its
counterparties and analyzes in detail the activities of its larger debtors.
The trade and financial relations of BEH EAD are mainly related to its subsidiaries. Accordingly, the credit risk for
the Company is related to the risk that any of the debtor companies will not be able to cover its liabilities and therefore
realize a financial loss. In this regard, control over the revenues, expenses and implementation of the subsidiaries is
carried out on a monthly basis.
With regard to receivables from third parties, the Company carries out ongoing monitoring of their size and maturity,
so that the Company can take timely actions to collect them.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
20
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Business risk
The business risk is determined by the specificity of the Holding’s business and concerns the uncertainty associated
with generating sufficient revenue. There is no business risk for the Company’s activities as a whole since the revenue
generated by the Company is mainly from loans and services provided to subsidiaries and dividends.
Cash flow risk
The cash flow risk is related to the uncertainty of cash inflows from an investment and is interrelated to currency risk.
The cash flows of the Company are subject to fluctuations in the amount of expected future cash flows associated with
a monetary financial instrument.
In order to reduce this risk, the Company regularly plans its cash flows and floating rate financial instruments have a
short-term nature with a period of less than one year. In order to achieve greater predictability of the expected cash
inflows, the majority of the loans granted to the companies are with fixed interest rates and annuity installments.
Climate-related matters
In 2024, the Company presented information on climate-related matters, and considered such reporting as a long-term
commitment, which will be further developed and broadened in the future. The legislation, regulatory bodies, partners
of the Company and the users of non-financial information draw great attention to the climate change. The European
Union adopted the European Green Deal as a transition to more sustainable economic and financial system and in the
coming years the detailed requirements for reporting climate change will become applicable as a part of the European
standards for reporting sustainability. The Company will analyze and subsequently adapt applicable regulatory
framework for its reporting, in accordance with the requirements of the Accounting Act ( amendment (State Gazette,
No. 26 of 27 March 2025)
As of 31 December 2024, the Company has not identified any significant risks caused by climate change that could
have a direct negative and material impact on its financial statements, but may affect its investments and returns in
the long term.
4. Future development, investments, forthcoming significant transactions and other
information under Art. 247 of the Commercial Act
4.1. Future development of Bulgarian Energy Holding EAD
BEH EAD is one of the leading energy companies in the region, with modern management and striving to reap the
benefits of bringing together different in their essence state-owned companies in the energy sector.
Reform of the electricity market
Due to its specificity, most of the subsidiaries of BEH EAD carry out their activities in the conditions of a hybrid
energy market, consisting of a regulated and unregulated (free) market segment.
The process of liberalization of the electricity market in Bulgaria is still ongoing. Since 1 July 2021, the wholesale
electricity market in the country is practically liberalized and all non-household consumers have switched from a
regulated to a free market. The consumers who did not choose an electricity supplier until 30 June 2021 are served by
a supplier of last resort (namely the electricity distribution companies and NEK EAD).
In April 2024 amendments to the Energy Act (prom. SG No. 39 of 2024, in force from 01.05.2024) were adopted to
regulate the postponement of the process of full liberalization of the electricity market. According to the
aforementioned Act, from 1 July 2025 the role of NEK EAD as a public electricity supplier will be abolished and the
EWRC will no longer set quotas for electricity producers. Notwithstanding the removal of the Public Supplier role,
the long-term contract to which NEK EAD is a party will not be terminated and the company will be compensated for
the difference in the prices at which it must purchase electricity and the market price at which it sells it. On the other
hand, the EWRC will start to set monthly compensation to cover part of the costs of household end customers for
electricity purchased from a final supplier at regulated prices. The compensation shall be determined as the difference
between the achieved weighted average price of the day-ahead market segment attributable to the respective final
supplier for the respective month and the base cost of electricity per 1 MWh determined by the State Budget Act for
the respective year and/or program adopted by the Council of Ministers, which the household final customer shall pay
for the respective regulatory period. The compensation may be for all or part of the amount of electricity purchased
by the household final customers, and the amount may be differentiated according to the amount of electricity
purchased.
Annual Individual Management Report
31 December 2024
20
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Business risk
The business risk is determined by the specificity of the Holding’s business and concerns the uncertainty associated
with generating sufficient revenue. There is no business risk for the Company’s activities as a whole since the revenue
generated by the Company is mainly from loans and services provided to subsidiaries and dividends.
Cash flow risk
The cash flow risk is related to the uncertainty of cash inflows from an investment and is interrelated to currency risk.
The cash flows of the Company are subject to fluctuations in the amount of expected future cash flows associated with
a monetary financial instrument.
In order to reduce this risk, the Company regularly plans its cash flows and floating rate financial instruments have a
short-term nature with a period of less than one year. In order to achieve greater predictability of the expected cash
inflows, the majority of the loans granted to the companies are with fixed interest rates and annuity installments.
Climate-related matters
In 2024, the Company presented information on climate-related matters, and considered such reporting as a long-term
commitment, which will be further developed and broadened in the future. The legislation, regulatory bodies, partners
of the Company and the users of non-financial information draw great attention to the climate change. The European
Union adopted the European Green Deal as a transition to more sustainable economic and financial system and in the
coming years the detailed requirements for reporting climate change will become applicable as a part of the European
standards for reporting sustainability. The Company will analyze and subsequently adapt applicable regulatory
framework for its reporting, in accordance with the requirements of the Accounting Act ( amendment (State Gazette,
No. 26 of 27 March 2025)
As of 31 December 2024, the Company has not identified any significant risks caused by climate change that could
have a direct negative and material impact on its financial statements, but may affect its investments and returns in
the long term.
4. Future development, investments, forthcoming significant transactions and other
information under Art. 247 of the Commercial Act
4.1. Future development of Bulgarian Energy Holding EAD
BEH EAD is one of the leading energy companies in the region, with modern management and striving to reap the
benefits of bringing together different in their essence state-owned companies in the energy sector.
Reform of the electricity market
Due to its specificity, most of the subsidiaries of BEH EAD carry out their activities in the conditions of a hybrid
energy market, consisting of a regulated and unregulated (free) market segment.
The process of liberalization of the electricity market in Bulgaria is still ongoing. Since 1 July 2021, the wholesale
electricity market in the country is practically liberalized and all non-household consumers have switched from a
regulated to a free market. The consumers who did not choose an electricity supplier until 30 June 2021 are served by
a supplier of last resort (namely the electricity distribution companies and NEK EAD).
In April 2024 amendments to the Energy Act (prom. SG No. 39 of 2024, in force from 01.05.2024) were adopted to
regulate the postponement of the process of full liberalization of the electricity market. According to the
aforementioned Act, from 1 July 2025 the role of NEK EAD as a public electricity supplier will be abolished and the
EWRC will no longer set quotas for electricity producers. Notwithstanding the removal of the Public Supplier role,
the long-term contract to which NEK EAD is a party will not be terminated and the company will be compensated for
the difference in the prices at which it must purchase electricity and the market price at which it sells it. On the other
hand, the EWRC will start to set monthly compensation to cover part of the costs of household end customers for
electricity purchased from a final supplier at regulated prices. The compensation shall be determined as the difference
between the achieved weighted average price of the day-ahead market segment attributable to the respective final
supplier for the respective month and the base cost of electricity per 1 MWh determined by the State Budget Act for
the respective year and/or program adopted by the Council of Ministers, which the household final customer shall pay
for the respective regulatory period. The compensation may be for all or part of the amount of electricity purchased
by the household final customers, and the amount may be differentiated according to the amount of electricity
purchased.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
21
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
By a decision of 6 October 2023, the National Assembly adopted a Roadmap to Climate Neutrality. It was updated by
the Council of Ministers by Decision N.59 of 26 January 2024. The Climate Neutrality Roadmap sets the end date for
electricity generation from coal-fired power plants at 31 December 2038. Its main objective is to outline a transition
towards decarbonization of the Bulgarian economy and transformation of coal regions through the implementation of
various policies and measures and the promotion of the use of clean and innovative technologies. The strategic goal
is to achieve climate neutrality by 2050 through a structured energy transition and targeted investments in new
electricity generation capacities from low-emission sources, production, transmission and storage of renewable
energy, energy efficiency and low-carbon technologies in all economy sectors.
The Roadmap presents the targeted measures and policies in the electricity sector by periods, taking into account the
development of other sectors of the economy, among which the most important are:
- by 2024: adopted national goal of climate neutrality by 2050 in the Climate Change Mitigation Act (CCMA);
Harmonized strategic documents in the Energy sector: The Long-Term Strategy (LTS) for Decarbonization
and the Integrated National Energy and Climate Plan (INECP) corresponding to the National Climate
Neutrality Goal by 2050;
- by 2026: new RES capacities put into operation (3 500 MW); storage systems (batteries) (1 000 MW);
Development of projects for the construction of a new nuclear power plant and a new PSHPP and repair of
existing PSHPP;
- by 2030: Installed RES (7 500 MW), offshore wind power plants and storage systems (1 600 MW);
Implementation of projects for the construction of a new nuclear power plant and a new PSHPP;
- by 2035: Installed RES (over 10 000 MW), large-scale offshore wind power plants (1 500 MW) and storage
systems; Preparation for the operation of the new nuclear power plant and the new PSHPP;
- by 2040: Installed RES (14 000 MW), large-scale offshore wind power plants (2 500 MW) and storage
systems (2 000 MW); A new nuclear power plant and a new PSHPP were launched;
- by 2045: measures for the reclamation of contaminated land related to the extraction and use of fossil fuels.
Reform of the natural gas market
Since the beginning of 2024, the downward trend in natural gas prices on European gas markets that began in the last
two months of 2022 has continued, and throughout 2023 Europe has been able to replace most of its Russian gas
through increased imports of liquefied natural gas (LNG), mainly from the US and Qatar, and to a lesser extent through
increased imports of pipeline gas from Norway. In contrast to long-term fixed-price contracts with Russia, LNG is
traded primarily on the spot market, making it vulnerable to price fluctuations and competition from other large buyers
such as Asia, as well as to long-term availability and security of supply. There are other reasons for uncertainty related
to infrastructure development and geopolitical situations, as well as Europe's commitment to decarbonization, which
implies a gradual reduction in gas demand over the long term. The expiry of the contract for the transit of Russian gas
through Ukraine has forced European and regional players to look for alternative supply routes. Greece, with its
increased LNG regasification capacity, has the ambition to become a regional gas hub, facilitating trade and pricing,
making investment in gas storage facilities and pipeline infrastructure crucial to maximize flexibility and security of
supply.
The commissioning of the liquefied natural gas terminal in the city of Alexandroupolis, as well as the gas connection
with Serbia and the interconnector with Turkey, in 2024 are expected to have a positive impact on gas prices in the
region, with a view to diversifying supply sources and developing gas transmission infrastructure.
Natural gas demand in Bulgaria in 2024 remains at similar levels compared to the previous year. It should be noted
significant share of natural gas transactions carried out on the Balkan Gas Hub EAD platform, has significantly
increased its liquidity. Following the suspension of transit through Ukraine, Bulgaria is the only route for Russian
natural gas supply to South-Eastern and Central Europe. Many companies in the region still consume gas from Russia
under long-term contracts, some of which is also sold on the Bulgarian market. At the same time, gas production
companies from the Caspian region have entered the market. This has led to a significant reduction in the prices of
natural gas available in Bulgaria in 2024, which were at significantly lower levels than prices on European gas markets.
Natural gas prices were affected by a number of factors, with the downward trend in European gas markets that started
in the last two months of 2022 continuing in 2023 and 2024 due to:
- the high occupancy rate of natural gas storage facilities in Europe;
- securing alternative supplies of liquefied natural gas;
Annual Individual Management Report
31 December 2024
21
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
By a decision of 6 October 2023, the National Assembly adopted a Roadmap to Climate Neutrality. It was updated by
the Council of Ministers by Decision N.59 of 26 January 2024. The Climate Neutrality Roadmap sets the end date for
electricity generation from coal-fired power plants at 31 December 2038. Its main objective is to outline a transition
towards decarbonization of the Bulgarian economy and transformation of coal regions through the implementation of
various policies and measures and the promotion of the use of clean and innovative technologies. The strategic goal
is to achieve climate neutrality by 2050 through a structured energy transition and targeted investments in new
electricity generation capacities from low-emission sources, production, transmission and storage of renewable
energy, energy efficiency and low-carbon technologies in all economy sectors.
The Roadmap presents the targeted measures and policies in the electricity sector by periods, taking into account the
development of other sectors of the economy, among which the most important are:
- by 2024: adopted national goal of climate neutrality by 2050 in the Climate Change Mitigation Act (CCMA);
Harmonized strategic documents in the Energy sector: The Long-Term Strategy (LTS) for Decarbonization
and the Integrated National Energy and Climate Plan (INECP) corresponding to the National Climate
Neutrality Goal by 2050;
- by 2026: new RES capacities put into operation (3 500 MW); storage systems (batteries) (1 000 MW);
Development of projects for the construction of a new nuclear power plant and a new PSHPP and repair of
existing PSHPP;
- by 2030: Installed RES (7 500 MW), offshore wind power plants and storage systems (1 600 MW);
Implementation of projects for the construction of a new nuclear power plant and a new PSHPP;
- by 2035: Installed RES (over 10 000 MW), large-scale offshore wind power plants (1 500 MW) and storage
systems; Preparation for the operation of the new nuclear power plant and the new PSHPP;
- by 2040: Installed RES (14 000 MW), large-scale offshore wind power plants (2 500 MW) and storage
systems (2 000 MW); A new nuclear power plant and a new PSHPP were launched;
- by 2045: measures for the reclamation of contaminated land related to the extraction and use of fossil fuels.
Reform of the natural gas market
Since the beginning of 2024, the downward trend in natural gas prices on European gas markets that began in the last
two months of 2022 has continued, and throughout 2023 Europe has been able to replace most of its Russian gas
through increased imports of liquefied natural gas (LNG), mainly from the US and Qatar, and to a lesser extent through
increased imports of pipeline gas from Norway. In contrast to long-term fixed-price contracts with Russia, LNG is
traded primarily on the spot market, making it vulnerable to price fluctuations and competition from other large buyers
such as Asia, as well as to long-term availability and security of supply. There are other reasons for uncertainty related
to infrastructure development and geopolitical situations, as well as Europe's commitment to decarbonization, which
implies a gradual reduction in gas demand over the long term. The expiry of the contract for the transit of Russian gas
through Ukraine has forced European and regional players to look for alternative supply routes. Greece, with its
increased LNG regasification capacity, has the ambition to become a regional gas hub, facilitating trade and pricing,
making investment in gas storage facilities and pipeline infrastructure crucial to maximize flexibility and security of
supply.
The commissioning of the liquefied natural gas terminal in the city of Alexandroupolis, as well as the gas connection
with Serbia and the interconnector with Turkey, in 2024 are expected to have a positive impact on gas prices in the
region, with a view to diversifying supply sources and developing gas transmission infrastructure.
Natural gas demand in Bulgaria in 2024 remains at similar levels compared to the previous year. It should be noted
significant share of natural gas transactions carried out on the Balkan Gas Hub EAD platform, has significantly
increased its liquidity. Following the suspension of transit through Ukraine, Bulgaria is the only route for Russian
natural gas supply to South-Eastern and Central Europe. Many companies in the region still consume gas from Russia
under long-term contracts, some of which is also sold on the Bulgarian market. At the same time, gas production
companies from the Caspian region have entered the market. This has led to a significant reduction in the prices of
natural gas available in Bulgaria in 2024, which were at significantly lower levels than prices on European gas markets.
Natural gas prices were affected by a number of factors, with the downward trend in European gas markets that started
in the last two months of 2022 continuing in 2023 and 2024 due to:
- the high occupancy rate of natural gas storage facilities in Europe;
- securing alternative supplies of liquefied natural gas;
Bulgarian Energy Holding EAD
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- limited economic activity in Europe (and Asia);
- the construction and commissioning of new LNG terminals across Europe;
- a decline in demand for natural gas (partly due to imposed restrictions on consumption).
The objectives of BEH EAD are focused on the following main and priority areas:
Financial sustainability and modernization of BEH Group
• Improving corporate management practices
✓ Increasing transparency and sustainability in line with OECD principles and the Guidelines for Corporate
Governance of State-Owned Enterprises. • Providing funding for key activities and projects:
✓ Effective management of financial assets and instruments;
✓ Participation in capital markets to attract external financing from international financial institutions on
competitive terms;
✓ Leveraging the advantages arising from the scale of the holding structure (economies of scale) ;
✓ Supporting independent transmission operators in negotiating credit resources to finance projects of
particular importance, especially regarding climate change mitigation and sustainable low-carbon
economy development; • Cost optimization in BEH Group:
✓ Forecasting and planning the expenses of BEH Group;
✓ Transparency and predictability of expenses;
✓ Increasing the efficiency of the business activities. • Elimination of deficits in BEH Group:
✓ Continuous monitoring and control of the generated tariff deficit;
✓ Cooperating with and supporting the Ministry of Energy, EWRC, and the Energy Commission in
developing normative and regulatory changes related to sector reform and compensation for generated tariff
deficits. • Decarbonization of BEH Group
✓ Integrating decarbonization goals within the strategic direction and development framework of Bulgaria’s
energy sector;
✓ Identifying solutions for sustainable development and decarbonization;
• Diversification of sources
✓ Projects aimed at securing natural gas supplies through new sources. The purpose is to achieve
independence by securing more natural gas suppliers;
✓ Increasing the technical capacity of the interconnection Greece-Bulgaria with proven binding market
interest in accordance with the Decision to grant an Exception for the IGB project to the Regulatory
Authorities EWRC and RAE of 25.07.2018, approved by the European Commission.
✓ Acquisition by BEH EAD of an interest in the exploration activities under the Oil and Gas Exploration
Contracts in the area of Block 1-21 Han Asparuh
• Diversification of routes
✓ Projects aimed at eliminating the risk of a single import route for natural gas and making optimal use
of existing pipeline routes;
Annual Individual Management Report
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- limited economic activity in Europe (and Asia);
- the construction and commissioning of new LNG terminals across Europe;
- a decline in demand for natural gas (partly due to imposed restrictions on consumption).
The objectives of BEH EAD are focused on the following main and priority areas:
Financial sustainability and modernization of BEH Group
• Improving corporate management practices
✓ Increasing transparency and sustainability in line with OECD principles and the Guidelines for Corporate
Governance of State-Owned Enterprises. • Providing funding for key activities and projects:
✓ Effective management of financial assets and instruments;
✓ Participation in capital markets to attract external financing from international financial institutions on
competitive terms;
✓ Leveraging the advantages arising from the scale of the holding structure (economies of scale) ;
✓ Supporting independent transmission operators in negotiating credit resources to finance projects of
particular importance, especially regarding climate change mitigation and sustainable low-carbon
economy development; • Cost optimization in BEH Group:
✓ Forecasting and planning the expenses of BEH Group;
✓ Transparency and predictability of expenses;
✓ Increasing the efficiency of the business activities. • Elimination of deficits in BEH Group:
✓ Continuous monitoring and control of the generated tariff deficit;
✓ Cooperating with and supporting the Ministry of Energy, EWRC, and the Energy Commission in
developing normative and regulatory changes related to sector reform and compensation for generated tariff
deficits. • Decarbonization of BEH Group
✓ Integrating decarbonization goals within the strategic direction and development framework of Bulgaria’s
energy sector;
✓ Identifying solutions for sustainable development and decarbonization;
• Diversification of sources
✓ Projects aimed at securing natural gas supplies through new sources. The purpose is to achieve
independence by securing more natural gas suppliers;
✓ Increasing the technical capacity of the interconnection Greece-Bulgaria with proven binding market
interest in accordance with the Decision to grant an Exception for the IGB project to the Regulatory
Authorities EWRC and RAE of 25.07.2018, approved by the European Commission.
✓ Acquisition by BEH EAD of an interest in the exploration activities under the Oil and Gas Exploration
Contracts in the area of Block 1-21 Han Asparuh
• Diversification of routes
✓ Projects aimed at eliminating the risk of a single import route for natural gas and making optimal use
of existing pipeline routes;
Bulgarian Energy Holding EAD
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✓ Shareholding of Bulgaria in the new FSRU LNG terminal near Alexandroupolis, Greece, through
Bulgartransgaz EAD;
✓ Research of the possibilities and expediency of possible participation in other new investment intentions
to build terminals for liquefied natural gas in the region;
✓ Provision of LNG regasification and storage capacity to terminals in Turkey.
• Security, reliability and continuity of gas supplies
✓ Extension of UGS Chiren capacity.
• Investments for the development of nuclear energy
✓ Construction of new nuclear facilities.
• Increasing the life cycle of the power generating facilities that guarantee system security along with
ensuring long-term profitability
✓ Projects aimed at extending the useful life of a number of capacities that are key to the energy system,
as they ensure the security of electricity supply, the balance of the energy system and the increase in
the value of services offered.
✓ Main current projects in this direction:
o Ensuring the long-term operation of the 5th and 6th nuclear power units above their design
resource in the following 30 years and the implementation of measures ensuring the operation
of the units at increased power;
o Rehabilitation of hydropower capacities, expansion of the production capacity and
modernization of the capacities with the purpose of ensuring the long-term and effective
exploitation of the hydropower resources of Bulgaria;
✓ Support of NPP Kozloduy EAD regarding the implementation of its policy on Safety Management and
maintaining and enhancing the Safety Culture.
• Diversifying the supplies of fresh nuclear fuel
✓ Completion of the diversification process through supplies of an alternative type of nuclear fuel;
✓ Reducing the dependence of NPP Kozloduy EAD on a single supplier of nuclear fuel subject to
compliance with the conditions and requirements for nuclear safety.
• Regional and European connectivity of the systems
✓ Projects aiming at optimally connecting the Bulgarian market with regional and European markets, thus
achieving one of the major European aims – merger of the markets, on the one hand, and enhanced
energy security, on the other hand.
✓ The main ongoing projects in this direction are the Vertical Gas Corridor, which will interconnect the
networks of Bulgaria, Greece, Romania and Hungary and will allow the transmission of natural gas
along the axis of this corridor. Improved connectivity of the transmission systems within the Vertical
Corridor is in line with the overall European priorities in the Energy sector to enhance energy security,
market integration and increased competition through diversification of routes and sources of natural
gas;
✓ Expansion and increase of electricity grid capacity.
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✓ Shareholding of Bulgaria in the new FSRU LNG terminal near Alexandroupolis, Greece, through
Bulgartransgaz EAD;
✓ Research of the possibilities and expediency of possible participation in other new investment intentions
to build terminals for liquefied natural gas in the region;
✓ Provision of LNG regasification and storage capacity to terminals in Turkey.
• Security, reliability and continuity of gas supplies
✓ Extension of UGS Chiren capacity.
• Investments for the development of nuclear energy
✓ Construction of new nuclear facilities.
• Increasing the life cycle of the power generating facilities that guarantee system security along with
ensuring long-term profitability
✓ Projects aimed at extending the useful life of a number of capacities that are key to the energy system,
as they ensure the security of electricity supply, the balance of the energy system and the increase in
the value of services offered.
✓ Main current projects in this direction:
o Ensuring the long-term operation of the 5th and 6th nuclear power units above their design
resource in the following 30 years and the implementation of measures ensuring the operation
of the units at increased power;
o Rehabilitation of hydropower capacities, expansion of the production capacity and
modernization of the capacities with the purpose of ensuring the long-term and effective
exploitation of the hydropower resources of Bulgaria;
✓ Support of NPP Kozloduy EAD regarding the implementation of its policy on Safety Management and
maintaining and enhancing the Safety Culture.
• Diversifying the supplies of fresh nuclear fuel
✓ Completion of the diversification process through supplies of an alternative type of nuclear fuel;
✓ Reducing the dependence of NPP Kozloduy EAD on a single supplier of nuclear fuel subject to
compliance with the conditions and requirements for nuclear safety.
• Regional and European connectivity of the systems
✓ Projects aiming at optimally connecting the Bulgarian market with regional and European markets, thus
achieving one of the major European aims – merger of the markets, on the one hand, and enhanced
energy security, on the other hand.
✓ The main ongoing projects in this direction are the Vertical Gas Corridor, which will interconnect the
networks of Bulgaria, Greece, Romania and Hungary and will allow the transmission of natural gas
along the axis of this corridor. Improved connectivity of the transmission systems within the Vertical
Corridor is in line with the overall European priorities in the Energy sector to enhance energy security,
market integration and increased competition through diversification of routes and sources of natural
gas;
✓ Expansion and increase of electricity grid capacity.
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4.2. Investments
On 19 January 2024, the Vertical Corridor Memorandum was renewed in Athens, Greece, within the framework of
the Interconnection Initiative - CESEC, with the participation of the gas transmission operators from Ukraine,
Moldova, and Slovakia. The Vertical Corridor is a strategic route for transporting additional volumes of natural gas
from alternative sources to the region, including LNG through existing and future LNG terminals in Greece.
The capacity enhancement projects at the Kulata/Sidirokastro interconnection point from Greece to Bulgaria and at
the Negru Voda 1/Kardam interconnection point from Bulgaria to Romania are a key part of the overall vision of the
Vertical Corridor, and the simultaneous availability of the expanded infrastructure under both projects is necessary to
achieve the stated objectives of diversification and improved security of supply. The implementation of these projects
will enable Bulgartransgaz EAD’s gas transmission network to technically accommodate increased natural gas
volumes from diverse and reliable sources, including LNG, flowing south to north. This will support diversification
and enhance supply security for Bulgaria and the region, while optimizing the use of existing infrastructure.
By decision of the National Assembly (prom. in SG No. 23 of 19 March 2024) the Minister of Energy, in their capacity
as the person, exercising the rights of the state as the sole owner of the capital of BEH EAD was instructed, in
accordance with applicable Bulgarian and EU legislation, to increase the capital of Bulgartransgaz EAD by BGN
200,000 thousand no later than 1 May 2024. The funds from the capital increase will be used by Bulgartransgaz EAD,
specifically for the preparation and implementation of the projects in connection with the Vertical Corridor initiative
of the gas transmission operators of Bulgaria, Greece, Romania, Hungary, Slovakia, Ukraine and Moldova, providing
the opportunity for the transmission of additional volumes of natural gas from diverse and reliable sources in the
south-north direction. On 20.06.2024, the capital increase of Bulgartransgaz EAD in the amount of BGN 200,000
thousand was registered in the Commercial Register and the Register of Non-Profit Legal Entities, following the
authorization granted by the Minister of Energy under Protocol No. E-РД-21-15/13.06. After the increase, the total
amount of the capital of Bulgartransgaz EAD is BGN 1,614,786,264, distributed in 1,614,786,264 ordinary registered
voting shares with a par value of BGN 1 each, fully owned by Bulgarian Energy Holding EAD.
4.3. Upcoming significant transactions and events
In relation to an adopted policy by BEH EAD for purchasing greenhouse gas emission allowances and based on of a
contract concluded in July 2021 between BEH EAD as a seller and TPP Maritsa East 2 EAD as a buyer, the holding
has bought greenhouse gas emission allowances of the EUA type for ensuring the production activity in the period
between 2021 and 2024. Under the agreement BEH EAD is obligated to purchase greenhouse gas emission allowances
on a regular basis upon receiving an order submitted by the buyer. The purchased allowances are transferred to the
account of the buyer after they are completely paid by it. The goal is the optimization of the costs for carbon emissions
by implementing a competitive principle in buying them through reducing the brokerag e commissions.
In 2025, Bulgarian Energy Holding EAD will continue to implement the adopted policy for ongoing purchase of
quotas for greenhouse gas emissions to cover the obligations of TPP Maritsa East 2 EAD in relation to the greenhouse
gases emitted by the plant.
Acquisition of a share of the rights and obligations under the Oil and Gas Exploration Contracts in the area of
Block 1-21 Han Asparuh
By Decision of the National Assembly of the Republic of Bulgaria of 21.07.2023 (prom. SG No. 63/2023) the Minister
of Energy was instructed to negotiate the terms and conditions for BEH EAD to acquire up to 20% of the rights and
obligations under the Oil and Gas Exploration Contracts for Block 1-21 Han Asparuh.
The Decision recorded in item 21 of Protocol No. 25 from the Council of Ministers meeting held on 5 June 2024
authorizes TotalEnergy EP Bulgaria B.V. to transfer its share of 57.14 percent of the rights and obligations arising
from the permit to OMV Offshore Bulgaria GMBH. The same decision extends the term of the permit for oil and gas
exploration by 23 months as a result of a delay caused by a force majeure event (the decision of TotalEnergies EP
Bulgaria B.V. to withdraw from the permit and the contract, as well as the continuation of the military actions of
Russia against Ukraine, and the consequences of the same on the security of the Black Sea while carrying out the
Annual Individual Management Report
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
4.2. Investments
On 19 January 2024, the Vertical Corridor Memorandum was renewed in Athens, Greece, within the framework of
the Interconnection Initiative - CESEC, with the participation of the gas transmission operators from Ukraine,
Moldova, and Slovakia. The Vertical Corridor is a strategic route for transporting additional volumes of natural gas
from alternative sources to the region, including LNG through existing and future LNG terminals in Greece.
The capacity enhancement projects at the Kulata/Sidirokastro interconnection point from Greece to Bulgaria and at
the Negru Voda 1/Kardam interconnection point from Bulgaria to Romania are a key part of the overall vision of the
Vertical Corridor, and the simultaneous availability of the expanded infrastructure under both projects is necessary to
achieve the stated objectives of diversification and improved security of supply. The implementation of these projects
will enable Bulgartransgaz EAD’s gas transmission network to technically accommodate increased natural gas
volumes from diverse and reliable sources, including LNG, flowing south to north. This will support diversification
and enhance supply security for Bulgaria and the region, while optimizing the use of existing infrastructure.
By decision of the National Assembly (prom. in SG No. 23 of 19 March 2024) the Minister of Energy, in their capacity
as the person, exercising the rights of the state as the sole owner of the capital of BEH EAD was instructed, in
accordance with applicable Bulgarian and EU legislation, to increase the capital of Bulgartransgaz EAD by BGN
200,000 thousand no later than 1 May 2024. The funds from the capital increase will be used by Bulgartransgaz EAD,
specifically for the preparation and implementation of the projects in connection with the Vertical Corridor initiative
of the gas transmission operators of Bulgaria, Greece, Romania, Hungary, Slovakia, Ukraine and Moldova, providing
the opportunity for the transmission of additional volumes of natural gas from diverse and reliable sources in the
south-north direction. On 20.06.2024, the capital increase of Bulgartransgaz EAD in the amount of BGN 200,000
thousand was registered in the Commercial Register and the Register of Non-Profit Legal Entities, following the
authorization granted by the Minister of Energy under Protocol No. E-РД-21-15/13.06. After the increase, the total
amount of the capital of Bulgartransgaz EAD is BGN 1,614,786,264, distributed in 1,614,786,264 ordinary registered
voting shares with a par value of BGN 1 each, fully owned by Bulgarian Energy Holding EAD.
4.3. Upcoming significant transactions and events
In relation to an adopted policy by BEH EAD for purchasing greenhouse gas emission allowances and based on of a
contract concluded in July 2021 between BEH EAD as a seller and TPP Maritsa East 2 EAD as a buyer, the holding
has bought greenhouse gas emission allowances of the EUA type for ensuring the production activity in the period
between 2021 and 2024. Under the agreement BEH EAD is obligated to purchase greenhouse gas emission allowances
on a regular basis upon receiving an order submitted by the buyer. The purchased allowances are transferred to the
account of the buyer after they are completely paid by it. The goal is the optimization of the costs for carbon emissions
by implementing a competitive principle in buying them through reducing the brokerag e commissions.
In 2025, Bulgarian Energy Holding EAD will continue to implement the adopted policy for ongoing purchase of
quotas for greenhouse gas emissions to cover the obligations of TPP Maritsa East 2 EAD in relation to the greenhouse
gases emitted by the plant.
Acquisition of a share of the rights and obligations under the Oil and Gas Exploration Contracts in the area of
Block 1-21 Han Asparuh
By Decision of the National Assembly of the Republic of Bulgaria of 21.07.2023 (prom. SG No. 63/2023) the Minister
of Energy was instructed to negotiate the terms and conditions for BEH EAD to acquire up to 20% of the rights and
obligations under the Oil and Gas Exploration Contracts for Block 1-21 Han Asparuh.
The Decision recorded in item 21 of Protocol No. 25 from the Council of Ministers meeting held on 5 June 2024
authorizes TotalEnergy EP Bulgaria B.V. to transfer its share of 57.14 percent of the rights and obligations arising
from the permit to OMV Offshore Bulgaria GMBH. The same decision extends the term of the permit for oil and gas
exploration by 23 months as a result of a delay caused by a force majeure event (the decision of TotalEnergies EP
Bulgaria B.V. to withdraw from the permit and the contract, as well as the continuation of the military actions of
Russia against Ukraine, and the consequences of the same on the security of the Black Sea while carrying out the
Bulgarian Energy Holding EAD
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31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
operations), certified by Force Majeure Certificate No 007/09.02.2024, issued by the Bulgarian Chamber of
Commerce and Industry.
Pursuant to Decision No. 394/07.06.2024 of the Council of Ministers, Supplementary Agreement No. 10 to the
Exploration Contract was signed, under which TotalEnergies EP Bulgaria B.V. transferred its 57.14% interest in the
rights and obligations under the permit to OMV Offshore Bulgaria GMBH, resulting in the company holding a 100%
interest in the project.
By Decision No. 83 of 20 February 2025 of the Council of Ministers (prom. SG No. 16/2025) OMV Offshore Bulgaria
GMBH was allowed to transfer 50 percent of the rights and obligations arising from Decision No 649 of the Council
of Ministers of 2012 for the grant of the oil and gas exploration permit - underground resources, in the area of Block
1-21 Han Asparuh, located in the exclusive economic zone of the Republic of Bulgaria in the Black Sea, to NewMed
Energy Balkan Limited, operating through its branch NewMed Energy Balkan Limited - Branch Bulgaria foreign
trader branch (FTB).
Based on the above decision, on 12 March 2025, the Minister of Energy entered into a supplemental agreement with
the parties for a partial assignment of the rights and obligations under the oil and gas exploration contract. The oil and
gas exploration in Block 1-21 Han Asparuh has thus been continued, with the two companies (OMV Offshore Bulgaria
GMBH and NewMed Energy Balkan Limited - Bulgaria Branch FTB) now each holding a 50 percent stake in the
project, with OMV Petrom (through OMV Offshore Bulgaria GMBH) as its operator. The block is located in the
exclusive economic zone of the Republic of Bulgaria in the deep Black Sea and, upon successful production and future
discovery of the block's gas potential, the country would have its own energy source that would provide it with natural
gas at the most affordable prices possible, guaranteeing the country's energy independence. Additionally, the
development of the field is expected to stimulate investor interest in the region and increase the competitiveness of
the sector and of household and industrial consumers of natural gas.
The parties are exploring the possibility of acquiring a share of BEH EAD for participation in the exploration activities
under the Oil and Gas Exploration Contract.
Building New Nuclear Facilities
In fulfillment of Bulgaria’s strategic goals to ensure its energy independence and security in 2023, steps were taken
to build two new nuclear units with a total installed capacity of 2300 MW. In early 2023, an agreement was signed
with Westinghouse Electric Company LLC for the provision of front-end engineering design (FEED) services to
support the construction of an AP1000 nuclear reactor facility at the NPP Kozloduy site.
On 18 December 2023, a Decision of the National Assembly was adopted (prom. SG No. 105/2023) to take action on
the construction of Units 7 and 8 at NPP Kozloduy Site No. 2 with AP1000 technology with an indicative schedule of
priority activities Annex No. 1 to the Decision.
Pursuant to the decision, in the second half of December 2023 the Ministry of Energy and BEH EAD started
preliminary preparation of documentation for the pre-selection process of construction companies, and on 28
December 2023 Bulgarian Energy Holding EAD increased the capital of NPP Kozloduy - New Builds EAD by a cash
contribution of BGN 1,500,000 thousand.
Following a procedure for the selection of a contractor for the project and in accordance with the Decision of the
National Assembly of 23 February 2024, negotiations have been launched with Hyundai Engineering & Construction
Co., which has been shortlisted as a potential construction company for the engineering, construction, delivery and
commissioning of a nuclear power plant at the approved site in Kozloduy, with AP1000 technology. In November
2024, an engineering contract was signed between NPP Kozloduy - New Builds EAD and a consortium between the
Korean Hyundai Engineering and Construction and the American Westinghouse Electric Company. In October 2024,
Annual Individual Management Report
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
operations), certified by Force Majeure Certificate No 007/09.02.2024, issued by the Bulgarian Chamber of
Commerce and Industry.
Pursuant to Decision No. 394/07.06.2024 of the Council of Ministers, Supplementary Agreement No. 10 to the
Exploration Contract was signed, under which TotalEnergies EP Bulgaria B.V. transferred its 57.14% interest in the
rights and obligations under the permit to OMV Offshore Bulgaria GMBH, resulting in the company holding a 100%
interest in the project.
By Decision No. 83 of 20 February 2025 of the Council of Ministers (prom. SG No. 16/2025) OMV Offshore Bulgaria
GMBH was allowed to transfer 50 percent of the rights and obligations arising from Decision No 649 of the Council
of Ministers of 2012 for the grant of the oil and gas exploration permit - underground resources, in the area of Block
1-21 Han Asparuh, located in the exclusive economic zone of the Republic of Bulgaria in the Black Sea, to NewMed
Energy Balkan Limited, operating through its branch NewMed Energy Balkan Limited - Branch Bulgaria foreign
trader branch (FTB).
Based on the above decision, on 12 March 2025, the Minister of Energy entered into a supplemental agreement with
the parties for a partial assignment of the rights and obligations under the oil and gas exploration contract. The oil and
gas exploration in Block 1-21 Han Asparuh has thus been continued, with the two companies (OMV Offshore Bulgaria
GMBH and NewMed Energy Balkan Limited - Bulgaria Branch FTB) now each holding a 50 percent stake in the
project, with OMV Petrom (through OMV Offshore Bulgaria GMBH) as its operator. The block is located in the
exclusive economic zone of the Republic of Bulgaria in the deep Black Sea and, upon successful production and future
discovery of the block's gas potential, the country would have its own energy source that would provide it with natural
gas at the most affordable prices possible, guaranteeing the country's energy independence. Additionally, the
development of the field is expected to stimulate investor interest in the region and increase the competitiveness of
the sector and of household and industrial consumers of natural gas.
The parties are exploring the possibility of acquiring a share of BEH EAD for participation in the exploration activities
under the Oil and Gas Exploration Contract.
Building New Nuclear Facilities
In fulfillment of Bulgaria’s strategic goals to ensure its energy independence and security in 2023, steps were taken
to build two new nuclear units with a total installed capacity of 2300 MW. In early 2023, an agreement was signed
with Westinghouse Electric Company LLC for the provision of front-end engineering design (FEED) services to
support the construction of an AP1000 nuclear reactor facility at the NPP Kozloduy site.
On 18 December 2023, a Decision of the National Assembly was adopted (prom. SG No. 105/2023) to take action on
the construction of Units 7 and 8 at NPP Kozloduy Site No. 2 with AP1000 technology with an indicative schedule of
priority activities Annex No. 1 to the Decision.
Pursuant to the decision, in the second half of December 2023 the Ministry of Energy and BEH EAD started
preliminary preparation of documentation for the pre-selection process of construction companies, and on 28
December 2023 Bulgarian Energy Holding EAD increased the capital of NPP Kozloduy - New Builds EAD by a cash
contribution of BGN 1,500,000 thousand.
Following a procedure for the selection of a contractor for the project and in accordance with the Decision of the
National Assembly of 23 February 2024, negotiations have been launched with Hyundai Engineering & Construction
Co., which has been shortlisted as a potential construction company for the engineering, construction, delivery and
commissioning of a nuclear power plant at the approved site in Kozloduy, with AP1000 technology. In November
2024, an engineering contract was signed between NPP Kozloduy - New Builds EAD and a consortium between the
Korean Hyundai Engineering and Construction and the American Westinghouse Electric Company. In October 2024,
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
an extension of the Front End Engineering Design (FEED) contract was signed with Westinghouse Electric Company
for the construction of Units 7 and 8 with AP1000 type reactors at the NPP Kozloduy site.
Planned increase in the capital of BEH EAD in the Updated Medium-Term Budget Forecast for the period 2025-
2028
By Decision of the Council of Ministers No. 88 of 24.02.2025, an Updated Medium -Term Budget Forecast for the
period 2025-2028 was approved. It is part of the explanatory memorandum to the draft law of the State Budget of the
Republic of Bulgaria for 2025 (prom. SG No. 26 of 27.03.2025). In view of the implementation of investment
programs, as well as of assigned public policies for the capitalization of commercial companies with state participation
in the capital, a capital increase of BEH EAD in the total amount of BGN 2.5 billion is envisaged. This is aimed at
providing financing for structurally decisive projects in the energy sector, such as the Chaira, Batak and Dospat
pumped storage hydropower plants, NPP Kozloduy Units 7 and 8, hydropower plants, hydropower transmission
infrastructure, projects to increase the technical capacity for gas transmission, expansion of the gas transmission
network, reconstruction of power lines, etc. In addition, a BGN 250 million capital increase of BEH EAD is foreseen
to provide funds to Maritsa East Mines EAD for the implementation of technical reclamation of the disturbed areas
of the East Maritsa Coal Basin deposit.
5. Events after the reporting period
There were no adjusting events or other significant non-adjusting events between the date of the separate financial
statements and the date of their approval for issue, except for the following non-adjusting events:
Repayment of Bulgarian Energy Holding EAD's obligations under a loan received from NPP Kozloduy EAD
On 20 January 2025, Bulgarian Energy Holding EAD's obligation in the amount of BGN 25,000 thousand under a
loan agreement dated 18 October 2024 with NPP Kozloduy EAD was repaid.
Change in the management of Bulgarian Energy Holding EAD
By a protocol decision of 7 February 2025 of the Minister of Energy, Galina Tsvetanova Todorova was dismissed as
a member of the Board of Directors of Bulgarian Energy Holding EAD and Diyan Atanasov Ivanov was elected in
her place until a new competitive procedure is held. The change was entered in the Commercial Register and the
Register of Non-Profit Legal Entities on 13 February 2025.
Credit rating of Bulgarian Energy Holding EAD
On 17 March 2025, Fitch Ratings revised the outlook on Bulgarian Energy Holding EAD's long-term rating (BB+) to
stable from positive and affirmed the rating on non-secured and unsubordinated debt at BB+. The outlook revision
reflects the expected increase in leverage and high capital expenditure associated with the construction of the new
nuclear units.
Conclusion of Annex to Loan Agreement with Bulgartransgaz EAD
On 31 March 2025, Annex 2 was concluded with Bulgartransgaz EAD to amend the terms of the loan agreement dated
17 February 2023 in the amount of BGN 87,527 thousand, in connection with the financing provided by BEH EAD
for the implementation of the project “Expansion of the capacity of the Chiren underground gas storage facility”, with
a repayment period of 31 March 31 2030. Until 31 December 2026 Bulgartransgaz EAD shall have the right to
repeatedly draw down and repay (revolve), in whole or in part, amounts from the loan, after which date the parties
shall agree on a repayment plan for the remaining principal obligation.
On 31 March 2025, with accordance with the annex, an amount of BGN 87,527 thousand was transferred by the
subsidiary to Bulgarian Energy Holding EAD.
Extension of the loan agreement with Minproekt EAD
On 24 April 2025, an additional agreement was signed to extend the term of the loan agreement between Bulgarian
Energy Holding EAD and Minproekt EAD until 12 February 2027, approved by a protocol decision of the Board of
Directors of Bulgarian Energy Holding EAD on 6 February 2025 and a protocol of 23 April 2025 of the Minister of
Energy.
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an extension of the Front End Engineering Design (FEED) contract was signed with Westinghouse Electric Company
for the construction of Units 7 and 8 with AP1000 type reactors at the NPP Kozloduy site.
Planned increase in the capital of BEH EAD in the Updated Medium-Term Budget Forecast for the period 2025-
2028
By Decision of the Council of Ministers No. 88 of 24.02.2025, an Updated Medium -Term Budget Forecast for the
period 2025-2028 was approved. It is part of the explanatory memorandum to the draft law of the State Budget of the
Republic of Bulgaria for 2025 (prom. SG No. 26 of 27.03.2025). In view of the implementation of investment
programs, as well as of assigned public policies for the capitalization of commercial companies with state participation
in the capital, a capital increase of BEH EAD in the total amount of BGN 2.5 billion is envisaged. This is aimed at
providing financing for structurally decisive projects in the energy sector, such as the Chaira, Batak and Dospat
pumped storage hydropower plants, NPP Kozloduy Units 7 and 8, hydropower plants, hydropower transmission
infrastructure, projects to increase the technical capacity for gas transmission, expansion of the gas transmission
network, reconstruction of power lines, etc. In addition, a BGN 250 million capital increase of BEH EAD is foreseen
to provide funds to Maritsa East Mines EAD for the implementation of technical reclamation of the disturbed areas
of the East Maritsa Coal Basin deposit.
5. Events after the reporting period
There were no adjusting events or other significant non-adjusting events between the date of the separate financial
statements and the date of their approval for issue, except for the following non-adjusting events:
Repayment of Bulgarian Energy Holding EAD's obligations under a loan received from NPP Kozloduy EAD
On 20 January 2025, Bulgarian Energy Holding EAD's obligation in the amount of BGN 25,000 thousand under a
loan agreement dated 18 October 2024 with NPP Kozloduy EAD was repaid.
Change in the management of Bulgarian Energy Holding EAD
By a protocol decision of 7 February 2025 of the Minister of Energy, Galina Tsvetanova Todorova was dismissed as
a member of the Board of Directors of Bulgarian Energy Holding EAD and Diyan Atanasov Ivanov was elected in
her place until a new competitive procedure is held. The change was entered in the Commercial Register and the
Register of Non-Profit Legal Entities on 13 February 2025.
Credit rating of Bulgarian Energy Holding EAD
On 17 March 2025, Fitch Ratings revised the outlook on Bulgarian Energy Holding EAD's long-term rating (BB+) to
stable from positive and affirmed the rating on non-secured and unsubordinated debt at BB+. The outlook revision
reflects the expected increase in leverage and high capital expenditure associated with the construction of the new
nuclear units.
Conclusion of Annex to Loan Agreement with Bulgartransgaz EAD
On 31 March 2025, Annex 2 was concluded with Bulgartransgaz EAD to amend the terms of the loan agreement dated
17 February 2023 in the amount of BGN 87,527 thousand, in connection with the financing provided by BEH EAD
for the implementation of the project “Expansion of the capacity of the Chiren underground gas storage facility”, with
a repayment period of 31 March 31 2030. Until 31 December 2026 Bulgartransgaz EAD shall have the right to
repeatedly draw down and repay (revolve), in whole or in part, amounts from the loan, after which date the parties
shall agree on a repayment plan for the remaining principal obligation.
On 31 March 2025, with accordance with the annex, an amount of BGN 87,527 thousand was transferred by the
subsidiary to Bulgarian Energy Holding EAD.
Extension of the loan agreement with Minproekt EAD
On 24 April 2025, an additional agreement was signed to extend the term of the loan agreement between Bulgarian
Energy Holding EAD and Minproekt EAD until 12 February 2027, approved by a protocol decision of the Board of
Directors of Bulgarian Energy Holding EAD on 6 February 2025 and a protocol of 23 April 2025 of the Minister of
Energy.
Bulgarian Energy Holding EAD
Annual Individual Management Report
31 December 2024
27
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Early partial repayment of dividend obligation of Bulgartransgaz EAD
On 25 April 2025, Annex No. 1 was concluded with Bulgartransgaz EAD to the Agreement of 9 December 2024 with
BEH EAD for the rescheduling of Bulgartransgaz EAD's obligations in the amount of BGN 257,251 thousand arising
from the dividends due by the company for 2021 and 2022. The annex formalizes the possibility of Bulgartransgaz
EAD to make an early partial repayment of its obligation.
Decisions on the establishment and payment to the state of deductions from the profit of state-owned enterprises and
commercial companies with state participation in the capital
By Order No. 1 of 2 May 2025 of the Council of Ministers (CoM), it was determined that state-owned enterprises and
commercial companies with state participation in the capital, with the exception of hospitals, mental health centers
and companies in the Water Supply and Sewerage sector, shall distribute a dividend for the financial year 2024, in
compliance with the requirements of Art. 247a of the Commercial Act, after deducting the deductions for the Reserve
fund, when this fund is not replenished, in accordance with Art. 101 of the State Budget Act of the Republic of
Bulgaria for 2025 – at 100 percent.
Pursuant to the Order, Bulgarian Energy Holding EAD shall distribute and pay a 6 -month (interim) dividend based
on the adopted 6-month financial statements as of 30 June 2025 in the amount of 100 percent of the reported profit,
with the respective application of Article 247a of the Commercial Act.
Signed with electronic signature
VALENTIN NIKOLOV
EXECUTIVE DIRECTOR
BULGARIAN ENERGY HOLDING EAD
Sofia, 28 April 2025
Annual Individual Management Report
31 December 2024
27
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Early partial repayment of dividend obligation of Bulgartransgaz EAD
On 25 April 2025, Annex No. 1 was concluded with Bulgartransgaz EAD to the Agreement of 9 December 2024 with
BEH EAD for the rescheduling of Bulgartransgaz EAD's obligations in the amount of BGN 257,251 thousand arising
from the dividends due by the company for 2021 and 2022. The annex formalizes the possibility of Bulgartransgaz
EAD to make an early partial repayment of its obligation.
Decisions on the establishment and payment to the state of deductions from the profit of state-owned enterprises and
commercial companies with state participation in the capital
By Order No. 1 of 2 May 2025 of the Council of Ministers (CoM), it was determined that state-owned enterprises and
commercial companies with state participation in the capital, with the exception of hospitals, mental health centers
and companies in the Water Supply and Sewerage sector, shall distribute a dividend for the financial year 2024, in
compliance with the requirements of Art. 247a of the Commercial Act, after deducting the deductions for the Reserve
fund, when this fund is not replenished, in accordance with Art. 101 of the State Budget Act of the Republic of
Bulgaria for 2025 – at 100 percent.
Pursuant to the Order, Bulgarian Energy Holding EAD shall distribute and pay a 6 -month (interim) dividend based
on the adopted 6-month financial statements as of 30 June 2025 in the amount of 100 percent of the reported profit,
with the respective application of Article 247a of the Commercial Act.
Signed with electronic signature
VALENTIN NIKOLOV
EXECUTIVE DIRECTOR
BULGARIAN ENERGY HOLDING EAD
Sofia, 28 April 2025
BULGARIAN ENERGY HOLDING EAD
CORPORATE GOVERNANCE STATEMENT
31 December 2024
CORPORATE GOVERNANCE STATEMENT
31 December 2024
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
2
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
1. GENERAL PROVISIONS
This Corporate Governance Statement of Bulgarian Energy Holding EAD (BEH EAD, the Company) was prepared
in compliance with the requirements of Art. 40 para. 1 of the Accountancy Act and according to Art. 100n, para. 8 in
relation to para. 7, item 1 of the Public Offering of Securities Act (POSA).
Bulgarian Energy Holding EAD is a public interest entity under §1, item 22 of the additional provisions of the
Accountancy Act and Art. 2 of Directive 2013/34/EU of the European Parliament and of the Council whose
transferable securities are admitted to trading on a regulated market in a Member State of the European Union.
BEH EAD is a separate legal entity under the Bulgarian law, a sole-owner joint stock company acting in accordance
with the provisions of the Commercial Act, the Public Enterprises Act, the Rules on the application of the Public
Enterprises Act (the Rules) and the other legislative acts of the Republic of Bulgaria. The sole owner of the capital,
who has all the rights of a shareholder under the law and the Articles of Association, is the Bulgarian state through
the Minister of Energy.
The Company is managed by a one-tier management system. The Board of Directors has management, representative
and control functions.
The implementation of the Corporate Governance Code is both a statutory requirement and a result from the
willingness of the management for a constant improvement of the corporate governance principles and practices
adopted by the Company. The efforts of the executive management are focused on the transparency of the activity
through presentation of due and complete information, stakeholder consideration, independence, and prevention of
conflict of interests.
BEH EAD complies with the established principles and norms of corporate governance set out in the current
regulations applicable to the holding's activities. The company is also committed to specific actions and policies
regarding the sustainable development of its subsidiaries, including the disclosure of information related to climate
and social aspects of their operations. The Board of Directors of BEH EAD encourages the implementation and
monitors the observation on behalf of the subsidiaries of the established principles for sustainable development at a
group level, as well as it contributes to the establishment of sustainable development culture.
BEH EAD places great importance on fostering effective relationships with various stakeholders. These stakeholders
include certain individuals or groups directly impacted by the Company’s operations and who also possess the ability
to influence its activities. This includes suppliers, clients, employees, creditors, advocacy groups, and others. The
Company identifies these stakeholders based on their significance, areas of influence, roles, and commitment to
sustainable development. The Board of Directors of BEH EAD complies with legal requirements when engaging with
stakeholders. The corporate management of the Company ensures the protection of stakeholder rights as mandated by
law or through mutual agreements with the companies. In line with good corporate governance practice, the Company
complies with the principles of transparency, accountability and business ethics.
The Corporate Governance Statement is a separate report that is published together with the management report, both
of which are subject to publication on BEH EAD's corporate website: www.bgenh.com.
Corporate Governance Statement
31 December 2024
2
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
1. GENERAL PROVISIONS
This Corporate Governance Statement of Bulgarian Energy Holding EAD (BEH EAD, the Company) was prepared
in compliance with the requirements of Art. 40 para. 1 of the Accountancy Act and according to Art. 100n, para. 8 in
relation to para. 7, item 1 of the Public Offering of Securities Act (POSA).
Bulgarian Energy Holding EAD is a public interest entity under §1, item 22 of the additional provisions of the
Accountancy Act and Art. 2 of Directive 2013/34/EU of the European Parliament and of the Council whose
transferable securities are admitted to trading on a regulated market in a Member State of the European Union.
BEH EAD is a separate legal entity under the Bulgarian law, a sole-owner joint stock company acting in accordance
with the provisions of the Commercial Act, the Public Enterprises Act, the Rules on the application of the Public
Enterprises Act (the Rules) and the other legislative acts of the Republic of Bulgaria. The sole owner of the capital,
who has all the rights of a shareholder under the law and the Articles of Association, is the Bulgarian state through
the Minister of Energy.
The Company is managed by a one-tier management system. The Board of Directors has management, representative
and control functions.
The implementation of the Corporate Governance Code is both a statutory requirement and a result from the
willingness of the management for a constant improvement of the corporate governance principles and practices
adopted by the Company. The efforts of the executive management are focused on the transparency of the activity
through presentation of due and complete information, stakeholder consideration, independence, and prevention of
conflict of interests.
BEH EAD complies with the established principles and norms of corporate governance set out in the current
regulations applicable to the holding's activities. The company is also committed to specific actions and policies
regarding the sustainable development of its subsidiaries, including the disclosure of information related to climate
and social aspects of their operations. The Board of Directors of BEH EAD encourages the implementation and
monitors the observation on behalf of the subsidiaries of the established principles for sustainable development at a
group level, as well as it contributes to the establishment of sustainable development culture.
BEH EAD places great importance on fostering effective relationships with various stakeholders. These stakeholders
include certain individuals or groups directly impacted by the Company’s operations and who also possess the ability
to influence its activities. This includes suppliers, clients, employees, creditors, advocacy groups, and others. The
Company identifies these stakeholders based on their significance, areas of influence, roles, and commitment to
sustainable development. The Board of Directors of BEH EAD complies with legal requirements when engaging with
stakeholders. The corporate management of the Company ensures the protection of stakeholder rights as mandated by
law or through mutual agreements with the companies. In line with good corporate governance practice, the Company
complies with the principles of transparency, accountability and business ethics.
The Corporate Governance Statement is a separate report that is published together with the management report, both
of which are subject to publication on BEH EAD's corporate website: www.bgenh.com.
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 1 of POSA
BEH EAD adheres, as appropriate, to the National Corporate Governance Code, established by the Chairperson of the
Financial Supervision Commission within the meaning of art. 100n, para. 8, i. 1, letter “а“ of POSA by Decision No.
850-ККУ of 25.11.2021 and adopted by the National Corporate Governance Committee. The Code is applied on a
“comply or explain” principle, i.e. in case of diversion the management has to clarify the reasons .
BEH EAD protects the rights of the sole shareholder – the state, described in Chapter 3 of the National Corporate
Governance Code.
BEH EAD implements a Corporate Governance Policy, adopted by the Board of Directors of BEH EAD by a
Resolution under item I.2. of Protocol No. 27-2018/17.05.2018. The main purpose of the Corporate Governance
Policy is maintaining and improving standards and management quality corresponding to the best world practices for
transparency, respect to the interested parties, independence, and avoidance of conflict of interests in implementing
the Company activity. As a public enterprise in the energy sector, BEH EAD plays a key role for the economy of
Bulgaria, which predetermines the significance of the good corporate governance. BEH EAD is aware of its
importance for maintaining the economic effectiveness and competitiveness of the Republic of Bulgaria. Its
implementation raises the efficiency, transparency, and responsibility of Bulgarian Energy Holding EAD in pursuing
its activity at levels, competitive to the private sector. It is mandatory for all companies within the holding, as their
executive managements develop and apply internal implementing rules, strategies, and policies in conformity with it.
The strategic goals of the Corporate Governance Policy are:
- Balancing the development of the Company with the interests of the owner, management, stakeholders, actual
and potential investors;
- Ensuring a mechanism for an honest, responsible and effective management of the Company on behalf of
the management bodies;
- Providing for effective supervision on the management on behalf of the principal and the regulatory bodies;
- Ensuring information security and foreseeability of real and potential investors/bondholders in making
investment decisions.
- Achieving transparency and publicity of the processes for providing information on behalf of the Company
to employees, partners, and stakeholders.
- Raising the trust of the owner, existing and potential investors, and stakeholders and maintaining the good
name of BEH EAD to the public.
BEH EAD adheres to an Information Disclosure Policy of BEH EAD adopted by a Decision under item I.1.10 of
Protocol No. 75-2022 of 13 October 2022 of the Board of Directors of BEH EAD. The Policy defines the scope of the
information subject to disclosure by BEH EAD in its capacity as a public enterprise, within the meaning of Art. 2,
para. 1 of the Public Enterprises Act. The Company discloses and provides easy access to all essential information,
including the financial status of the holding and BEH Group companies and its structure. BEH EAD discloses any
essential information regarding the operational activity of the Company, regardless of its nature, in compliance with
the principle of equal treatment of the addressees. As soon as possible, the Company discloses publicly internal
information in accordance with Regulation (EU) No. 596/2014 of the European Parliament. The Policy is publicly
accessible on the corporate webpage of the Company at: www.bgenh.com.
BEH EAD strictly complies with the requirements for disclosure of information in terms of time and completeness
according to the Bulgarian legislation and instructions of the Minister of Energy. Information on the annual, half -
yearly and quarterly financial statements, management reports is disclosed in a timely manner on BEH EAD's website
and through the electronic information system for public enterprises administered by the Public Enterprises and
Control Agency.
BEH EAD does not publish a non-financial statement on an individual basis because it applies Article 51 of the
Accountancy Act, according to which the parent company of a large group prepares a consolidated non -financial
statement. The first reporting period for which the report on the activities of enterprises under Chapter Seven of the
Act includes a sustainability report is 2026. The consolidated non-financial statement shall include information on
how and to what extent the companies' activities qualify as environmentally sustainable, namely: what part of their
turnover is the result of products and services, related to economic activities qualified as environmentally sustainable;
the share of capital and operational expenses, if applicable, allocated to assets or processes linked to sustainable
activities.
3. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 2 of POSA
Corporate Governance Statement
31 December 2024
3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 1 of POSA
BEH EAD adheres, as appropriate, to the National Corporate Governance Code, established by the Chairperson of the
Financial Supervision Commission within the meaning of art. 100n, para. 8, i. 1, letter “а“ of POSA by Decision No.
850-ККУ of 25.11.2021 and adopted by the National Corporate Governance Committee. The Code is applied on a
“comply or explain” principle, i.e. in case of diversion the management has to clarify the reasons .
BEH EAD protects the rights of the sole shareholder – the state, described in Chapter 3 of the National Corporate
Governance Code.
BEH EAD implements a Corporate Governance Policy, adopted by the Board of Directors of BEH EAD by a
Resolution under item I.2. of Protocol No. 27-2018/17.05.2018. The main purpose of the Corporate Governance
Policy is maintaining and improving standards and management quality corresponding to the best world practices for
transparency, respect to the interested parties, independence, and avoidance of conflict of interests in implementing
the Company activity. As a public enterprise in the energy sector, BEH EAD plays a key role for the economy of
Bulgaria, which predetermines the significance of the good corporate governance. BEH EAD is aware of its
importance for maintaining the economic effectiveness and competitiveness of the Republic of Bulgaria. Its
implementation raises the efficiency, transparency, and responsibility of Bulgarian Energy Holding EAD in pursuing
its activity at levels, competitive to the private sector. It is mandatory for all companies within the holding, as their
executive managements develop and apply internal implementing rules, strategies, and policies in conformity with it.
The strategic goals of the Corporate Governance Policy are:
- Balancing the development of the Company with the interests of the owner, management, stakeholders, actual
and potential investors;
- Ensuring a mechanism for an honest, responsible and effective management of the Company on behalf of
the management bodies;
- Providing for effective supervision on the management on behalf of the principal and the regulatory bodies;
- Ensuring information security and foreseeability of real and potential investors/bondholders in making
investment decisions.
- Achieving transparency and publicity of the processes for providing information on behalf of the Company
to employees, partners, and stakeholders.
- Raising the trust of the owner, existing and potential investors, and stakeholders and maintaining the good
name of BEH EAD to the public.
BEH EAD adheres to an Information Disclosure Policy of BEH EAD adopted by a Decision under item I.1.10 of
Protocol No. 75-2022 of 13 October 2022 of the Board of Directors of BEH EAD. The Policy defines the scope of the
information subject to disclosure by BEH EAD in its capacity as a public enterprise, within the meaning of Art. 2,
para. 1 of the Public Enterprises Act. The Company discloses and provides easy access to all essential information,
including the financial status of the holding and BEH Group companies and its structure. BEH EAD discloses any
essential information regarding the operational activity of the Company, regardless of its nature, in compliance with
the principle of equal treatment of the addressees. As soon as possible, the Company discloses publicly internal
information in accordance with Regulation (EU) No. 596/2014 of the European Parliament. The Policy is publicly
accessible on the corporate webpage of the Company at: www.bgenh.com.
BEH EAD strictly complies with the requirements for disclosure of information in terms of time and completeness
according to the Bulgarian legislation and instructions of the Minister of Energy. Information on the annual, half -
yearly and quarterly financial statements, management reports is disclosed in a timely manner on BEH EAD's website
and through the electronic information system for public enterprises administered by the Public Enterprises and
Control Agency.
BEH EAD does not publish a non-financial statement on an individual basis because it applies Article 51 of the
Accountancy Act, according to which the parent company of a large group prepares a consolidated non -financial
statement. The first reporting period for which the report on the activities of enterprises under Chapter Seven of the
Act includes a sustainability report is 2026. The consolidated non-financial statement shall include information on
how and to what extent the companies' activities qualify as environmentally sustainable, namely: what part of their
turnover is the result of products and services, related to economic activities qualified as environmentally sustainable;
the share of capital and operational expenses, if applicable, allocated to assets or processes linked to sustainable
activities.
3. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 2 of POSA
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
4
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The number of the companies in which the members of the Board of Directors can hold managerial positions and the
number of successive mandates of the independent members of the Board of Directors is not defined in the regulatory
acts of BEH EAD. However, the Company complies with the good practices, without a formal regulatory requirement
for prevention of high concentration of control functions in individual.
The remuneration of the Board of Directors of BEH EAD is determined in accordance with the terms and conditions
of the Rules on the application of the Public Enterprises Act. No remuneration other than that specified in the Rules
is allowed. As a public enterprise, BEH EAD complies with the provisions of the Public Enterprises Act and its
bylaws, and does not apply a deliberate Remuneration Policy.
4. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 3 of POSA
By a decision of the Board of Directors of 28 February 2017, an Internal Audit Unit was established at BEH EAD,
which is a separate department of direct subordination to the Executive Director. The internal audit activities comply
with the requirements of the Public Sector Internal Audit Act. By a decision of the Board of Directors of BEH EAD
under item I.2.1. of Protocol No. 68-2017/31.10.2017, as amended by a decision under item I.4.1. of Protocol No.
43/2023 of 29.06.2023, the Statute of the Internal Audit Department was approved. By a decision of the Board of
Directors of BEH EAD under item I.1.1. of Protocol No. 47-2023/12.07.2023, a Methodology for the implementation
of internal audit activities by the Internal Audit Department was approved. The scope of audit engagements for
assurance and consultation covers BEH EAD and its subsidiaries, excluding the independent transmission operators.
Internal audit supports management and its subordinate entities in achieving the holding company's objectives by:
− Identifying and assessing holding company risks;
− Assessing the adequacy and effectiveness of the financial management and control system with regard to:
a) Identifying, assessing and managing risk by holding company management;
b) compliance with the legislation, internal acts and contracts;
c) reliability and the comprehensiveness of the financial and operational information;
d) effectiveness, efficiency and economy of the activities;
e) protecting assets and information;
f) performing tasks and achieving goals.
− Provides recommendations for improving the activities and processes of management and control in the
holding and its subsidiaries.
On 2 April 2014, a Financial Management and Control System was approved in BEH EAD, which entered into force
on 14 April 2014. In 2024, the Financial Management and Control System was updated and adopted by the Decision
of the Board of Directors of BEH EAD under item I.2.1 of Protocol No. 111-2024/15.11.2024 and is effective as of
29 November 2024.
The purpose of the system is to provide reasonable assurance that the objectives of the Company are achieved through:
− compliance with legislation, the Company's bylaws and contracts entered into;
− reliability and comprehensiveness of financial and operational information;
− economy, efficiency and effectiveness of the activities;
− storage and protection of assets and information;
− preventing and detecting fraud and irregularities and taking follow-up action.
Financial management and control are carried out through the following interrelated elements:
− control environment;
− risk management;
− control activities;
− information and communication;
− monitoring.
The control environment includes:
− personal integrity and professional ethics of the employees of the Company;
− management philosophy and work style;
Corporate Governance Statement
31 December 2024
4
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The number of the companies in which the members of the Board of Directors can hold managerial positions and the
number of successive mandates of the independent members of the Board of Directors is not defined in the regulatory
acts of BEH EAD. However, the Company complies with the good practices, without a formal regulatory requirement
for prevention of high concentration of control functions in individual.
The remuneration of the Board of Directors of BEH EAD is determined in accordance with the terms and conditions
of the Rules on the application of the Public Enterprises Act. No remuneration other than that specified in the Rules
is allowed. As a public enterprise, BEH EAD complies with the provisions of the Public Enterprises Act and its
bylaws, and does not apply a deliberate Remuneration Policy.
4. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 3 of POSA
By a decision of the Board of Directors of 28 February 2017, an Internal Audit Unit was established at BEH EAD,
which is a separate department of direct subordination to the Executive Director. The internal audit activities comply
with the requirements of the Public Sector Internal Audit Act. By a decision of the Board of Directors of BEH EAD
under item I.2.1. of Protocol No. 68-2017/31.10.2017, as amended by a decision under item I.4.1. of Protocol No.
43/2023 of 29.06.2023, the Statute of the Internal Audit Department was approved. By a decision of the Board of
Directors of BEH EAD under item I.1.1. of Protocol No. 47-2023/12.07.2023, a Methodology for the implementation
of internal audit activities by the Internal Audit Department was approved. The scope of audit engagements for
assurance and consultation covers BEH EAD and its subsidiaries, excluding the independent transmission operators.
Internal audit supports management and its subordinate entities in achieving the holding company's objectives by:
− Identifying and assessing holding company risks;
− Assessing the adequacy and effectiveness of the financial management and control system with regard to:
a) Identifying, assessing and managing risk by holding company management;
b) compliance with the legislation, internal acts and contracts;
c) reliability and the comprehensiveness of the financial and operational information;
d) effectiveness, efficiency and economy of the activities;
e) protecting assets and information;
f) performing tasks and achieving goals.
− Provides recommendations for improving the activities and processes of management and control in the
holding and its subsidiaries.
On 2 April 2014, a Financial Management and Control System was approved in BEH EAD, which entered into force
on 14 April 2014. In 2024, the Financial Management and Control System was updated and adopted by the Decision
of the Board of Directors of BEH EAD under item I.2.1 of Protocol No. 111-2024/15.11.2024 and is effective as of
29 November 2024.
The purpose of the system is to provide reasonable assurance that the objectives of the Company are achieved through:
− compliance with legislation, the Company's bylaws and contracts entered into;
− reliability and comprehensiveness of financial and operational information;
− economy, efficiency and effectiveness of the activities;
− storage and protection of assets and information;
− preventing and detecting fraud and irregularities and taking follow-up action.
Financial management and control are carried out through the following interrelated elements:
− control environment;
− risk management;
− control activities;
− information and communication;
− monitoring.
The control environment includes:
− personal integrity and professional ethics of the employees of the Company;
− management philosophy and work style;
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
5
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
− an organizational structure ensuring separation of responsibilities, hierarchy and clear rules, rights, obligations
and reporting levels;
− human resource management policies and procedures;
− competence of staff.
By a Decision under item I.3. of Protocol № 21 -2022/06.04.2022 of the Board of Directors of BEH EAD,
updated Risk Management Policy of BEH EAD was adopted in accordance with the Guidelines of the Ministry of
Finance for Risk Management in Public Sector Organizations. The rules and procedures for risk management in BEH
EAD are an integral part thereof.
The management of BEH EAD undertakes constant commitment to the processes of identification, assessment,
analysis and management of risks within the holding, as well as commitment to these processes at all management
and expert levels.
The following are determined in the Risk Management Strategy
- the stages of the risk management process and their content;
- the participants in the implementation of the risk management process.
The implementation of the Strategy aims to:
- Identify, analyze and assess risks with a view to ensuring the possibility of fulfilling the Company’s goals;
- Determine the level of risk appetite and risk response actions (restriction, transfer, acceptance or termination);
- Establish and implement adequate and effective control mechanisms;
- Identify the roles and responsibilities of participants in the risk management process;
- Protect the Company’s reputation.
The Risk Management process in the Company comprises the following:
- Defining the main objectives of the Company;
- Identifying the risks;
- Risk control;
- Risk assessment;
- Documenting the risk;
- Defining the level of risk – risk appetite;
- Review and reporting on risk.
The Executive Director shall implement controls designed to provide reasonable assurance that risks are contained
within tolerable limits and shall include, at a minimum:
- authorization and approval procedures;
- separation of responsibilities in a manner that prevents a single employee from having concurrent approval,
execution, and control responsibilities;
- a dual signature system that does not permit a financial commitment or payment to be made without the
signatures of the Executive Director and the Chief Accountant and Head of the Accounting Department;
- rules for access to assets and information;
- prior control for legality;
- ongoing control over the performance of financial commitments and contracts entered into;
- ex-post performance evaluations;
- policies and procedures for objective, accurate, complete, reliable and timely accounting of all business
transactions in accordance with the accounting policies adopted at BEH EAD;
- policies and procedures for human resources management;
- policies and procedures for maintaining personal integrity and professional ethics.
The information and communication systems in the company shall ensure:
- identification, collection and dissemination in appropriate form and timing of reliable and credible
information to enable each employee to assume specific responsibility;
- effective communication flowing horizontally and vertically to all hierarchical levels of the company;
- establishing an appropriate management information system for the company to make all employees aware
of clear and precise instructions and orders regarding their roles and responsibilities in relation to financial
management and control;
Corporate Governance Statement
31 December 2024
5
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
− an organizational structure ensuring separation of responsibilities, hierarchy and clear rules, rights, obligations
and reporting levels;
− human resource management policies and procedures;
− competence of staff.
By a Decision under item I.3. of Protocol № 21 -2022/06.04.2022 of the Board of Directors of BEH EAD,
updated Risk Management Policy of BEH EAD was adopted in accordance with the Guidelines of the Ministry of
Finance for Risk Management in Public Sector Organizations. The rules and procedures for risk management in BEH
EAD are an integral part thereof.
The management of BEH EAD undertakes constant commitment to the processes of identification, assessment,
analysis and management of risks within the holding, as well as commitment to these processes at all management
and expert levels.
The following are determined in the Risk Management Strategy
- the stages of the risk management process and their content;
- the participants in the implementation of the risk management process.
The implementation of the Strategy aims to:
- Identify, analyze and assess risks with a view to ensuring the possibility of fulfilling the Company’s goals;
- Determine the level of risk appetite and risk response actions (restriction, transfer, acceptance or termination);
- Establish and implement adequate and effective control mechanisms;
- Identify the roles and responsibilities of participants in the risk management process;
- Protect the Company’s reputation.
The Risk Management process in the Company comprises the following:
- Defining the main objectives of the Company;
- Identifying the risks;
- Risk control;
- Risk assessment;
- Documenting the risk;
- Defining the level of risk – risk appetite;
- Review and reporting on risk.
The Executive Director shall implement controls designed to provide reasonable assurance that risks are contained
within tolerable limits and shall include, at a minimum:
- authorization and approval procedures;
- separation of responsibilities in a manner that prevents a single employee from having concurrent approval,
execution, and control responsibilities;
- a dual signature system that does not permit a financial commitment or payment to be made without the
signatures of the Executive Director and the Chief Accountant and Head of the Accounting Department;
- rules for access to assets and information;
- prior control for legality;
- ongoing control over the performance of financial commitments and contracts entered into;
- ex-post performance evaluations;
- policies and procedures for objective, accurate, complete, reliable and timely accounting of all business
transactions in accordance with the accounting policies adopted at BEH EAD;
- policies and procedures for human resources management;
- policies and procedures for maintaining personal integrity and professional ethics.
The information and communication systems in the company shall ensure:
- identification, collection and dissemination in appropriate form and timing of reliable and credible
information to enable each employee to assume specific responsibility;
- effective communication flowing horizontally and vertically to all hierarchical levels of the company;
- establishing an appropriate management information system for the company to make all employees aware
of clear and precise instructions and orders regarding their roles and responsibilities in relation to financial
management and control;
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- implementing a documentation and document management system containing rules for the compilation,
formatting, circulation, use and archiving of documents;
- establishing an effective and timely reporting system, including levels and timelines for reporting, types of
reports, forms of reporting when errors, irregularities, misuse, fraud or abuse are detected.
The Executive Director of BEH EAD shall ensure monitoring of the financial management and control system in order
to assess its functioning and to identify weaknesses and deficiencies in a timely manner and ensure its timely updating.
The system includes ongoing monitoring, self-assessment and internal audit
5. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 4 of POSA
5.1. Information under Art. 10, paragraph 1 (c) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
Bulgarian Energy Holding EAD is the owner of an economically related group, which includes the following
companies as of 31 December 2024:
Company Country of
incorporation Main activity
31 December
2024 г.
31 December
2023
% %
Subsidiaries
Natsionalna Elektricheska
Kompania (NEK) EAD
Bulgaria electricity generation and public
electricity supplier
100% 100%
Bulgargaz EAD Bulgaria public supply of natural gas 100% 100%
Bulgartransgaz EAD Bulgaria storage and transmission of
natural gas 100% 100%
Bulgartel EAD Bulgaria implementation of
telecommunications 100% 100%
Bulgartel Skopje DOOEL Macedonia implementation of
telecommunications 100% 100%
Balkan Gas Hub EAD Bulgaria
construction and operation of an
electronic platform for trade with
natural gas, energy products,
green and white certificates,
carbon-gas emissions
100% 100%
NPP Kozloduy EAD Bulgaria generation of electricity and
thermal energy 100% 100%
HPP Kozloduy EAD Bulgaria
production and distribution of
electricity from a hydroelectric
power plant
100% 100%
NPP Kozloduy – New Builds EAD Bulgaria construction of energy units of a
nuclear power plant 100% 100%
NPP Construction Supervision
EOOD Bulgaria
assessing the compliance of
investment projects and
exercising construction
supervision in design and
construction
100% 100%
NPP Service LTD Bulgaria repair of general and special
purpose machines and equipment 100% 100%
Interpriborservice OOD
(in bankruptcy) Bulgaria installation and maintenance of
automated systems 63.96% 63.96%
TPP Maritsa East 2 EAD Bulgaria generation of electricity and
thermal energy 100% 100%
Mini Maritsa – Iztok EAD Bulgaria coal extraction and sale 100% 100%
Electricity System Operator EAD Bulgaria transmission of electricity 100% 100%
Corporate Governance Statement
31 December 2024
6
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- implementing a documentation and document management system containing rules for the compilation,
formatting, circulation, use and archiving of documents;
- establishing an effective and timely reporting system, including levels and timelines for reporting, types of
reports, forms of reporting when errors, irregularities, misuse, fraud or abuse are detected.
The Executive Director of BEH EAD shall ensure monitoring of the financial management and control system in order
to assess its functioning and to identify weaknesses and deficiencies in a timely manner and ensure its timely updating.
The system includes ongoing monitoring, self-assessment and internal audit
5. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 4 of POSA
5.1. Information under Art. 10, paragraph 1 (c) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
Bulgarian Energy Holding EAD is the owner of an economically related group, which includes the following
companies as of 31 December 2024:
Company Country of
incorporation Main activity
31 December
2024 г.
31 December
2023
% %
Subsidiaries
Natsionalna Elektricheska
Kompania (NEK) EAD
Bulgaria electricity generation and public
electricity supplier
100% 100%
Bulgargaz EAD Bulgaria public supply of natural gas 100% 100%
Bulgartransgaz EAD Bulgaria storage and transmission of
natural gas 100% 100%
Bulgartel EAD Bulgaria implementation of
telecommunications 100% 100%
Bulgartel Skopje DOOEL Macedonia implementation of
telecommunications 100% 100%
Balkan Gas Hub EAD Bulgaria
construction and operation of an
electronic platform for trade with
natural gas, energy products,
green and white certificates,
carbon-gas emissions
100% 100%
NPP Kozloduy EAD Bulgaria generation of electricity and
thermal energy 100% 100%
HPP Kozloduy EAD Bulgaria
production and distribution of
electricity from a hydroelectric
power plant
100% 100%
NPP Kozloduy – New Builds EAD Bulgaria construction of energy units of a
nuclear power plant 100% 100%
NPP Construction Supervision
EOOD Bulgaria
assessing the compliance of
investment projects and
exercising construction
supervision in design and
construction
100% 100%
NPP Service LTD Bulgaria repair of general and special
purpose machines and equipment 100% 100%
Interpriborservice OOD
(in bankruptcy) Bulgaria installation and maintenance of
automated systems 63.96% 63.96%
TPP Maritsa East 2 EAD Bulgaria generation of electricity and
thermal energy 100% 100%
Mini Maritsa – Iztok EAD Bulgaria coal extraction and sale 100% 100%
Electricity System Operator EAD Bulgaria transmission of electricity 100% 100%
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Company Country of
incorporation Main activity
31 December
2024 г.
31 December
2023
% %
ESO Engineering EOOD Bulgaria
construction of technologies and
projects for energy facilities and
project management
100% 100%
ESO Project EOOD Bulgaria
conceptual projects in
accordance with the Spatial
Development Act, consulting
activity
100% 100%
ECO Charge EAD Bulgaria
construction and operation of
electric and hydrogen refueling
systems
100% -
National Energy Operator EAD Bulgaria
Construction and operation of
systems for storage and
utilization of electricity from
RES
100% 100%
Minproekt EAD Bulgaria Design, research and
development engineering 100% 100%
Joint ventures
ICGB AD Bulgaria construction and operation of a
gas transmission system 50% 50%
South Stream Bulgaria AD Bulgaria construction and operation of a
gas transmission system 50% 50%
Southeast Electricity Network
Coordination Center (SEleNe CC) Greece
Regional Security Coordinator for
Southeast Europe with the purpose
of maintaining the electricity
system
33% 33%
Gastrade S.A. Greece construction of a liquefied natural
gas terminal 20% 20%
Associated companies
ContourGlobal Maritsa Iztok 3 AD Bulgaria generation of electricity 27% 27%
ContourGlobal Operations
Bulgaria AD Bulgaria
operation and maintenance of a
thermal power plant 27% 27%
ZAD Energy AD Bulgaria insurance and reinsurance 48.08% 48.08%
Allianz Bulgaria Pension Company
AD Bulgaria Pensions 34% 34%
Hydro Power Company Gorna Arda
AD Bulgaria
construction of hydroelectric
power plants 24% 24%
5.2. Information under Art. 10, paragraph 1 (d) of Directive 2004/25/EC of the European Parliament and
of the Council of 21 April 2004
BEH EAD has no issued securities with special rights of control.
5.3. Information under Art. 10, paragraph 1 (f) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
There are no restrictions on voting rights.
Corporate Governance Statement
31 December 2024
7
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Company Country of
incorporation Main activity
31 December
2024 г.
31 December
2023
% %
ESO Engineering EOOD Bulgaria
construction of technologies and
projects for energy facilities and
project management
100% 100%
ESO Project EOOD Bulgaria
conceptual projects in
accordance with the Spatial
Development Act, consulting
activity
100% 100%
ECO Charge EAD Bulgaria
construction and operation of
electric and hydrogen refueling
systems
100% -
National Energy Operator EAD Bulgaria
Construction and operation of
systems for storage and
utilization of electricity from
RES
100% 100%
Minproekt EAD Bulgaria Design, research and
development engineering 100% 100%
Joint ventures
ICGB AD Bulgaria construction and operation of a
gas transmission system 50% 50%
South Stream Bulgaria AD Bulgaria construction and operation of a
gas transmission system 50% 50%
Southeast Electricity Network
Coordination Center (SEleNe CC) Greece
Regional Security Coordinator for
Southeast Europe with the purpose
of maintaining the electricity
system
33% 33%
Gastrade S.A. Greece construction of a liquefied natural
gas terminal 20% 20%
Associated companies
ContourGlobal Maritsa Iztok 3 AD Bulgaria generation of electricity 27% 27%
ContourGlobal Operations
Bulgaria AD Bulgaria
operation and maintenance of a
thermal power plant 27% 27%
ZAD Energy AD Bulgaria insurance and reinsurance 48.08% 48.08%
Allianz Bulgaria Pension Company
AD Bulgaria Pensions 34% 34%
Hydro Power Company Gorna Arda
AD Bulgaria
construction of hydroelectric
power plants 24% 24%
5.2. Information under Art. 10, paragraph 1 (d) of Directive 2004/25/EC of the European Parliament and
of the Council of 21 April 2004
BEH EAD has no issued securities with special rights of control.
5.3. Information under Art. 10, paragraph 1 (f) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
There are no restrictions on voting rights.
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
5.4. Information under Art. 10, paragraph 1 (h) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
The rules that regulate the appointment and replacement of the board members are described in item 5.
The Sole Owner of the Capital amends and supplements the Company’s Articles of Association.
5.5. Information under Art. 10, paragraph 1 (i) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
The powers of the members of the Board of Directors are described in item 6.
6. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 5 of POSA
The governing bodies of BEH EAD are:
- The Sole Owner of the Capital;
- The Board of Directors.
BEH EAD has appointed an Audit committee under Art. 107 of the Independent Financial Audit and Assurance of
Sustainability Reporting Act.
6.1. Sole Owner of the Capital
6.1.1. Status
The Sole Owner of the Capital of BEH EAD is the Republic of Bulgaria. The State’s rights as the Sole Owner of the
Capital are exercised by the Minister of Energy, who has the capacity of Principal of the Company, and is the body
empowered to make all decisions falling within the competence of the Sole Owner of the Capital according to the law
or to the Articles of Association.
6.1.2. Competence
(1) The Sole Owner of the Capital has all the rights of а shareholder of the BEH EAD according to the law and
to the Articles of Association. The Sole Owner of the Capital shall decide on all matters which the law places
within the competence of the General Meeting of the Shareholders.
(2) The Sole Owner of the Capital:
- Amends and supplements the Articles of Association of BEH EAD;
- increases and decreases the capital of the Company;
- transforms or terminates the Company;
- selects and dismisses the members of the Board of Directors and determines their remuneration;
- selects and dismisses the chartered accountant;
- approves the annual financial statements, following the attestation of the appointed chartered
accountant;
- decides on issuing bonds, distributing profits, replenishing the reserve fund and paying out dividends;
- appoints the liquidators upon termination of the Company, except in the event of insolvency, and enters
into contracts with them;
- discharges the members of the Board of Directors from liability;
- makes decisions on the opening, transfer or closure of branches of the Company;
- determines the amount of the compensation for the owners of nationalized properties, which they
receive in the cases set forth in Art.18 of the Transformation and Privatization of Governmental and
Municipal Enterprises Act (repealed) and the Compensation of Owners of Nationalized Properties Act;
Corporate Governance Statement
31 December 2024
8
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
5.4. Information under Art. 10, paragraph 1 (h) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
The rules that regulate the appointment and replacement of the board members are described in item 5.
The Sole Owner of the Capital amends and supplements the Company’s Articles of Association.
5.5. Information under Art. 10, paragraph 1 (i) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.
The powers of the members of the Board of Directors are described in item 6.
6. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 5 of POSA
The governing bodies of BEH EAD are:
- The Sole Owner of the Capital;
- The Board of Directors.
BEH EAD has appointed an Audit committee under Art. 107 of the Independent Financial Audit and Assurance of
Sustainability Reporting Act.
6.1. Sole Owner of the Capital
6.1.1. Status
The Sole Owner of the Capital of BEH EAD is the Republic of Bulgaria. The State’s rights as the Sole Owner of the
Capital are exercised by the Minister of Energy, who has the capacity of Principal of the Company, and is the body
empowered to make all decisions falling within the competence of the Sole Owner of the Capital according to the law
or to the Articles of Association.
6.1.2. Competence
(1) The Sole Owner of the Capital has all the rights of а shareholder of the BEH EAD according to the law and
to the Articles of Association. The Sole Owner of the Capital shall decide on all matters which the law places
within the competence of the General Meeting of the Shareholders.
(2) The Sole Owner of the Capital:
- Amends and supplements the Articles of Association of BEH EAD;
- increases and decreases the capital of the Company;
- transforms or terminates the Company;
- selects and dismisses the members of the Board of Directors and determines their remuneration;
- selects and dismisses the chartered accountant;
- approves the annual financial statements, following the attestation of the appointed chartered
accountant;
- decides on issuing bonds, distributing profits, replenishing the reserve fund and paying out dividends;
- appoints the liquidators upon termination of the Company, except in the event of insolvency, and enters
into contracts with them;
- discharges the members of the Board of Directors from liability;
- makes decisions on the opening, transfer or closure of branches of the Company;
- determines the amount of the compensation for the owners of nationalized properties, which they
receive in the cases set forth in Art.18 of the Transformation and Privatization of Governmental and
Municipal Enterprises Act (repealed) and the Compensation of Owners of Nationalized Properties Act;
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
9
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- approves decisions of the Board of Directors for: disposition transactions with fixed assets and for
establishment of real rights over real estate where the value exceeds the lower value of BGN 500
thousand or 5% of the total book value of fixed assets as of 31 December of the previous year; for use
or rental of real estate or assets, the book value of which exceeds 5% of the total book value of fixed
assets as of 31 December of the previous year; for acquisition of shares and / or stocks in other
companies, as well as for disposal of shares and / or stocks – owned by the Company in other companies;
to obtain loans or credits; lending; for concluding contracts for joint activity (the so-called joint venture);
to assume bill of exchange obligations; to secure the obligations of the Company by establishing a
mortgage or pledge on fixed assets of the Company; to provide collateral in favor of third parties; for
the conclusion of a court or out-of-court agreement, which recognizes the obligations of the Company
or forgives the receivables of the Company from third parties; for significant changes in the activity of
the Company; for significant organizational changes, for long-term cooperation of essential importance
for the Company, as well as for the termination of such cooperation;
- approves the selection of an insurer when concluding compulsory insurance contracts;
- authorizes the conclusion of contracts for sale, exchange and renting of fixed assets, as well as the
establishment of a right in rem through direct negotiation, where the starting price is defined by an
independent appraiser;
- authorizes the sale or exchange of houses, studios, offices and garages of the Company’s employees;
- approves the Company’s business program prepared by the Board of Directors;
- makes decisions on the distribution of the Company’s profit and its payment, and on the payment of
royalties to the members of the Board of Directors, as well as determines their amount.
- elects, authorizes and dismisses the Company’s procurator(s), determines the scope of their
representative power, concludes the contract(s) for procuration with notarized certification of
signatures.
- Also decides on other matters, provided for by the law and the Articles of Association.
6.1.3. Decision-making
(1) The Sole Owner of the Capital shall make decisions within the competence of an ordinary annual
General Meeting once а year, and within the competence of an extraordinary General Meeting as necessary.
No invitation is announced in the Commercial Register and the Register of Non-Profit Legal Entities by
the Sole Owner of the Capital on the exercise of the competence of the General Meeting. The Sole Owner
of the Capital may make decisions within the competence of the General Meeting at any time in writing.
(2) The Board of Directors fulfills its obligations under Art. 223, respectively under Art. 251 of the
Commerce Act, by sending a written application to the Sole Owner of the Capital regarding the necessity,
respectively the readiness, to make decisions by the Sole Owner of the Capital. The written application
shall contain proposals concerning the matters on which the Board of Directors proposes to the Sole Owner
of the Capital to make decisions. The proposals do not bind the Sole Owner of the Capital to consider and
decide on the issues raised, and do not limit them with respect to the range of issues on which they can
make decisions.
(3) For the decisions of the Sole owner of the Capital, a protocol is drawn up in writing and it is signed by
the Principal of BEH EAD.
(4) If the Sole Owner of the Capital wishes the members of the Board of Directors to be present during
the decision-making process, they are obliged to do so. The Sole Owner of the Capital may require from
the present members of the Board of Directors or from other persons invited by them, to countersign the
record with the decisions made by the Sole Owner of the Capital.
Corporate Governance Statement
31 December 2024
9
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- approves decisions of the Board of Directors for: disposition transactions with fixed assets and for
establishment of real rights over real estate where the value exceeds the lower value of BGN 500
thousand or 5% of the total book value of fixed assets as of 31 December of the previous year; for use
or rental of real estate or assets, the book value of which exceeds 5% of the total book value of fixed
assets as of 31 December of the previous year; for acquisition of shares and / or stocks in other
companies, as well as for disposal of shares and / or stocks – owned by the Company in other companies;
to obtain loans or credits; lending; for concluding contracts for joint activity (the so-called joint venture);
to assume bill of exchange obligations; to secure the obligations of the Company by establishing a
mortgage or pledge on fixed assets of the Company; to provide collateral in favor of third parties; for
the conclusion of a court or out-of-court agreement, which recognizes the obligations of the Company
or forgives the receivables of the Company from third parties; for significant changes in the activity of
the Company; for significant organizational changes, for long-term cooperation of essential importance
for the Company, as well as for the termination of such cooperation;
- approves the selection of an insurer when concluding compulsory insurance contracts;
- authorizes the conclusion of contracts for sale, exchange and renting of fixed assets, as well as the
establishment of a right in rem through direct negotiation, where the starting price is defined by an
independent appraiser;
- authorizes the sale or exchange of houses, studios, offices and garages of the Company’s employees;
- approves the Company’s business program prepared by the Board of Directors;
- makes decisions on the distribution of the Company’s profit and its payment, and on the payment of
royalties to the members of the Board of Directors, as well as determines their amount.
- elects, authorizes and dismisses the Company’s procurator(s), determines the scope of their
representative power, concludes the contract(s) for procuration with notarized certification of
signatures.
- Also decides on other matters, provided for by the law and the Articles of Association.
6.1.3. Decision-making
(1) The Sole Owner of the Capital shall make decisions within the competence of an ordinary annual
General Meeting once а year, and within the competence of an extraordinary General Meeting as necessary.
No invitation is announced in the Commercial Register and the Register of Non-Profit Legal Entities by
the Sole Owner of the Capital on the exercise of the competence of the General Meeting. The Sole Owner
of the Capital may make decisions within the competence of the General Meeting at any time in writing.
(2) The Board of Directors fulfills its obligations under Art. 223, respectively under Art. 251 of the
Commerce Act, by sending a written application to the Sole Owner of the Capital regarding the necessity,
respectively the readiness, to make decisions by the Sole Owner of the Capital. The written application
shall contain proposals concerning the matters on which the Board of Directors proposes to the Sole Owner
of the Capital to make decisions. The proposals do not bind the Sole Owner of the Capital to consider and
decide on the issues raised, and do not limit them with respect to the range of issues on which they can
make decisions.
(3) For the decisions of the Sole owner of the Capital, a protocol is drawn up in writing and it is signed by
the Principal of BEH EAD.
(4) If the Sole Owner of the Capital wishes the members of the Board of Directors to be present during
the decision-making process, they are obliged to do so. The Sole Owner of the Capital may require from
the present members of the Board of Directors or from other persons invited by them, to countersign the
record with the decisions made by the Sole Owner of the Capital.
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
10
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
6.2. Board of Directors of BEH EAD
6.2.1. Composition
As of 31.12.2024, BEH EAD is managed by a Board of Directors comprising the following members::
Veselina Lachezarova Kanatova-Buchkova
Galina Tsvetanova Todorova
Valentin Aleksiev Nikolov
Kalin Boyanov Filipov
Ivo Ivanov Todorov
Veselina Lachezarova Kanatova-Buchkova was elected Chairperson of the Board of Directors and Valentin Aleksiev
Nikolov and Galina Tsvetanova Todorova were elected to represent the Company and were appointed as Executive
Directors at a meeting of the Board of Directors.
As of the date of issuance of the Corporate Governance Statement, the current Board of Directors of BEH EAD,
appointed by the relevant protocol decisions of the Minister of Energy, is as follows:
Veselina Lachezarova Kanatova-Buchkova
Diyan Atanasov Ivanov
Valentin Aleksiev Nikolov
Kalin Boyanov Filipov
Ivo Ivanov Todorov
Veselina Lachezarova Kanatova-Buchkova was elected Chairperson of the Board of Directors, and Valentin Aleksiev
Nikolov, who was appointed Executive Director at a meeting of the Board of Directors, was elected to represent the
Company.
6.2.2. Status
(1) The Board of Directors reports to the Sole Owner of the Capital for the management of the Company.
It holds meetings depending on the necessity, but at least once every three months.
(2) The Board of Directors consists of at least five members – natural persons, who are elected and
appointed after holding a competition, under conditions and in accordance with the procedure, regulated in
the Regulations for implementation of the Public Enterprises Act.
(3) The Board of Directors elects one or two of its members as executive members and the rest are non -
executive members. The term of the Board of Directors has а duration of 3 (three) years, as of the entry of
the Board of Directors in the Commercial Register and the Register of Non-Profit Legal Entities, with the
Board of Directors continuing to exercise its competence until а new Board of Directors is entered even
after its term has expired.
(4) A member of the Board of Directors of the Company can be a Bulgarian citizen or a citizen of the
European Union, a member-state under the Agreement on the European Economic Area or the
Confederation of Switzerland, who:
- Has a university degree;
- Has at least 5 years of professional experience;
- Is not placed under guardianship;
- Has not been convicted of a general criminal offense;
- Is not deprived of the right to hold the respective office;
- Is not declared insolvent as a sole trader or a general partner in a company, which has been declared
insolvent, if there are unsatisfied creditors left;
Corporate Governance Statement
31 December 2024
10
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
6.2. Board of Directors of BEH EAD
6.2.1. Composition
As of 31.12.2024, BEH EAD is managed by a Board of Directors comprising the following members::
Veselina Lachezarova Kanatova-Buchkova
Galina Tsvetanova Todorova
Valentin Aleksiev Nikolov
Kalin Boyanov Filipov
Ivo Ivanov Todorov
Veselina Lachezarova Kanatova-Buchkova was elected Chairperson of the Board of Directors and Valentin Aleksiev
Nikolov and Galina Tsvetanova Todorova were elected to represent the Company and were appointed as Executive
Directors at a meeting of the Board of Directors.
As of the date of issuance of the Corporate Governance Statement, the current Board of Directors of BEH EAD,
appointed by the relevant protocol decisions of the Minister of Energy, is as follows:
Veselina Lachezarova Kanatova-Buchkova
Diyan Atanasov Ivanov
Valentin Aleksiev Nikolov
Kalin Boyanov Filipov
Ivo Ivanov Todorov
Veselina Lachezarova Kanatova-Buchkova was elected Chairperson of the Board of Directors, and Valentin Aleksiev
Nikolov, who was appointed Executive Director at a meeting of the Board of Directors, was elected to represent the
Company.
6.2.2. Status
(1) The Board of Directors reports to the Sole Owner of the Capital for the management of the Company.
It holds meetings depending on the necessity, but at least once every three months.
(2) The Board of Directors consists of at least five members – natural persons, who are elected and
appointed after holding a competition, under conditions and in accordance with the procedure, regulated in
the Regulations for implementation of the Public Enterprises Act.
(3) The Board of Directors elects one or two of its members as executive members and the rest are non -
executive members. The term of the Board of Directors has а duration of 3 (three) years, as of the entry of
the Board of Directors in the Commercial Register and the Register of Non-Profit Legal Entities, with the
Board of Directors continuing to exercise its competence until а new Board of Directors is entered even
after its term has expired.
(4) A member of the Board of Directors of the Company can be a Bulgarian citizen or a citizen of the
European Union, a member-state under the Agreement on the European Economic Area or the
Confederation of Switzerland, who:
- Has a university degree;
- Has at least 5 years of professional experience;
- Is not placed under guardianship;
- Has not been convicted of a general criminal offense;
- Is not deprived of the right to hold the respective office;
- Is not declared insolvent as a sole trader or a general partner in a company, which has been declared
insolvent, if there are unsatisfied creditors left;
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
11
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- Has not been а member of an executive or supervisory body, respectively cooperative, terminated
due to insolvency in the last two years before the appointment, if there are unsatisfied creditors left;
- Is not a husband/wife or a person in de facto cohabitation, relative in a straight line, or in a collateral
line up to the fourth degree inclusive, and by matchmaking - up to the second degree inclusive, of a
manager or a member of a collective body for management and control of this public enterprise ;
- Does not hold a senior public office under Art. 6, para. 1, items 1-38 and 41-45 of the Counteracting
Corruption and on the Forfeiture of Illegally Acquired Property Act, is also not a member of a
political office or a municipal secretary;
- Does not perform commercial transactions similar to the Company’s activity on its own behalf or
on the behalf of a third party.
- Is not a partner in a general partnership, limited partnership companies and limited liability
companies, when it performs an activity similar to that of the Company;
- Is not a director or member of an executive or supervisory body of another public company.
(5) Executive members of the boards of directors cannot be persons who work under an employment
contract or under an official legal relationship.
(6) The Company may have one or two procurators, for which people who meet the above requirements
may be chosen. The procurators are assigned and empowered by the Sole Owner of the Capital of the
Company. The contracts with the procurator(s) are signed by the Sole Owner of the Capital.
6.2.3. Functions
The Board of Directors shall manage the Company and supervise the activities of the Executive Director(s), including
with respect to compliance with the Policies. It shall perform all functions and decide on all matters which are not
within the exclusive competence of the Sole Owner of the Capital by virtue of the law or the Articles of Association.
The Board of Directors shall adopt Regulations for its operation.
The Board of Directors may establish special committees comprising its members, such as remuneration or risk
management committees. The committees prepare decisions to be adopted by the Board of Directors. The decision -
making powers are not delegated to the committees themselves. The committees shall be chaired by an independent
member of the Board.
The Board of Directors conducts annual self-assessments of its performance and effectiveness, which are presented
to the body, exercising the rights of the State and the Agency for Public Companies and Control.
6.2.4. Competence
(1) The Board of Directors shall exercise all the powers of the Board of Directors in accordance with the
law and the Articles of Association of BEH EAD.
(2) The Board of Directors:
- organizes, manages and monitors the entire activity of BEH EAD;
- prepares a business program of BEH EAD for the whole term and for each year separately and ensures
its implementation;
- implements the investment policy of the Company and decides on the acquisition of property and other
real estate rights;
- settles the issues related to the movement and the marketing of the equity securities of BEH EAD, the
bonds and the securities in commercial circulation, which are not of the exclusive competence of the
Sole Owner of the Capital, or which have been delegated to it by the principal;
- elects one or two of its members as executive directors and authorizes them to manage and represent
the Company before third parties. In the event that two Executive Directors are elected, they shall
represent the Company in a manner determined by the Board of Directors.
- makes unanimous decisions on all transactions set forth in Art. 236, para. 2 of the Commerce Act;
Corporate Governance Statement
31 December 2024
11
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- Has not been а member of an executive or supervisory body, respectively cooperative, terminated
due to insolvency in the last two years before the appointment, if there are unsatisfied creditors left;
- Is not a husband/wife or a person in de facto cohabitation, relative in a straight line, or in a collateral
line up to the fourth degree inclusive, and by matchmaking - up to the second degree inclusive, of a
manager or a member of a collective body for management and control of this public enterprise ;
- Does not hold a senior public office under Art. 6, para. 1, items 1-38 and 41-45 of the Counteracting
Corruption and on the Forfeiture of Illegally Acquired Property Act, is also not a member of a
political office or a municipal secretary;
- Does not perform commercial transactions similar to the Company’s activity on its own behalf or
on the behalf of a third party.
- Is not a partner in a general partnership, limited partnership companies and limited liability
companies, when it performs an activity similar to that of the Company;
- Is not a director or member of an executive or supervisory body of another public company.
(5) Executive members of the boards of directors cannot be persons who work under an employment
contract or under an official legal relationship.
(6) The Company may have one or two procurators, for which people who meet the above requirements
may be chosen. The procurators are assigned and empowered by the Sole Owner of the Capital of the
Company. The contracts with the procurator(s) are signed by the Sole Owner of the Capital.
6.2.3. Functions
The Board of Directors shall manage the Company and supervise the activities of the Executive Director(s), including
with respect to compliance with the Policies. It shall perform all functions and decide on all matters which are not
within the exclusive competence of the Sole Owner of the Capital by virtue of the law or the Articles of Association.
The Board of Directors shall adopt Regulations for its operation.
The Board of Directors may establish special committees comprising its members, such as remuneration or risk
management committees. The committees prepare decisions to be adopted by the Board of Directors. The decision -
making powers are not delegated to the committees themselves. The committees shall be chaired by an independent
member of the Board.
The Board of Directors conducts annual self-assessments of its performance and effectiveness, which are presented
to the body, exercising the rights of the State and the Agency for Public Companies and Control.
6.2.4. Competence
(1) The Board of Directors shall exercise all the powers of the Board of Directors in accordance with the
law and the Articles of Association of BEH EAD.
(2) The Board of Directors:
- organizes, manages and monitors the entire activity of BEH EAD;
- prepares a business program of BEH EAD for the whole term and for each year separately and ensures
its implementation;
- implements the investment policy of the Company and decides on the acquisition of property and other
real estate rights;
- settles the issues related to the movement and the marketing of the equity securities of BEH EAD, the
bonds and the securities in commercial circulation, which are not of the exclusive competence of the
Sole Owner of the Capital, or which have been delegated to it by the principal;
- elects one or two of its members as executive directors and authorizes them to manage and represent
the Company before third parties. In the event that two Executive Directors are elected, they shall
represent the Company in a manner determined by the Board of Directors.
- makes unanimous decisions on all transactions set forth in Art. 236, para. 2 of the Commerce Act;
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
12
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- adopts Corporate Governance Policy, Financial and Accounting Policy, Information Technology
Policy, Human Resource Management Policy, Investment Management and Projects Policy, Public
Procurement Policy (including Policy for Conducting Tenders, Competitions and Direct Contracts for
the Supply of Goods and Delivery of Works and Services), Policy on Tenders, Competitions and Direct
Contracts for Sale, Exchange and Leasing of Fixed Assets, Risk Management and Internal Audit Policy,
and other policies that are mandatory for the Company and its subsidiaries; it is also responsible for
implementing those policies;
- makes proposals to the principal for resolving issues, which are within the competence of the Sole
Owner of the Capital, and decides on all other issues stipulated to be resolved by the Board of Directors
in the current Articles of Association..
(3) With а prior written approval of the Principal, the Board of Directors may change the Executive Director
at any time, and replace him/her with another member of the Board of Directors.
6.2.5. Contracts with members of the Board of Directors of BEH EAD, Remunerations and Expenses
(1) Each member of the Board of Directors concludes a management contract with the Sole Owner of the
Capital. The contract is concluded until the end of the term of the Board of Directors and contains the rights
and obligations of the parties, the amount of remuneration and the method of its payment, the liability of
the parties in case of default, the grounds for termination of the contract, and the type and amount of the
guarantee, which the members provide for their management, and the amount of the penalty for early
termination of the contract not through the fault of the member of the Board of Directors, as well as the
relations between the parties in the period from the termination of the contract to the deletion of the released
member of the Board of Directors from the Commercial Register and the Register of Non -Profit Legal
Entities.
The members of the Board of Directors receive remuneration determined in terms of amount and method
of payment by the Sole Owner of the Capital in compliance with the current regulations
(3) The members of the Board of Directors must provide a guarantee for their management in the amount
of not less than three monthly gross remunerations, determined by the Sole Owner of the Capital. The
guarantee given shall be returned after termination of the contract, and following the decision of the Sole
Owner of the Company for discharge from responsibility. When the guarantee was paid in cash, the interest
on the paid amount are subject to reimbursement as well.
In case of need of business trips, the members of the Board of Directors are sent on а mission abroad by
the Minister of Energy under conditions established by the Minister, pursuant to the regulatory framework
in force, and for those in Bulgaria – by the Executive Director (the Executive Directors) (including if the
Executive Director (the Executive Directors) is/are sent on а mission alone at the expense of the Company.
When conducting meetings of the bodies of the Company, the expenses for holding the meeting and for
seconding the members of the Board of Directors, if the venue differs from the place of residence of a
member of the Board of Directors, are borne by the Company.
6.2.6. Statute of the chief (sole) executive member of the Board of Directors.
(1) The Board of Directors entrusts the Executive Director(s) to manage and represent the Company. The
non-executive members of the Board of Directors control the activities of the Executive Director/ Executive
Directors.
The sole Executive Director represents the Company individually and is entitled to perform all activities
and transactions related to the Company’s activities, as well as to draw up and sign documents on behalf of
the Company and to authorize other persons to perform single activities and transactions.
(3) The Executive Director organizes the activities of the Company in compliance with the law, the Articles
of Association, the decisions of the Sole Owner of the Capital, the Policies and the Decisions of the Board
of Directors. He/she undertakes the operational management of the Company activities, concludes and
terminates the employment contracts and other contracts of the employees and partners of the Company,
and is responsible for the accountability and the archives of the Company. The Executive Direc tor also
decides on all other matters which are not of the exclusive competence of the Sole Owner of the Capital or
of the Board of Directors, according to the law or these Articles of Association, or as delegated to him/her
by a decision of the Sole Owner of the Capital.
Corporate Governance Statement
31 December 2024
12
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- adopts Corporate Governance Policy, Financial and Accounting Policy, Information Technology
Policy, Human Resource Management Policy, Investment Management and Projects Policy, Public
Procurement Policy (including Policy for Conducting Tenders, Competitions and Direct Contracts for
the Supply of Goods and Delivery of Works and Services), Policy on Tenders, Competitions and Direct
Contracts for Sale, Exchange and Leasing of Fixed Assets, Risk Management and Internal Audit Policy,
and other policies that are mandatory for the Company and its subsidiaries; it is also responsible for
implementing those policies;
- makes proposals to the principal for resolving issues, which are within the competence of the Sole
Owner of the Capital, and decides on all other issues stipulated to be resolved by the Board of Directors
in the current Articles of Association..
(3) With а prior written approval of the Principal, the Board of Directors may change the Executive Director
at any time, and replace him/her with another member of the Board of Directors.
6.2.5. Contracts with members of the Board of Directors of BEH EAD, Remunerations and Expenses
(1) Each member of the Board of Directors concludes a management contract with the Sole Owner of the
Capital. The contract is concluded until the end of the term of the Board of Directors and contains the rights
and obligations of the parties, the amount of remuneration and the method of its payment, the liability of
the parties in case of default, the grounds for termination of the contract, and the type and amount of the
guarantee, which the members provide for their management, and the amount of the penalty for early
termination of the contract not through the fault of the member of the Board of Directors, as well as the
relations between the parties in the period from the termination of the contract to the deletion of the released
member of the Board of Directors from the Commercial Register and the Register of Non -Profit Legal
Entities.
The members of the Board of Directors receive remuneration determined in terms of amount and method
of payment by the Sole Owner of the Capital in compliance with the current regulations
(3) The members of the Board of Directors must provide a guarantee for their management in the amount
of not less than three monthly gross remunerations, determined by the Sole Owner of the Capital. The
guarantee given shall be returned after termination of the contract, and following the decision of the Sole
Owner of the Company for discharge from responsibility. When the guarantee was paid in cash, the interest
on the paid amount are subject to reimbursement as well.
In case of need of business trips, the members of the Board of Directors are sent on а mission abroad by
the Minister of Energy under conditions established by the Minister, pursuant to the regulatory framework
in force, and for those in Bulgaria – by the Executive Director (the Executive Directors) (including if the
Executive Director (the Executive Directors) is/are sent on а mission alone at the expense of the Company.
When conducting meetings of the bodies of the Company, the expenses for holding the meeting and for
seconding the members of the Board of Directors, if the venue differs from the place of residence of a
member of the Board of Directors, are borne by the Company.
6.2.6. Statute of the chief (sole) executive member of the Board of Directors.
(1) The Board of Directors entrusts the Executive Director(s) to manage and represent the Company. The
non-executive members of the Board of Directors control the activities of the Executive Director/ Executive
Directors.
The sole Executive Director represents the Company individually and is entitled to perform all activities
and transactions related to the Company’s activities, as well as to draw up and sign documents on behalf of
the Company and to authorize other persons to perform single activities and transactions.
(3) The Executive Director organizes the activities of the Company in compliance with the law, the Articles
of Association, the decisions of the Sole Owner of the Capital, the Policies and the Decisions of the Board
of Directors. He/she undertakes the operational management of the Company activities, concludes and
terminates the employment contracts and other contracts of the employees and partners of the Company,
and is responsible for the accountability and the archives of the Company. The Executive Direc tor also
decides on all other matters which are not of the exclusive competence of the Sole Owner of the Capital or
of the Board of Directors, according to the law or these Articles of Association, or as delegated to him/her
by a decision of the Sole Owner of the Capital.
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
13
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
(4) The management contract with the Executive Director, a member of the Board of Directors, is signed
by the Chairman or, respectively, by the Deputy Chairman of the Board of Directors. The Executive
Director signs the contracts with the other members of the Board of Directors, unless the representative of
the Sole Owner of the Capital signs such contracts personally.
6.2.7. Representation of BEH EAD
The company shall be represented before third parties by the Executive Director and, where there is more than one,
they shall represent the company in such manner as the Board of Directors may decide.
6.3. Audit Committee
6.3.1. Composition
As of 31.12.2024, the composition of the Audit Committee of BEH EAD, elected with a mandate until 02.02.2027,
according to the protocols of the Minister of Energy, is as follows:
Viktor Andreev Videnov – Chairman – elected by Protocol No. E-РД-21-23 of 08.08.2024.
Vanya Doneva Georgieva – member – re-elected by Protocol No. E-РД-21-5 of 02.02.2024.
Stanislava Plamenova Manolova – member – elected by Protocol No. E-РД-21-30 of 27.09.2024.
Status
The committee is a specialized, supervisory, consultative body. The Members of the Committee are appointed by the
Minister of Energy of the Republic of Bulgaria in his/her capacity as the Sole Owner of the Capital of BEH EAD upon
suggestion of the Board of Directors of BEH EAD. The committee consists of 3 to 5 members, one of them being a
Chairman.
6.3.2. Remuneration
The remuneration of the members of the audit committee is determined by the Minister of Energy and is at the expense
of BEH EAD. By Protocol No. Е-РД-21-7 of 26.02.2021, the Minister of Energy determines the remuneration of the
members of the Audit Committee as follows:
- A member of the Audit Committee receives 80% of the monthly remuneration of a member of the Board of
Directors of the Company.
- The chairman of the Audit Committee receives 85% of the monthly remuneration of a member of the Board
of Directors of the Company.
By Protocol No.Е-РД-21-25 of 29.08.2017, the Minister of Energy has approved the Statute of the Audit Committee
of BEH EAD.
6.3.3. Duties and authority
(1) The Audit Committee carries out its activities in accordance with the requirements of the Independent
Financial Audit and Assurance of Sustainability Reporting Act, Regulation (ЕO) No. 537/2014 of the
European Parliament and of the Council of 16 April 2014 on specific requirements regarding statutory audit
of public-interest entities and repealing Commission Decision 2005/909/EC (Regulation (EU) No
537/2014), Directive 2014/56 and Directive 2006/43 of the European Parliament and of the Council and
this Statute.
(2) The Committee has the following authority:
- to monitor the financial reporting process and make recommendations or suggestions to ensure its
effectiveness;
- to review and upon a discretion to express opinion on the accounting policy of the holding and its
implementation upon the financial reporting;
Corporate Governance Statement
31 December 2024
13
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
(4) The management contract with the Executive Director, a member of the Board of Directors, is signed
by the Chairman or, respectively, by the Deputy Chairman of the Board of Directors. The Executive
Director signs the contracts with the other members of the Board of Directors, unless the representative of
the Sole Owner of the Capital signs such contracts personally.
6.2.7. Representation of BEH EAD
The company shall be represented before third parties by the Executive Director and, where there is more than one,
they shall represent the company in such manner as the Board of Directors may decide.
6.3. Audit Committee
6.3.1. Composition
As of 31.12.2024, the composition of the Audit Committee of BEH EAD, elected with a mandate until 02.02.2027,
according to the protocols of the Minister of Energy, is as follows:
Viktor Andreev Videnov – Chairman – elected by Protocol No. E-РД-21-23 of 08.08.2024.
Vanya Doneva Georgieva – member – re-elected by Protocol No. E-РД-21-5 of 02.02.2024.
Stanislava Plamenova Manolova – member – elected by Protocol No. E-РД-21-30 of 27.09.2024.
Status
The committee is a specialized, supervisory, consultative body. The Members of the Committee are appointed by the
Minister of Energy of the Republic of Bulgaria in his/her capacity as the Sole Owner of the Capital of BEH EAD upon
suggestion of the Board of Directors of BEH EAD. The committee consists of 3 to 5 members, one of them being a
Chairman.
6.3.2. Remuneration
The remuneration of the members of the audit committee is determined by the Minister of Energy and is at the expense
of BEH EAD. By Protocol No. Е-РД-21-7 of 26.02.2021, the Minister of Energy determines the remuneration of the
members of the Audit Committee as follows:
- A member of the Audit Committee receives 80% of the monthly remuneration of a member of the Board of
Directors of the Company.
- The chairman of the Audit Committee receives 85% of the monthly remuneration of a member of the Board
of Directors of the Company.
By Protocol No.Е-РД-21-25 of 29.08.2017, the Minister of Energy has approved the Statute of the Audit Committee
of BEH EAD.
6.3.3. Duties and authority
(1) The Audit Committee carries out its activities in accordance with the requirements of the Independent
Financial Audit and Assurance of Sustainability Reporting Act, Regulation (ЕO) No. 537/2014 of the
European Parliament and of the Council of 16 April 2014 on specific requirements regarding statutory audit
of public-interest entities and repealing Commission Decision 2005/909/EC (Regulation (EU) No
537/2014), Directive 2014/56 and Directive 2006/43 of the European Parliament and of the Council and
this Statute.
(2) The Committee has the following authority:
- to monitor the financial reporting process and make recommendations or suggestions to ensure its
effectiveness;
- to review and upon a discretion to express opinion on the accounting policy of the holding and its
implementation upon the financial reporting;
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
14
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- to monitor the effectiveness of the adopted current controls upon the monthly review of the financial
statement of BEH EAD;
- to observe the due and reliable submission of financial information from the subsidiary companies upon
the drawing up of the annual consolidated financial statement of BEH EAD;
- to monitor the effectiveness of the internal control system, of the risk management system and the
activity on internal audit with regard to the financial reporting at BEH EAD;
- to review and express opinion on the risk management strategy, the risk-register of the holding and the
annual report on the condition of the financial management and control system;
- to express opinion on the stature and membership of the internal audit unit and on the strategic and
annual plans for the internal audit activity;
- discusses and adopts the Annual report on the internal audit activity and if necessary, makes itself aware
of and provide opinions on individual audit reports from audit commitments made as well as on all
significant issues, related to the internal audit;
- to be in charge for the procedure on selection of the certified auditor, except for in the cases, when the
audited enterprise has a selection committee and recommends its appointment;
- to verify and monitor the independence of the statutory auditor and to make decisions in the cases
provided by the law, in accordance with the requirements of Chapters 6 and 7 of the Independent
Financial Audit Act, and with Art. 6 of Regulation (EU) No 537/2014, including the advisability of
providing services outside the audit under Art. 5 of the same Regulation;
- to supervise the statutory audit of annual and consolidated financial statements, including its
performance, taking into account the findings and conclusions of the Commission for Public Oversight
on Statutory Auditors regarding the application of Art. 26, para. 6 of Regulation (EU) No 537/2014;
- makes itself aware of the audit strategy and the audit plan of the statutory audit and expresses opinion
on them, by judging the arguments in support of important decisions and a choice made in the stage of
planning;
- to perform monitoring on the implementation of the audit plan by giving recommendations to the
Holding management and the auditors for elimination of difficulties.
- reviews the draft audit reports under Art. 59 and Art. 60 of the Independent Financial Audit and
Assurance of Sustainability Reporting Act and key audit matters identified, the findings made and the
audit opinion expressed, and forms an opinion on the statutory auditor's annual work which includes:
independence of the auditor; objectivity and professional skepticism; composition of the audit team;
findings from audits by the Commission for Public Oversight on Statutory Auditors; communication
and relationships with BEH EAD’s management. The annual opinion is formed on the basis of criteria
adopted by the Audit Committee and communicated in advance with the auditor;
- to discuss the additional auditor’s report (drawn up in accordance with Art. 11, item 2 of Regulation
(ЕU) No. 537/2014) and gives recommendations to the management of BEH EAD for removing the
significant weaknesses and failures, found in the report;
- for the purposes of coordinating the relations with the Audit Committees of the subsidiaries of the
Holding, the Committee is entitled, following the approval of the Board of Directors of BEH EAD:
- to request information from the Audit Committees of the subsidiaries in connection with the
performance of its activities and, if necessary, to inform the Board of Directors of BEH EAD
when it considers that there are facts and circumstances that are relevant for the activity of the
respective subsidiary;
- to carry out investigations within its powers in the respective subsidiaries of BEH EAD after
informing the management of BEH EAD and the management of the respective subsidiary. The
investigations may be carried out at the proposal of any member of the Committee. The decision
to conduct the investigation determines its term and subject, as well as the persons to conduct it.
Corporate Governance Statement
31 December 2024
14
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- to monitor the effectiveness of the adopted current controls upon the monthly review of the financial
statement of BEH EAD;
- to observe the due and reliable submission of financial information from the subsidiary companies upon
the drawing up of the annual consolidated financial statement of BEH EAD;
- to monitor the effectiveness of the internal control system, of the risk management system and the
activity on internal audit with regard to the financial reporting at BEH EAD;
- to review and express opinion on the risk management strategy, the risk-register of the holding and the
annual report on the condition of the financial management and control system;
- to express opinion on the stature and membership of the internal audit unit and on the strategic and
annual plans for the internal audit activity;
- discusses and adopts the Annual report on the internal audit activity and if necessary, makes itself aware
of and provide opinions on individual audit reports from audit commitments made as well as on all
significant issues, related to the internal audit;
- to be in charge for the procedure on selection of the certified auditor, except for in the cases, when the
audited enterprise has a selection committee and recommends its appointment;
- to verify and monitor the independence of the statutory auditor and to make decisions in the cases
provided by the law, in accordance with the requirements of Chapters 6 and 7 of the Independent
Financial Audit Act, and with Art. 6 of Regulation (EU) No 537/2014, including the advisability of
providing services outside the audit under Art. 5 of the same Regulation;
- to supervise the statutory audit of annual and consolidated financial statements, including its
performance, taking into account the findings and conclusions of the Commission for Public Oversight
on Statutory Auditors regarding the application of Art. 26, para. 6 of Regulation (EU) No 537/2014;
- makes itself aware of the audit strategy and the audit plan of the statutory audit and expresses opinion
on them, by judging the arguments in support of important decisions and a choice made in the stage of
planning;
- to perform monitoring on the implementation of the audit plan by giving recommendations to the
Holding management and the auditors for elimination of difficulties.
- reviews the draft audit reports under Art. 59 and Art. 60 of the Independent Financial Audit and
Assurance of Sustainability Reporting Act and key audit matters identified, the findings made and the
audit opinion expressed, and forms an opinion on the statutory auditor's annual work which includes:
independence of the auditor; objectivity and professional skepticism; composition of the audit team;
findings from audits by the Commission for Public Oversight on Statutory Auditors; communication
and relationships with BEH EAD’s management. The annual opinion is formed on the basis of criteria
adopted by the Audit Committee and communicated in advance with the auditor;
- to discuss the additional auditor’s report (drawn up in accordance with Art. 11, item 2 of Regulation
(ЕU) No. 537/2014) and gives recommendations to the management of BEH EAD for removing the
significant weaknesses and failures, found in the report;
- for the purposes of coordinating the relations with the Audit Committees of the subsidiaries of the
Holding, the Committee is entitled, following the approval of the Board of Directors of BEH EAD:
- to request information from the Audit Committees of the subsidiaries in connection with the
performance of its activities and, if necessary, to inform the Board of Directors of BEH EAD
when it considers that there are facts and circumstances that are relevant for the activity of the
respective subsidiary;
- to carry out investigations within its powers in the respective subsidiaries of BEH EAD after
informing the management of BEH EAD and the management of the respective subsidiary. The
investigations may be carried out at the proposal of any member of the Committee. The decision
to conduct the investigation determines its term and subject, as well as the persons to conduct it.
Bulgarian Energy Holding EAD
Corporate Governance Statement
31 December 2024
15
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
7. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 6 of POSA
As a public enterprise, BEH EAD complies with the provisions of the Public Enterprises Act and its bylaws, and does
not apply a deliberate Diversity Policy. The Board of Directors of BEH EAD is appointed by an official decision of
the Minister of Energy after conducting a competition, under the conditions and order provided for in the Rules on the
Implementation of the Public Enterprises Act, according to which the principles of publicity, tra nsparency, free and
loyal competition, equality and proportionality have to be complied with upon conduction of the competition
procedures, and no discrimination should be allowed.
Signed with electronic signature
VALENTIN NIKOLOV
EXECUTIVE DIRECTOR
BULGARIAN ENERGY HOLDING EAD
Corporate Governance Statement
31 December 2024
15
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
7. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 6 of POSA
As a public enterprise, BEH EAD complies with the provisions of the Public Enterprises Act and its bylaws, and does
not apply a deliberate Diversity Policy. The Board of Directors of BEH EAD is appointed by an official decision of
the Minister of Energy after conducting a competition, under the conditions and order provided for in the Rules on the
Implementation of the Public Enterprises Act, according to which the principles of publicity, tra nsparency, free and
loyal competition, equality and proportionality have to be complied with upon conduction of the competition
procedures, and no discrimination should be allowed.
Signed with electronic signature
VALENTIN NIKOLOV
EXECUTIVE DIRECTOR
BULGARIAN ENERGY HOLDING EAD
1
INDEPENDENT JOINT AUDITORS’ REPORT
To the sole shareholder of
Bulgarian Energy Holding EAD
Sofia, 16 Veslets Str.
Report on the Audit of the Separate Financial Statements
Opinion
We have audited the separate financial statements of Bulgarian Energy Holding EAD („the Company“) , which
comprise the separate statement of financial position as at 31 December 2024 and separate statement of profit
or loss, separate statement of comprehensive income, separate statement of changes in equity and separate
statement of cash flows for the year then ended, and notes to the separate financial statements, comprising
material accounting policy information and other explanatory information.
In our opinion, the accompanying separate financial statements give a true and fair view of the financial position
of the Company as at 31 December 2024 and of its financial performance and its cash flows for the year then
ended in accordance with IFRS Accounting Standards, as adopted by the EU and Bulgarian legislation.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under
those standards are further described in the “Auditors’ Responsibilities for the Audit of the Financial Statements ”
section of our report. We are independent of the Company in accordance with the International Code of Ethics
for Professional Accountants (including International Independent Standards) issued by the International Ethics
Standards Board for Accountants (IESBA Code) , together with the ethical requirements of Bulgarian Independent
Financial Audit and Assurance of Sustainability Reporting Act, and we have fulfilled our other responsibilities in
accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and
appropriate to provide a basis for our opinion.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of
the separate financial statements of the current period. These matters were addressed in the context of our audit
of the separate financial statements as a whole, and in forming our opinion thereon, and we do not provide a
separate opinion on these matters.
Impairment of loans granted to related parties and receivables from “Toplofikatsia Sofia” EAD
Notes 23 Receivables from “Toplofikatsia Sofia” EAD, 32.1 Loans granted to related parties and 35.5 Credit
risk to the separate financial statements
Key audit matter How this matter was addressed during the audit
Company’s debt instruments carried at amortised
cost mainly consist of loans to related parties with
carrying value of BGN 1,856,369 thousand and
receivables from “Toplofikatsia Sofia” EAD with
carrying value of BGN 9,994 thousand. The
recoverable amount of these financial assets is one
of the main accounting estimates used in preparing
the separate financial statements, because it
requires application of management’s significant
judgements, key estimates and assumptions and
these receivables account for 26% of Company’s
total assets.
Due to the significant amount of receivables and the
significance of the estimates and their related
During the audit, our audit procedures included, but
were not limited to the following:
- analysis of the adequacy of the policies and
procedures applied with respect to the
classification and subsequent accounting of
debt instruments carried at amortized cost in
accordance with IFRS 9 Financial Instruments,
including changes in estimates during the
period;
- analysis and assessment if there are factors
indicating significant increase of credit risk
related to the debt instruments carried at
amortised cost;
INDEPENDENT JOINT AUDITORS’ REPORT
To the sole shareholder of
Bulgarian Energy Holding EAD
Sofia, 16 Veslets Str.
Report on the Audit of the Separate Financial Statements
Opinion
We have audited the separate financial statements of Bulgarian Energy Holding EAD („the Company“) , which
comprise the separate statement of financial position as at 31 December 2024 and separate statement of profit
or loss, separate statement of comprehensive income, separate statement of changes in equity and separate
statement of cash flows for the year then ended, and notes to the separate financial statements, comprising
material accounting policy information and other explanatory information.
In our opinion, the accompanying separate financial statements give a true and fair view of the financial position
of the Company as at 31 December 2024 and of its financial performance and its cash flows for the year then
ended in accordance with IFRS Accounting Standards, as adopted by the EU and Bulgarian legislation.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under
those standards are further described in the “Auditors’ Responsibilities for the Audit of the Financial Statements ”
section of our report. We are independent of the Company in accordance with the International Code of Ethics
for Professional Accountants (including International Independent Standards) issued by the International Ethics
Standards Board for Accountants (IESBA Code) , together with the ethical requirements of Bulgarian Independent
Financial Audit and Assurance of Sustainability Reporting Act, and we have fulfilled our other responsibilities in
accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and
appropriate to provide a basis for our opinion.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of
the separate financial statements of the current period. These matters were addressed in the context of our audit
of the separate financial statements as a whole, and in forming our opinion thereon, and we do not provide a
separate opinion on these matters.
Impairment of loans granted to related parties and receivables from “Toplofikatsia Sofia” EAD
Notes 23 Receivables from “Toplofikatsia Sofia” EAD, 32.1 Loans granted to related parties and 35.5 Credit
risk to the separate financial statements
Key audit matter How this matter was addressed during the audit
Company’s debt instruments carried at amortised
cost mainly consist of loans to related parties with
carrying value of BGN 1,856,369 thousand and
receivables from “Toplofikatsia Sofia” EAD with
carrying value of BGN 9,994 thousand. The
recoverable amount of these financial assets is one
of the main accounting estimates used in preparing
the separate financial statements, because it
requires application of management’s significant
judgements, key estimates and assumptions and
these receivables account for 26% of Company’s
total assets.
Due to the significant amount of receivables and the
significance of the estimates and their related
During the audit, our audit procedures included, but
were not limited to the following:
- analysis of the adequacy of the policies and
procedures applied with respect to the
classification and subsequent accounting of
debt instruments carried at amortized cost in
accordance with IFRS 9 Financial Instruments,
including changes in estimates during the
period;
- analysis and assessment if there are factors
indicating significant increase of credit risk
related to the debt instruments carried at
amortised cost;
2
uncertainties due to the dynamics in the energy
industry, we determined the impairment of the loans
provided to related parties and receivables from
“Toplofikatsia Sofia” EAD as key audit matter.
- calculation of the required impairment of
individual receivables and performance of tests
of details to determine their classification and
amount;
- analysis of the financial condition of the debtors;
- application of professional judgement in
assessing the key assumptions used in the
models for calculation of expected credit losses
on loans granted to related parties and
receivables from Toplofikatsia Sofia EAD;
- assessment of the adequacy of disclosures in
the separate financial statements, including the
main assumptions, judgements and estimates.
Information Other than the Separate Financial Statements and Auditors’ Report Thereon
Management is responsible for the other information. The other information comprises the annual management
report and the corporate governance statement, prepared by management in accordance with Bulgarian
Accountancy Act and other applicable legislative requirements, but does not include the separate financial
statements and our auditors’ report thereon.
Our opinion on the separate financial statements does not cover the other information and we do not express
any form of assurance conclusion thereon. In connection with our audit of the separate financial statements, our
responsibility is to read the other information and, in doing so, consider whether the other information is materially
inconsistent with the financial statements or whether our knowledge obtained in the audit may indicate that there
is a material misstatement or otherwise the other information appears to be materially misstated. If, based on
the work we have performed, we conclude that there is a material misstatement of this other information, we are
required to report that fact. We have nothing to report in this regard.
Responsibilities of Management and Those Charged with Governance for the Separate Financial
Statements
Management is responsible for the preparation and fair presentation of the separate financial statements in
accordance with IFRS Accounting Standards, as adopted by the EU and Bulgarian legislation, and for such
internal control as management determines is necessary to enable the preparation of separate financial
statements that are free from material misstatement, whether due to fraud or error.
In preparing the separate financial statements, management is responsible for assessing the Company’s ability
to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going
concern basis of accounting unless management either intends to liquidate the Company or to cease operations,
or has no realistic alternative but to do so.
Those charged with governance are responsible for overseeing the Company’s financial reporting process.
Auditors’ Responsibilities for the Audit of the Separate Financial Statements
Our objectives are to obtain reasonable assurance about whether the separate financial statements as a whole
are free from material misstatement, whether due to fraud or error, and to issue an auditors ’ report that includes
our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted
in accordance with ISAs and Bulgarian Independent Financial Audit and Assurance of Sustainability Reporting
Act will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and
are considered material if, individually or in the aggregate, they could reasonably be expected to influence the
economic decisions of users taken on the basis of these separate financial statements.
As part of our audit in accordance with ISAs, we exercise professional judgment and maintain professional
skepticism throughout the audit. We also:
− identify and assess the risks of material misstatement of the separate financial statements, whether due to
fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence
that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material
misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion,
forgery, intentional omissions, misrepresentations, or the override of internal control;
uncertainties due to the dynamics in the energy
industry, we determined the impairment of the loans
provided to related parties and receivables from
“Toplofikatsia Sofia” EAD as key audit matter.
- calculation of the required impairment of
individual receivables and performance of tests
of details to determine their classification and
amount;
- analysis of the financial condition of the debtors;
- application of professional judgement in
assessing the key assumptions used in the
models for calculation of expected credit losses
on loans granted to related parties and
receivables from Toplofikatsia Sofia EAD;
- assessment of the adequacy of disclosures in
the separate financial statements, including the
main assumptions, judgements and estimates.
Information Other than the Separate Financial Statements and Auditors’ Report Thereon
Management is responsible for the other information. The other information comprises the annual management
report and the corporate governance statement, prepared by management in accordance with Bulgarian
Accountancy Act and other applicable legislative requirements, but does not include the separate financial
statements and our auditors’ report thereon.
Our opinion on the separate financial statements does not cover the other information and we do not express
any form of assurance conclusion thereon. In connection with our audit of the separate financial statements, our
responsibility is to read the other information and, in doing so, consider whether the other information is materially
inconsistent with the financial statements or whether our knowledge obtained in the audit may indicate that there
is a material misstatement or otherwise the other information appears to be materially misstated. If, based on
the work we have performed, we conclude that there is a material misstatement of this other information, we are
required to report that fact. We have nothing to report in this regard.
Responsibilities of Management and Those Charged with Governance for the Separate Financial
Statements
Management is responsible for the preparation and fair presentation of the separate financial statements in
accordance with IFRS Accounting Standards, as adopted by the EU and Bulgarian legislation, and for such
internal control as management determines is necessary to enable the preparation of separate financial
statements that are free from material misstatement, whether due to fraud or error.
In preparing the separate financial statements, management is responsible for assessing the Company’s ability
to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going
concern basis of accounting unless management either intends to liquidate the Company or to cease operations,
or has no realistic alternative but to do so.
Those charged with governance are responsible for overseeing the Company’s financial reporting process.
Auditors’ Responsibilities for the Audit of the Separate Financial Statements
Our objectives are to obtain reasonable assurance about whether the separate financial statements as a whole
are free from material misstatement, whether due to fraud or error, and to issue an auditors ’ report that includes
our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted
in accordance with ISAs and Bulgarian Independent Financial Audit and Assurance of Sustainability Reporting
Act will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and
are considered material if, individually or in the aggregate, they could reasonably be expected to influence the
economic decisions of users taken on the basis of these separate financial statements.
As part of our audit in accordance with ISAs, we exercise professional judgment and maintain professional
skepticism throughout the audit. We also:
− identify and assess the risks of material misstatement of the separate financial statements, whether due to
fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence
that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material
misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion,
forgery, intentional omissions, misrepresentations, or the override of internal control;
3
− obtain an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of
the Company’s internal control;
− evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates
and related disclosures made by management;
− conclude on the appropriateness of management’s use of the going concern basis of accounting and, based
on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that
may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude that a
material uncertainty exists, we are required to draw attention in our auditors ’ report to the related disclosures
in the separate financial statements or, if such disclosures are inadequate, to modify our opinion. Our
conclusions are based on the audit evidence obtained up to the date of our auditors’ report. However,
future events or conditions may cause the Company to cease to continue as a going concern;
− evaluate the overall presentation, structure and content of the separate financial statements, including the
disclosures, and whether the separate financial statements represent the underlying transactions and
events in a manner that achieves fair presentation.
We communicate with those charged with governance regarding, among other matters, the planned scope and
timing of the audit and significant audit findings, including any significant deficiencies in internal control that we
identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical
requirements regarding independence, and to communicate with them all relationships and other matters that
may reasonably be thought to bear on our independence, and where applicable, related safeguards.
From the matters communicated with those charged with governance, we determine those matters that were of
most significance in the audit of the separate financial statements of the current period and are therefore the key
audit matters. We describe these matters in our auditors’ report unless law or regulation precludes public
disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be
communicated in our report because the adverse consequences of doing so would reasonably be expected to
outweigh the public interest benefits of such communication.
We are jointly liable for the performance of our joint audit and the issued joint auditors’ opinion in accordance
with the requirements of Bulgarian Independent Financial Audit and Assurance of Sustainability Reporting Act.
Upon acceptance and performance of the joint audit engagement on which we report, we have complied with
the “Guidelines on performance of joint audit“ issued by Bulgarian Institute of Certified Public Accountants and
Bulgarian Commission for Public Oversight of Statutory Auditors.
Report on Other Legal and Regulatory Requirements
In addition to our responsibilities for reporting under ISAs, described above in section “Information Other than
the Separate Financial Statements and Auditors’ Report Thereon”, regarding the annual management report,
including the corporate governance statement, we have performed the additional procedures contained in the
Guidelines of the professional organisation of certified public accountants and registered auditors in Bulgaria -
Institute of Certified Public Accountants (ICPA). The procedures on the existence, form and contents of the other
information have been carried out in order to state whether the other information includes the elements and
disclosures in accordance with Chapter Seven of Bulgarian Accountancy Act and Article 100m, paragraph (10)
in relation to Article 100m, paragraph (8), subparagraphs (3) and (4) of Bulgarian Public Offering of Securities
Act.
Statement Pursuant to Article 37, Paragraph (6) of Bulgarian Accountancy Act
Based on the procedures performed, we describe the outcome of our work:
(a) the information in the individual management report is consistent with the separate financial statements
for the same reporting period;
(b) the management report is prepared in accordance with the applicable legal requirements;
(c) as a result of the acquired knowledge and understanding of the activities of the Company and the
environment in which it operates, we have found no cases of material misrepresentation in the
management report;
(d) the corporate governance statement for the financial year contains the required information in
accordance with the applicable legal requirements, including Article 100m, paragraph (8) of Bulgarian
Public Offering of Securities Act;
Statement Pursuant to Article 100m, Paragraph (10) of Bulgarian Public Offering of Securities Act
− obtain an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of
the Company’s internal control;
− evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates
and related disclosures made by management;
− conclude on the appropriateness of management’s use of the going concern basis of accounting and, based
on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that
may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude that a
material uncertainty exists, we are required to draw attention in our auditors ’ report to the related disclosures
in the separate financial statements or, if such disclosures are inadequate, to modify our opinion. Our
conclusions are based on the audit evidence obtained up to the date of our auditors’ report. However,
future events or conditions may cause the Company to cease to continue as a going concern;
− evaluate the overall presentation, structure and content of the separate financial statements, including the
disclosures, and whether the separate financial statements represent the underlying transactions and
events in a manner that achieves fair presentation.
We communicate with those charged with governance regarding, among other matters, the planned scope and
timing of the audit and significant audit findings, including any significant deficiencies in internal control that we
identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical
requirements regarding independence, and to communicate with them all relationships and other matters that
may reasonably be thought to bear on our independence, and where applicable, related safeguards.
From the matters communicated with those charged with governance, we determine those matters that were of
most significance in the audit of the separate financial statements of the current period and are therefore the key
audit matters. We describe these matters in our auditors’ report unless law or regulation precludes public
disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be
communicated in our report because the adverse consequences of doing so would reasonably be expected to
outweigh the public interest benefits of such communication.
We are jointly liable for the performance of our joint audit and the issued joint auditors’ opinion in accordance
with the requirements of Bulgarian Independent Financial Audit and Assurance of Sustainability Reporting Act.
Upon acceptance and performance of the joint audit engagement on which we report, we have complied with
the “Guidelines on performance of joint audit“ issued by Bulgarian Institute of Certified Public Accountants and
Bulgarian Commission for Public Oversight of Statutory Auditors.
Report on Other Legal and Regulatory Requirements
In addition to our responsibilities for reporting under ISAs, described above in section “Information Other than
the Separate Financial Statements and Auditors’ Report Thereon”, regarding the annual management report,
including the corporate governance statement, we have performed the additional procedures contained in the
Guidelines of the professional organisation of certified public accountants and registered auditors in Bulgaria -
Institute of Certified Public Accountants (ICPA). The procedures on the existence, form and contents of the other
information have been carried out in order to state whether the other information includes the elements and
disclosures in accordance with Chapter Seven of Bulgarian Accountancy Act and Article 100m, paragraph (10)
in relation to Article 100m, paragraph (8), subparagraphs (3) and (4) of Bulgarian Public Offering of Securities
Act.
Statement Pursuant to Article 37, Paragraph (6) of Bulgarian Accountancy Act
Based on the procedures performed, we describe the outcome of our work:
(a) the information in the individual management report is consistent with the separate financial statements
for the same reporting period;
(b) the management report is prepared in accordance with the applicable legal requirements;
(c) as a result of the acquired knowledge and understanding of the activities of the Company and the
environment in which it operates, we have found no cases of material misrepresentation in the
management report;
(d) the corporate governance statement for the financial year contains the required information in
accordance with the applicable legal requirements, including Article 100m, paragraph (8) of Bulgarian
Public Offering of Securities Act;
Statement Pursuant to Article 100m, Paragraph (10) of Bulgarian Public Offering of Securities Act
4
Based on the procedures performed and our knowledge of the Company and the environment in which it
operates, in our opinion, there is no material misstatement in the description of the main characteristics of the
internal control system and of the risk management system of the Company in connection with the financial
reporting process and also in the information pursuant to Article 10, paragraph 1, items “c”, “d”, “f”, “h” and “i” of
Directive 2004/25/EC of the European Parliament and of the Council of 21 April 2004 on takeover bids, which
are included in the corporate governance statement, being a component of the annual management report.
Additional reporting concerning the audit of separate financial statements in connection with Article
100m, paragraph (4), subparagraph (3) of Bulgarian Public Offering of Securities Act
− Statement on Article 100m, paragraph 4, subparagraph (3), item "b" of Public Offering of Securities Act
Related party transactions are disclosed in note 32 to the separate financial statements. Based on the performed
audit procedures on related party transactions as part of our audit of separate financial statements as a whole,
no facts, circumstances or other information have come to our attention that caused us to conclude that the
related party transactions are not disclosed in the accompanying separate financial statements for the year
ended on 31 December 2024 in all material respects, in accordance with the requirements of IAS 24 „Related
Party Disclosures“. The results of our audit procedures on related party transactions were taken into
consideration for the purposes of issuing an auditors’ opinion on the separate financial statements as a whole,
not for issuing a separate opinion only on related party transactions.
− Statement on Article 100m, paragraph (4), subparagraph 3, item "c" of Public Offering of Securities Act
Our responsibilities for audit of the separate financial statements as a whole, described in our report in section
„Responsibilities of the Auditor for the Audit of Separate Financial Statements“, include assessment whether the
separate financial statements present fairly the significant transactions and events. Based on the performed audit
procedures on the significant transactions, which are fundamental to the separate financial statements for the
year ended on 31 December 2024, no facts, circumstances or other information have come to our attention that
caused us to conclude that there are instances of unfair presentation and disclosure in accordance with the
requirements of IFRS Accounting Standards, as adopted by the EU. The results of our audit procedures on the
significant transactions and events of the Company which are material to the separate financial statements, were
taken into consideration for the purposes of issuing an auditors’ opinion on the separate financial statements as
a whole, not for issuing a separate opinion only on the significant transactions.
Reporting on compliance of the electronic format of the separate financial statements included in the
annual separate financial report on the activity under Art. 100m, paragraph 4 of Bulgarian Public Offering
of Securities Act with the requirements of ESEF Regulation
In addition to our responsibilities and reporting under ISA, described above in the section "Auditors ’
Responsibilities for the Audit of the Separate Financial Statements", we have followed the procedures in
accordance with the Guidelines on Issuing of Audit Opinion regarding the Implementation of the European Single
Electronic Format ( ESEF) for the separate financial statements of companies whose securities are admitted to
trading on a regulated market in the European Union (EU)" of Bulgarian Institute of Chartered Accountants
(ICPA) in Bulgaria". These procedures include verifying the electronic file format and whether the human
readable part of it corresponds to the audited separate financial statements and expressing an opinion regarding
the compliance of the electronic format of the separate financial statements of Bulgarian Energy Holding EAD
for the year ending 31 December 2024, contained in the electronic file „635400E1RWKJXPSBCV07 -20241231-
BG-SEP.xhtml“, with the requirements of Commission Delegated Regulation (EU) 2019/815 of 17 December
2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to
regulatory technical standards on the specification of a single electronic reporting format (“ESEF Regulation”).
Based on these requirements, the electronic format of the separate financial statements included in the annual
separate financial report on the activity under Art. 100m, para. 4 of Bulgarian Public Offering of Securities Act,
must be submitted in XHTML format.
The management of the Company is responsible for the application of the requirements of ESEF Regulation
when preparing the electronic format of the separate financial statements in XHTML.
Our opinion is only regarding the electronic format of the separate financial statements included in the electronic
file „635400E1RWKJXPSBCV07-20241231-BG-SEP.xhtml“ and does not include the other information
contained in the annual individual financial report on the activity under art. 100m, para. 4 of Bulgarian Public
Offering of Securities Act.
Based on the procedures performed and our knowledge of the Company and the environment in which it
operates, in our opinion, there is no material misstatement in the description of the main characteristics of the
internal control system and of the risk management system of the Company in connection with the financial
reporting process and also in the information pursuant to Article 10, paragraph 1, items “c”, “d”, “f”, “h” and “i” of
Directive 2004/25/EC of the European Parliament and of the Council of 21 April 2004 on takeover bids, which
are included in the corporate governance statement, being a component of the annual management report.
Additional reporting concerning the audit of separate financial statements in connection with Article
100m, paragraph (4), subparagraph (3) of Bulgarian Public Offering of Securities Act
− Statement on Article 100m, paragraph 4, subparagraph (3), item "b" of Public Offering of Securities Act
Related party transactions are disclosed in note 32 to the separate financial statements. Based on the performed
audit procedures on related party transactions as part of our audit of separate financial statements as a whole,
no facts, circumstances or other information have come to our attention that caused us to conclude that the
related party transactions are not disclosed in the accompanying separate financial statements for the year
ended on 31 December 2024 in all material respects, in accordance with the requirements of IAS 24 „Related
Party Disclosures“. The results of our audit procedures on related party transactions were taken into
consideration for the purposes of issuing an auditors’ opinion on the separate financial statements as a whole,
not for issuing a separate opinion only on related party transactions.
− Statement on Article 100m, paragraph (4), subparagraph 3, item "c" of Public Offering of Securities Act
Our responsibilities for audit of the separate financial statements as a whole, described in our report in section
„Responsibilities of the Auditor for the Audit of Separate Financial Statements“, include assessment whether the
separate financial statements present fairly the significant transactions and events. Based on the performed audit
procedures on the significant transactions, which are fundamental to the separate financial statements for the
year ended on 31 December 2024, no facts, circumstances or other information have come to our attention that
caused us to conclude that there are instances of unfair presentation and disclosure in accordance with the
requirements of IFRS Accounting Standards, as adopted by the EU. The results of our audit procedures on the
significant transactions and events of the Company which are material to the separate financial statements, were
taken into consideration for the purposes of issuing an auditors’ opinion on the separate financial statements as
a whole, not for issuing a separate opinion only on the significant transactions.
Reporting on compliance of the electronic format of the separate financial statements included in the
annual separate financial report on the activity under Art. 100m, paragraph 4 of Bulgarian Public Offering
of Securities Act with the requirements of ESEF Regulation
In addition to our responsibilities and reporting under ISA, described above in the section "Auditors ’
Responsibilities for the Audit of the Separate Financial Statements", we have followed the procedures in
accordance with the Guidelines on Issuing of Audit Opinion regarding the Implementation of the European Single
Electronic Format ( ESEF) for the separate financial statements of companies whose securities are admitted to
trading on a regulated market in the European Union (EU)" of Bulgarian Institute of Chartered Accountants
(ICPA) in Bulgaria". These procedures include verifying the electronic file format and whether the human
readable part of it corresponds to the audited separate financial statements and expressing an opinion regarding
the compliance of the electronic format of the separate financial statements of Bulgarian Energy Holding EAD
for the year ending 31 December 2024, contained in the electronic file „635400E1RWKJXPSBCV07 -20241231-
BG-SEP.xhtml“, with the requirements of Commission Delegated Regulation (EU) 2019/815 of 17 December
2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to
regulatory technical standards on the specification of a single electronic reporting format (“ESEF Regulation”).
Based on these requirements, the electronic format of the separate financial statements included in the annual
separate financial report on the activity under Art. 100m, para. 4 of Bulgarian Public Offering of Securities Act,
must be submitted in XHTML format.
The management of the Company is responsible for the application of the requirements of ESEF Regulation
when preparing the electronic format of the separate financial statements in XHTML.
Our opinion is only regarding the electronic format of the separate financial statements included in the electronic
file „635400E1RWKJXPSBCV07-20241231-BG-SEP.xhtml“ and does not include the other information
contained in the annual individual financial report on the activity under art. 100m, para. 4 of Bulgarian Public
Offering of Securities Act.
5
Based on the performed procedures, our opinion is that the electronic format of the separate financial statements
of the Company for the year ended 31 December 2024, contained in the attached electronic file
„635400E1RWKJXPSBCV07-20241231-BG-SEP.xhtm“, has been prepared in all material respects in
accordance with the requirements of the ESEF Regulation.
Reporting Pursuant to Article 59 of Bulgarian Independent Financial Audit and Assurance of
Sustainability Reporting Act in relation to Article 10 of Regulation (ЕС) № 537/2014
In accordance with the requirements of Bulgarian Independent Financial Audit and Assurance of Sustainability
Reporting Act and in relation with Article 10 of Regulation (ЕС) № 537/2014, we report additionally the
information as follows:
− Grant Thornton OOD and Zaharinova Nexia EOOD as participants in the consortium DZZD "AUDIT BEH"
were appointed as statutory auditors of the separate financial statements of Bulgarian Energy Holding EAD
for the year ended on 31 December 2024 by the sole shareholder on 02.02.2024 for a period of three year
(2024-2026) .
− The audit of the separate financial statements of the Company for the year ended on 31 December 2024
has been performed for fourth consecutive year by each of the joint auditors.
− In support of our joint audit opinion, we have provided a description of the most significant assessed risks
of material misstatement, a summary of the joint auditors’ response and where relevant, key observations
arising with respect to those risks in the section „Key audit matters“ of this report .
− We confirm that our joint audit opinion is consistent with the additional report to the audit committee, which
was provided in accordance with Article 60 of Bulgarian Independent Financial Audit and Assurance of
Sustainability Reporting Act.
− We declare that prohibited non-audit services referred to in Article 64 of Bulgarian Independent Financial
Audit and Assurance of Sustainability Reporting Act were not provided.
− We confirm that we remained independent of the Company in performing the audit.
− For the period for which we were engaged as statutory auditors, we have not provided any other services
to the Company and its controlled undertakings in addition to the statutory audit which have not been
disclosed in individual activity report or the separate financial statements.
9 May 2025
For Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm with reg. № 138
Silvia Dinova Stoycho Milev
Registered auditor, responsible for the audit Registered auditor, responsible for the audit
Signed with electronic signature Signed with electronic signature
Mariy Apostolov, Managing Partner Dimitrina Zaharinova, Manager
Signed with electronic signature Signed with electronic signature
Bulgaria, Sofia, 1421 Bulgaria, Sofia, 1309
26, Cherni Vrah Blvd. 157-159 Konstantin Velichkov Blvd., fl. 1, office 3
Based on the performed procedures, our opinion is that the electronic format of the separate financial statements
of the Company for the year ended 31 December 2024, contained in the attached electronic file
„635400E1RWKJXPSBCV07-20241231-BG-SEP.xhtm“, has been prepared in all material respects in
accordance with the requirements of the ESEF Regulation.
Reporting Pursuant to Article 59 of Bulgarian Independent Financial Audit and Assurance of
Sustainability Reporting Act in relation to Article 10 of Regulation (ЕС) № 537/2014
In accordance with the requirements of Bulgarian Independent Financial Audit and Assurance of Sustainability
Reporting Act and in relation with Article 10 of Regulation (ЕС) № 537/2014, we report additionally the
information as follows:
− Grant Thornton OOD and Zaharinova Nexia EOOD as participants in the consortium DZZD "AUDIT BEH"
were appointed as statutory auditors of the separate financial statements of Bulgarian Energy Holding EAD
for the year ended on 31 December 2024 by the sole shareholder on 02.02.2024 for a period of three year
(2024-2026) .
− The audit of the separate financial statements of the Company for the year ended on 31 December 2024
has been performed for fourth consecutive year by each of the joint auditors.
− In support of our joint audit opinion, we have provided a description of the most significant assessed risks
of material misstatement, a summary of the joint auditors’ response and where relevant, key observations
arising with respect to those risks in the section „Key audit matters“ of this report .
− We confirm that our joint audit opinion is consistent with the additional report to the audit committee, which
was provided in accordance with Article 60 of Bulgarian Independent Financial Audit and Assurance of
Sustainability Reporting Act.
− We declare that prohibited non-audit services referred to in Article 64 of Bulgarian Independent Financial
Audit and Assurance of Sustainability Reporting Act were not provided.
− We confirm that we remained independent of the Company in performing the audit.
− For the period for which we were engaged as statutory auditors, we have not provided any other services
to the Company and its controlled undertakings in addition to the statutory audit which have not been
disclosed in individual activity report or the separate financial statements.
9 May 2025
For Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm with reg. № 138
Silvia Dinova Stoycho Milev
Registered auditor, responsible for the audit Registered auditor, responsible for the audit
Signed with electronic signature Signed with electronic signature
Mariy Apostolov, Managing Partner Dimitrina Zaharinova, Manager
Signed with electronic signature Signed with electronic signature
Bulgaria, Sofia, 1421 Bulgaria, Sofia, 1309
26, Cherni Vrah Blvd. 157-159 Konstantin Velichkov Blvd., fl. 1, office 3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Annual Separate Financial Statements
Bulgarian Energy Holding EAD
31 December 2024
Annual Separate Financial Statements
Bulgarian Energy Holding EAD
31 December 2024
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
1
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Profit or Loss
for the year ending 31 December
Notes 2024 2023
thousand
BGN
thousand
BGN
Dividend income 5 632,297 855,113
Revenue from contracts with clients 6 2,116 2,035
Revenue 634,413 857,148
Other income 7 349 46
(Expenses for)/reintegration of impairment 8 (62,658) 119,794
Expenses for materials 9 (172) (240)
Hired services expenses 10 (5,007) (2,309)
Depreciation and amortisation of non-financial assets 19, 20 (741) (652)
Employee benefit expenses 12 (10,477) (9,873)
Expenses for provisions 34 - (615)
Other expenses 13 (1,161) (930)
Operating profit 554,546 962,369
Finance income 14 192,955 218,020
Finance costs 15 (73,623) (74,617)
Profit before tax 673,878 1,105,772
Income tax expenses 16 (4,427) (25,143)
Net profit for the year 669,451 1,080,629
BGN BGN
Earnings per share 17 0.193 0.312
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
1
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Profit or Loss
for the year ending 31 December
Notes 2024 2023
thousand
BGN
thousand
BGN
Dividend income 5 632,297 855,113
Revenue from contracts with clients 6 2,116 2,035
Revenue 634,413 857,148
Other income 7 349 46
(Expenses for)/reintegration of impairment 8 (62,658) 119,794
Expenses for materials 9 (172) (240)
Hired services expenses 10 (5,007) (2,309)
Depreciation and amortisation of non-financial assets 19, 20 (741) (652)
Employee benefit expenses 12 (10,477) (9,873)
Expenses for provisions 34 - (615)
Other expenses 13 (1,161) (930)
Operating profit 554,546 962,369
Finance income 14 192,955 218,020
Finance costs 15 (73,623) (74,617)
Profit before tax 673,878 1,105,772
Income tax expenses 16 (4,427) (25,143)
Net profit for the year 669,451 1,080,629
BGN BGN
Earnings per share 17 0.193 0.312
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
2
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Comprehensive Income
for the year ended 31 December
Notes 2024 2023
thousand BGN thousand BGN
Profit for the year 669,451 1,080,629
Other comprehensive income/(loss):
Items that will not be reclassified to profit or loss:
Revaluation of property, plant and equipment 19 1,158 -
Income tax related to items that will not be reclassified to
profit or loss (116) -
1,042 -
Net change in the fair value of equity instruments 24 166 63
Income tax related to items that will not be reclassified to
profit or loss (17) (6)
149 57
Revaluation of liabilities under defined benefit plans 30 383 (377)
Income tax related to items that will not be reclassified to
profit or loss (38) 38
345 (339)
Other comprehensive income/(loss) for the year, net of
tax 1,536 (282)
Total comprehensive income for the year, net of tax 670,987 1,080,347
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
2
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Comprehensive Income
for the year ended 31 December
Notes 2024 2023
thousand BGN thousand BGN
Profit for the year 669,451 1,080,629
Other comprehensive income/(loss):
Items that will not be reclassified to profit or loss:
Revaluation of property, plant and equipment 19 1,158 -
Income tax related to items that will not be reclassified to
profit or loss (116) -
1,042 -
Net change in the fair value of equity instruments 24 166 63
Income tax related to items that will not be reclassified to
profit or loss (17) (6)
149 57
Revaluation of liabilities under defined benefit plans 30 383 (377)
Income tax related to items that will not be reclassified to
profit or loss (38) 38
345 (339)
Other comprehensive income/(loss) for the year, net of
tax 1,536 (282)
Total comprehensive income for the year, net of tax 670,987 1,080,347
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Financial Position
as of 31 December
Notes 31 December
2024
31 December
2023
thousand
BGN
thousand
BGN
ASSETS
Non-current assets
Investments in subsidiaries, associates and joint ventures 18 4,521,873 4,321,922
Loans granted to related parties 32.1 1,537,117 1,662,529
Property, plant and equipment 19 9,686 8,568
Intangible assets 20 227 250
Deferred tax assets 21 217,371 215,185
Trade and other receivables 22 31 25
6,286,305 6,208,479
Current assets
Loans granted to related parties 32.1 319,252 305,476
Trade receivables from related parties 32.3 282,398 8,676
Receivables from Toplofikatsia Sofia EAD 23 9,994 61,274
Trade and other receivables 22 2,284 133
Financial assets at fair value 24 885 719
Inventories 4 4
Income tax receivables - 1,061
Cash and cash equivalents 25 313,041 220,012
927,858 597,355
TOTAL ASSETS 7,214,163 6,805,834
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
3
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Financial Position
as of 31 December
Notes 31 December
2024
31 December
2023
thousand
BGN
thousand
BGN
ASSETS
Non-current assets
Investments in subsidiaries, associates and joint ventures 18 4,521,873 4,321,922
Loans granted to related parties 32.1 1,537,117 1,662,529
Property, plant and equipment 19 9,686 8,568
Intangible assets 20 227 250
Deferred tax assets 21 217,371 215,185
Trade and other receivables 22 31 25
6,286,305 6,208,479
Current assets
Loans granted to related parties 32.1 319,252 305,476
Trade receivables from related parties 32.3 282,398 8,676
Receivables from Toplofikatsia Sofia EAD 23 9,994 61,274
Trade and other receivables 22 2,284 133
Financial assets at fair value 24 885 719
Inventories 4 4
Income tax receivables - 1,061
Cash and cash equivalents 25 313,041 220,012
927,858 597,355
TOTAL ASSETS 7,214,163 6,805,834
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
4
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Financial Position as of
31 December (continued)
Notes 31 December
2024
31 December
2023
thousand BGN thousand BGN
EQUITY AND LIABILITIES
Equity
Share capital 26.1 3,463,942 3,463,942
Other reserves 26.2 380,591 380,491
Reserve from revaluation of financial assets at fair value
through other comprehensive income 26.3 473 324
Revaluation reserve of non-financial assets 26.4 1,795 770
Reserve from remeasurement of defined benefit plans 26.5 (234) (579)
Retained earnings 669,467 280,628
Total equity 4,516,034 4,125,576
Non-Current liabilities
Issued bonds 27 1,171,640 2,343,262
Loans received 29 213,515 214,946
Loans received from related parties 32.2 5,545 16,497
Trade and other payables 31 613 1,100
Retirement employee benefit obligations 30 1,382 1,521
Provisions for liabilities 34 53,715 53,715
1,446,410 2,631,041
Current liabilities
Issued bonds 27 1,206,731 33,691
Loans received 29 1,865 434
Loans received from related parties 32.2 36,039 10,772
Trade and other payables 31 4,854 4,016
Income tax liability 1,985 -
Retirement employee benefit obligations 30 245 304
1,251,719 49,217
Total liabilities 2,698,129 2,680,258
TOTAL EQUITY AND LIABILITIES 7,214,163 6,805,834
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
4
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Financial Position as of
31 December (continued)
Notes 31 December
2024
31 December
2023
thousand BGN thousand BGN
EQUITY AND LIABILITIES
Equity
Share capital 26.1 3,463,942 3,463,942
Other reserves 26.2 380,591 380,491
Reserve from revaluation of financial assets at fair value
through other comprehensive income 26.3 473 324
Revaluation reserve of non-financial assets 26.4 1,795 770
Reserve from remeasurement of defined benefit plans 26.5 (234) (579)
Retained earnings 669,467 280,628
Total equity 4,516,034 4,125,576
Non-Current liabilities
Issued bonds 27 1,171,640 2,343,262
Loans received 29 213,515 214,946
Loans received from related parties 32.2 5,545 16,497
Trade and other payables 31 613 1,100
Retirement employee benefit obligations 30 1,382 1,521
Provisions for liabilities 34 53,715 53,715
1,446,410 2,631,041
Current liabilities
Issued bonds 27 1,206,731 33,691
Loans received 29 1,865 434
Loans received from related parties 32.2 36,039 10,772
Trade and other payables 31 4,854 4,016
Income tax liability 1,985 -
Retirement employee benefit obligations 30 245 304
1,251,719 49,217
Total liabilities 2,698,129 2,680,258
TOTAL EQUITY AND LIABILITIES 7,214,163 6,805,834
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
5
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Changes in Equity
for the year ended 31 December
Share
capital
Other
reserves
Reserve from
revaluation of
financial assets at fair
value through other
comprehensive income
Revaluation
reserve of non-
financial assets
Reserve from
remeasurement
of defined
benefit plans
Retained
earnings
Total
equity
thousand
BGN
thousand
BGN thousand BGN thousand BGN thousand BGN thousand
BGN
thousand
BGN
Balance as of 1 January 2024 3,463,942 380,491 324 770 (579) 280,628 4,125,576
Distribution of dividends (note 17.2) - - - - - (280,529) (280,529)
Transactions with the owner - - - - - (280,529) (280,529)
Profit for the year - - - - - 669,451 669,451
Other comprehensive income - - 149 1,042 345 - 1,536
Total comprehensive income for the year - - 149 1,042 345 669,451 670,987
Transfer to reserves - 100 - - - (100) -
Derecognized revaluation reserve - - - (17) - 17 -
Balance as of 31 December 2024 3,463,942 380,591 473 1,795 (234) 669,467 4,516,034
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on 2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
5
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Changes in Equity
for the year ended 31 December
Share
capital
Other
reserves
Reserve from
revaluation of
financial assets at fair
value through other
comprehensive income
Revaluation
reserve of non-
financial assets
Reserve from
remeasurement
of defined
benefit plans
Retained
earnings
Total
equity
thousand
BGN
thousand
BGN thousand BGN thousand BGN thousand BGN thousand
BGN
thousand
BGN
Balance as of 1 January 2024 3,463,942 380,491 324 770 (579) 280,628 4,125,576
Distribution of dividends (note 17.2) - - - - - (280,529) (280,529)
Transactions with the owner - - - - - (280,529) (280,529)
Profit for the year - - - - - 669,451 669,451
Other comprehensive income - - 149 1,042 345 - 1,536
Total comprehensive income for the year - - 149 1,042 345 669,451 670,987
Transfer to reserves - 100 - - - (100) -
Derecognized revaluation reserve - - - (17) - 17 -
Balance as of 31 December 2024 3,463,942 380,591 473 1,795 (234) 669,467 4,516,034
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on 2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
6
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Changes in Equity
for the year ended on 31 December (continued)
Share
capital
Other
reserves
Reserve from
revaluation of
financial assets at fair
value through other
comprehensive income
Revaluation
reserve of non-
financial assets
Reserve from
remeasurement
of defined
benefit plans
Retained
earnings
Total
equity
thousand
BGN
thousand
BGN thousand BGN thousand BGN thousand BGN thousand
BGN
thousand
BGN
Balance as of 1 January 2023 3,462,942 380,491 267 770 (240) 639,859 4,484,089
Increase in capital through in-kind contribution 1,000 - - - - - 1,000
Distribution of dividends (note 17.2) - - - - - (1,439, 706) (1,439, 706)
Transactions with the owner 1,000 - - - - (1,439, 706) (1,438,706)
Profit for the year - - - - - 1,080,629 1,080,629
Other comprehensive loss - - 57 - (339) - (282)
Total comprehensive income for the year - - 57 - (339) 1,080,629 1,080,347
Royalties (payment) - - - - - (154) (154)
Balance as of 31 December 2023 3,463,942 380,491 324 770 (579) 280,628 4,125,576
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on 2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
6
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Changes in Equity
for the year ended on 31 December (continued)
Share
capital
Other
reserves
Reserve from
revaluation of
financial assets at fair
value through other
comprehensive income
Revaluation
reserve of non-
financial assets
Reserve from
remeasurement
of defined
benefit plans
Retained
earnings
Total
equity
thousand
BGN
thousand
BGN thousand BGN thousand BGN thousand BGN thousand
BGN
thousand
BGN
Balance as of 1 January 2023 3,462,942 380,491 267 770 (240) 639,859 4,484,089
Increase in capital through in-kind contribution 1,000 - - - - - 1,000
Distribution of dividends (note 17.2) - - - - - (1,439, 706) (1,439, 706)
Transactions with the owner 1,000 - - - - (1,439, 706) (1,438,706)
Profit for the year - - - - - 1,080,629 1,080,629
Other comprehensive loss - - 57 - (339) - (282)
Total comprehensive income for the year - - 57 - (339) 1,080,629 1,080,347
Royalties (payment) - - - - - (154) (154)
Balance as of 31 December 2023 3,463,942 380,491 324 770 (579) 280,628 4,125,576
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on 2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
7
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Cash Flows
for the year ended 31 December
Notes 2024 2023
thousand BGN thousand BGN
Cash flows from operating activities
Dividends received 375,045 630,432
Cash paid to suppliers 0 (232,412) (250,168)
Cash paid to employees and social security institutions (10,956) (8,651)
Proceeds from related parties, net 216,729 248,373
Loans granted to related parties (112,120) (492,527)
Proceeds from loans granted to related parties 205,238 779,931
Interest received on loans granted to related parties 128,364 126,744
Proceeds from Toplofikatsia Sofia EAD 64,791 124,134
Cash flows from main activities 634,679 1,158,268
Interest received on current and deposit accounts 2,168 1,597
Fees and commissions paid (6) (6)
Foreign exchange losses (12) (16)
Income tax paid (4,800) (9,000)
Income tax refunded 1,061 2,068
Other taxes refunded, net (410) 40
Net cash flows from operating activities 632,680 1,152,951
Cash flows from investing activities
Capital increase in subsidiaries 18 (200,000) (1,530, 000)
Payments for property, plant and equipment (664) (147)
Payments for property, plant and equipment from related parties (274) -
Net cash flows from investing activities (200,938) (1,530, 147)
Cash flows from financing activities
Proceeds from loans granted from related parties 29 25,000 -
Loan payments to related parties 29 (10,772) (185,959)
Interest paid on bond issue 29 (69,823) (69,823)
Interest paid on loans 29 (1,774) (1,774)
Interests paid on loans taken from related parties 29 (371) (1,034)
Payments for issued bank guarantee - (702)
Lease payments (437) (448)
Dividends paid (280,529) (1,439, 706)
Net cash flows from financing activities (338,706) (1,699, 446)
Net change of cash 220,403 (2,076, 642)
Gross amount of cash on 1 January 93,036 2,297,045
Gross amount of cash and cash equivalents at the end of the year 313,439 220,403
Effect from expected credit losses (398) (391)
Cash as of 31 December 25 313,041 220,012
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Separate financial statements
31 December 2024
7
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Separate Statement of Cash Flows
for the year ended 31 December
Notes 2024 2023
thousand BGN thousand BGN
Cash flows from operating activities
Dividends received 375,045 630,432
Cash paid to suppliers 0 (232,412) (250,168)
Cash paid to employees and social security institutions (10,956) (8,651)
Proceeds from related parties, net 216,729 248,373
Loans granted to related parties (112,120) (492,527)
Proceeds from loans granted to related parties 205,238 779,931
Interest received on loans granted to related parties 128,364 126,744
Proceeds from Toplofikatsia Sofia EAD 64,791 124,134
Cash flows from main activities 634,679 1,158,268
Interest received on current and deposit accounts 2,168 1,597
Fees and commissions paid (6) (6)
Foreign exchange losses (12) (16)
Income tax paid (4,800) (9,000)
Income tax refunded 1,061 2,068
Other taxes refunded, net (410) 40
Net cash flows from operating activities 632,680 1,152,951
Cash flows from investing activities
Capital increase in subsidiaries 18 (200,000) (1,530, 000)
Payments for property, plant and equipment (664) (147)
Payments for property, plant and equipment from related parties (274) -
Net cash flows from investing activities (200,938) (1,530, 147)
Cash flows from financing activities
Proceeds from loans granted from related parties 29 25,000 -
Loan payments to related parties 29 (10,772) (185,959)
Interest paid on bond issue 29 (69,823) (69,823)
Interest paid on loans 29 (1,774) (1,774)
Interests paid on loans taken from related parties 29 (371) (1,034)
Payments for issued bank guarantee - (702)
Lease payments (437) (448)
Dividends paid (280,529) (1,439, 706)
Net cash flows from financing activities (338,706) (1,699, 446)
Net change of cash 220,403 (2,076, 642)
Gross amount of cash on 1 January 93,036 2,297,045
Gross amount of cash and cash equivalents at the end of the year 313,439 220,403
Effect from expected credit losses (398) (391)
Cash as of 31 December 25 313,041 220,012
Signed with electronic signature Signed with electronic signature
Valentin Nikolov Marieta Velikova
Executive Director Chief Accountant
Date of preparation: 28 April 2025
The separate financial statements were approved for issue by a decision of the Board of Directors of BEH EAD on
2 May 2025 and signed on its behalf on 9 May 2025.
The notes on pages 8 to 69 form an integral part of the separate financial statements.
Auditors’ report issued by:
Grant Thornton OOD Zaharinova Nexia EOOD
Audit firm, reg. № 032 Audit firm, reg. №138
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Signed with electronic
signature
Mariy Apostolov Silvia Dinova Dimitrina Zaharinova Stoycho Milev
Manager Registered Auditor Manager Registered Auditor
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
8
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Notes to the Separate Financial Statements
1.General information and scope of activity
Bulgarian Energy Holding EAD is a sole owner joint-stock company registered in Bulgaria, UIC 831373560 in the
Commercial Register and the Register of Non-Profit Legal Entities. The company is the successor of the Neft i Gas
(Oil and Gas) State Company, founded in 1973, renamed in December 1975 to Gazosnabdyavane (Gas Supply). In
accordance with the Decree on Business Activities, in the beginning of 1990, the Company was renamed to Bulgargaz.
Bulgargaz was transformed into a sole-owner joint-stock company by order of the Council of Ministers of
12 May 1993. By a plan of transformation dated 27 October 2006 and annexed thereto, Bulgargaz EAD was
transformed into Bulgargaz Holding EAD by separating into two sole joint stock companies – Bulgartransgaz EAD
and Bulgargaz EAD under the terms of Article 262 (d) of the Commercial Act. Bulgartransgaz EAD and Bulgargaz
EAD are legal successors of the respective portion of the property (rights and obligations) of Bulgargaz Holding EAD.
The transformation was registered in the court by decision No. 45 dated 15 January 2007 of the Sofia City Court.
With protocol No. RD-21-305 dated 18 September 2008 of the Minister of Economy and Energy the company name
was changed from Bulgargaz Holding EAD to Bulgarian Energy Holding EAD and the capital through was raised
through an in-kind contribution at par value of all shares of the capital of Natsionalna Elektricheska Kompania EAD,
NPP Kozloduy EAD, TPP Maritsa East 2 EAD and Mini Maritsa Iztok EAD.
The Company’s registered office and business address are located in Sofia, 1000, Oborishte District, 16 Veslets Str.
Bulgarian Energy Holding EAD has a scope of activity: Acquisition, evaluation and sale of participations in trading
companies operating in the fields of production, extraction, transmission, transit, storage, management, distribution,
sale and/or purchase of natural gas, electricity, thermal power, coal, as well as any other types of energy and raw
materials for the production and participation in the management of such companies, their financing, acquisition,
evaluation, issuance and sale of bonds, acquisition, evaluation and sale of patents, concession of licenses for use of
the above companies as well as performance of own production or trade activities.
As of 31 December 2024, Bulgarian Energy Holding EAD has been managed by a Board of Directors (BOD) with the
following members: Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors, Kalin
Boyanov Filipov – Vice-Chairperson of the Board of Directors, Valentin Aleksiev Nikolov - Executive Member,
Galina Tsvetanova Todorova - Executive Member, and Ivo Ivanov Todorov – Member of the Board of Directors. The
Company is represented by the Executive Directors.
The sole and ultimate owner of the Company is the Republic of Bulgaria through the Minister of Energy.
As at 31 December 2024, the total number of employees of the Company under employment contracts is 101 employed
people (31 December 2023: 101 employed people).
2. Statement of compliance with IFRS Accounting Standards and Application of the Going Concern Principle
The separate financial statements have been prepared on a historical cost basis, except for property, plant and
equipment, which is presented at revalued amounts, and equity instruments designated at fair value through other
comprehensive income.
The separate financial statements are presented in Bulgarian Lev (BGN), which is the Company's functional and
presentation currency, and all items are rounded to the nearest thousand Bulgarian Lev (BGN thousand), unless
otherwise stated.
The Company prepares its financial statements on the basis of IFRS Accounting Standards, as adopted by the EU. For
the purposes of paragraph 1(8) of the Additional Provisions of the Accounting Act applicable in Bulgaria, these include
International Accounting Standards (IAS) adopted in accordance with Regulation (EC) 1606/2002 of the European
Parliament and of the Council.
These are the separate financial statement of Bulgarian Energy Holding EAD, where investments in subsidiaries,
associates and joint ventures are presented at cost. In compliance with the requirements of IFRS 10 Consolidated
Financial Statements and the Accountancy Act, the Company also prepares and issues consolidated financial
statements.
The separate financial statements of Bulgarian Energy Holding EAD for the year ending 31 December 2024 were
approved for issue via decision of the Board of Directors by Protocol № 31-2025 dated 2 May 2025.
Separate financial statements
31 December 2024
8
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Notes to the Separate Financial Statements
1.General information and scope of activity
Bulgarian Energy Holding EAD is a sole owner joint-stock company registered in Bulgaria, UIC 831373560 in the
Commercial Register and the Register of Non-Profit Legal Entities. The company is the successor of the Neft i Gas
(Oil and Gas) State Company, founded in 1973, renamed in December 1975 to Gazosnabdyavane (Gas Supply). In
accordance with the Decree on Business Activities, in the beginning of 1990, the Company was renamed to Bulgargaz.
Bulgargaz was transformed into a sole-owner joint-stock company by order of the Council of Ministers of
12 May 1993. By a plan of transformation dated 27 October 2006 and annexed thereto, Bulgargaz EAD was
transformed into Bulgargaz Holding EAD by separating into two sole joint stock companies – Bulgartransgaz EAD
and Bulgargaz EAD under the terms of Article 262 (d) of the Commercial Act. Bulgartransgaz EAD and Bulgargaz
EAD are legal successors of the respective portion of the property (rights and obligations) of Bulgargaz Holding EAD.
The transformation was registered in the court by decision No. 45 dated 15 January 2007 of the Sofia City Court.
With protocol No. RD-21-305 dated 18 September 2008 of the Minister of Economy and Energy the company name
was changed from Bulgargaz Holding EAD to Bulgarian Energy Holding EAD and the capital through was raised
through an in-kind contribution at par value of all shares of the capital of Natsionalna Elektricheska Kompania EAD,
NPP Kozloduy EAD, TPP Maritsa East 2 EAD and Mini Maritsa Iztok EAD.
The Company’s registered office and business address are located in Sofia, 1000, Oborishte District, 16 Veslets Str.
Bulgarian Energy Holding EAD has a scope of activity: Acquisition, evaluation and sale of participations in trading
companies operating in the fields of production, extraction, transmission, transit, storage, management, distribution,
sale and/or purchase of natural gas, electricity, thermal power, coal, as well as any other types of energy and raw
materials for the production and participation in the management of such companies, their financing, acquisition,
evaluation, issuance and sale of bonds, acquisition, evaluation and sale of patents, concession of licenses for use of
the above companies as well as performance of own production or trade activities.
As of 31 December 2024, Bulgarian Energy Holding EAD has been managed by a Board of Directors (BOD) with the
following members: Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors, Kalin
Boyanov Filipov – Vice-Chairperson of the Board of Directors, Valentin Aleksiev Nikolov - Executive Member,
Galina Tsvetanova Todorova - Executive Member, and Ivo Ivanov Todorov – Member of the Board of Directors. The
Company is represented by the Executive Directors.
The sole and ultimate owner of the Company is the Republic of Bulgaria through the Minister of Energy.
As at 31 December 2024, the total number of employees of the Company under employment contracts is 101 employed
people (31 December 2023: 101 employed people).
2. Statement of compliance with IFRS Accounting Standards and Application of the Going Concern Principle
The separate financial statements have been prepared on a historical cost basis, except for property, plant and
equipment, which is presented at revalued amounts, and equity instruments designated at fair value through other
comprehensive income.
The separate financial statements are presented in Bulgarian Lev (BGN), which is the Company's functional and
presentation currency, and all items are rounded to the nearest thousand Bulgarian Lev (BGN thousand), unless
otherwise stated.
The Company prepares its financial statements on the basis of IFRS Accounting Standards, as adopted by the EU. For
the purposes of paragraph 1(8) of the Additional Provisions of the Accounting Act applicable in Bulgaria, these include
International Accounting Standards (IAS) adopted in accordance with Regulation (EC) 1606/2002 of the European
Parliament and of the Council.
These are the separate financial statement of Bulgarian Energy Holding EAD, where investments in subsidiaries,
associates and joint ventures are presented at cost. In compliance with the requirements of IFRS 10 Consolidated
Financial Statements and the Accountancy Act, the Company also prepares and issues consolidated financial
statements.
The separate financial statements of Bulgarian Energy Holding EAD for the year ending 31 December 2024 were
approved for issue via decision of the Board of Directors by Protocol № 31-2025 dated 2 May 2025.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
9
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Macroeconomic factors and the ongoing war between Russia and Ukraine
The Company has no investments or outstanding balances with customers and suppliers from Russia or Ukraine and
due to the nature of its business, namely holding activities related to investment management and the provision of
services, as well as the lack of dependence on raw material supplies, apart from funds received from Gazprom
International in the amount of EUR 1,107 thousand under the South Stream project, which will be used in the final
liquidation of the project company. However, some of the subsidiaries' activities may be directly affected in the
medium and long term in connection with contracts for the purchase of raw materials, supplies and equipment from
Russian contractors. Actions are undertaken for negotiating and contacting alternative suppliers, as well as for
obtaining a derogation from the sanctions of the European Union against the Russian Federation in connection with
particular imports of certain spare parts, materials, and receipt of services.
Climate-related matters
The legislation, the regulatory bodies, the partners of the Company and the users of non -financial information draw
great attention to the climate change. The European Union adopted the European Green Deal as a transition to more
sustainable economic and financial system and in the following years the detailed requirements for reporting the
climate change will become applicable as a part of the European standards for reporting sustainability. 31 December
2024, the Company has not identified any major risks caused by the climate changes that could have a direct negative
and material impact on its separate financial statement, but in a long-term context, they could affect its investments
and their profitability.
Environmental, social and governance (ESG) rating
For a public company actively involved in raising funds through capital markets, such as Bulgarian Energy Holding
EAD, attracting investor interest is associated with strict compliance with of social, governance and environmental
aspects of activities within the holding. The ESG rating is awarded after thorough analysis of the rules and policies of
a particular company, related to the ecological, social, and governance aspects; after assessing the overall impact and
environmental footprint left by the company through its business activities, as well as after a thorough review of the
available public information on the corporate website, articles and news about the company
The rating was assigned by Sustainalytics – a company, part of the Morningstar structure, which is a globally
recognized supplier of ESG researches, ratings, and data The corporate ESG assessment given to Bulgarian Energy
Holding EAD is a one-time assessment that is valid at the time of its assignment and it is prepared on the basis of the
information provided by Bulgarian Energy Holding EAD. The ESG risk assessment report includes a general ESG
risk rating, an assessment of the Company’s exposure and an assessment of its governance. Exposure refers to the
extent to which the Company is exposed to various material risks related to environmental, social, and governance
aspects. The governance assessment shows how well the Company manages these aspects.
As of 31 December 2024, BEH Group's ESG rating as determined by Sustainalytics is 35.5 points (“high risk”). BEH's
ESG Risk Score, which refers to the extent to which the company is exposed to various material risks related to
environmental, social, and governance aspects, is 53.8 points (“medium risk”). The governance score reflecting how
well the company manages these aspects is 36.8 points (“average performance”).
Principle – assumption of a going concern
The sole shareholder of the Company is the Bulgarian State through the Minister of Energy, in their capacity as
Principal. The functioning and the future development of the Company is entirely dependent on the future intentions
and strategy of the state regarding the continuation of its functions and activities within the energy sector in Bulgaria.
The management has analyzed the validity of the going concern assumption, taking into account the principal’s
intentions in the short and medium term. As a result, it has come to the conclusion that the use of the going concern
assumption is appropriate. Management has also taken into account the available information on the foreseeable
future, the above-described circumstances related to macroeconomic factors and the ongoing war between Russia and
Ukraine, the Bulgarian Recovery and Resilience Plan, approved by the EU, and the dynamics of the energy market
globally and in Bulgaria. In addition, as at 31 December 2024 current liabilities exceed current assets by BGN 323,861
thousand. Included in current liabilities is a liability of BGN 1,206,731 thousand for bonds issued, of which BGN
1,193,971 thousand is for a bond issue maturing on 28 June 2025. In accordance with the Company's adopted Business
Program, the Company will refinance the bond issue maturing on 30 June 2025 with a new bond issue in 2025. The
Board of Directors expects that the Company will have sufficient financial resources to continue in operation for the
foreseeable future and will continue to apply the going concern basis in preparing the Independent Financial
Statements.
Separate financial statements
31 December 2024
9
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Macroeconomic factors and the ongoing war between Russia and Ukraine
The Company has no investments or outstanding balances with customers and suppliers from Russia or Ukraine and
due to the nature of its business, namely holding activities related to investment management and the provision of
services, as well as the lack of dependence on raw material supplies, apart from funds received from Gazprom
International in the amount of EUR 1,107 thousand under the South Stream project, which will be used in the final
liquidation of the project company. However, some of the subsidiaries' activities may be directly affected in the
medium and long term in connection with contracts for the purchase of raw materials, supplies and equipment from
Russian contractors. Actions are undertaken for negotiating and contacting alternative suppliers, as well as for
obtaining a derogation from the sanctions of the European Union against the Russian Federation in connection with
particular imports of certain spare parts, materials, and receipt of services.
Climate-related matters
The legislation, the regulatory bodies, the partners of the Company and the users of non -financial information draw
great attention to the climate change. The European Union adopted the European Green Deal as a transition to more
sustainable economic and financial system and in the following years the detailed requirements for reporting the
climate change will become applicable as a part of the European standards for reporting sustainability. 31 December
2024, the Company has not identified any major risks caused by the climate changes that could have a direct negative
and material impact on its separate financial statement, but in a long-term context, they could affect its investments
and their profitability.
Environmental, social and governance (ESG) rating
For a public company actively involved in raising funds through capital markets, such as Bulgarian Energy Holding
EAD, attracting investor interest is associated with strict compliance with of social, governance and environmental
aspects of activities within the holding. The ESG rating is awarded after thorough analysis of the rules and policies of
a particular company, related to the ecological, social, and governance aspects; after assessing the overall impact and
environmental footprint left by the company through its business activities, as well as after a thorough review of the
available public information on the corporate website, articles and news about the company
The rating was assigned by Sustainalytics – a company, part of the Morningstar structure, which is a globally
recognized supplier of ESG researches, ratings, and data The corporate ESG assessment given to Bulgarian Energy
Holding EAD is a one-time assessment that is valid at the time of its assignment and it is prepared on the basis of the
information provided by Bulgarian Energy Holding EAD. The ESG risk assessment report includes a general ESG
risk rating, an assessment of the Company’s exposure and an assessment of its governance. Exposure refers to the
extent to which the Company is exposed to various material risks related to environmental, social, and governance
aspects. The governance assessment shows how well the Company manages these aspects.
As of 31 December 2024, BEH Group's ESG rating as determined by Sustainalytics is 35.5 points (“high risk”). BEH's
ESG Risk Score, which refers to the extent to which the company is exposed to various material risks related to
environmental, social, and governance aspects, is 53.8 points (“medium risk”). The governance score reflecting how
well the company manages these aspects is 36.8 points (“average performance”).
Principle – assumption of a going concern
The sole shareholder of the Company is the Bulgarian State through the Minister of Energy, in their capacity as
Principal. The functioning and the future development of the Company is entirely dependent on the future intentions
and strategy of the state regarding the continuation of its functions and activities within the energy sector in Bulgaria.
The management has analyzed the validity of the going concern assumption, taking into account the principal’s
intentions in the short and medium term. As a result, it has come to the conclusion that the use of the going concern
assumption is appropriate. Management has also taken into account the available information on the foreseeable
future, the above-described circumstances related to macroeconomic factors and the ongoing war between Russia and
Ukraine, the Bulgarian Recovery and Resilience Plan, approved by the EU, and the dynamics of the energy market
globally and in Bulgaria. In addition, as at 31 December 2024 current liabilities exceed current assets by BGN 323,861
thousand. Included in current liabilities is a liability of BGN 1,206,731 thousand for bonds issued, of which BGN
1,193,971 thousand is for a bond issue maturing on 28 June 2025. In accordance with the Company's adopted Business
Program, the Company will refinance the bond issue maturing on 30 June 2025 with a new bond issue in 2025. The
Board of Directors expects that the Company will have sufficient financial resources to continue in operation for the
foreseeable future and will continue to apply the going concern basis in preparing the Independent Financial
Statements.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
10
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
3.Changes in the accounting policy
3.1. General
For the current financial year, the Company has adopted all new and/or revised standards and interpretations issued
by the International Accounting Standards Board (IASB) and adopted by the EU and by the IFRS Interpretations
Committee, respectively, which enter into force on 1 January 2024, but these do not have a significant effect on the
Company's separate financial statement. The Company has not adopted standards, interpretations or amendments,
which are published, but still not effective.
3.2. New standards, amendments and interpretations to IFRS accounting standards effective from 1 January
2024.
Amendments to IAS 1 Presentation of Financial Statements: Classification of liabilities as current and non -
current, effective from 1 January 2024, adopted by the EU
Changes in the classification of liabilities as current or non-current affect only the presentation of liabilities in the
statement of financial state, but not their amount, the time of assets, liabilities, income or expenses, or the information
recognition, which the companies disclose concerning these items. The amendments are intended to clarify the
following:
• classification of liabilities as current or non-current should be based on rights existing at the end of the
reporting period, and all affected paragraphs of the standard now use the same term, namely the ‘right’ to
defer settlement of the liability by at least twelve months. It is expressly stated that only available rights ‘at
the end of the reporting period’ should affect the classification of the liability;
• classification is not affected by the entity's expectation of whether it will exercise its right to defer settlement
of the liability; and
• the liabilities settlement may be affected by transferring cash, equity instruments, other assets or services to
the counterparty.
Amendments to IAS 1 Presentation of Financial Statements: Non-current liabilities linked to financial
indicators, effective from 1 January 2024, adopted by the EU
IAS 1 is amended as follows:
• It is specified that if the right to defer settlement for at least 12 months is subject to conditions being met by
the entity after the reporting period, then those conditions shall not affect whether the right to defer settlement
exists at the end of the reporting period (the reporting date) for the purposes of classifying the liability as a
current or a non-current one; and
• for non-current liabilities, subject to conditions, the entity is required to disclose information about:
o the conditions (e.g. the nature and date by which the entity must comply with the condition);
o whether the entity would have complied with the conditions based on the circumstances at the
reporting date; and
o whether and how the entity expects to comply with the conditions by the date on which the financial
measures are to be calculated under the contract.
Amendments in IFRS 16 Leases: Lease liabilities on sale and leaseback effective from 1 January 2024, adopted
by the EU
The amendments to IFRS 16 require an entity that is a seller-lessee to subsequently measure lease liabilities arising
from a leaseback in a way that does not recognize any amount of profit or loss that relates to the right of use that it
retains. The new requirements do not prevent the seller-lessee from recognizing the gain or loss associated with the
partial or full termination of the lease contract in the current profit or loss. The amendments to IFRS 16 do not prescribe
specific measurement requirements for lease liabilities arising from a leaseback.
Amendments to IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments: Disclosures: Agreements
for funding suppliers, effective from 1 January 2024, adopted by the EU
The amendments to IAS 7 and IFRS 7 add disclosure requirements as well as guidance within existing disclosure
requirements related to the provision of qualitative and quantitative information about supplier obligation financing
arrangements. These amendments add two disclosure objectives that will require entities to disclose in the notes
information that enables users of financial statements to assess how supplier financing arrangements affect an entity's
liabilities and cash flows and to understand the effect of supplier financing arrangements on an entity's exposure to
liquidity risk and how an entity may be affected if the arrangements are no longer available to it.
Separate financial statements
31 December 2024
10
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
3.Changes in the accounting policy
3.1. General
For the current financial year, the Company has adopted all new and/or revised standards and interpretations issued
by the International Accounting Standards Board (IASB) and adopted by the EU and by the IFRS Interpretations
Committee, respectively, which enter into force on 1 January 2024, but these do not have a significant effect on the
Company's separate financial statement. The Company has not adopted standards, interpretations or amendments,
which are published, but still not effective.
3.2. New standards, amendments and interpretations to IFRS accounting standards effective from 1 January
2024.
Amendments to IAS 1 Presentation of Financial Statements: Classification of liabilities as current and non -
current, effective from 1 January 2024, adopted by the EU
Changes in the classification of liabilities as current or non-current affect only the presentation of liabilities in the
statement of financial state, but not their amount, the time of assets, liabilities, income or expenses, or the information
recognition, which the companies disclose concerning these items. The amendments are intended to clarify the
following:
• classification of liabilities as current or non-current should be based on rights existing at the end of the
reporting period, and all affected paragraphs of the standard now use the same term, namely the ‘right’ to
defer settlement of the liability by at least twelve months. It is expressly stated that only available rights ‘at
the end of the reporting period’ should affect the classification of the liability;
• classification is not affected by the entity's expectation of whether it will exercise its right to defer settlement
of the liability; and
• the liabilities settlement may be affected by transferring cash, equity instruments, other assets or services to
the counterparty.
Amendments to IAS 1 Presentation of Financial Statements: Non-current liabilities linked to financial
indicators, effective from 1 January 2024, adopted by the EU
IAS 1 is amended as follows:
• It is specified that if the right to defer settlement for at least 12 months is subject to conditions being met by
the entity after the reporting period, then those conditions shall not affect whether the right to defer settlement
exists at the end of the reporting period (the reporting date) for the purposes of classifying the liability as a
current or a non-current one; and
• for non-current liabilities, subject to conditions, the entity is required to disclose information about:
o the conditions (e.g. the nature and date by which the entity must comply with the condition);
o whether the entity would have complied with the conditions based on the circumstances at the
reporting date; and
o whether and how the entity expects to comply with the conditions by the date on which the financial
measures are to be calculated under the contract.
Amendments in IFRS 16 Leases: Lease liabilities on sale and leaseback effective from 1 January 2024, adopted
by the EU
The amendments to IFRS 16 require an entity that is a seller-lessee to subsequently measure lease liabilities arising
from a leaseback in a way that does not recognize any amount of profit or loss that relates to the right of use that it
retains. The new requirements do not prevent the seller-lessee from recognizing the gain or loss associated with the
partial or full termination of the lease contract in the current profit or loss. The amendments to IFRS 16 do not prescribe
specific measurement requirements for lease liabilities arising from a leaseback.
Amendments to IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments: Disclosures: Agreements
for funding suppliers, effective from 1 January 2024, adopted by the EU
The amendments to IAS 7 and IFRS 7 add disclosure requirements as well as guidance within existing disclosure
requirements related to the provision of qualitative and quantitative information about supplier obligation financing
arrangements. These amendments add two disclosure objectives that will require entities to disclose in the notes
information that enables users of financial statements to assess how supplier financing arrangements affect an entity's
liabilities and cash flows and to understand the effect of supplier financing arrangements on an entity's exposure to
liquidity risk and how an entity may be affected if the arrangements are no longer available to it.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
11
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
3.3. Standards, amendments and interpretations not yet effective and not applied by the Company from an
earlier date
The following new standard is not effective and has not been adopted by the EU for the financial year beginning 1
January 2024 and has not been applied by the Company as of an earlier date, but is expected to have an effect on
disclosures in the future financial statements:
IFRS 18 Presentation and Disclosures in Financial Statements, effective 1 January 2027, not yet adopted by the
EU
IFRS 18 aims to improve the way entities disclose their financial statements, with a focus on financial performance
information in the income statement. IFRS 18 is accompanied by limited amendments to the requirements in IAS 7
Statement of Cash Flows. IFRS 18 is effective from 1 January 2027. Companies are permitted to apply IFRS 18 before
that date. IFRS 18 replaces IAS 1 Financial statements presentation. The requirements described in IAS 1 that have
not changed have been transferred to IFRS 18 and other standards. IFRS 18 will affect all entities in all industries.
Although IFRS 18 will not affect how companies measure financial performance, it will affect how companies present
and disclose financial performance. IFRS 18 aims to improve financial reporting by:
• requirement for additional defined subtotals in the profit and loss statement; The addition of defined subtotals
to the profit and loss statement facilitates the comparison of entities' financial performance and provides a
consistent point of reference for investor analysis.
• requirement to disclose performance measures determined by management. Requiring companies to disclose
information on management-defined performance indicators increases discipline in their use and
transparency in their calculation.
• adding new principles for grouping (aggregation and disaggregation) of information. Specifying
requirements for whether information should be in the main financial statements or in the notes and providing
principles for the level of detail required improves the effective communication of information.
At the date of approval of this separate financial statement, the following new standards, amendments and
interpretations to existing standards have also been issued but are not effective or adopted by the EU for the financial
year beginning 1 January 2024 and have not been previously adopted by the Company. They are not expected to have
a material impact on the Company's financial statements:
- Amendments to IAS 21 Effects of Changes in Foreign Exchange Rates: No convertibility, effective from 1
January 2025, not yet adopted by the EU;
- Annual improvements, effective from 1 January 2026, not yet adopted by the EU;
- Amendments to the classification and measurement of financial instruments (amendments to IFRS 9 and
IFRS 7), effective from 1 January 2026, not yet adopted by the EU;
- IFRS 19 Subsidiaries without public reporting: Disclosures, effective from 1 January 2027, not yet adopted
by the EU.
4.Material Accounting Policy Information
4.1 General
The most significant accounting policies applied in the preparation of this separate financial statement are set out
below.
The separate financial statement has been prepared in accordance with the principles for evaluation of all types of
assets, liabilities, income and expenses under the IFRS accounting standards. The valuation bases are disclosed in
detail later in the accounting policy to the separate financial statement.
It should be noted that accounting estimates and assumptions have been used in the preparation of the separate
financial statement presented. Although these are based on information provided to management at the date of the
separate financial statements, actual results may differ from the estimates and assumptions made.
The presentation of the separate financial statement in conformity with IFRS accounting standards requires
management to make best estimates, accruals and reasonable assumptions that affect the reported amounts of assets
and liabilities, income and expenses and disclosure of contingent assets and liabilities at the end of the reporting
period. These estimates, accruals and assumptions are based on information available at the end of the reporting period,
so future actual results may differ. Items that involve a higher degree of subjective judgment or calculation complexity,
or where assumptions and accounting estimates are significant to the financial statement, are disclosed in Note 4.19.
Separate financial statements
31 December 2024
11
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
3.3. Standards, amendments and interpretations not yet effective and not applied by the Company from an
earlier date
The following new standard is not effective and has not been adopted by the EU for the financial year beginning 1
January 2024 and has not been applied by the Company as of an earlier date, but is expected to have an effect on
disclosures in the future financial statements:
IFRS 18 Presentation and Disclosures in Financial Statements, effective 1 January 2027, not yet adopted by the
EU
IFRS 18 aims to improve the way entities disclose their financial statements, with a focus on financial performance
information in the income statement. IFRS 18 is accompanied by limited amendments to the requirements in IAS 7
Statement of Cash Flows. IFRS 18 is effective from 1 January 2027. Companies are permitted to apply IFRS 18 before
that date. IFRS 18 replaces IAS 1 Financial statements presentation. The requirements described in IAS 1 that have
not changed have been transferred to IFRS 18 and other standards. IFRS 18 will affect all entities in all industries.
Although IFRS 18 will not affect how companies measure financial performance, it will affect how companies present
and disclose financial performance. IFRS 18 aims to improve financial reporting by:
• requirement for additional defined subtotals in the profit and loss statement; The addition of defined subtotals
to the profit and loss statement facilitates the comparison of entities' financial performance and provides a
consistent point of reference for investor analysis.
• requirement to disclose performance measures determined by management. Requiring companies to disclose
information on management-defined performance indicators increases discipline in their use and
transparency in their calculation.
• adding new principles for grouping (aggregation and disaggregation) of information. Specifying
requirements for whether information should be in the main financial statements or in the notes and providing
principles for the level of detail required improves the effective communication of information.
At the date of approval of this separate financial statement, the following new standards, amendments and
interpretations to existing standards have also been issued but are not effective or adopted by the EU for the financial
year beginning 1 January 2024 and have not been previously adopted by the Company. They are not expected to have
a material impact on the Company's financial statements:
- Amendments to IAS 21 Effects of Changes in Foreign Exchange Rates: No convertibility, effective from 1
January 2025, not yet adopted by the EU;
- Annual improvements, effective from 1 January 2026, not yet adopted by the EU;
- Amendments to the classification and measurement of financial instruments (amendments to IFRS 9 and
IFRS 7), effective from 1 January 2026, not yet adopted by the EU;
- IFRS 19 Subsidiaries without public reporting: Disclosures, effective from 1 January 2027, not yet adopted
by the EU.
4.Material Accounting Policy Information
4.1 General
The most significant accounting policies applied in the preparation of this separate financial statement are set out
below.
The separate financial statement has been prepared in accordance with the principles for evaluation of all types of
assets, liabilities, income and expenses under the IFRS accounting standards. The valuation bases are disclosed in
detail later in the accounting policy to the separate financial statement.
It should be noted that accounting estimates and assumptions have been used in the preparation of the separate
financial statement presented. Although these are based on information provided to management at the date of the
separate financial statements, actual results may differ from the estimates and assumptions made.
The presentation of the separate financial statement in conformity with IFRS accounting standards requires
management to make best estimates, accruals and reasonable assumptions that affect the reported amounts of assets
and liabilities, income and expenses and disclosure of contingent assets and liabilities at the end of the reporting
period. These estimates, accruals and assumptions are based on information available at the end of the reporting period,
so future actual results may differ. Items that involve a higher degree of subjective judgment or calculation complexity,
or where assumptions and accounting estimates are significant to the financial statement, are disclosed in Note 4.19.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
12
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
4.2 Presentation of the separate financial statement and comparative information
The separate financial statement is presented in accordance with IAS 1 Presentation of Financial Statements. The
Company has adopted the presentation of the separate profit and loss report of and other comprehensive income in
two separate statements: a profit and loss report and a statement of comprehensive income.
Two comparative periods are presented in the separate statement of financial position when the Company applies an
accounting policy retrospectively, retrospectively restates financial statement items or reclassifies financial statement
items and this has a material effect on the information in the separate statement of financial position at the beginning
of the previous period.
4.3 Foreign currency transactions
Transactions in foreign currency are reported in the functional currency of the Company at the official exchange rate
at the date of the transaction (the Bulgarian National Bank’s fixed exchange rate). The foreign exchange gains and
losses resulting from the settlement of such transactions and the revaluation of foreign currency monetary items at the
end of the reporting period are recognized in profit or loss.
Non-monetary items valued at historical cost in foreign currency are reported at the exchange rate at the date of the
transaction (they are not revalued). Non-monetary items measured at fair value in a foreign currency are translated at
the exchange rate at the date that the fair value was determined.
4.4 Revenue recognition
Recognizing and evaluating revenue from client contracts
Revenue from contracts with clients is recognized when control of the goods and/or services promised in the contract,
is transferred to the client in an amount that reflects the remuneration the Company expects to be entitled to in
exchange for those goods or services.
The control is transferred to the customer when (or as) he/she meets the obligation to perform, according to the terms
of the contract, by transferring the promised goods or services to the customer. An asset (good or service) is transferred
when (or as) the customer gains control over that asset.
In the initial evaluation of its contracts with clients, the Company assesses whether two or more contracts should be
considered in combination and accounted for as one, and whether the goods and/or services promised in each separate
and/or combined contract should be accounted for as one and/or more performance obligations.
Any promise to transfer goods and / or services that are distinguishable (in themselves and in the context of the
contract) is accounted for as a single performance obligation.
The Company recognizes revenue for each individual performance obligation at the level of a separate contract with
a client by analyzing the type, term and conditions of each specific contract. In the case of contracts with similar
characteristics, revenue is recognized on a portfolio basis only if grouping it in a portfolio would not have a materially
different effect on the financial statements.
Contracts with customers usually involve a single performance.
Assessment
Revenue is measured on the basis of the transaction price specified for each contract.
In determining the transaction price, the Company takes into account the terms and conditions of the contract and its
usual business practices.
The transaction price is the amount of the remuneration the Company expects to be entitled to in exchange for the
transfer of the promised goods or services to the client, except for amounts collected on behalf of third parties (e.g.
value added tax). The remuneration promised in the contract with the customer may include fixed amounts, variable
amounts, or both.
When (or as) a performance obligation is met, the Company recognizes as income the cost of the transaction (which
excludes estimates of variable remuneration containing limitations), that is attributable to that obligation to perform.
The Company examines whether there are other promises in the contract that are separate performance obligations,
for which part of the transaction price should be allocated.
Separate financial statements
31 December 2024
12
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
4.2 Presentation of the separate financial statement and comparative information
The separate financial statement is presented in accordance with IAS 1 Presentation of Financial Statements. The
Company has adopted the presentation of the separate profit and loss report of and other comprehensive income in
two separate statements: a profit and loss report and a statement of comprehensive income.
Two comparative periods are presented in the separate statement of financial position when the Company applies an
accounting policy retrospectively, retrospectively restates financial statement items or reclassifies financial statement
items and this has a material effect on the information in the separate statement of financial position at the beginning
of the previous period.
4.3 Foreign currency transactions
Transactions in foreign currency are reported in the functional currency of the Company at the official exchange rate
at the date of the transaction (the Bulgarian National Bank’s fixed exchange rate). The foreign exchange gains and
losses resulting from the settlement of such transactions and the revaluation of foreign currency monetary items at the
end of the reporting period are recognized in profit or loss.
Non-monetary items valued at historical cost in foreign currency are reported at the exchange rate at the date of the
transaction (they are not revalued). Non-monetary items measured at fair value in a foreign currency are translated at
the exchange rate at the date that the fair value was determined.
4.4 Revenue recognition
Recognizing and evaluating revenue from client contracts
Revenue from contracts with clients is recognized when control of the goods and/or services promised in the contract,
is transferred to the client in an amount that reflects the remuneration the Company expects to be entitled to in
exchange for those goods or services.
The control is transferred to the customer when (or as) he/she meets the obligation to perform, according to the terms
of the contract, by transferring the promised goods or services to the customer. An asset (good or service) is transferred
when (or as) the customer gains control over that asset.
In the initial evaluation of its contracts with clients, the Company assesses whether two or more contracts should be
considered in combination and accounted for as one, and whether the goods and/or services promised in each separate
and/or combined contract should be accounted for as one and/or more performance obligations.
Any promise to transfer goods and / or services that are distinguishable (in themselves and in the context of the
contract) is accounted for as a single performance obligation.
The Company recognizes revenue for each individual performance obligation at the level of a separate contract with
a client by analyzing the type, term and conditions of each specific contract. In the case of contracts with similar
characteristics, revenue is recognized on a portfolio basis only if grouping it in a portfolio would not have a materially
different effect on the financial statements.
Contracts with customers usually involve a single performance.
Assessment
Revenue is measured on the basis of the transaction price specified for each contract.
In determining the transaction price, the Company takes into account the terms and conditions of the contract and its
usual business practices.
The transaction price is the amount of the remuneration the Company expects to be entitled to in exchange for the
transfer of the promised goods or services to the client, except for amounts collected on behalf of third parties (e.g.
value added tax). The remuneration promised in the contract with the customer may include fixed amounts, variable
amounts, or both.
When (or as) a performance obligation is met, the Company recognizes as income the cost of the transaction (which
excludes estimates of variable remuneration containing limitations), that is attributable to that obligation to perform.
The Company examines whether there are other promises in the contract that are separate performance obligations,
for which part of the transaction price should be allocated.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
13
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
When determining the transaction price, account is taken of the impact of variable remuneration, the existence of
significant components of funding, non-monetary remuneration, and remuneration owed to the client (if any).
Performance obligations and recognition approach to main types of revenue under customer contracts
Revenues from services
Revenue from provision of services is recognized in the accounting period in which the services are provided. The
Company transfers control of the services over time and therefore satisfies the obligation to perform and recognizes
revenue over time. If at the end of the reporting period the service under the contract is not fully performed, revenue
is recognized on the basis of the actual service provided by the end of the reporting period, as a proportion of the total
services to be provided because the client receives and consumes benefits simultaneously. This is determined on the
basis of the actual time spent on work performed, relative to the total expected time to perform the service.
The client pays for the services provided on the basis of the clauses set out in the specific contract. The ordinary credit
period is from 10 to 30 days after the provision of the services. In cases where the services provided by the Company
exceed the payment, an asset under the contract is recognized. If the payments exceed the services provided, a liability
under the contract is recognized.
Proceeds from sales of current assets
Revenues from sales of short-term assets and materials are recognized when the control of the assets sold is transferred.
Delivery occurs when the assets have been sent to the customer, the risks of potential losses have been transferred to
the buyer and he/she has accepted the assets in accordance with the sales contract. The usual payment term is within
30 days after delivery.
Principal or agent
When a third party participates in the provision of goods or services to a client, the Company determines whether the
nature of their promise is an obligation to perform, related to the provision of the particular goods or services
(principal), or to arrange for the third party to provide those goods or services (agent).
The Company is the principal when it controls the promised commodity or service before transferring it to the client.
Nevertheless, the Company does not necessarily act as the principal if it receives the ownership of an asset only
temporarily, before the ownership right is transferred to the client.
The Company is an agent if the Company’s obligation to perform is to arrange the delivery of the goods or services
from a third party. When an agent company fulfils an obligation to perform, it recognizes revenue at the amount of a
fee or commission it expects to be entitled to in exchange for arranging for the goods and services to be provided by
another party. The fee or commission of the Company may be the net amount of remuneration the Company retains
after paying to the other party the consideration received in exchange for the goods or services to be provided by that
party.
The Company is an agent in its contracts for the sale of greenhouse gas emission allowances with the subsidiary TPP
Maritsa East 2 EAD.
Significant accounting assessments, estimates and assumptions relating to income from contracts with clients, are
presented in note 4.19.
Contractual balances
Trade receivables and assets under contracts
The receivable is the right of the Company to receive remuneration of a certain amount, which is unconditional (i.e.
before the payment of the remuneration becomes due, it is only necessary that a certain period of time expires).
The asset under a contract is the right of the Company to receive remuneration in return for the goods or services it
has transferred to the client, but which is not unconditional (the accrual of the receivable). If, through the transfer of
the goods and / or the provision of the services, the Company fulfils its obligation before the client pays the relevant
remuneration and / or before the payment becomes due, a contract asset is recognized for the earned remuneration
(which is conditional). Recognized assets under a contract are reclassified as a trade receivable when the right to
remuneration becomes unconditional.
Contract liabilities
As a liability under a contract, the Company represents payments received from the client and/or an unconditional
right to receive payment before it has fulfilled its performance obligations under the contract. Contract liabilities are
recognized as income when (or as) the performance obligations are met.
Separate financial statements
31 December 2024
13
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
When determining the transaction price, account is taken of the impact of variable remuneration, the existence of
significant components of funding, non-monetary remuneration, and remuneration owed to the client (if any).
Performance obligations and recognition approach to main types of revenue under customer contracts
Revenues from services
Revenue from provision of services is recognized in the accounting period in which the services are provided. The
Company transfers control of the services over time and therefore satisfies the obligation to perform and recognizes
revenue over time. If at the end of the reporting period the service under the contract is not fully performed, revenue
is recognized on the basis of the actual service provided by the end of the reporting period, as a proportion of the total
services to be provided because the client receives and consumes benefits simultaneously. This is determined on the
basis of the actual time spent on work performed, relative to the total expected time to perform the service.
The client pays for the services provided on the basis of the clauses set out in the specific contract. The ordinary credit
period is from 10 to 30 days after the provision of the services. In cases where the services provided by the Company
exceed the payment, an asset under the contract is recognized. If the payments exceed the services provided, a liability
under the contract is recognized.
Proceeds from sales of current assets
Revenues from sales of short-term assets and materials are recognized when the control of the assets sold is transferred.
Delivery occurs when the assets have been sent to the customer, the risks of potential losses have been transferred to
the buyer and he/she has accepted the assets in accordance with the sales contract. The usual payment term is within
30 days after delivery.
Principal or agent
When a third party participates in the provision of goods or services to a client, the Company determines whether the
nature of their promise is an obligation to perform, related to the provision of the particular goods or services
(principal), or to arrange for the third party to provide those goods or services (agent).
The Company is the principal when it controls the promised commodity or service before transferring it to the client.
Nevertheless, the Company does not necessarily act as the principal if it receives the ownership of an asset only
temporarily, before the ownership right is transferred to the client.
The Company is an agent if the Company’s obligation to perform is to arrange the delivery of the goods or services
from a third party. When an agent company fulfils an obligation to perform, it recognizes revenue at the amount of a
fee or commission it expects to be entitled to in exchange for arranging for the goods and services to be provided by
another party. The fee or commission of the Company may be the net amount of remuneration the Company retains
after paying to the other party the consideration received in exchange for the goods or services to be provided by that
party.
The Company is an agent in its contracts for the sale of greenhouse gas emission allowances with the subsidiary TPP
Maritsa East 2 EAD.
Significant accounting assessments, estimates and assumptions relating to income from contracts with clients, are
presented in note 4.19.
Contractual balances
Trade receivables and assets under contracts
The receivable is the right of the Company to receive remuneration of a certain amount, which is unconditional (i.e.
before the payment of the remuneration becomes due, it is only necessary that a certain period of time expires).
The asset under a contract is the right of the Company to receive remuneration in return for the goods or services it
has transferred to the client, but which is not unconditional (the accrual of the receivable). If, through the transfer of
the goods and / or the provision of the services, the Company fulfils its obligation before the client pays the relevant
remuneration and / or before the payment becomes due, a contract asset is recognized for the earned remuneration
(which is conditional). Recognized assets under a contract are reclassified as a trade receivable when the right to
remuneration becomes unconditional.
Contract liabilities
As a liability under a contract, the Company represents payments received from the client and/or an unconditional
right to receive payment before it has fulfilled its performance obligations under the contract. Contract liabilities are
recognized as income when (or as) the performance obligations are met.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
14
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Assets and liabilities arising from a contract shall be presented net in the separate statement of financial position, even
if they result from different contractual obligations to perform the contract.
Subsequent to initial recognition, trade receivables and contract assets are reviewed for impairment in accordance
with the rules of IFRS 9 Financial Instruments.
Dividend income
The dividend income is recognized when the right for its receipt is established.
Interest income
Interest income is calculated by applying the effective interest rate on the gross carrying amount of financial assets
except for financial assets which are impaired (Phase 3) for which interest income is calculated by applying the
effective interest rate on their amortized value (i.e. the gross book value adjusted for the loss provision).
Net profit from sale of property, plant and equipment
Profit or losses arising on the derecognition of property, plant and equipment or an intangible asset as a result of a sale
are included in profit or loss when the asset is derecognized. The asset is derecognized at the time control of the asset
being sold is transferred.
4.5 Expenses
Expenses are recognized as incurred and on an accruals and comparability basis and to the extent that this would not
result in the recognition of assets/liabilities that do not meet the definitions of such under IFRS accounting standards.
Prepaid expenses are deferred for derecognition as current expenses in the period to which they relate.
4.6 Taxes
Current income tax
Current taxes on Company profits are determined in accordance with the requirements of the Bulgarian tax legislation
– the Corporate Income Tax Act. The nominal tax rate in Bulgaria for 2024 is 10% (2023: 10%). Current tax assets
and liabilities for the current and prior periods are recognized at the amount expected to be recovered from or paid to
the tax authorities.
Deferred tax
Deferred tax is provided using the balance sheet method, providing for temporary differences as of the reporting date,
arising between the tax bases of assets and liabilities and their carrying amounts in the financial statements.
Deferred tax liabilities are recognized for all taxable temporary differences:
• except to the extent that the deferred tax liability arises from the initial recognition of an asset or liability of
a transaction that is not a business combination and affects neither accounting profit nor tax profit or loss at
the time of the transaction; and
• for taxable temporary differences related to investments in subsidiaries, associates and interests in joint
ventures, except to the extent that the Company is able to control the timing of the reversal of the temporary
difference and the temporary difference is unlikely to reverse in the foreseeable future.
Deferred tax assets are recognized for all deductible temporary differences, unused tax credits carried forward and
unused tax losses, to the extent that it is probable that taxable profit will be available against which the deductible
temporary differences, deferred tax credits carried forward and unused tax credits can be utilized losses:
• unless the deferred tax asset arises from the initial recognition of an asset or liability of a transaction that is
not a business combination and does not affect either the accounting profit or the tax profit or loss at the
time of the transaction; and
• for deductible temporary differences related to investments in subsidiaries, associates and interests in joint
ventures, a deferred tax asset is recognized only to the extent that the temporary difference is likely to reverse
in the foreseeable future and to generate taxable profit, against to take advantage of the temporary difference.
The Company reviews the carrying amount of deferred tax assets at each reporting date and reduces it to the extent
that it is no longer probable that sufficient taxable profit will be available allowing for all or part of the deferred tax
asset to be recovered. Unrecognized deferred tax assets are reviewed at each reporting date and are recognized to the
Separate financial statements
31 December 2024
14
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Assets and liabilities arising from a contract shall be presented net in the separate statement of financial position, even
if they result from different contractual obligations to perform the contract.
Subsequent to initial recognition, trade receivables and contract assets are reviewed for impairment in accordance
with the rules of IFRS 9 Financial Instruments.
Dividend income
The dividend income is recognized when the right for its receipt is established.
Interest income
Interest income is calculated by applying the effective interest rate on the gross carrying amount of financial assets
except for financial assets which are impaired (Phase 3) for which interest income is calculated by applying the
effective interest rate on their amortized value (i.e. the gross book value adjusted for the loss provision).
Net profit from sale of property, plant and equipment
Profit or losses arising on the derecognition of property, plant and equipment or an intangible asset as a result of a sale
are included in profit or loss when the asset is derecognized. The asset is derecognized at the time control of the asset
being sold is transferred.
4.5 Expenses
Expenses are recognized as incurred and on an accruals and comparability basis and to the extent that this would not
result in the recognition of assets/liabilities that do not meet the definitions of such under IFRS accounting standards.
Prepaid expenses are deferred for derecognition as current expenses in the period to which they relate.
4.6 Taxes
Current income tax
Current taxes on Company profits are determined in accordance with the requirements of the Bulgarian tax legislation
– the Corporate Income Tax Act. The nominal tax rate in Bulgaria for 2024 is 10% (2023: 10%). Current tax assets
and liabilities for the current and prior periods are recognized at the amount expected to be recovered from or paid to
the tax authorities.
Deferred tax
Deferred tax is provided using the balance sheet method, providing for temporary differences as of the reporting date,
arising between the tax bases of assets and liabilities and their carrying amounts in the financial statements.
Deferred tax liabilities are recognized for all taxable temporary differences:
• except to the extent that the deferred tax liability arises from the initial recognition of an asset or liability of
a transaction that is not a business combination and affects neither accounting profit nor tax profit or loss at
the time of the transaction; and
• for taxable temporary differences related to investments in subsidiaries, associates and interests in joint
ventures, except to the extent that the Company is able to control the timing of the reversal of the temporary
difference and the temporary difference is unlikely to reverse in the foreseeable future.
Deferred tax assets are recognized for all deductible temporary differences, unused tax credits carried forward and
unused tax losses, to the extent that it is probable that taxable profit will be available against which the deductible
temporary differences, deferred tax credits carried forward and unused tax credits can be utilized losses:
• unless the deferred tax asset arises from the initial recognition of an asset or liability of a transaction that is
not a business combination and does not affect either the accounting profit or the tax profit or loss at the
time of the transaction; and
• for deductible temporary differences related to investments in subsidiaries, associates and interests in joint
ventures, a deferred tax asset is recognized only to the extent that the temporary difference is likely to reverse
in the foreseeable future and to generate taxable profit, against to take advantage of the temporary difference.
The Company reviews the carrying amount of deferred tax assets at each reporting date and reduces it to the extent
that it is no longer probable that sufficient taxable profit will be available allowing for all or part of the deferred tax
asset to be recovered. Unrecognized deferred tax assets are reviewed at each reporting date and are recognized to the
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
15
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
extent that it is probable that future taxable profits will be available against which the deferred tax asset can be
recovered.
Deferred tax assets and liabilities are measured at the tax rates that are expected to apply in the period in which the
asset is realized or the liability is settled, based on the tax rates (and tax laws) that are in force or enacted, to a
significant extent, at the date of the separate statement of financial position. As of 31 December 2024, the Company's
deferred income taxes have been measured at the rate effective for 2024 of 10% (2023: 10%).
Deferred taxes related to items that are reported as other components of comprehensive income or equity in the
separate statement of financial position are also reported directly to the related component of comprehensive income
or balance sheet equity.
The Company offsets deferred tax assets and liabilities only when it has the legal right to deduct current tax assets
from current tax liabilities and the deferred tax assets and liabilities relate to income taxes levied by the same tax
authority on the same taxable entity.
Additional tax
Due to the size of the BEH Group's business activities, the Company is subject to additional corporate tax requirements
pursuant to the amendments to the Corporate Income Tax Act, which are in effect from 1 January 2024.
The requirements of the Second Pillar of Taxation have been transposed into Bulgarian law and became effective on
1 January 2024. During the period, the Company's management has assessed the applicable tax legislation to determine
the potential exposure to tax liabilities under the Second Pillar and has concluded that the Company will incur
additional national tax liability under Art. 260я 25 of the Corporate Income Tax Act for 2024 (note 16).
Value Added Tax (VAT)
Revenue, expenses and assets are recognized net of VAT, except when:
• VAT arising from the purchase of assets or services is not refundable by the tax authorities, in which case
VAT is recognized as part of the cost of acquisition of the asset or as part of the relevant item of expenditure,
as appropriate; and
• receivables and payables are reported with VAT included.
The net amount of VAT recoverable from or payable to the tax authorities is included in the value of receivables or
payables in the separate statement of financial position.
4.7 Pension and other liabilities to employees
Short-term income
The short-term compensation for employees in the form of wages, bonuses and social security payments and benefits
(due for settlement within 12 months after the end of the period in which the personnel worked for them or met the
conditions for receiving them) are recognized as an expense in the separate profit and loss report, unless an IFRS
accounting standard requires that amount to be capitalized in the cost of an asset in the period in which labor is
expended for them and/or the requirements for their receipt as a current liability are met (net of any amounts already
paid and deductions due).
The Company reports short-term obligations under compensable leaves, occurred on the basis of unused annual leave
in the cases, in which is expected the leaves to arise within 12 months following the date of the reporting period,
during which the hired individuals have rendered the labor, related to these leaves. At the date of each financial
statement, the Company makes assessment of the amount of the expected costs under the accruing compensable leaves,
which is expected to be paid as a result of unused right of accrued leave. The assessment includes the approximate
estimate of the amounts for the remunerations themselves and of the contributions for the obligatory social and health
insurance, which the employer owes on these amounts.
Long-term retirement income
The Company owes retirement benefits to its employees under defined benefit plans and defined contribution plans.
Defined contribution plans
Defined contribution plans are retirement plans under which the Company pays fixed contributions into state funds.
The main obligation of the employer is to provide compulsory insurance of the hired staff for the Pension Fund,
Supplementary Compulsory Pension Insurance (SCPI), General Sickness and Maternity Fund (GSMF),
Unemployment Fund, Occupational Accident and Sickness Fund (OASF) and health insurance (HI).
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extent that it is probable that future taxable profits will be available against which the deferred tax asset can be
recovered.
Deferred tax assets and liabilities are measured at the tax rates that are expected to apply in the period in which the
asset is realized or the liability is settled, based on the tax rates (and tax laws) that are in force or enacted, to a
significant extent, at the date of the separate statement of financial position. As of 31 December 2024, the Company's
deferred income taxes have been measured at the rate effective for 2024 of 10% (2023: 10%).
Deferred taxes related to items that are reported as other components of comprehensive income or equity in the
separate statement of financial position are also reported directly to the related component of comprehensive income
or balance sheet equity.
The Company offsets deferred tax assets and liabilities only when it has the legal right to deduct current tax assets
from current tax liabilities and the deferred tax assets and liabilities relate to income taxes levied by the same tax
authority on the same taxable entity.
Additional tax
Due to the size of the BEH Group's business activities, the Company is subject to additional corporate tax requirements
pursuant to the amendments to the Corporate Income Tax Act, which are in effect from 1 January 2024.
The requirements of the Second Pillar of Taxation have been transposed into Bulgarian law and became effective on
1 January 2024. During the period, the Company's management has assessed the applicable tax legislation to determine
the potential exposure to tax liabilities under the Second Pillar and has concluded that the Company will incur
additional national tax liability under Art. 260я 25 of the Corporate Income Tax Act for 2024 (note 16).
Value Added Tax (VAT)
Revenue, expenses and assets are recognized net of VAT, except when:
• VAT arising from the purchase of assets or services is not refundable by the tax authorities, in which case
VAT is recognized as part of the cost of acquisition of the asset or as part of the relevant item of expenditure,
as appropriate; and
• receivables and payables are reported with VAT included.
The net amount of VAT recoverable from or payable to the tax authorities is included in the value of receivables or
payables in the separate statement of financial position.
4.7 Pension and other liabilities to employees
Short-term income
The short-term compensation for employees in the form of wages, bonuses and social security payments and benefits
(due for settlement within 12 months after the end of the period in which the personnel worked for them or met the
conditions for receiving them) are recognized as an expense in the separate profit and loss report, unless an IFRS
accounting standard requires that amount to be capitalized in the cost of an asset in the period in which labor is
expended for them and/or the requirements for their receipt as a current liability are met (net of any amounts already
paid and deductions due).
The Company reports short-term obligations under compensable leaves, occurred on the basis of unused annual leave
in the cases, in which is expected the leaves to arise within 12 months following the date of the reporting period,
during which the hired individuals have rendered the labor, related to these leaves. At the date of each financial
statement, the Company makes assessment of the amount of the expected costs under the accruing compensable leaves,
which is expected to be paid as a result of unused right of accrued leave. The assessment includes the approximate
estimate of the amounts for the remunerations themselves and of the contributions for the obligatory social and health
insurance, which the employer owes on these amounts.
Long-term retirement income
The Company owes retirement benefits to its employees under defined benefit plans and defined contribution plans.
Defined contribution plans
Defined contribution plans are retirement plans under which the Company pays fixed contributions into state funds.
The main obligation of the employer is to provide compulsory insurance of the hired staff for the Pension Fund,
Supplementary Compulsory Pension Insurance (SCPI), General Sickness and Maternity Fund (GSMF),
Unemployment Fund, Occupational Accident and Sickness Fund (OASF) and health insurance (HI).
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
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The amounts of the social security contributions are approved specifically by the Social Security Budget Act and the
NHIF Budget Act for the respective year. The contributions are distributed between the employer and the insured
person in accordance with the rules of the Social Security Code (SSC).
These retirement benefit plans applied by the Company as an employer are defined contribution plans. In them, the
employer pays monthly certain contributions to state funds, as well as to universal and occupational pension funds –
on the basis of fixed percentages by law and has no legal or constructive obligation to pay future contributions to the
funds in cases where they do not have sufficient funds to pay persons the amounts earned by them for the period of
their work experience. The obligations regarding the health insurance are similar.
Contributions payable by the company under defined contribution plans for social security and health insurance are
recognized as a current expense in the profit and loss report unless an IFRS accounting standard requires that amount
to be capitalized in the cost of an asset and as a current liability.
Defined benefit plans
Under the Bulgarian labor legislation and the Internal Rules for the determination of the salary, the Company as an
employer is obliged to pay from five to ten gross monthly salaries to its employees upon retirement, depending on the
length of service. If the employee has worked for the same employer or in the group in the last 9 years of service, they
must receive eleven gross monthly salaries in retirement, and if they have worked for less than 9 years – six gross
monthly salaries. The staff retirement plan is not funded.
The Company determines its retirement benefit obligations by using an actuarial valuation method. The management
of the Company assesses the defined benefit obligation once a year with the assistance of an independent actuary. The
assessment of liabilities is based on standard inflation rates, expected changes in health care costs and mortality. Future
wage increases are also taken into account. The discount factors are determined at the end of each year, taking into
account the yield on high-quality corporate bonds, which are denominated in the currency in which the income will
be paid and have a maturity close to that of the respective pension liabilities.
Expenses for pension benefits of employees related to current service are included in “Staff expenses”, and the amount
of discounting liabilities is included as interest expense in “Financial expenses”. The effects of subsequent estimates
of liabilities that are, in essence, actuarial gains and losses, are recognized immediately in the period in which they
arise and are presented under other components of comprehensive income in the item “Revaluation of liabilities under
defined benefit plans”.
The liability for staff retirement benefits presented in the separate statement of financial position consists of the present
value of the obligation to pay those benefits.
4.8 Financial instruments
A financial instrument is any contract that generates a financial asset of an entity and a financial liability or equity
instrument of another entity.
A financial asset is any asset that represents: cash, an equity instrument of another entity, a contractual right to receive
or exchange cash or financial instruments with another entity under potentially favorable conditions, and a contract to
be settled with instruments of the entity. Company’s equity is a non -derivative in which it can or will receive a variable
number of its equity instruments, or a derivative that can or will be settled by exchanging a fixed amount of cash or
other financial assets for a fixed number of equity instruments.
A financial liability is any liability that represents: a contractual right to provide or exchange cash or financial
instruments with another entity under potentially adverse conditions, and a contract that will be settled with the issuer’s
equity instruments and is a non-derivative in which the Company may or will not receive a variable number of the
entity’s equity instruments or a derivative that can or will be settled, other than the exchange of a fixed amount of
cash or other financial assets, for a fixed number of the entity’s equity instruments.
4.9.1. Financial assets
Initial recognition and classification
The Company initially recognizes a financial asset at the time it becomes a party to a contractual agreement, and
classifies it according to the business model for managing financial assets and the characteristics of the contracted
cash flows.
The Company classifies its financial assets according to their subsequent measurement in three categories: “financial
assets measured at amortized cost”, “financial assets measured at fair value through other comprehensive income”, or
Separate financial statements
31 December 2024
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The amounts of the social security contributions are approved specifically by the Social Security Budget Act and the
NHIF Budget Act for the respective year. The contributions are distributed between the employer and the insured
person in accordance with the rules of the Social Security Code (SSC).
These retirement benefit plans applied by the Company as an employer are defined contribution plans. In them, the
employer pays monthly certain contributions to state funds, as well as to universal and occupational pension funds –
on the basis of fixed percentages by law and has no legal or constructive obligation to pay future contributions to the
funds in cases where they do not have sufficient funds to pay persons the amounts earned by them for the period of
their work experience. The obligations regarding the health insurance are similar.
Contributions payable by the company under defined contribution plans for social security and health insurance are
recognized as a current expense in the profit and loss report unless an IFRS accounting standard requires that amount
to be capitalized in the cost of an asset and as a current liability.
Defined benefit plans
Under the Bulgarian labor legislation and the Internal Rules for the determination of the salary, the Company as an
employer is obliged to pay from five to ten gross monthly salaries to its employees upon retirement, depending on the
length of service. If the employee has worked for the same employer or in the group in the last 9 years of service, they
must receive eleven gross monthly salaries in retirement, and if they have worked for less than 9 years – six gross
monthly salaries. The staff retirement plan is not funded.
The Company determines its retirement benefit obligations by using an actuarial valuation method. The management
of the Company assesses the defined benefit obligation once a year with the assistance of an independent actuary. The
assessment of liabilities is based on standard inflation rates, expected changes in health care costs and mortality. Future
wage increases are also taken into account. The discount factors are determined at the end of each year, taking into
account the yield on high-quality corporate bonds, which are denominated in the currency in which the income will
be paid and have a maturity close to that of the respective pension liabilities.
Expenses for pension benefits of employees related to current service are included in “Staff expenses”, and the amount
of discounting liabilities is included as interest expense in “Financial expenses”. The effects of subsequent estimates
of liabilities that are, in essence, actuarial gains and losses, are recognized immediately in the period in which they
arise and are presented under other components of comprehensive income in the item “Revaluation of liabilities under
defined benefit plans”.
The liability for staff retirement benefits presented in the separate statement of financial position consists of the present
value of the obligation to pay those benefits.
4.8 Financial instruments
A financial instrument is any contract that generates a financial asset of an entity and a financial liability or equity
instrument of another entity.
A financial asset is any asset that represents: cash, an equity instrument of another entity, a contractual right to receive
or exchange cash or financial instruments with another entity under potentially favorable conditions, and a contract to
be settled with instruments of the entity. Company’s equity is a non -derivative in which it can or will receive a variable
number of its equity instruments, or a derivative that can or will be settled by exchanging a fixed amount of cash or
other financial assets for a fixed number of equity instruments.
A financial liability is any liability that represents: a contractual right to provide or exchange cash or financial
instruments with another entity under potentially adverse conditions, and a contract that will be settled with the issuer’s
equity instruments and is a non-derivative in which the Company may or will not receive a variable number of the
entity’s equity instruments or a derivative that can or will be settled, other than the exchange of a fixed amount of
cash or other financial assets, for a fixed number of the entity’s equity instruments.
4.9.1. Financial assets
Initial recognition and classification
The Company initially recognizes a financial asset at the time it becomes a party to a contractual agreement, and
classifies it according to the business model for managing financial assets and the characteristics of the contracted
cash flows.
The Company classifies its financial assets according to their subsequent measurement in three categories: “financial
assets measured at amortized cost”, “financial assets measured at fair value through other comprehensive income”, or
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
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This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
“financial assets at fair value through profit or loss”, as appropriate, according to the contractual terms of the
instruments and the Company's established business models, in accordance with IFRS 9 Financial Instruments.
The business model of the Company for management of financial assets refers to the way in which it manages its
financial assets to generate cash flows. The business model determines whether cash flows will result from the
collection of contractual cash flows, the sale of financial assets, or both.
The management of the Company has determined that the financial assets which are cash in banks, trade receivables,
other receivables, judicial and adjudicated receivables and receivables from related parties, are held by the Company
in order to obtain the agreed cash flows and are expected to generate cash flows, which are only payments of principal
and interest (applied business model). These financial assets are subsequently classified and measured at amortized
cost.
Initial measurement
Initially, all financial assets, with the exception of trade receivables, are measured at fair value, plus direct transaction
costs, if they are not carried at fair value through profit or loss when the net of transaction costs are initially recognized.
Trade receivables that do not contain a significant financing component and for which the Company applies the
practicable measure under IFRS 15 Revenue from Contracts with Customers in this respect are initially measured at
the relevant transaction price, in accordance with IFRS 15 Revenue from Contracts with Customers.
Subsequent measurement and presentation
For the purposes of subsequent measurement and presentation, financial assets are classified into one of the following
categories: “financial assets measured at amortized cost” (debt instruments), “financial assets measured at fair value
through other comprehensive income by reclassifying accumulated gains and losses” (debt instruments), “financial
assets designated at fair value in other comprehensive income, excluding reclassification of accumulated gains and
derecognition losses” (equity instruments) or “financial assets measured at fair value through profit or loss” (debt and
equity instruments).
Financial assets at amortized cost (debt instruments)
This category includes cash in banks, trade receivables, other receivables, court and award receivables and receivables
from related parties and loans. This category of financial assets is the most significant for the Company.
The Company evaluates and measures financial assets at amortized cost if both of the following conditions are met:
• The financial asset is held within a business model in order to hold financial assets in order to collect
contractual cash flows;
• The agreed terms of the financial asset led to certain cash flow dates, which are only principal payments and
interest on the outstanding principal.
The subsequent evaluation is made using the “effective interest rate” method, which calculates interest income by
applying the effective interest rate to the gross carrying amount of the instruments. For purchased or created assets,
with initial credit impairment and those with subsequently recognized credit impairment, the effective interest rate
and the effective interest rate adjusted for credit losses are applied, respectively, but at the amortized cost of the asset.
Financial assets in this category are subject to impairment testing at the date of each financial statement of the
Company, the changes being reflected in profit or loss.
Gains and losses are recognized in profit or loss when the asset is derecognized, modified or impaired.
Financial assets measured at fair value through other comprehensive income (equity instruments)
Upon initial recognition, the Company classifies the investments in equity instruments in this category when they
meet the definition of equity under IAS 32 Financial Instruments: Presentation and are not held for trading.
Subsequent evaluation of this instrument is carried at fair value and changes are recognized in other comprehensive
income. Fair values are determined based on quoted prices in an active market, and when there is no such - based on
evaluation techniques, usually an analysis of discounted cash flows.
Profits and losses on these financial assets are never reclassified to profit or loss. Dividends are recognized in the item
“financial income” in the separate profit and loss report when the right to payment is established.
The Company has made an irrevocable choice to classify in this category its minority equity investments that it holds
in the long term and in relation to its business interests in these companies. They are traded on capital markets.
Financial assets at fair value through profit or loss
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“financial assets at fair value through profit or loss”, as appropriate, according to the contractual terms of the
instruments and the Company's established business models, in accordance with IFRS 9 Financial Instruments.
The business model of the Company for management of financial assets refers to the way in which it manages its
financial assets to generate cash flows. The business model determines whether cash flows will result from the
collection of contractual cash flows, the sale of financial assets, or both.
The management of the Company has determined that the financial assets which are cash in banks, trade receivables,
other receivables, judicial and adjudicated receivables and receivables from related parties, are held by the Company
in order to obtain the agreed cash flows and are expected to generate cash flows, which are only payments of principal
and interest (applied business model). These financial assets are subsequently classified and measured at amortized
cost.
Initial measurement
Initially, all financial assets, with the exception of trade receivables, are measured at fair value, plus direct transaction
costs, if they are not carried at fair value through profit or loss when the net of transaction costs are initially recognized.
Trade receivables that do not contain a significant financing component and for which the Company applies the
practicable measure under IFRS 15 Revenue from Contracts with Customers in this respect are initially measured at
the relevant transaction price, in accordance with IFRS 15 Revenue from Contracts with Customers.
Subsequent measurement and presentation
For the purposes of subsequent measurement and presentation, financial assets are classified into one of the following
categories: “financial assets measured at amortized cost” (debt instruments), “financial assets measured at fair value
through other comprehensive income by reclassifying accumulated gains and losses” (debt instruments), “financial
assets designated at fair value in other comprehensive income, excluding reclassification of accumulated gains and
derecognition losses” (equity instruments) or “financial assets measured at fair value through profit or loss” (debt and
equity instruments).
Financial assets at amortized cost (debt instruments)
This category includes cash in banks, trade receivables, other receivables, court and award receivables and receivables
from related parties and loans. This category of financial assets is the most significant for the Company.
The Company evaluates and measures financial assets at amortized cost if both of the following conditions are met:
• The financial asset is held within a business model in order to hold financial assets in order to collect
contractual cash flows;
• The agreed terms of the financial asset led to certain cash flow dates, which are only principal payments and
interest on the outstanding principal.
The subsequent evaluation is made using the “effective interest rate” method, which calculates interest income by
applying the effective interest rate to the gross carrying amount of the instruments. For purchased or created assets,
with initial credit impairment and those with subsequently recognized credit impairment, the effective interest rate
and the effective interest rate adjusted for credit losses are applied, respectively, but at the amortized cost of the asset.
Financial assets in this category are subject to impairment testing at the date of each financial statement of the
Company, the changes being reflected in profit or loss.
Gains and losses are recognized in profit or loss when the asset is derecognized, modified or impaired.
Financial assets measured at fair value through other comprehensive income (equity instruments)
Upon initial recognition, the Company classifies the investments in equity instruments in this category when they
meet the definition of equity under IAS 32 Financial Instruments: Presentation and are not held for trading.
Subsequent evaluation of this instrument is carried at fair value and changes are recognized in other comprehensive
income. Fair values are determined based on quoted prices in an active market, and when there is no such - based on
evaluation techniques, usually an analysis of discounted cash flows.
Profits and losses on these financial assets are never reclassified to profit or loss. Dividends are recognized in the item
“financial income” in the separate profit and loss report when the right to payment is established.
The Company has made an irrevocable choice to classify in this category its minority equity investments that it holds
in the long term and in relation to its business interests in these companies. They are traded on capital markets.
Financial assets at fair value through profit or loss
Bulgarian Energy Holding EAD
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The Company estimates all other financial assets other than those that are measured at amortized cost or at fair value
through other comprehensive income at fair value through profit or loss.
In the event that this eliminates or significantly reduces the measurement or recognition inconsistency of a financial
asset that would result from recognizing results and changes based on different bases, the Company may apply the
exceptions under IFRS 9 Financial Instruments and designate a financial asset as at fair value through profit and loss
on initial recognition as irrevocable, including contracts to deliver a non-financial item. Such financial assets are
presented in the notes to the financial statements separately from other instruments to which this valuation approach
is mandatory.
Derecognition
A financial asset (or, where applicable, part of a financial asset or part of a group of similar financial assets) is
derecognized when the contractual rights to the cash flows of the asset have expired, or the Company has transferred
its rights to receive cash flows from the asset or it has undertaken to pay all the cash flows received without significant
delay to a third party under a “transfer” arrangement.
When a financial asset is derecognized in its entirety, the difference between 1) the carrying amount (measured at the
date of derecognition) and 2) the consideration received (including any new asset received without the new assumption
of a new liability) is recognized in profit or loss.
When the Company has transferred its rights to receive cash flows from an asset, or has entered into a transfer
agreement, it assesses whether and to what extent the risks and rewards of ownership are preserved. When the
Company neither transfers nor substantially retains all the risks and rewards of the asset, nor transfers control over the
asset, it continues to recognize the transferred asset to the extent of its continuing involvement. In this case the
Company recognizes a related liability. The transferred asset and the related liability are measured on a basis that
reflects the rights and obligations that the Company has retained.
Impairment of financial assets
The Company recognizes provisions for expected credit losses for all debt instruments that are not carried at fair value
through profit or loss, using the approach presented in the table below:
Type of financial asset Category under IFRS 9 Financial
Instruments
Impairment approach
1 Short-term trade receivables Debt instruments measured at
amortized cost
Simplified approach
2 Trade receivables with financing
component
Debt instruments measured at
amortized cost
Standardized approach
3 Short-term receivables from related
parties
Debt instruments measured at
amortized cost
Simplified approach
4 Receivables from related parties
with a financing component
Debt instruments measured at
amortized cost
Standardized approach
5 Loans receivable Debt instruments measured at
amortized cost
Standardized approach
6 Cash Debt instruments measured at
amortized cost
Standardized approach
7 Other financial, court and awarded
receivables
Debt instruments measured at
amortized cost
Simplified approach
Expected credit losses represent a probabilistic weighted estimate of credit losses (i.e. the present value of each
shortfall) for the expected maturity of the financial instrument. Cash deficit is the difference between the cash flows
payable to the Company in accordance with the contract, and the cash flows that the Company expects to receive.
Because the expected credit losses account for the amount and timing of payments, an expected credit loss is
recognized even if the Company expects the asset to be fully paid, but later than the due date.
Impairment and losses on financial instruments are dealt with in three stages – the first two being the expected credit
losses for losses that may arise as a result of default, and the third as credit impairment (loss), based on evidence of
potential or actual failure to perform on the instruments.
Expected credit losses for exposures for which there is no significant increase in credit risk compared to initial
recognition are recognized for credit losses that may arise as a result of default events over the next 12 months. For
credit exposures for which there is a significant increase in credit risk after initial recognition, an adjustment of the
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The Company estimates all other financial assets other than those that are measured at amortized cost or at fair value
through other comprehensive income at fair value through profit or loss.
In the event that this eliminates or significantly reduces the measurement or recognition inconsistency of a financial
asset that would result from recognizing results and changes based on different bases, the Company may apply the
exceptions under IFRS 9 Financial Instruments and designate a financial asset as at fair value through profit and loss
on initial recognition as irrevocable, including contracts to deliver a non-financial item. Such financial assets are
presented in the notes to the financial statements separately from other instruments to which this valuation approach
is mandatory.
Derecognition
A financial asset (or, where applicable, part of a financial asset or part of a group of similar financial assets) is
derecognized when the contractual rights to the cash flows of the asset have expired, or the Company has transferred
its rights to receive cash flows from the asset or it has undertaken to pay all the cash flows received without significant
delay to a third party under a “transfer” arrangement.
When a financial asset is derecognized in its entirety, the difference between 1) the carrying amount (measured at the
date of derecognition) and 2) the consideration received (including any new asset received without the new assumption
of a new liability) is recognized in profit or loss.
When the Company has transferred its rights to receive cash flows from an asset, or has entered into a transfer
agreement, it assesses whether and to what extent the risks and rewards of ownership are preserved. When the
Company neither transfers nor substantially retains all the risks and rewards of the asset, nor transfers control over the
asset, it continues to recognize the transferred asset to the extent of its continuing involvement. In this case the
Company recognizes a related liability. The transferred asset and the related liability are measured on a basis that
reflects the rights and obligations that the Company has retained.
Impairment of financial assets
The Company recognizes provisions for expected credit losses for all debt instruments that are not carried at fair value
through profit or loss, using the approach presented in the table below:
Type of financial asset Category under IFRS 9 Financial
Instruments
Impairment approach
1 Short-term trade receivables Debt instruments measured at
amortized cost
Simplified approach
2 Trade receivables with financing
component
Debt instruments measured at
amortized cost
Standardized approach
3 Short-term receivables from related
parties
Debt instruments measured at
amortized cost
Simplified approach
4 Receivables from related parties
with a financing component
Debt instruments measured at
amortized cost
Standardized approach
5 Loans receivable Debt instruments measured at
amortized cost
Standardized approach
6 Cash Debt instruments measured at
amortized cost
Standardized approach
7 Other financial, court and awarded
receivables
Debt instruments measured at
amortized cost
Simplified approach
Expected credit losses represent a probabilistic weighted estimate of credit losses (i.e. the present value of each
shortfall) for the expected maturity of the financial instrument. Cash deficit is the difference between the cash flows
payable to the Company in accordance with the contract, and the cash flows that the Company expects to receive.
Because the expected credit losses account for the amount and timing of payments, an expected credit loss is
recognized even if the Company expects the asset to be fully paid, but later than the due date.
Impairment and losses on financial instruments are dealt with in three stages – the first two being the expected credit
losses for losses that may arise as a result of default, and the third as credit impairment (loss), based on evidence of
potential or actual failure to perform on the instruments.
Expected credit losses for exposures for which there is no significant increase in credit risk compared to initial
recognition are recognized for credit losses that may arise as a result of default events over the next 12 months. For
credit exposures for which there is a significant increase in credit risk after initial recognition, an adjustment of the
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Separate financial statements
31 December 2024
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loss for expected credit losses is required relative to the remaining life of the exposure, regardless of the default time
(CPA for the entire life of the instrument).
Receivables from loans to related parties and receivables with a financing element – For the calculation of the
expected credit losses on loans granted to related parties and long-term receivables with a financing element, the
Company applies a standardized approach for impairment. Under this approach, the Company applies a “three -tier”
impairment model based on changes from the initial recognition of the credit quality of the financial instrument (asset).
Expected credit losses are recognized in three stages:
a. A financial asset that is not impaired at its initial origination/acquisition is classified in Phase 1. Since its initial
recognition, its credit risk and performance have been subject to continuous monitoring and analysis. The expected
credit losses of financial assets classified in Phase 1 are determined on the basis of credit losses resulting from possible
default events that could occur within the next 12 months of the life of the respective asset (12-month expected credit
losses for the instrument).
b. In cases where, after the initial recognition of a financial asset, its credit risk increases significantly and as a resul t
its performance deteriorates, it is classified in Phase 2. The expected credit losses of financial assets classified in Phase
2 are determined for the entire remaining life (term) of the respective asset, regardless of the moment of occurrence
of the default (expected credit losses for the whole life (term) of the instrument).
c. In cases where the credit risk of a financial asset increases to a level that indicates that a default event has occurred,
the financial asset is considered impaired and is classified in Phase 3. At this stage, the losses incurred are determined
and calculated. asset for the rest of its life (term).
The management of the Company has developed a policy and a set of criteria for analyzing, identifying and assessing
the occurrence of a “significant increase in credit risk”.
For trade receivables and contract assets arising from transactions within the scope of IFRS 15 Revenue from
Contracts with Customers that do not contain a significant financing component, the Company applies a simplified
approach in accordance with IFRS 9 Financial Instruments by recognizing an impairment loss for expected credit
losses based on the expected credit loss for the entire term of the receivables at each reporting date. The Company
applies a matrix that calculates the expected credit losses on trade receivables. Receivables are categorized by arrears
and are grouped by type and client segments with different models of credit losses.
For baseline data on trade receivables, the Company uses its accumulated experience of credit losses on such
instruments to measure expected credit losses. The historical data used are for periods from 3 to 5 years ago, grouped
by type and relevant models of customer segments, and adjusted by forecast factors specific to debtors and industry
concerned.
For cash at banks, the Company recognizes impairment for expected credit losses by applying the standardized
approach, and the credit rating of the financial institutions in which the Company has deposited its cash is used to
determine the loss from default in the model parameters.
At each reporting date, the Company evaluates the impairment for each instrument at an amount equal to the expected
lifetime losses, if the credit risk for that instrument has increased significantly since the initial recognition.
If, at the reporting date, the credit risk on a financial instrument has not increased significantly compared to the initial
recognition, the impairment for this financial instrument is equal to the expected 12-month credit loss.
Additional disclosures related to the impairment of financial assets are also contained in the following notes:
➢ Disclosures of significant assessments and assumptions, note 4.19
➢ Trade and other receivables, note 22
➢ Loans granted to related parties, note 32. 1
➢ Receivables from related parties, note 32.3
➢ Cash, note 25
➢ Credit risk, note 35.5
4.9.2. Financial liabilities
Initial recognition, classification and measurement
The Company recognizes a financial liability in its separate statement of financial position only when it becomes a
party to the contractual provisions of the financial instrument.
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31 December 2024
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loss for expected credit losses is required relative to the remaining life of the exposure, regardless of the default time
(CPA for the entire life of the instrument).
Receivables from loans to related parties and receivables with a financing element – For the calculation of the
expected credit losses on loans granted to related parties and long-term receivables with a financing element, the
Company applies a standardized approach for impairment. Under this approach, the Company applies a “three -tier”
impairment model based on changes from the initial recognition of the credit quality of the financial instrument (asset).
Expected credit losses are recognized in three stages:
a. A financial asset that is not impaired at its initial origination/acquisition is classified in Phase 1. Since its initial
recognition, its credit risk and performance have been subject to continuous monitoring and analysis. The expected
credit losses of financial assets classified in Phase 1 are determined on the basis of credit losses resulting from possible
default events that could occur within the next 12 months of the life of the respective asset (12-month expected credit
losses for the instrument).
b. In cases where, after the initial recognition of a financial asset, its credit risk increases significantly and as a resul t
its performance deteriorates, it is classified in Phase 2. The expected credit losses of financial assets classified in Phase
2 are determined for the entire remaining life (term) of the respective asset, regardless of the moment of occurrence
of the default (expected credit losses for the whole life (term) of the instrument).
c. In cases where the credit risk of a financial asset increases to a level that indicates that a default event has occurred,
the financial asset is considered impaired and is classified in Phase 3. At this stage, the losses incurred are determined
and calculated. asset for the rest of its life (term).
The management of the Company has developed a policy and a set of criteria for analyzing, identifying and assessing
the occurrence of a “significant increase in credit risk”.
For trade receivables and contract assets arising from transactions within the scope of IFRS 15 Revenue from
Contracts with Customers that do not contain a significant financing component, the Company applies a simplified
approach in accordance with IFRS 9 Financial Instruments by recognizing an impairment loss for expected credit
losses based on the expected credit loss for the entire term of the receivables at each reporting date. The Company
applies a matrix that calculates the expected credit losses on trade receivables. Receivables are categorized by arrears
and are grouped by type and client segments with different models of credit losses.
For baseline data on trade receivables, the Company uses its accumulated experience of credit losses on such
instruments to measure expected credit losses. The historical data used are for periods from 3 to 5 years ago, grouped
by type and relevant models of customer segments, and adjusted by forecast factors specific to debtors and industry
concerned.
For cash at banks, the Company recognizes impairment for expected credit losses by applying the standardized
approach, and the credit rating of the financial institutions in which the Company has deposited its cash is used to
determine the loss from default in the model parameters.
At each reporting date, the Company evaluates the impairment for each instrument at an amount equal to the expected
lifetime losses, if the credit risk for that instrument has increased significantly since the initial recognition.
If, at the reporting date, the credit risk on a financial instrument has not increased significantly compared to the initial
recognition, the impairment for this financial instrument is equal to the expected 12-month credit loss.
Additional disclosures related to the impairment of financial assets are also contained in the following notes:
➢ Disclosures of significant assessments and assumptions, note 4.19
➢ Trade and other receivables, note 22
➢ Loans granted to related parties, note 32. 1
➢ Receivables from related parties, note 32.3
➢ Cash, note 25
➢ Credit risk, note 35.5
4.9.2. Financial liabilities
Initial recognition, classification and measurement
The Company recognizes a financial liability in its separate statement of financial position only when it becomes a
party to the contractual provisions of the financial instrument.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
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Upon initial recognition, financial liabilities are classified as: “financial liabilities subsequently measured at amortized
cost” (loans and borrowings, trade and other payables) or as “financial liabilities measured at fair value through profit
or loss.”
Initial recognition takes place at the settlement date and is carried at fair value plus, in the case of financial liabilitie s
that are not carried at fair value through profit or loss, directly attributable to the acquisition or issue of the financial
liability. Management fees for received loans are deferred over the period of use of the loans, using the effective
interest rate method and are included in the amortized cost of loans.
The financial liabilities of the Company include bank loans, trade and other payables and finance lease liabilities.
According to their maturity, financial liabilities are classified into long-term and short-term.
Subsequent evaluation
The subsequent valuation of financial liabilities depends on their classification, as described below:
Financial liabilities reported at fair value through profit or loss
Financial liabilities at fair value through profit or loss include financial liabilities held for trading and financial
liabilities initially recognized at fair value through profit or loss.
Financial liabilities are classified as held for trading if they are made for redemption in the near future.
Profit or losses on liabilities held for trading are recognized in the separate profit and loss report.
Financial liabilities designated on initial recognition at fair value through profit or loss are designated at the initial
recognition date and only if the criteria in IFRS 9 Financial Instruments are met.
The Company has not designated financial liabilities as measured at fair value through profit or loss.
Financial liabilities measured at amortized cost
The category of “financial liabilities reported at amortized cost” includes borrowings, trade payables and other
payables where the Company has become a party to a contract or arrangement and which should be settled in net cash.
This category has the most significant share for the Company’s financial instruments and for it as a whole.
The received loans are temporarily attracted funds against services from Bulgarian or foreign banks and other financial
institutions, commercial loans, etc.
Bank loans are taken to provide long-term support to the Company’s business. They are reflected in the Company's
statement of financial position, net of loan costs. Direct transaction costs are recognized in the profit and loss report
on an accrual basis using the effective interest method and are added to the carrying amount of the financial liability
to the extent that they are not settled at the end of the period in which they are incurred.
Financial liabilities are subsequently measured at amortized cost using the effective interest method. Amortized cost
is calculated by taking into account any discount or premium on acquisition, including fees or charges, which are an
integral part of the effective interest rate. Expenses (calculated using the effective interest method) are included as
financial expenses in the profit or loss report and other comprehensive income in the line “Financial expenses”.
For financial liabilities that are carried at amortized cost, the gain or loss is recognized in profit or loss for the period
in which the financial asset or financial liability is derecognized or impaired through the amortization process.
Trade payables are initially recognized at nominal value and subsequently measured at amortized cost less settlement
payments.
Dividends payable to the sole shareholder are recognized when the dividends are approved by the General Meeting.
Derecognition
The Company derecognizes a financial liability only when the liability is settled (fulfilled), the liability expires, or the
creditor waives their rights.
When an existing financial liability is replaced by another from the same lender under significantly different conditions
or the terms of an existing liability are substantially changed, such exchange or change is treated as a write-off of the
original liability and the recognition of a new liability. The difference in the respective carrying amounts is recognized
in the profit and loss report.
The difference between the carrying amount of the financial liability settled or transferred to another party and the
consideration paid for the settlement, including cash and a transfer of non-monetary assets, is recognized in profit or
loss for the period.
Separate financial statements
31 December 2024
20
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Upon initial recognition, financial liabilities are classified as: “financial liabilities subsequently measured at amortized
cost” (loans and borrowings, trade and other payables) or as “financial liabilities measured at fair value through profit
or loss.”
Initial recognition takes place at the settlement date and is carried at fair value plus, in the case of financial liabilitie s
that are not carried at fair value through profit or loss, directly attributable to the acquisition or issue of the financial
liability. Management fees for received loans are deferred over the period of use of the loans, using the effective
interest rate method and are included in the amortized cost of loans.
The financial liabilities of the Company include bank loans, trade and other payables and finance lease liabilities.
According to their maturity, financial liabilities are classified into long-term and short-term.
Subsequent evaluation
The subsequent valuation of financial liabilities depends on their classification, as described below:
Financial liabilities reported at fair value through profit or loss
Financial liabilities at fair value through profit or loss include financial liabilities held for trading and financial
liabilities initially recognized at fair value through profit or loss.
Financial liabilities are classified as held for trading if they are made for redemption in the near future.
Profit or losses on liabilities held for trading are recognized in the separate profit and loss report.
Financial liabilities designated on initial recognition at fair value through profit or loss are designated at the initial
recognition date and only if the criteria in IFRS 9 Financial Instruments are met.
The Company has not designated financial liabilities as measured at fair value through profit or loss.
Financial liabilities measured at amortized cost
The category of “financial liabilities reported at amortized cost” includes borrowings, trade payables and other
payables where the Company has become a party to a contract or arrangement and which should be settled in net cash.
This category has the most significant share for the Company’s financial instruments and for it as a whole.
The received loans are temporarily attracted funds against services from Bulgarian or foreign banks and other financial
institutions, commercial loans, etc.
Bank loans are taken to provide long-term support to the Company’s business. They are reflected in the Company's
statement of financial position, net of loan costs. Direct transaction costs are recognized in the profit and loss report
on an accrual basis using the effective interest method and are added to the carrying amount of the financial liability
to the extent that they are not settled at the end of the period in which they are incurred.
Financial liabilities are subsequently measured at amortized cost using the effective interest method. Amortized cost
is calculated by taking into account any discount or premium on acquisition, including fees or charges, which are an
integral part of the effective interest rate. Expenses (calculated using the effective interest method) are included as
financial expenses in the profit or loss report and other comprehensive income in the line “Financial expenses”.
For financial liabilities that are carried at amortized cost, the gain or loss is recognized in profit or loss for the period
in which the financial asset or financial liability is derecognized or impaired through the amortization process.
Trade payables are initially recognized at nominal value and subsequently measured at amortized cost less settlement
payments.
Dividends payable to the sole shareholder are recognized when the dividends are approved by the General Meeting.
Derecognition
The Company derecognizes a financial liability only when the liability is settled (fulfilled), the liability expires, or the
creditor waives their rights.
When an existing financial liability is replaced by another from the same lender under significantly different conditions
or the terms of an existing liability are substantially changed, such exchange or change is treated as a write-off of the
original liability and the recognition of a new liability. The difference in the respective carrying amounts is recognized
in the profit and loss report.
The difference between the carrying amount of the financial liability settled or transferred to another party and the
consideration paid for the settlement, including cash and a transfer of non-monetary assets, is recognized in profit or
loss for the period.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
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4.9.3 Compensation of financial instruments
Financial assets and financial liabilities are offset and the net amount is presented in the separate statement of financial
position when there is a legally enforceable right to offset the recognized amounts and the Company intends to settle
on a net basis or to simultaneously realize the assets and settle the liabilities.
4.9.4 Fair value of financial instruments
At each reporting date, the fair value of financial instruments that are actively traded in the markets is determined on
the basis of quoted market prices or dealer quotations (“buy” prices for long positions and “sell” prices for short
positions), without deduct transaction costs.
The fair value of financial instruments for which there is no active market is determined using valuation techniques.
These techniques include the use of recent direct market transactions; references to the current fair value of another
instrument that is substantially the same; discounted cash flow analysis and other valuation models.
An analysis of the fair values of the financial instruments and further details of how they are measured is given in note
36.
4.9 Equity, reserves and dividend payments
The registered capital of the Company reflects the nominal value of the issued shares. Other reserves include general
reserves and additional reserves. Revaluation reserves include a revaluation reserve of property, plant and equipment,
a revaluation reserve for available-for-sale financial assets, and a revaluation reserve for defined benefit plans.
Retained earnings include the current financial result and accumulated profits and uncovered losses from previous
years.
Dividend liabilities of the sole shareholder are included in the line “Related Party Payables” in the separate statement
of financial position, when the dividends are approved for distribution by the General Meeting before the end of the
reporting period.
All transactions with the Company’s sole shareholder are presented separately in the separate statement of changes in
equity.
4.10 Property, plant and equipment
Property, plant and equipment are initially measured at cost price, including the expenses on acquisition, as well as
any direct costs of bringing the asset to working condition. Their subsequent measurement after initial recognition
applies to a whole class of similar assets as follows:
No. Class of property, plant and equipment Model for a subsequent
assessment
1 Land Revaluation model
2 Improvements on land and plots Revaluation model
3 Buildings and constructions
• massive Revaluation model
• non-massive Cost model
4 Plant and equipment Revaluation model
5 Computer systems Cost model
6 Vehicles
• freight vehicles Revaluation model
• passenger cars Cost model
• specialized motor vehicles Revaluation model
7 Furniture, fixtures and fittings Cost model
8 Spare parts, accounted as property, plant and equipment Revaluation model
9 Other property, plant and equipment Cost model
Property, plant and equipment that are accounted for using the revaluation model are subsequently measured at
revalued amount, which is equal to the fair value at the date of measurement, less any accumulated depreciation and
impairment losses. Revaluations made are presented in the separate statement of comprehensive income and are
accounted for in the equity (revaluation reserve), if not preceded by previously accrued expenses. When the revalued
asset is sold or derecognized, the remaining revaluation reserve is charged to retained earnings.
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4.9.3 Compensation of financial instruments
Financial assets and financial liabilities are offset and the net amount is presented in the separate statement of financial
position when there is a legally enforceable right to offset the recognized amounts and the Company intends to settle
on a net basis or to simultaneously realize the assets and settle the liabilities.
4.9.4 Fair value of financial instruments
At each reporting date, the fair value of financial instruments that are actively traded in the markets is determined on
the basis of quoted market prices or dealer quotations (“buy” prices for long positions and “sell” prices for short
positions), without deduct transaction costs.
The fair value of financial instruments for which there is no active market is determined using valuation techniques.
These techniques include the use of recent direct market transactions; references to the current fair value of another
instrument that is substantially the same; discounted cash flow analysis and other valuation models.
An analysis of the fair values of the financial instruments and further details of how they are measured is given in note
36.
4.9 Equity, reserves and dividend payments
The registered capital of the Company reflects the nominal value of the issued shares. Other reserves include general
reserves and additional reserves. Revaluation reserves include a revaluation reserve of property, plant and equipment,
a revaluation reserve for available-for-sale financial assets, and a revaluation reserve for defined benefit plans.
Retained earnings include the current financial result and accumulated profits and uncovered losses from previous
years.
Dividend liabilities of the sole shareholder are included in the line “Related Party Payables” in the separate statement
of financial position, when the dividends are approved for distribution by the General Meeting before the end of the
reporting period.
All transactions with the Company’s sole shareholder are presented separately in the separate statement of changes in
equity.
4.10 Property, plant and equipment
Property, plant and equipment are initially measured at cost price, including the expenses on acquisition, as well as
any direct costs of bringing the asset to working condition. Their subsequent measurement after initial recognition
applies to a whole class of similar assets as follows:
No. Class of property, plant and equipment Model for a subsequent
assessment
1 Land Revaluation model
2 Improvements on land and plots Revaluation model
3 Buildings and constructions
• massive Revaluation model
• non-massive Cost model
4 Plant and equipment Revaluation model
5 Computer systems Cost model
6 Vehicles
• freight vehicles Revaluation model
• passenger cars Cost model
• specialized motor vehicles Revaluation model
7 Furniture, fixtures and fittings Cost model
8 Spare parts, accounted as property, plant and equipment Revaluation model
9 Other property, plant and equipment Cost model
Property, plant and equipment that are accounted for using the revaluation model are subsequently measured at
revalued amount, which is equal to the fair value at the date of measurement, less any accumulated depreciation and
impairment losses. Revaluations made are presented in the separate statement of comprehensive income and are
accounted for in the equity (revaluation reserve), if not preceded by previously accrued expenses. When the revalued
asset is sold or derecognized, the remaining revaluation reserve is charged to retained earnings.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
22
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The revaluations are performed in the following time intervals:
• when the fair value of assets undergoes only minor changes, the revaluation is made every three years;
• when the fair value of property, plant and equipment changes substantially in shorter time intervals, the revaluation
is carried out at shorter time intervals so that the carrying amount of the asset does not differ materially from its
fair value.
The frequency of subsequent revaluation of property, plant and equipment when applying the revaluation model,
depends on whether the carrying amount materially differs from the fair value of a revalued asset at the end of the
reporting period.
In this regard, when performing the annual inventory at the end of the reporting period (financial year end), the
Company reviews property, plant and equipment for indications as to whether their carrying amount differs
significantly from their fair value. A substantial deviation is the deviation of the carrying amount from the fair value
of the asset at the date of preparation of the financial statements by more than 5%. The deviation is significant also if
it is below 5%, but the difference between the carrying amount and the fair value as a cumulative amount of property,
plant and equipment, is significant for the purpose of preparation of the financial statements.
Property, plant and equipment reported using the acquisition price model is subsequently measured at cost less
accumulated depreciation and impairment losses. Impairment losses are reported as an expense and recognized in the
profit and loss report for the period.
Subsequent costs associated with certain property, plant and equipment are added to the carrying amount of the asset,
when it is probable that the Company will have economic benefits that exceed the initially estimated effectiveness of
an existing asset. All other subsequent costs are recognized as an expense for the period in which they are incurred.
Depreciation of property, plant and equipment is calculated using the straight-line method over the estimated useful
lives of the individual asset groups as follows:
Plant and equipment 3-30 years
Vehicles 2-12 years
Fixtures and fittings 5-10 years
Property, plant and equipment is derecognized upon sale or when no future economic benefits are expected from its
use or at its disposal. Profit or losses arising on derecognition of the asset, being the difference between the net disposal
proceeds, if any, and the carrying amount of the asset, are included in the profit and loss report when the asset is
derecognized.
At the end of each financial year, residual values, useful lives and depreciation methods are reviewed and if
expectations differ from previous estimates, they are revised in future periods.
The materiality threshold chosen for the Company’s property, plant and equipment amounts to BGN 500.
4.11 Leasing
The Company as a lessee
The Company estimates whether the contract is or contains a lease. A lease is defined as “a contract or part of a
contract that gives the right to use an asset (the underlying asset) for a period of time in return for payment.” The
Company, in order to apply this definition, estimates whether the contract complies with three key evaluations, which
are whether:
∙ The contract comprises a certain asset that is either explicitly identified in the contract, or is indicated
implicitly, which will be identified when the asset is made available to the Company;
∙ The Company is entitled to obtain essentially all economic benefits derived from the use of such an asset
during the entire period of use, taking into consideration its rights within the defined scope of the contract;
∙ The Company is entitled to guide the use of the asset in question during the whole period of use. The
Company assesses whether it has the right to direct “how and for what purpose” the asset to be used
throughout the period of use.
Separate financial statements
31 December 2024
22
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The revaluations are performed in the following time intervals:
• when the fair value of assets undergoes only minor changes, the revaluation is made every three years;
• when the fair value of property, plant and equipment changes substantially in shorter time intervals, the revaluation
is carried out at shorter time intervals so that the carrying amount of the asset does not differ materially from its
fair value.
The frequency of subsequent revaluation of property, plant and equipment when applying the revaluation model,
depends on whether the carrying amount materially differs from the fair value of a revalued asset at the end of the
reporting period.
In this regard, when performing the annual inventory at the end of the reporting period (financial year end), the
Company reviews property, plant and equipment for indications as to whether their carrying amount differs
significantly from their fair value. A substantial deviation is the deviation of the carrying amount from the fair value
of the asset at the date of preparation of the financial statements by more than 5%. The deviation is significant also if
it is below 5%, but the difference between the carrying amount and the fair value as a cumulative amount of property,
plant and equipment, is significant for the purpose of preparation of the financial statements.
Property, plant and equipment reported using the acquisition price model is subsequently measured at cost less
accumulated depreciation and impairment losses. Impairment losses are reported as an expense and recognized in the
profit and loss report for the period.
Subsequent costs associated with certain property, plant and equipment are added to the carrying amount of the asset,
when it is probable that the Company will have economic benefits that exceed the initially estimated effectiveness of
an existing asset. All other subsequent costs are recognized as an expense for the period in which they are incurred.
Depreciation of property, plant and equipment is calculated using the straight-line method over the estimated useful
lives of the individual asset groups as follows:
Plant and equipment 3-30 years
Vehicles 2-12 years
Fixtures and fittings 5-10 years
Property, plant and equipment is derecognized upon sale or when no future economic benefits are expected from its
use or at its disposal. Profit or losses arising on derecognition of the asset, being the difference between the net disposal
proceeds, if any, and the carrying amount of the asset, are included in the profit and loss report when the asset is
derecognized.
At the end of each financial year, residual values, useful lives and depreciation methods are reviewed and if
expectations differ from previous estimates, they are revised in future periods.
The materiality threshold chosen for the Company’s property, plant and equipment amounts to BGN 500.
4.11 Leasing
The Company as a lessee
The Company estimates whether the contract is or contains a lease. A lease is defined as “a contract or part of a
contract that gives the right to use an asset (the underlying asset) for a period of time in return for payment.” The
Company, in order to apply this definition, estimates whether the contract complies with three key evaluations, which
are whether:
∙ The contract comprises a certain asset that is either explicitly identified in the contract, or is indicated
implicitly, which will be identified when the asset is made available to the Company;
∙ The Company is entitled to obtain essentially all economic benefits derived from the use of such an asset
during the entire period of use, taking into consideration its rights within the defined scope of the contract;
∙ The Company is entitled to guide the use of the asset in question during the whole period of use. The
Company assesses whether it has the right to direct “how and for what purpose” the asset to be used
throughout the period of use.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
23
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Valuation and recognition of a lease as a lessee
On the date when the lease starts, the Company recognizes a right-of-use asset and lease obligation in the balance
sheet. The right-of-use asset is valued at cost, which consists of the initial assessment of the lease liability, all initial
direct costs incurred by the Company, assessment of all costs of dismantling and removal of the asset at the end of the
lease, and any kind of lease payments made before the commencement date of the lease (without any incentives
received).
The Company amortizes the right-of-use assets by linear base from the lease commencement date to the earlier one
of either the end of the useful life of the right-of-use asset, or the end of the lease term. The Company also conducts
a right-of-use asset impairment review, when it has such indicators.
On the starting date the Company assesses the lease obligation under the current value of the outstanding lease
payments by such date, discounted, using the interest rate that is included in the lease contract. If that percentage
cannot be determined directly, the Company uses the interest rate which it would have to pay in order to borrow for a
similar period of time with a similar collateral, the funds required to obtain an asset with a similar value in a similar
economic environment.
Lease payments included in the measurement of a lease liability consist of fixed payments, variable payments based
on an index or percentage, amounts expected to be payable under a residual guarantee and payments arising from
options reasonably certain to are exercised.
After the starting date the Company assesses the lease liability by increasing the balance sheet value, in order to record
the interest on the lease liability and reduce the balance sheet value, in order to reflect the lease payments made, and
revalues the balance sheet value of the liability, in order to reflect the revaluations or amendments of the lease contract,
or record the adjusted in-substance fixed lease payments.
The Company is facing potential future increases in the variable lease payments based on an index or interest rate,
which are not included in the lease liability until their entry into force. When adjustments to lease payments, based on
an index or interest rate, become effective, the lease liability is revalued and adjusted for the asset to be used.
When the lease liability is revalued, the corresponding adjustment is reflected in the asset with the right of use or in
the profit and loss, if the asset with the right of use is already reduced to zero.
The Company has chosen to take into account the short-term leases, and lease contracts whose main asset has a low
value, using exemptions from the recognition requirements. Instead of recognizing an asset with a right of use and a
lease liability, payments in respect of them are recognized as an expense in the profit or loss on a line during the lease
term.
In the separated statement of financial position, right-of-use assets are included in property, plant and equipment and
lease liabilities are included in trade and other payables.
The Company as a lessor
The Company's accounting policy under IFRS 16 Leases has not changed since the comparative period.
As a lessor, the Company classifies its lease contracts as operating or financial lease.
A lease is classified as a finance lease if it transfers substantially all the risks and rewards incidental to ownership of
the underlying asset and is classified as an operating lease if it does not.
4.12 Borrowing costs
Borrowing costs directly attributable to the acquisition, construction or production of an asset that necessarily takes a
substantial period of time to get ready for its intended use or sale, are capitalized as part of the acquisition price thereof.
All other borrowing costs are recognized as an expense in the period to which they relate. Borrowing costs include
interest and other costs that the Company incurs in connection with the borrowing of funds.
4.13 Intangible assets
Intangible assets that are separately acquired are initially measured at acquisition price. After initial recognition
intangible assets are evaluated at cost less accumulated amortization and accumulated impairment losses.
Separate financial statements
31 December 2024
23
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Valuation and recognition of a lease as a lessee
On the date when the lease starts, the Company recognizes a right-of-use asset and lease obligation in the balance
sheet. The right-of-use asset is valued at cost, which consists of the initial assessment of the lease liability, all initial
direct costs incurred by the Company, assessment of all costs of dismantling and removal of the asset at the end of the
lease, and any kind of lease payments made before the commencement date of the lease (without any incentives
received).
The Company amortizes the right-of-use assets by linear base from the lease commencement date to the earlier one
of either the end of the useful life of the right-of-use asset, or the end of the lease term. The Company also conducts
a right-of-use asset impairment review, when it has such indicators.
On the starting date the Company assesses the lease obligation under the current value of the outstanding lease
payments by such date, discounted, using the interest rate that is included in the lease contract. If that percentage
cannot be determined directly, the Company uses the interest rate which it would have to pay in order to borrow for a
similar period of time with a similar collateral, the funds required to obtain an asset with a similar value in a similar
economic environment.
Lease payments included in the measurement of a lease liability consist of fixed payments, variable payments based
on an index or percentage, amounts expected to be payable under a residual guarantee and payments arising from
options reasonably certain to are exercised.
After the starting date the Company assesses the lease liability by increasing the balance sheet value, in order to record
the interest on the lease liability and reduce the balance sheet value, in order to reflect the lease payments made, and
revalues the balance sheet value of the liability, in order to reflect the revaluations or amendments of the lease contract,
or record the adjusted in-substance fixed lease payments.
The Company is facing potential future increases in the variable lease payments based on an index or interest rate,
which are not included in the lease liability until their entry into force. When adjustments to lease payments, based on
an index or interest rate, become effective, the lease liability is revalued and adjusted for the asset to be used.
When the lease liability is revalued, the corresponding adjustment is reflected in the asset with the right of use or in
the profit and loss, if the asset with the right of use is already reduced to zero.
The Company has chosen to take into account the short-term leases, and lease contracts whose main asset has a low
value, using exemptions from the recognition requirements. Instead of recognizing an asset with a right of use and a
lease liability, payments in respect of them are recognized as an expense in the profit or loss on a line during the lease
term.
In the separated statement of financial position, right-of-use assets are included in property, plant and equipment and
lease liabilities are included in trade and other payables.
The Company as a lessor
The Company's accounting policy under IFRS 16 Leases has not changed since the comparative period.
As a lessor, the Company classifies its lease contracts as operating or financial lease.
A lease is classified as a finance lease if it transfers substantially all the risks and rewards incidental to ownership of
the underlying asset and is classified as an operating lease if it does not.
4.12 Borrowing costs
Borrowing costs directly attributable to the acquisition, construction or production of an asset that necessarily takes a
substantial period of time to get ready for its intended use or sale, are capitalized as part of the acquisition price thereof.
All other borrowing costs are recognized as an expense in the period to which they relate. Borrowing costs include
interest and other costs that the Company incurs in connection with the borrowing of funds.
4.13 Intangible assets
Intangible assets that are separately acquired are initially measured at acquisition price. After initial recognition
intangible assets are evaluated at cost less accumulated amortization and accumulated impairment losses.
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The useful lives of intangible assets are defined as limited as follows:
Patents, licenses 5-10 years
Software products 2-8 years
Other intangible assets 2 years
Intangible assets with finite useful lives are amortized over their useful lives and tested for impairment whenever there
is any indication that they may be impaired. The amortization period and the method of amortization of intangible
assets with finite useful lives are reviewed at least at the end of each financial year. The changes in the expected useful
life or pattern of consumption of the future economic benefits of the intangible asset are accounted for by changing
the amortization period or method and are treated as a change in accounting estimates.
Profit or losses arising on the derecognition of an intangible asset representing the difference between the net disposal
proceeds and the carrying amount of the asset are included in the profit and loss report when the asset is derecognized.
4.14 Investments in subsidiaries
Subsidiaries are all entities that are controlled by the Company. Control of a subsidiary of the Company is the right to
manage and determine the financial and operating policies of an entity in order to obtain benefits from its activities.
In the Company's separate financial statements, investments in subsidiaries are reported at cost.
Long-term investments in subsidiaries are presented in the financial statements at cost (prime cost), which is the fair
value of the consideration paid, including the direct costs of acquiring the investment less the accumulated impairment.
When conditions for impairment are identified, the latter is recognized in the separate profit and loss report.
Upon purchase and sale of investments in subsidiaries and associates, the “date of conclusion” of the transaction is
applied.
Investments are derecognized when the rights that result from them are transferred to other entities upon the
occurrence of the legal basis and thus the control of the economic benefits of the investment is lost. Profit/(loss) on
their sale shall be presented accordingly on the face of the profit and loss report.
The Company recognizes a dividend from a subsidiary in profit or loss in its separate financial statements when its
right to receive the dividend is established.
4.15 Investments in associates and joint ventures
A joint venture is a contractual arrangement whereby the Company and other independent parties undertake an
economic activity subject to joint control and the parties holding joint control of the entity are entitled to the net assets
of the entity. Investments in joint ventures are reported at cost.
Associates are those entities over which the Company is able to exercise significant influence, but which are neither
subsidiaries nor joint ventures. Investments in associates are reported at cost.
The Company recognizes a dividend from a joint venture or associate in profit or loss in its separate financial
statements when its right to receive the dividend is established.
4.16 Impairment of non-financial assets and investments in subsidiaries, joint ventures and associates
At each reporting date, the Company assesses whether there are indications that an asset is impaired. In the case of
such indications, or when an annual impairment test of an asset is required, the Company determines the recoverable
amount of that asset. The recoverable amount of the asset is the higher one of the fair value less costs to sell the asset
or cash-generating unit (CGU) and its value in use. The recoverable amount is determined for a separate asset unless
the use of the asset does not generate cash flows that are substantially independent of the cash flows generated by
other assets or groups of assets. When the carrying amount of an asset or CGU is higher than its recoverable amount,
the asset is considered to be impaired and its carrying amount is reduced to its recoverable amount.
In determining the value in use of an asset, the expected future cash flows are discounted to their present value using
a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the
asset. The fair value less the costs to sell is determined using an appropriate measurement model. The made
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The useful lives of intangible assets are defined as limited as follows:
Patents, licenses 5-10 years
Software products 2-8 years
Other intangible assets 2 years
Intangible assets with finite useful lives are amortized over their useful lives and tested for impairment whenever there
is any indication that they may be impaired. The amortization period and the method of amortization of intangible
assets with finite useful lives are reviewed at least at the end of each financial year. The changes in the expected useful
life or pattern of consumption of the future economic benefits of the intangible asset are accounted for by changing
the amortization period or method and are treated as a change in accounting estimates.
Profit or losses arising on the derecognition of an intangible asset representing the difference between the net disposal
proceeds and the carrying amount of the asset are included in the profit and loss report when the asset is derecognized.
4.14 Investments in subsidiaries
Subsidiaries are all entities that are controlled by the Company. Control of a subsidiary of the Company is the right to
manage and determine the financial and operating policies of an entity in order to obtain benefits from its activities.
In the Company's separate financial statements, investments in subsidiaries are reported at cost.
Long-term investments in subsidiaries are presented in the financial statements at cost (prime cost), which is the fair
value of the consideration paid, including the direct costs of acquiring the investment less the accumulated impairment.
When conditions for impairment are identified, the latter is recognized in the separate profit and loss report.
Upon purchase and sale of investments in subsidiaries and associates, the “date of conclusion” of the transaction is
applied.
Investments are derecognized when the rights that result from them are transferred to other entities upon the
occurrence of the legal basis and thus the control of the economic benefits of the investment is lost. Profit/(loss) on
their sale shall be presented accordingly on the face of the profit and loss report.
The Company recognizes a dividend from a subsidiary in profit or loss in its separate financial statements when its
right to receive the dividend is established.
4.15 Investments in associates and joint ventures
A joint venture is a contractual arrangement whereby the Company and other independent parties undertake an
economic activity subject to joint control and the parties holding joint control of the entity are entitled to the net assets
of the entity. Investments in joint ventures are reported at cost.
Associates are those entities over which the Company is able to exercise significant influence, but which are neither
subsidiaries nor joint ventures. Investments in associates are reported at cost.
The Company recognizes a dividend from a joint venture or associate in profit or loss in its separate financial
statements when its right to receive the dividend is established.
4.16 Impairment of non-financial assets and investments in subsidiaries, joint ventures and associates
At each reporting date, the Company assesses whether there are indications that an asset is impaired. In the case of
such indications, or when an annual impairment test of an asset is required, the Company determines the recoverable
amount of that asset. The recoverable amount of the asset is the higher one of the fair value less costs to sell the asset
or cash-generating unit (CGU) and its value in use. The recoverable amount is determined for a separate asset unless
the use of the asset does not generate cash flows that are substantially independent of the cash flows generated by
other assets or groups of assets. When the carrying amount of an asset or CGU is higher than its recoverable amount,
the asset is considered to be impaired and its carrying amount is reduced to its recoverable amount.
In determining the value in use of an asset, the expected future cash flows are discounted to their present value using
a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the
asset. The fair value less the costs to sell is determined using an appropriate measurement model. The made
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calculations are confirmed by using other measurement models or other available sources of information about the
fair value of an asset or a cash-generating unit. Impairment losses are recognized as expenses in the separate profit
and loss report except for non-current assets that have been revalued in prior periods and the revaluation increase is
recognized in the other comprehensive income. In that case, the impairment loss also relates to other comprehensive
income to the extent of the previously recognized revaluation of the related asset.
At each reporting date, the Company assesses whether there are indications that the impairment loss of an asset
recognized in prior periods may no longer exist or may have decreased. If such indications exist, the Company
determines the recoverable amount of the asset or cash-generating unit. An impairment loss is reversed only when
there has been a change in the estimates used to determine the asset’s recoverable amount since the last impairment
loss was recognized. The reversal of an impairment loss is limited so that the carrying amount of the asset may not
exceed its recoverable amount and does not exceed the carrying amount (after deduction of depreciation) that would
have been determined if no impairment loss had been recognized in previous years. The reversal of an impairment
loss is recognized in the separate profit and loss report unless the asset is carried a revalued amount, in which case the
reversal is treated as a revaluation increase.
4.17 Cash
Cash and deposits in the separated statement of financial position include cash in bank accounts, cash on hand and
short-term deposits with an initial maturity of three months or less.
Subsequent evaluation
Cash and cash equivalents held in banks are subsequently presented at amortized cost less any accumulated
impairment for expected credit losses.
4.18 Provisions
Provisions are recognized when the Company has a present obligation (either legal or constructive) as a result of past
events, it is probable that the obligation will result in an outflow of economic resources from the Company, and
amounts can be estimated reliably. When the Company expects that some or all of the expenses necessary to settle the
provision will be recovered, for example under an insurance contract, the reimbursement is recognized as a separate
asset, but only when it is practically certain that these costs will be recovered. Provision expenses are presented in the
separate profit and loss report, net of any recoverable amounts. When the effect of the time value of money is
significant, provisions are discounted using the current pre-tax discount rate, which reflects, where appropriate, the
specific risks of the obligation. When discounting is used, the increase in the provision due to the passage of time is
presented as a financial expense.
4.19 Significant judgments of management in applying accounting policies. Uncertainty of accounting
estimates
The preparation of the financial statements requires management to make accounting estimates, judgements and
assumptions, which affect the accounting policy application and the reported amounts of assets, liabilities, income
and expenses. Actual results may differ from the Management’s assumptions, estimates and presumptions and, in rare
cases, may fully match to the previously estimated results.
Estimates of accounting and relevant material assumptions are reviewed on an ongoing basis. The results of a change
in accounting estimates are recognized in the period in which the change is made, as well as in each future period
affected.
Information on significant assumptions, estimates and assumptions, as well as the main sources of uncertainty in the
use of accounting estimates that have the most significant effect on the recognition and measurement of assets,
liabilities, income and expenses, is presented below.
Recognition and valuation of expected credit losses of debt instruments at amortized cost (Note4.8)
The valuation of the expected credit loss of financial assets at amortized cost (loans, receivables, cash and cash
equivalents) requires the use of models and material assumptions about future economic conditions and credit behavior
of clients and debtors. For the application of these requirements the Company’s management makes a number of
significant judgments setting criteria for identifying and assessing significant credit risk increases, appropriate models
and assumptions to measure expected credit losses, identifying and assessing the dependence between historical
default rates and the behavior of certain macro indicators to reflect the future effects of the estimated credit losses.
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calculations are confirmed by using other measurement models or other available sources of information about the
fair value of an asset or a cash-generating unit. Impairment losses are recognized as expenses in the separate profit
and loss report except for non-current assets that have been revalued in prior periods and the revaluation increase is
recognized in the other comprehensive income. In that case, the impairment loss also relates to other comprehensive
income to the extent of the previously recognized revaluation of the related asset.
At each reporting date, the Company assesses whether there are indications that the impairment loss of an asset
recognized in prior periods may no longer exist or may have decreased. If such indications exist, the Company
determines the recoverable amount of the asset or cash-generating unit. An impairment loss is reversed only when
there has been a change in the estimates used to determine the asset’s recoverable amount since the last impairment
loss was recognized. The reversal of an impairment loss is limited so that the carrying amount of the asset may not
exceed its recoverable amount and does not exceed the carrying amount (after deduction of depreciation) that would
have been determined if no impairment loss had been recognized in previous years. The reversal of an impairment
loss is recognized in the separate profit and loss report unless the asset is carried a revalued amount, in which case the
reversal is treated as a revaluation increase.
4.17 Cash
Cash and deposits in the separated statement of financial position include cash in bank accounts, cash on hand and
short-term deposits with an initial maturity of three months or less.
Subsequent evaluation
Cash and cash equivalents held in banks are subsequently presented at amortized cost less any accumulated
impairment for expected credit losses.
4.18 Provisions
Provisions are recognized when the Company has a present obligation (either legal or constructive) as a result of past
events, it is probable that the obligation will result in an outflow of economic resources from the Company, and
amounts can be estimated reliably. When the Company expects that some or all of the expenses necessary to settle the
provision will be recovered, for example under an insurance contract, the reimbursement is recognized as a separate
asset, but only when it is practically certain that these costs will be recovered. Provision expenses are presented in the
separate profit and loss report, net of any recoverable amounts. When the effect of the time value of money is
significant, provisions are discounted using the current pre-tax discount rate, which reflects, where appropriate, the
specific risks of the obligation. When discounting is used, the increase in the provision due to the passage of time is
presented as a financial expense.
4.19 Significant judgments of management in applying accounting policies. Uncertainty of accounting
estimates
The preparation of the financial statements requires management to make accounting estimates, judgements and
assumptions, which affect the accounting policy application and the reported amounts of assets, liabilities, income
and expenses. Actual results may differ from the Management’s assumptions, estimates and presumptions and, in rare
cases, may fully match to the previously estimated results.
Estimates of accounting and relevant material assumptions are reviewed on an ongoing basis. The results of a change
in accounting estimates are recognized in the period in which the change is made, as well as in each future period
affected.
Information on significant assumptions, estimates and assumptions, as well as the main sources of uncertainty in the
use of accounting estimates that have the most significant effect on the recognition and measurement of assets,
liabilities, income and expenses, is presented below.
Recognition and valuation of expected credit losses of debt instruments at amortized cost (Note4.8)
The valuation of the expected credit loss of financial assets at amortized cost (loans, receivables, cash and cash
equivalents) requires the use of models and material assumptions about future economic conditions and credit behavior
of clients and debtors. For the application of these requirements the Company’s management makes a number of
significant judgments setting criteria for identifying and assessing significant credit risk increases, appropriate models
and assumptions to measure expected credit losses, identifying and assessing the dependence between historical
default rates and the behavior of certain macro indicators to reflect the future effects of the estimated credit losses.
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Approach to impairment of cash in banks
Cash and cash equivalents are the most liquid financial instruments. They are not bearers of settlement risk, and the
liquidity risk they bear is limited to the technical possibility that an order related to them will not be executed.
However, cash deposited with banks carries credit risk from the counterparty (default risk). Counterparty risk is the
probability that the counterparty to a financial transaction will fail to meet its contractual obligations. The Company
applies the standardized approach for calculating the expected credit losses of cash in banks, and the credit rating of
the financial institutions in which the Company has deposited its cash is used to determine the loss given default in
the model parameters. As of 31 December 2024, management’ s best estimate of expected credit losses on cash at
banks amounted to BGN 398 thousand. (31 December 2023: BGN 391 thousand). (Note 25).
Approach for impairment of short-term trade and other receivables and receivables from related parties
The Company applies a simplified approach to calculate the expected credit losses for trade receivables that do not
contain a financing element.
For the purpose of determining the expected credit losses, modelling is performed at the client’s industry level.
Modelling is the inherent removal of financial risk that clients bring to companies in the Company.
The expected credit losses are calculated for each single receivable (invoice, interest sheet, etc.), adjusted on the basis
of the days in arrears and the standard payment cycle by the counterparty. The average number of days of delay per
client is determined on the basis of historical information for the period of coverage of receivables by clients. The
retrospective review is performed for a period of 3 to 5 years.
The additional risk is identified on the basis of historical experience for the collection of receivables, including
deteriorating financial condition, liquidity problems and other difficulties.
The assessment of the ratio between the observed historical data on default, the forecast economic conditions, the
determination of the risk by industries and the amount of the expected credit losses is a significant assessment.
Information on impairment of expected credit losses of the Company is presented in notes 22, 23, 32.1 and 32.3.
Approach for impairment of granted loans, trade receivables and receivables from related parties with a financing
element
The Company applies an individual approach for impairment of receivables with a financing element and granted
loans. The impairment model is based on the cash flows agreed in the terms of the financial instrument, as well as the
assumptions and estimates of expected cash flows and the feasibility of the financial asset adopted by management in
preparing the financial statements.
Expected credit losses represent a probability-weighted estimate of credit losses (i.e. the present value of each
shortfall) for the expected maturity of the financial instrument. Cash deficit is the difference between the cash flows
payable to the Company in accordance with the contract, and the cash flows that the Company expects to receive.
Because the expected credit losses account for the amount and timing of payments, an expected credit loss is
recognized even if the Company expects the asset to be fully paid, but later than the due date.
Depending on the characteristics of the asset and the counterparty, the expected future cash flows of the asset may
differ materially from the agreed ones. This would also lead to significant levels of expected credit losses on the asset.
A revision of the expected future cash flows of each specific asset is performed at each reporting date.
Information on impairment of the Company’s expected credit losses on loans granted to related parties is presented in
Note 32.1, of expected credit losses on receivables with a financing element are provided in Notes 23 and 32.3.
When determining the expected credit losses for 2024 and the impairment charges, the Company took into account
the following available information:
• Regarding the subsidiary Bulgargaz EAD: On 6 July 2024 the contract for the credit line in the amount of
BGN 60,000 thousand granted by Bulgarian Energy Holding EAD to the subsidiary company Bulgargaz
EAD expired. The agreement dated 02.08.2024 extends the term of the credit line by 12 months, starting
from 06.07.2024. Bulgargaz EAD pays monthly interest obligations on the loans provided according to the
agreed terms. At present, no Business Program has been submitted for approval by the subsidiary for the
period 2025 - 2029 demonstrating its ability to repay the principal of the loans.
• Regarding the subsidiary Mini Maritsa-Iztok EAD: In 2024, loans in the amount of BGN 110,000 thousand
were granted to the subsidiary Mini Maritsa-Iztok EAD under two framework financing agreements. The
unutilized amount as of 31.12.2024 is BGN 90,000 thousand. In calculating the expected credit losses, the
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Approach to impairment of cash in banks
Cash and cash equivalents are the most liquid financial instruments. They are not bearers of settlement risk, and the
liquidity risk they bear is limited to the technical possibility that an order related to them will not be executed.
However, cash deposited with banks carries credit risk from the counterparty (default risk). Counterparty risk is the
probability that the counterparty to a financial transaction will fail to meet its contractual obligations. The Company
applies the standardized approach for calculating the expected credit losses of cash in banks, and the credit rating of
the financial institutions in which the Company has deposited its cash is used to determine the loss given default in
the model parameters. As of 31 December 2024, management’ s best estimate of expected credit losses on cash at
banks amounted to BGN 398 thousand. (31 December 2023: BGN 391 thousand). (Note 25).
Approach for impairment of short-term trade and other receivables and receivables from related parties
The Company applies a simplified approach to calculate the expected credit losses for trade receivables that do not
contain a financing element.
For the purpose of determining the expected credit losses, modelling is performed at the client’s industry level.
Modelling is the inherent removal of financial risk that clients bring to companies in the Company.
The expected credit losses are calculated for each single receivable (invoice, interest sheet, etc.), adjusted on the basis
of the days in arrears and the standard payment cycle by the counterparty. The average number of days of delay per
client is determined on the basis of historical information for the period of coverage of receivables by clients. The
retrospective review is performed for a period of 3 to 5 years.
The additional risk is identified on the basis of historical experience for the collection of receivables, including
deteriorating financial condition, liquidity problems and other difficulties.
The assessment of the ratio between the observed historical data on default, the forecast economic conditions, the
determination of the risk by industries and the amount of the expected credit losses is a significant assessment.
Information on impairment of expected credit losses of the Company is presented in notes 22, 23, 32.1 and 32.3.
Approach for impairment of granted loans, trade receivables and receivables from related parties with a financing
element
The Company applies an individual approach for impairment of receivables with a financing element and granted
loans. The impairment model is based on the cash flows agreed in the terms of the financial instrument, as well as the
assumptions and estimates of expected cash flows and the feasibility of the financial asset adopted by management in
preparing the financial statements.
Expected credit losses represent a probability-weighted estimate of credit losses (i.e. the present value of each
shortfall) for the expected maturity of the financial instrument. Cash deficit is the difference between the cash flows
payable to the Company in accordance with the contract, and the cash flows that the Company expects to receive.
Because the expected credit losses account for the amount and timing of payments, an expected credit loss is
recognized even if the Company expects the asset to be fully paid, but later than the due date.
Depending on the characteristics of the asset and the counterparty, the expected future cash flows of the asset may
differ materially from the agreed ones. This would also lead to significant levels of expected credit losses on the asset.
A revision of the expected future cash flows of each specific asset is performed at each reporting date.
Information on impairment of the Company’s expected credit losses on loans granted to related parties is presented in
Note 32.1, of expected credit losses on receivables with a financing element are provided in Notes 23 and 32.3.
When determining the expected credit losses for 2024 and the impairment charges, the Company took into account
the following available information:
• Regarding the subsidiary Bulgargaz EAD: On 6 July 2024 the contract for the credit line in the amount of
BGN 60,000 thousand granted by Bulgarian Energy Holding EAD to the subsidiary company Bulgargaz
EAD expired. The agreement dated 02.08.2024 extends the term of the credit line by 12 months, starting
from 06.07.2024. Bulgargaz EAD pays monthly interest obligations on the loans provided according to the
agreed terms. At present, no Business Program has been submitted for approval by the subsidiary for the
period 2025 - 2029 demonstrating its ability to repay the principal of the loans.
• Regarding the subsidiary Mini Maritsa-Iztok EAD: In 2024, loans in the amount of BGN 110,000 thousand
were granted to the subsidiary Mini Maritsa-Iztok EAD under two framework financing agreements. The
unutilized amount as of 31.12.2024 is BGN 90,000 thousand. In calculating the expected credit losses, the
Bulgarian Energy Holding EAD
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receivables have been classified in Stage 2 given the deteriorated financial performance of the subsidiary.
The draft Business Program submitted for the period 2025-2029 includes repayment of the utilized loans
according to the agreed terms. In order to restore the long-term technological and financial sustainability of
Mini Maritsa-Iztok EAD, the National Assembly of the Republic of Bulgaria adopted a decision to provide
funds for a period of four years in the amount of BGN 250,000 thousand per year. The funds are earmarked
as proceeds in the Business Program for the period 2025-2029. They are intended to increase the capital of
the subsidiary in the relevant year in accordance with Decree No. 121 of the Council of Ministers of
26.04.2024.
Approach to impairment of court and awarded receivables
In cases where the Company has taken legal action to satisfy its receivables, they are classified as court receivables.
This type of receivables is characterized by total default, i.e. the inability or unwillingness of the client to settle their
obligation. For this reason, regardless of the availability of decisions of the judicial authorities and the initiated
enforcement procedures, the collection of these receivables and resp. the expected future cash inflows are low and the
probability of default has already occurred relative to the original asset, i.e. is equal to 100%.
Expected credit losses represent the sum of expected credit losses for each lawsuit and award receivable based on the
historical recoverability of that asset class. Further information is also provided in note 22.
Impairment approach of investments in subsidiaries
The Company assesses at each reporting date whether there are indications that the value of an investment is impaired.
If such indications exist, the Company makes a formal assessment of the recoverable amount of the asset. In the event
that there are no indications of potential impairment of an investment, the Company does not perform any formal
assessment of the recoverable amount. An asset can be impaired when its carrying amount exceeds its recoverable
amount.
Any impairment loss that occurs is recognized as a reduction in the value of the investment and is expensed in the
statement of profit or loss in the income statements for the period in which it occurs.
The Company assesses whether there are indications that the value of a given asset is impaired as of the date of
drawing up the annual financial statements, taking into account external and internal sources of information, namely:
• The balance sheet amount of the reporting enterprise’s net assets is higher than its market capitalization (the
number of shares by their market value) – the companies in which Bulgarian Energy Holding EAD has a long-
term investment are not traded on active markets.
• Dividends from a subsidiary, joint venture or associate. For an investment in a subsidiary, joint venture or
associate, the investor recognizes dividends from the investment and there is evidence that:
- the carrying amount of the investment in the separated financial statements exceeds the carrying amounts in
the consolidated financial statements of the investee’s net assets, including related goodwill; or
- the dividends exceed the total comprehensive income of the subsidiary, joint venture or associate in the period
in which the dividends are declared.
The Company may also identify other indications that the value of the investment is impaired.
As of the date of preparation of the annual financial statements for 2024, Bulgarian Energy Holding EAD has reviewed
for indications of impairment of investments in all subsidiaries of the BEH Group, determined the coverage of the net
exposure to each company compared to the net assets of the subsidiary as of 31 December 2024 and calculated whether
dividends received in 2024 exceed the total amount of comprehensive income of each subsidiary for 2024. Bulgarian
Energy Holding EAD has performed an analysis of the financial status of the companies for which there is an
indication of impairment based on the business programs and 2024 financial results submitted by the subsidiaries.
Following the analysis, the Company's management has decided not to charge any further impairment to the
investments in subsidiaries other than that charged as of 31 December 2023.
Impairment of non-financial assets
The amount by which the carrying amount of an asset or cash-generating unit exceeds its recoverable amount which
is the higher of fair value less costs to sell an asset and its value in use, is recognized as impairment loss. In order to
determine the value in use, the Company’s management estimates the expected future cash flows for each cash -
generating unit and determines the appropriate discount factor in order to calculate the present value of those cash
flows. When calculating expected future cash flows, the management makes assumptions about future gross profits.
These assumptions are related to future events and circumstances. Actual results may differ and lead to significant
adjustments to the Company’s assets in the next accounting year.
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receivables have been classified in Stage 2 given the deteriorated financial performance of the subsidiary.
The draft Business Program submitted for the period 2025-2029 includes repayment of the utilized loans
according to the agreed terms. In order to restore the long-term technological and financial sustainability of
Mini Maritsa-Iztok EAD, the National Assembly of the Republic of Bulgaria adopted a decision to provide
funds for a period of four years in the amount of BGN 250,000 thousand per year. The funds are earmarked
as proceeds in the Business Program for the period 2025-2029. They are intended to increase the capital of
the subsidiary in the relevant year in accordance with Decree No. 121 of the Council of Ministers of
26.04.2024.
Approach to impairment of court and awarded receivables
In cases where the Company has taken legal action to satisfy its receivables, they are classified as court receivables.
This type of receivables is characterized by total default, i.e. the inability or unwillingness of the client to settle their
obligation. For this reason, regardless of the availability of decisions of the judicial authorities and the initiated
enforcement procedures, the collection of these receivables and resp. the expected future cash inflows are low and the
probability of default has already occurred relative to the original asset, i.e. is equal to 100%.
Expected credit losses represent the sum of expected credit losses for each lawsuit and award receivable based on the
historical recoverability of that asset class. Further information is also provided in note 22.
Impairment approach of investments in subsidiaries
The Company assesses at each reporting date whether there are indications that the value of an investment is impaired.
If such indications exist, the Company makes a formal assessment of the recoverable amount of the asset. In the event
that there are no indications of potential impairment of an investment, the Company does not perform any formal
assessment of the recoverable amount. An asset can be impaired when its carrying amount exceeds its recoverable
amount.
Any impairment loss that occurs is recognized as a reduction in the value of the investment and is expensed in the
statement of profit or loss in the income statements for the period in which it occurs.
The Company assesses whether there are indications that the value of a given asset is impaired as of the date of
drawing up the annual financial statements, taking into account external and internal sources of information, namely:
• The balance sheet amount of the reporting enterprise’s net assets is higher than its market capitalization (the
number of shares by their market value) – the companies in which Bulgarian Energy Holding EAD has a long-
term investment are not traded on active markets.
• Dividends from a subsidiary, joint venture or associate. For an investment in a subsidiary, joint venture or
associate, the investor recognizes dividends from the investment and there is evidence that:
- the carrying amount of the investment in the separated financial statements exceeds the carrying amounts in
the consolidated financial statements of the investee’s net assets, including related goodwill; or
- the dividends exceed the total comprehensive income of the subsidiary, joint venture or associate in the period
in which the dividends are declared.
The Company may also identify other indications that the value of the investment is impaired.
As of the date of preparation of the annual financial statements for 2024, Bulgarian Energy Holding EAD has reviewed
for indications of impairment of investments in all subsidiaries of the BEH Group, determined the coverage of the net
exposure to each company compared to the net assets of the subsidiary as of 31 December 2024 and calculated whether
dividends received in 2024 exceed the total amount of comprehensive income of each subsidiary for 2024. Bulgarian
Energy Holding EAD has performed an analysis of the financial status of the companies for which there is an
indication of impairment based on the business programs and 2024 financial results submitted by the subsidiaries.
Following the analysis, the Company's management has decided not to charge any further impairment to the
investments in subsidiaries other than that charged as of 31 December 2023.
Impairment of non-financial assets
The amount by which the carrying amount of an asset or cash-generating unit exceeds its recoverable amount which
is the higher of fair value less costs to sell an asset and its value in use, is recognized as impairment loss. In order to
determine the value in use, the Company’s management estimates the expected future cash flows for each cash -
generating unit and determines the appropriate discount factor in order to calculate the present value of those cash
flows. When calculating expected future cash flows, the management makes assumptions about future gross profits.
These assumptions are related to future events and circumstances. Actual results may differ and lead to significant
adjustments to the Company’s assets in the next accounting year.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
28
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
In most cases, the appropriate adjustments in relation to market risk and risk factors that are specific to individual
assets are assessed in determining the applicable discount factor.
Investments in associates
BEH EAD owns directly 0.32% of the share capital of ZAD Energy. The equity investment is accounted for as an
investment in an associate due to additional indirect participation in the capital of ZAD Energy through other
subsidiaries, resulting in a total direct and indirect equity participation of 48.08%.
Revenue from contracts with clients
In recognizing revenue from contracts with clients, management makes various estimates, estimates and assumptions
that affect the reported revenue, expenses, assets and liabilities under contracts. The key estimates and assumptions
that have a material impact on the amount and timing of recognizing revenue from client contracts are disclosed in
note 4.5 Revenue Recognition, Performance obligations and approach to recognizing the main types of revenue from
client contracts. Assets with the right of use and liabilities under leasing contracts
The management makes estimates based on its assessments of the elements of the lease in the contracts, the probable
terms of the leases, the options for extension and termination, the determination of the differential interest rate, etc.
upon recognition of “assets with the right of use” and liabilities under leasing contracts. These estimates affect the
reported income, expenses, assets and liabilities under leasing contracts and the corresponding disclosures.
As a result of uncertainty about these assumptions and estimates, changes in the carrying amount of usable assets,
lease liabilities and reported costs and income may arise as a result of changes in revaluations or changes in leases.
Retirement benefits
Retirement benefits are determined by actuarial valuation. This assessment requires assumptions to be made about the
discount rate, future wage growth, staff turnover and mortality rates. Due to the long -term nature of staff income at
retirement, these assumptions are subject to significant uncertainty. As of 31 December 2024, the Company’s liability
for staff retirement benefits recognized in the separated statement of financial position amounts to BGN 1,627
thousand (31 December 2023: BGN 1,825 thousand). Additional information on staff benefits at retirement is provided
in Note 30.
Useful life of property, plant and equipment and intangible assets
Financial reporting of property, plant and equipment and intangible assets includes the use of estimates for their
expected useful lives and residual values that are based on the Company’s management judgment. Information on the
useful life of property, plant and equipment is presented in Note 4.10, and intangible assets – Note 4.13.
Fair value of property, plant and equipment
The Company subsequently recognizes land and buildings at revalued amounts using independent external appraisers’
reports to determine their fair value. Detailed information for the revaluation, valuation methods used, assumptions
and fair value estimates, is presented in Note 19.
5.Dividend income
2024 2023
thousand BGN thousand BGN
Bulgartransgaz EAD 257,251 -
NPP Kozloduy EAD 241,673 364,731
Electricity System Operator EAD 123,503 40,989
Natsionalna Electricheska Kompania EAD - 449,314
ICGB AD 9,829 -
ZAD Energy 28 30
Transgaz S.A. Romania 13 27
Revenue from dividend-related default interest
Natsionalna Electricheska Kompania EAD - 22
632,297 855,113
Separate financial statements
31 December 2024
28
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
In most cases, the appropriate adjustments in relation to market risk and risk factors that are specific to individual
assets are assessed in determining the applicable discount factor.
Investments in associates
BEH EAD owns directly 0.32% of the share capital of ZAD Energy. The equity investment is accounted for as an
investment in an associate due to additional indirect participation in the capital of ZAD Energy through other
subsidiaries, resulting in a total direct and indirect equity participation of 48.08%.
Revenue from contracts with clients
In recognizing revenue from contracts with clients, management makes various estimates, estimates and assumptions
that affect the reported revenue, expenses, assets and liabilities under contracts. The key estimates and assumptions
that have a material impact on the amount and timing of recognizing revenue from client contracts are disclosed in
note 4.5 Revenue Recognition, Performance obligations and approach to recognizing the main types of revenue from
client contracts. Assets with the right of use and liabilities under leasing contracts
The management makes estimates based on its assessments of the elements of the lease in the contracts, the probable
terms of the leases, the options for extension and termination, the determination of the differential interest rate, etc.
upon recognition of “assets with the right of use” and liabilities under leasing contracts. These estimates affect the
reported income, expenses, assets and liabilities under leasing contracts and the corresponding disclosures.
As a result of uncertainty about these assumptions and estimates, changes in the carrying amount of usable assets,
lease liabilities and reported costs and income may arise as a result of changes in revaluations or changes in leases.
Retirement benefits
Retirement benefits are determined by actuarial valuation. This assessment requires assumptions to be made about the
discount rate, future wage growth, staff turnover and mortality rates. Due to the long -term nature of staff income at
retirement, these assumptions are subject to significant uncertainty. As of 31 December 2024, the Company’s liability
for staff retirement benefits recognized in the separated statement of financial position amounts to BGN 1,627
thousand (31 December 2023: BGN 1,825 thousand). Additional information on staff benefits at retirement is provided
in Note 30.
Useful life of property, plant and equipment and intangible assets
Financial reporting of property, plant and equipment and intangible assets includes the use of estimates for their
expected useful lives and residual values that are based on the Company’s management judgment. Information on the
useful life of property, plant and equipment is presented in Note 4.10, and intangible assets – Note 4.13.
Fair value of property, plant and equipment
The Company subsequently recognizes land and buildings at revalued amounts using independent external appraisers’
reports to determine their fair value. Detailed information for the revaluation, valuation methods used, assumptions
and fair value estimates, is presented in Note 19.
5.Dividend income
2024 2023
thousand BGN thousand BGN
Bulgartransgaz EAD 257,251 -
NPP Kozloduy EAD 241,673 364,731
Electricity System Operator EAD 123,503 40,989
Natsionalna Electricheska Kompania EAD - 449,314
ICGB AD 9,829 -
ZAD Energy 28 30
Transgaz S.A. Romania 13 27
Revenue from dividend-related default interest
Natsionalna Electricheska Kompania EAD - 22
632,297 855,113
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
29
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
6.Revenue from contracts with customers
2024 2023
thousand
BGN thousand BGN
Revenue from holding agreements services 2,038 1,999
Agent service from the sale of СО 2 emissions 35 36
Other 43 -
2,116 2,035
Revenue from holding agreements services
According to holding agreements signed with Bulgargaz EAD, NEK EAD, TPP Maritsa East 2 EAD, Mini Maritsa
Iztok EAD, NPP Kozloduy EAD, National Energy Operator EAD and Minproekt EAD, BEH EAD provides billable
services to its subsidiaries in the field of financial management, project and investment management, corporate
governance and business planning, legal and regulatory issues and public relations. Revenues are calculated based on
actual hours spent for the respective companies.
Revenue from agency service from sale of СО 2 emissions
In July 2021, a framework agreement was concluded with TPP Maritsa East 2 EAD for the sale and purchase of
European greenhouse gas emissions allowances of EUA type. By the commitment, BEH EAD undertakes to purchase
greenhouse gas emission allowances on a regular basis following an order from the buyer TPP Maritsa East 2 EAD.
The purchased allowances shall be transferred to the buyer’s account after full payment is made.
For 2024, the Company has purchased and transferred to the account of TPP Maritsa East 2 EAD in the National
Greenhouse Gas Emission Allowance Trading Register (the National Register) 1,803,687 tons of allowances (2023:
1,752,285 tons).
7.Other income
2024, 2023
thousand
BGN
thousand
BGN
Residual liability upon early termination of lease contract. 273 -
Refunds from related parties 64 17
Interest income on overdue receivables under holding agreements 6 -
Funding revenues for electricity consumed 6 2
Interest income overdue receivables from the sale of СО 2 emissions - 14
Gain on sale of assets - 12
Other - 1
349 46
Separate financial statements
31 December 2024
29
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
6.Revenue from contracts with customers
2024 2023
thousand
BGN thousand BGN
Revenue from holding agreements services 2,038 1,999
Agent service from the sale of СО 2 emissions 35 36
Other 43 -
2,116 2,035
Revenue from holding agreements services
According to holding agreements signed with Bulgargaz EAD, NEK EAD, TPP Maritsa East 2 EAD, Mini Maritsa
Iztok EAD, NPP Kozloduy EAD, National Energy Operator EAD and Minproekt EAD, BEH EAD provides billable
services to its subsidiaries in the field of financial management, project and investment management, corporate
governance and business planning, legal and regulatory issues and public relations. Revenues are calculated based on
actual hours spent for the respective companies.
Revenue from agency service from sale of СО 2 emissions
In July 2021, a framework agreement was concluded with TPP Maritsa East 2 EAD for the sale and purchase of
European greenhouse gas emissions allowances of EUA type. By the commitment, BEH EAD undertakes to purchase
greenhouse gas emission allowances on a regular basis following an order from the buyer TPP Maritsa East 2 EAD.
The purchased allowances shall be transferred to the buyer’s account after full payment is made.
For 2024, the Company has purchased and transferred to the account of TPP Maritsa East 2 EAD in the National
Greenhouse Gas Emission Allowance Trading Register (the National Register) 1,803,687 tons of allowances (2023:
1,752,285 tons).
7.Other income
2024, 2023
thousand
BGN
thousand
BGN
Residual liability upon early termination of lease contract. 273 -
Refunds from related parties 64 17
Interest income on overdue receivables under holding agreements 6 -
Funding revenues for electricity consumed 6 2
Interest income overdue receivables from the sale of СО 2 emissions - 14
Gain on sale of assets - 12
Other - 1
349 46
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
30
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
8.Impairment expenses
2024 2023
thousand
BGN
thousand
BGN
Impairment of investments:
Impairment costs of investment in Bulgargaz EAD (note 18) - (325,555)
Expenses for impairment of other investments (49) -
Impairment of debt instruments at amortized cost:
Impairment of loans to related parties (84,275) (211,453)
Impairment of receivables from Toplofikatsia Sofia EAD (4,701) (10,056)
Impairment of trade receivables from related parties (11) -
Impairment of other receivables from related parties (543) (3,640)
Impairment of cash (666) (596)
Reversal of impairment of loans granted to related parties 20,528 552,685
Reversal of impairment of receivables from Toplofikatsia Sofia EAD 5,951 110,776
Reversal of impairment of cash 658 7,633
Reintegrated impairment of other receivables from related parties 403 -
Reintegrated impairment of CCBn receivables 44 -
Reversal of impairment of trade receivables from related parties 3 -
(62,658) 119,794
9.Expenses for materials
2024 2023
thousand
BGN
thousand
BGN
Car maintenance costs (98) (136)
Office supplies and consumables (53) (70)
Cost of assets below the recognition threshold (21) (34)
(172) (240)
10.Hired services expenses
2024 2023
thousand
BGN
thousand
BGN
Consultancy service (4,233) (1,691)
Security (131) (108)
Advertisements and announcements (105) -
Subscription service (104) (102)
Insurances (118) (99)
Car maintenance (63) (91)
Heat, electricity and water (65) (69)
Cleaning (66) (50)
Communications (45) (40)
Miscellaneous fees (8) (24)
Rentals (20) (17)
Translation services (18) (13)
Repairs (13) (3)
Ensuring occupational health and safety (3) (1)
Other (15) (1)
(5,007) (2,309)
Separate financial statements
31 December 2024
30
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
8.Impairment expenses
2024 2023
thousand
BGN
thousand
BGN
Impairment of investments:
Impairment costs of investment in Bulgargaz EAD (note 18) - (325,555)
Expenses for impairment of other investments (49) -
Impairment of debt instruments at amortized cost:
Impairment of loans to related parties (84,275) (211,453)
Impairment of receivables from Toplofikatsia Sofia EAD (4,701) (10,056)
Impairment of trade receivables from related parties (11) -
Impairment of other receivables from related parties (543) (3,640)
Impairment of cash (666) (596)
Reversal of impairment of loans granted to related parties 20,528 552,685
Reversal of impairment of receivables from Toplofikatsia Sofia EAD 5,951 110,776
Reversal of impairment of cash 658 7,633
Reintegrated impairment of other receivables from related parties 403 -
Reintegrated impairment of CCBn receivables 44 -
Reversal of impairment of trade receivables from related parties 3 -
(62,658) 119,794
9.Expenses for materials
2024 2023
thousand
BGN
thousand
BGN
Car maintenance costs (98) (136)
Office supplies and consumables (53) (70)
Cost of assets below the recognition threshold (21) (34)
(172) (240)
10.Hired services expenses
2024 2023
thousand
BGN
thousand
BGN
Consultancy service (4,233) (1,691)
Security (131) (108)
Advertisements and announcements (105) -
Subscription service (104) (102)
Insurances (118) (99)
Car maintenance (63) (91)
Heat, electricity and water (65) (69)
Cleaning (66) (50)
Communications (45) (40)
Miscellaneous fees (8) (24)
Rentals (20) (17)
Translation services (18) (13)
Repairs (13) (3)
Ensuring occupational health and safety (3) (1)
Other (15) (1)
(5,007) (2,309)
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
31
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
11.Audit services remuneration
These separate financial statements have been audited by DZZD AUDIT BEH with participants in the Grant Thornton
OOD and Zaharinova Nexia EOOD associations, on the basis of a contract concluded between Bulgarian Energy
Holding EAD and DZZD AUDIT BEH.
The remuneration of the registered auditors is BGN 1,452 thousand excluding VAT and includes an independent
financial audit of the annual and interim separated financial statements of BEH EAD, NEK EAD, NPP Kozloduy
EAD, TPP Maritsa East 2 EAD, Mini Maritsa Iztok EAD, Bulgargaz EAD, NPP Kozloduy - New Builds EAD, HPP
Kozloduy EAD, National Energy Operator (NEO) / (Natsionalen Energien Operator) EAD, and Minpr oekt EAD, as
well as the annual and interim consolidated financial statements of BEH EAD and NPP Kozloduy EAD.
In 2024, the audit firm Grant Thornton OOD received remuneration for permitted services under two engagements
for the audit of forecast financial information in the total amount of BGN 39 thousand as well as under one engagement
of agreed-upon procedures of a subsidiary in the amount of BGN 44 thousand.
12.Personnel expenses
2024 2023
thousand
BGN
thousand
BGN
Remuneration (6,645) (5,989)
Social security (970) (1,063)
Social costs (2,340) (1,971)
Accrued retirement benefits (202) (503)
Unused annual leave and social security expenses thereto (320) (347)
(10,477) (9,873)
13.Other expenses
2024 2023
thousand
BGN
thousand
BGN
Donations (99) (351)
Written-off receivables (285) -
Balance of written off assets with right to use (235) -
Tax credit adjustment (234) (173)
Business trips and representative costs (141) (154)
Trainings, qualifications, seminars (76) (96)
Income Taxes (91) (95)
Other - (61)
(1,161) (930)
14.Financial income
2024 2023
thousand
BGN
thousand
BGN Interest income on loans granted at amortized cost 176,495 178,028
Interest income receivable from Toplofikatsia Sofia EAD 12,261 38,395
Interest income on bank current and deposit accounts 4,199 1,597
Total interest incomes under financial assets, which are not accounted at fair
value in the profit or loss 192,955 218,020
192,955 218,020
Separate financial statements
31 December 2024
31
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
11.Audit services remuneration
These separate financial statements have been audited by DZZD AUDIT BEH with participants in the Grant Thornton
OOD and Zaharinova Nexia EOOD associations, on the basis of a contract concluded between Bulgarian Energy
Holding EAD and DZZD AUDIT BEH.
The remuneration of the registered auditors is BGN 1,452 thousand excluding VAT and includes an independent
financial audit of the annual and interim separated financial statements of BEH EAD, NEK EAD, NPP Kozloduy
EAD, TPP Maritsa East 2 EAD, Mini Maritsa Iztok EAD, Bulgargaz EAD, NPP Kozloduy - New Builds EAD, HPP
Kozloduy EAD, National Energy Operator (NEO) / (Natsionalen Energien Operator) EAD, and Minpr oekt EAD, as
well as the annual and interim consolidated financial statements of BEH EAD and NPP Kozloduy EAD.
In 2024, the audit firm Grant Thornton OOD received remuneration for permitted services under two engagements
for the audit of forecast financial information in the total amount of BGN 39 thousand as well as under one engagement
of agreed-upon procedures of a subsidiary in the amount of BGN 44 thousand.
12.Personnel expenses
2024 2023
thousand
BGN
thousand
BGN
Remuneration (6,645) (5,989)
Social security (970) (1,063)
Social costs (2,340) (1,971)
Accrued retirement benefits (202) (503)
Unused annual leave and social security expenses thereto (320) (347)
(10,477) (9,873)
13.Other expenses
2024 2023
thousand
BGN
thousand
BGN
Donations (99) (351)
Written-off receivables (285) -
Balance of written off assets with right to use (235) -
Tax credit adjustment (234) (173)
Business trips and representative costs (141) (154)
Trainings, qualifications, seminars (76) (96)
Income Taxes (91) (95)
Other - (61)
(1,161) (930)
14.Financial income
2024 2023
thousand
BGN
thousand
BGN Interest income on loans granted at amortized cost 176,495 178,028
Interest income receivable from Toplofikatsia Sofia EAD 12,261 38,395
Interest income on bank current and deposit accounts 4,199 1,597
Total interest incomes under financial assets, which are not accounted at fair
value in the profit or loss 192,955 218,020
192,955 218,020
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
32
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
15.Financial expenses
2024 2023
thousand
BGN
thousand
BGN
Interest expense on bond issues (71,242) (71,198)
Interest expense on a loan received (1,774) (1,774)
Interest paid on loans taken from related parties (458) (1,034)
Lease interest expense (41) (65)
Interest expense on staff benefits in retirement (91) (57)
Total interest expense on financial liabilities not accounted for at fair value in
profit or loss (73,606) (74,128)
Fees for issued bank guarantee - (467)
Bank fees (5) (6)
Loss on exchange rate differences, net (12) (16)
(73,623) (74,617)
16.Income tax expenses
The reconciliation between the income tax expense and the book profit multiplied by the applicable tax rate for the
years ending 31 December 2024 and 31 December 2023, is presented below:
2024 2023
thousand
BGN
thousand
BGN
Profit before taxes 673,878 1,105,773
Tax rate 10% 10%
Tax expense at the applicable tax rate (67,388) (110,577)
Tax effect of:
Expenses not recognized for tax purposes (9,196) (55,380)
Non-taxable income 70,064 158,018
Current tax expense (6,520) (7,939)
Current tax expense in relation to national surtax under Article 260я 25 of the
Corporate Income Tax Act (264) -
Deferred tax income/(expense), net 2,357 (17,204)
Income tax expense (4,427) (25,143)
Deferred tax (expense)/income recognized recognised directly in other
comprehensive income (171) 32
Note 21 provides information on deferred tax assets and liabilities, including the amounts recognized in other
comprehensive income.
17. Earnings per share and dividends
17.1 Earnings per share
The basic earnings per share have been calculated using distributable net income as the numerator. The weighted
average number of shares used for the calculation of basic earnings per share and the net profit attributable to the
ordinary shareholder, are as follows:
Separate financial statements
31 December 2024
32
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
15.Financial expenses
2024 2023
thousand
BGN
thousand
BGN
Interest expense on bond issues (71,242) (71,198)
Interest expense on a loan received (1,774) (1,774)
Interest paid on loans taken from related parties (458) (1,034)
Lease interest expense (41) (65)
Interest expense on staff benefits in retirement (91) (57)
Total interest expense on financial liabilities not accounted for at fair value in
profit or loss (73,606) (74,128)
Fees for issued bank guarantee - (467)
Bank fees (5) (6)
Loss on exchange rate differences, net (12) (16)
(73,623) (74,617)
16.Income tax expenses
The reconciliation between the income tax expense and the book profit multiplied by the applicable tax rate for the
years ending 31 December 2024 and 31 December 2023, is presented below:
2024 2023
thousand
BGN
thousand
BGN
Profit before taxes 673,878 1,105,773
Tax rate 10% 10%
Tax expense at the applicable tax rate (67,388) (110,577)
Tax effect of:
Expenses not recognized for tax purposes (9,196) (55,380)
Non-taxable income 70,064 158,018
Current tax expense (6,520) (7,939)
Current tax expense in relation to national surtax under Article 260я 25 of the
Corporate Income Tax Act (264) -
Deferred tax income/(expense), net 2,357 (17,204)
Income tax expense (4,427) (25,143)
Deferred tax (expense)/income recognized recognised directly in other
comprehensive income (171) 32
Note 21 provides information on deferred tax assets and liabilities, including the amounts recognized in other
comprehensive income.
17. Earnings per share and dividends
17.1 Earnings per share
The basic earnings per share have been calculated using distributable net income as the numerator. The weighted
average number of shares used for the calculation of basic earnings per share and the net profit attributable to the
ordinary shareholder, are as follows:
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
33
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2024 2023
Net profit attributable to the shareholders (in BGN) 669,450,889.95 1,080,629,305.57
Weighted average number of shares 3,463,941,744 3,463,067,771
Earnings per share (BGN per share) 0.193 0.312
17.2 Dividends
The distribution of profit is made pursuant to a decision of the sole shareholder of the capital, in compliance with the
following order:
• at least 10% of the profit is allocated to the Reserve Fund;
• a dividend determined on the basis of a decision of the Council of Ministers in compliance with the State
Budget Act;
• at the proposal of the Board of Directors it is possible to set aside a part of the profit, subject to distribution
in certain funds of the Company;
By Decision No.16 of 3 October 2024 in Constitutional Case No.14 of 2024, the Constitutional Court unanimously
declared unconstitutional the Decision of the National Assembly of 29 March 2024 assigning the Minister of Energy,
respectively Bulgarian Energy Holding EAD, to not distribute a dividend from the Company's profit for the financial
year 2023. As a consequence of this act, the Council of Ministers (CoM) issued Order No. 3 of 16 October 2024
amending and supplementing Order No. 1 of the CoM of 2024 on the establishment and payment to the State of
deductions from the profits of State-owned enterprises and commercial companies with State participation in the
capital, supplemented by Order No. 2 of the CoM of 2024. Bulgarian Energy Holding EAD has an obli gation to pay
a dividend for the financial year 2023 in the amount of BGN 1,080,529 thousand, from which shall be deducted the
dividend paid in 2023 pursuant to item 5b and item 6a of Order No. 2 of the Council of Ministers of 2023 on the
establishment and payment to the State of deductions from the profits of State-owned enterprises and commercial
companies with State participation in the capital, as amended and supplemented by Orders No. 3, 4, 5 and 7 of the
Council of Ministers of 2023. The deadline for payment of the balance of the dividend is 18 October 2024. The
Company has deposited the balance dividend payable amounting to 280,529 thousand on time.
In 2024, the Company paid a dividend to the Republic of Bulgaria in the amount of BGN 280,529 thousand. (2023:
BGN 1,439,706 thousand).
18.Investments in subsidiaries, associates and joint ventures
31 December 2024 31 December 2023
Country of
incorporation Share Amount of
investments Share Amount of
investments
thousand BGN thousand BGN
Subsidiaries
Bulgartransgaz EAD Bulgaria 100% 934,569 100% 734,569
Bulgargaz EAD 325,391 325,391
Bulgargaz EAD – impairment (325,391) (325,391)
Bulgargaz EAD, net Bulgaria 100% - 100% -
NEK EAD Bulgaria 100% 1,051,427 100% 1,051,427
NPP Kozloduy EAD Bulgaria 100% 1,601,716 100% 1,601,716
TPP Maritsa East 2 EAD Bulgaria 100% 673,916 100% 673,916
Mini Maritsa Iztok EAD Bulgaria 100% 65,000 100% 65,000
Separate financial statements
31 December 2024
33
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2024 2023
Net profit attributable to the shareholders (in BGN) 669,450,889.95 1,080,629,305.57
Weighted average number of shares 3,463,941,744 3,463,067,771
Earnings per share (BGN per share) 0.193 0.312
17.2 Dividends
The distribution of profit is made pursuant to a decision of the sole shareholder of the capital, in compliance with the
following order:
• at least 10% of the profit is allocated to the Reserve Fund;
• a dividend determined on the basis of a decision of the Council of Ministers in compliance with the State
Budget Act;
• at the proposal of the Board of Directors it is possible to set aside a part of the profit, subject to distribution
in certain funds of the Company;
By Decision No.16 of 3 October 2024 in Constitutional Case No.14 of 2024, the Constitutional Court unanimously
declared unconstitutional the Decision of the National Assembly of 29 March 2024 assigning the Minister of Energy,
respectively Bulgarian Energy Holding EAD, to not distribute a dividend from the Company's profit for the financial
year 2023. As a consequence of this act, the Council of Ministers (CoM) issued Order No. 3 of 16 October 2024
amending and supplementing Order No. 1 of the CoM of 2024 on the establishment and payment to the State of
deductions from the profits of State-owned enterprises and commercial companies with State participation in the
capital, supplemented by Order No. 2 of the CoM of 2024. Bulgarian Energy Holding EAD has an obli gation to pay
a dividend for the financial year 2023 in the amount of BGN 1,080,529 thousand, from which shall be deducted the
dividend paid in 2023 pursuant to item 5b and item 6a of Order No. 2 of the Council of Ministers of 2023 on the
establishment and payment to the State of deductions from the profits of State-owned enterprises and commercial
companies with State participation in the capital, as amended and supplemented by Orders No. 3, 4, 5 and 7 of the
Council of Ministers of 2023. The deadline for payment of the balance of the dividend is 18 October 2024. The
Company has deposited the balance dividend payable amounting to 280,529 thousand on time.
In 2024, the Company paid a dividend to the Republic of Bulgaria in the amount of BGN 280,529 thousand. (2023:
BGN 1,439,706 thousand).
18.Investments in subsidiaries, associates and joint ventures
31 December 2024 31 December 2023
Country of
incorporation Share Amount of
investments Share Amount of
investments
thousand BGN thousand BGN
Subsidiaries
Bulgartransgaz EAD Bulgaria 100% 934,569 100% 734,569
Bulgargaz EAD 325,391 325,391
Bulgargaz EAD – impairment (325,391) (325,391)
Bulgargaz EAD, net Bulgaria 100% - 100% -
NEK EAD Bulgaria 100% 1,051,427 100% 1,051,427
NPP Kozloduy EAD Bulgaria 100% 1,601,716 100% 1,601,716
TPP Maritsa East 2 EAD Bulgaria 100% 673,916 100% 673,916
Mini Maritsa Iztok EAD Bulgaria 100% 65,000 100% 65,000
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
34
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2024 31 December 2023
Country of
incorporation Share Amount of
investments Share Amount of
investments
thousand BGN thousand BGN
ESO EAD Bulgaria 100% 96,103 100% 96,103
National Energy Operator (NEO) /
(Natsionalen Energien Operator)
EAD
Bulgaria 100% 30,000 100% 30,000
Minproekt EAD Bulgaria 100% 1,000 100% 1,000
4,453,731 4,253,731
Joint ventures
ICGB AD Bulgaria 50% 57,991 50% 57,991
South Stream Bulgaria AD 34,372 34,372
Impairment (24,242) (24,193)
South Stream Bulgaria AD, net Bulgaria 50% 10,130 50% 10,179
68,121 68,170
Affiliated company
ZAD Energy Bulgaria 0.32% 21 0.32% 21
21 21
4,521,873 4,321,922
Increase in investment in Bulgartransgaz EAD
Pursuant to the Decision of the National Assembly of 14.03.2024 to take action in connection with the Vertical
Corridor initiative of the gas transmission operators of Bulgaria, Greece, Romania, Hungary, Slovakia, Ukraine and
Moldova, providing the opportunity for the transmission of additional volumes of natural gas from diverse and reliable
sources in the south-north direction, "Bulgarian Energy Holding EAD increased the capital of Bulgartransgaz EAD
by a cash contribution of BGN 200,000,000 by issuing 200,000,000 new ordinary registered shares with voting rights
with a nominal value of one BGN each. The increase was entered in the Commercial Register and the Register of
Non-Profit Legal Entities on 20 June 2024.
Summarized financial information on associates and joint ventures
The tables contain summarized information on the basis of BEH EAD’s associate’ and joint ventures’ financial
statements.
31 December 2024 Total assets Total
liabilities
Revenues Net profit
/ (loss)
thousand BGN thousand
BGN
thousand
BGN
thousand
BGN
ICGB AD 601,173 448,389 68,954 32,393
South Streаm Bulgaria AD (non-audited data) 20,306 38 6 (261)
ZAD Energy 33,940 6,517 15,589 7,469
655,419 454,944 84,549 39,601
Separate financial statements
31 December 2024
34
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2024 31 December 2023
Country of
incorporation Share Amount of
investments Share Amount of
investments
thousand BGN thousand BGN
ESO EAD Bulgaria 100% 96,103 100% 96,103
National Energy Operator (NEO) /
(Natsionalen Energien Operator)
EAD
Bulgaria 100% 30,000 100% 30,000
Minproekt EAD Bulgaria 100% 1,000 100% 1,000
4,453,731 4,253,731
Joint ventures
ICGB AD Bulgaria 50% 57,991 50% 57,991
South Stream Bulgaria AD 34,372 34,372
Impairment (24,242) (24,193)
South Stream Bulgaria AD, net Bulgaria 50% 10,130 50% 10,179
68,121 68,170
Affiliated company
ZAD Energy Bulgaria 0.32% 21 0.32% 21
21 21
4,521,873 4,321,922
Increase in investment in Bulgartransgaz EAD
Pursuant to the Decision of the National Assembly of 14.03.2024 to take action in connection with the Vertical
Corridor initiative of the gas transmission operators of Bulgaria, Greece, Romania, Hungary, Slovakia, Ukraine and
Moldova, providing the opportunity for the transmission of additional volumes of natural gas from diverse and reliable
sources in the south-north direction, "Bulgarian Energy Holding EAD increased the capital of Bulgartransgaz EAD
by a cash contribution of BGN 200,000,000 by issuing 200,000,000 new ordinary registered shares with voting rights
with a nominal value of one BGN each. The increase was entered in the Commercial Register and the Register of
Non-Profit Legal Entities on 20 June 2024.
Summarized financial information on associates and joint ventures
The tables contain summarized information on the basis of BEH EAD’s associate’ and joint ventures’ financial
statements.
31 December 2024 Total assets Total
liabilities
Revenues Net profit
/ (loss)
thousand BGN thousand
BGN
thousand
BGN
thousand
BGN
ICGB AD 601,173 448,389 68,954 32,393
South Streаm Bulgaria AD (non-audited data) 20,306 38 6 (261)
ZAD Energy 33,940 6,517 15,589 7,469
655,419 454,944 84,549 39,601
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
35
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2023 Total assets Total
liabilities
Revenues Net profit
/ (loss)
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
ICGB AD 619,373 479,122 63,219 32,704
South Streаm Bulgaria AD (non-audited data) 20,553 195 - (268)
ZAD Energy 33,429 5,391 15,710 8,525
673,355 484,708 78,929 40,961
ICGB AD Joint Venture
BEH EAD is a shareholder in ICGB AD – a company with an equal interest of BEH EAD and IGI Poseidon (a
company with an equal interest of DEPA S.A. and Edison SpA), registered in 2011 in the Republic of Bulgaria,
intended to build and become an owner and operator of a gas interconnection network IGB.
In 2022, ICGB AD built the gas interconnector Greece-Bulgaria with a technical capacity of up to 3 billion m 3 /year
from Komotini to Stara Zagora with a length of 182 km.
ICGB AD is licensed and certified as a transmission network operator under the Independent Transmission Operator
model, with a two-tier management system – a Management and Supervisory Board, and since 1 October 2022, has
carried out natural gas transmission operations through the gas interconnector, through which all volumes of the
contracted Azeri gas for Bulgaria are transferred, and it receives revenues from the provision of transmission services
from transmission, based on current long-term transmission contracts, is approx. 1.5 billion m 3 /year.
The year 2024 is the second full year of operation of the gas pipeline.
South Stream Bulgaria Joint Venture AD
The South Stream project, which has been discontinued, provided for the construction of a new gas pipeline system
for transporting natural gas from Russia to the European market, through Bulgaria, with a technical capacity of 63
billion m3/year on the 900-kilometer Black Sea section. Shareholders with equal interest in the joint venture on the
Bulgarian territory (which is no longer operating) are Bulgarian Energy Holding EAD and Gazprom Krasnodar.
A decision on the liquidation of the project company is to be considered, and in the liquidation process, if such a
decision is taken, the remaining assets - land properties - should be sold.
For 2024, impairment of the investment was charged on a liquidation basis in the amount of BGN 49 thousand. (2023:
BGN 164 thousand). The total impairment charge on the investment as of 31 December 2024 is BGN 24,242 thousand.
(31 December 2023: BGN 24,193 thousand).
Separate financial statements
31 December 2024
35
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2023 Total assets Total
liabilities
Revenues Net profit
/ (loss)
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
ICGB AD 619,373 479,122 63,219 32,704
South Streаm Bulgaria AD (non-audited data) 20,553 195 - (268)
ZAD Energy 33,429 5,391 15,710 8,525
673,355 484,708 78,929 40,961
ICGB AD Joint Venture
BEH EAD is a shareholder in ICGB AD – a company with an equal interest of BEH EAD and IGI Poseidon (a
company with an equal interest of DEPA S.A. and Edison SpA), registered in 2011 in the Republic of Bulgaria,
intended to build and become an owner and operator of a gas interconnection network IGB.
In 2022, ICGB AD built the gas interconnector Greece-Bulgaria with a technical capacity of up to 3 billion m 3 /year
from Komotini to Stara Zagora with a length of 182 km.
ICGB AD is licensed and certified as a transmission network operator under the Independent Transmission Operator
model, with a two-tier management system – a Management and Supervisory Board, and since 1 October 2022, has
carried out natural gas transmission operations through the gas interconnector, through which all volumes of the
contracted Azeri gas for Bulgaria are transferred, and it receives revenues from the provision of transmission services
from transmission, based on current long-term transmission contracts, is approx. 1.5 billion m 3 /year.
The year 2024 is the second full year of operation of the gas pipeline.
South Stream Bulgaria Joint Venture AD
The South Stream project, which has been discontinued, provided for the construction of a new gas pipeline system
for transporting natural gas from Russia to the European market, through Bulgaria, with a technical capacity of 63
billion m3/year on the 900-kilometer Black Sea section. Shareholders with equal interest in the joint venture on the
Bulgarian territory (which is no longer operating) are Bulgarian Energy Holding EAD and Gazprom Krasnodar.
A decision on the liquidation of the project company is to be considered, and in the liquidation process, if such a
decision is taken, the remaining assets - land properties - should be sold.
For 2024, impairment of the investment was charged on a liquidation basis in the amount of BGN 49 thousand. (2023:
BGN 164 thousand). The total impairment charge on the investment as of 31 December 2024 is BGN 24,242 thousand.
(31 December 2023: BGN 24,193 thousand).
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
36
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
19.Property, plant and equipment
For the year as of
31 December 2024
Land
and
building
s
Plant and
equipment Vehicles
Equipment
and other
assets
Right of
use assets
Acquisit
ion costs Total
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Gross book value
Balance as of 1 January 2024 6,898 85 975 766 2,002 - 10,726
Additions 278 18 427 121 - 74 918
Disposals - - - (81) (454) - (535)
Revaluation on account of
accumulated depreciation (244) - - - - - (244)
Revaluation 1,157 - - - - - 1,157
Balance as of 31 December
2024 8,089 103 1,402 806 1,548 74 12,022
Depreciation
Balance as of 1 January 2024 (130) (21) (972) (590) (445) - (2,158)
Depreciation charges for the
year (114) (14) (27) (108) (455) - (718)
Revaluation on account of
accumulated depreciation 244 - - - - - 244
Disposals - - - 77 219 - 296
Balance as of 31 December
2024 - (35) (999) (621) (681) - (2,336)
Carrying amount
as of 31 December 2024 8,089 68 403 185 867 74 9,686
For the year as of
31 December 2023
Land and
buildings
Plant and
equipment Vehicles
Equipment
and other
assets
Right of use
assets Total
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Gross book value
Balance as of 1 January 2023 6,898 38 1,125 965 710 9,736
Additions - 50 - 73 1,444 1,567
Disposals - (3) (150) (272) (152) (577)
Balance as of 31 December 2023 6,898 85 975 766 2,002 10,726
Depreciation
Balance as of 1 January 2023 (24) (12) (1,100) (755) (218) (2,109)
Depreciation charges for the year (106) (12) (21) (105) (379) (623)
Disposals - 3 149 270 152 574
For the year as of
31 December 2023
Land and
buildings
Plant and
equipment Vehicles
Equipment
and other
assets
Right of use
assets Total
Balance as of 31 December 2023 (130) (21) (972) (590) (445) (2,158)
Carrying amount
as of 31 December 2023 6,768 64 3 176 1,557 8,568
Separate financial statements
31 December 2024
36
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
19.Property, plant and equipment
For the year as of
31 December 2024
Land
and
building
s
Plant and
equipment Vehicles
Equipment
and other
assets
Right of
use assets
Acquisit
ion costs Total
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Gross book value
Balance as of 1 January 2024 6,898 85 975 766 2,002 - 10,726
Additions 278 18 427 121 - 74 918
Disposals - - - (81) (454) - (535)
Revaluation on account of
accumulated depreciation (244) - - - - - (244)
Revaluation 1,157 - - - - - 1,157
Balance as of 31 December
2024 8,089 103 1,402 806 1,548 74 12,022
Depreciation
Balance as of 1 January 2024 (130) (21) (972) (590) (445) - (2,158)
Depreciation charges for the
year (114) (14) (27) (108) (455) - (718)
Revaluation on account of
accumulated depreciation 244 - - - - - 244
Disposals - - - 77 219 - 296
Balance as of 31 December
2024 - (35) (999) (621) (681) - (2,336)
Carrying amount
as of 31 December 2024 8,089 68 403 185 867 74 9,686
For the year as of
31 December 2023
Land and
buildings
Plant and
equipment Vehicles
Equipment
and other
assets
Right of use
assets Total
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Gross book value
Balance as of 1 January 2023 6,898 38 1,125 965 710 9,736
Additions - 50 - 73 1,444 1,567
Disposals - (3) (150) (272) (152) (577)
Balance as of 31 December 2023 6,898 85 975 766 2,002 10,726
Depreciation
Balance as of 1 January 2023 (24) (12) (1,100) (755) (218) (2,109)
Depreciation charges for the year (106) (12) (21) (105) (379) (623)
Disposals - 3 149 270 152 574
For the year as of
31 December 2023
Land and
buildings
Plant and
equipment Vehicles
Equipment
and other
assets
Right of use
assets Total
Balance as of 31 December 2023 (130) (21) (972) (590) (445) (2,158)
Carrying amount
as of 31 December 2023 6,768 64 3 176 1,557 8,568
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
37
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Revaluation of property, plant and equipment
Under the Company’s accounting policy, property, plant and equipment are revalued three years or at shorter intervals.
As of 31 December 2024, such a revaluation was carried out.
The revaluation of property, plant and equipment for subsequent revaluation was carried out by an independent
licensed appraiser in accordance with the Bulgarian Valuation Standards, the Accounting Act, IAS 16 Property, Plant
and Equipment and IFRS 13 Fair Value Measurement. As a result of the revaluation, the revaluation reserve was
increased by BGN 1,157 thousand.
The Company has reviewed property, plant and equipment for indicators of impairment as of 31 December 2024. No
indication has been identified that the carrying value of the assets exceeds their recoverable amount, including no
changes to the remaining useful lives of the assets. As a result, no impairment loss was recognized in the separate
financial statements.
Right of use assets
On 31 July 2019, the Company recognized BGN 71 thousand of cloud resources as a right-of-use asset for a period of
five years. The full contractual amount was paid at the beginning of the contract. To determine the present value of
the lease liability, Bulgarian Energy Holding EAD used a discount rate of 3.50%, which is an interest rate obtained
by the Company in financing its own activities in the last year, and corresponding to the market levels. As of 31
December 2024, the right-of-use asset has been written off.
On 1 May 2022, the Company has recognized right-of-use assets in the amount of BGN 459 thousand under a rental
contract of a real estate for administrative purposes for a period of five years with an option for extension. To determine
the present value of the lease liability, Bulgarian Energy Holding EAD has used a discount rate of 2.45%, which is
the interest rate obtained by the company when financing its activities in the last year and corresponding to market
levels.
On 1 February 2023, the Company has recognized right-of-use assets in the amount of BGN 83 thousand under a
rental contract of an office for a period of four years with an option for extension. To determine the present value of
the lease liability, Bulgarian Energy Holding EAD has used a discount rate of 2.45%, which is an interest rate obtained
by the Company in financing its own activities.
The Company has leased 10 motor vehicles under lease agreements. The duration of the agreements is from 2 to 5
years. The calculated annual interest rates for vehicle leases range from 0.98% to 24.05%.
As of 31 December 2024, and 31 December 2023, the Company had no commitments to purchase property, plant and
equipment and has not provided any collateral related thereto.
All depreciation expenses are included in the separate profit and loss report in the line “Depreciation expense of non -
financial assets”.
20.Intangible assets
For the year as of
31 December 2024 Software Patents and
licenses Other Acquisition
expenses Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross book value
Balance as of 1 January 2024 305 68 4 195 572
Balance as of 31 December 2024 305 68 4 195 572
For the year as of
31 December 2024 Software Patents and
licenses Other Acquisition
expenses Total
Amortisation
Balance as of 1 January 2024 (263) (56) (3) - (322)
Amortisation charges (18) (4) (1) - (23)
Balance as of 31 December 2024 (281) (60) (4) - (345)
Carrying amount
as of 31 December 2024 24 8 - 195 227
Separate financial statements
31 December 2024
37
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Revaluation of property, plant and equipment
Under the Company’s accounting policy, property, plant and equipment are revalued three years or at shorter intervals.
As of 31 December 2024, such a revaluation was carried out.
The revaluation of property, plant and equipment for subsequent revaluation was carried out by an independent
licensed appraiser in accordance with the Bulgarian Valuation Standards, the Accounting Act, IAS 16 Property, Plant
and Equipment and IFRS 13 Fair Value Measurement. As a result of the revaluation, the revaluation reserve was
increased by BGN 1,157 thousand.
The Company has reviewed property, plant and equipment for indicators of impairment as of 31 December 2024. No
indication has been identified that the carrying value of the assets exceeds their recoverable amount, including no
changes to the remaining useful lives of the assets. As a result, no impairment loss was recognized in the separate
financial statements.
Right of use assets
On 31 July 2019, the Company recognized BGN 71 thousand of cloud resources as a right-of-use asset for a period of
five years. The full contractual amount was paid at the beginning of the contract. To determine the present value of
the lease liability, Bulgarian Energy Holding EAD used a discount rate of 3.50%, which is an interest rate obtained
by the Company in financing its own activities in the last year, and corresponding to the market levels. As of 31
December 2024, the right-of-use asset has been written off.
On 1 May 2022, the Company has recognized right-of-use assets in the amount of BGN 459 thousand under a rental
contract of a real estate for administrative purposes for a period of five years with an option for extension. To determine
the present value of the lease liability, Bulgarian Energy Holding EAD has used a discount rate of 2.45%, which is
the interest rate obtained by the company when financing its activities in the last year and corresponding to market
levels.
On 1 February 2023, the Company has recognized right-of-use assets in the amount of BGN 83 thousand under a
rental contract of an office for a period of four years with an option for extension. To determine the present value of
the lease liability, Bulgarian Energy Holding EAD has used a discount rate of 2.45%, which is an interest rate obtained
by the Company in financing its own activities.
The Company has leased 10 motor vehicles under lease agreements. The duration of the agreements is from 2 to 5
years. The calculated annual interest rates for vehicle leases range from 0.98% to 24.05%.
As of 31 December 2024, and 31 December 2023, the Company had no commitments to purchase property, plant and
equipment and has not provided any collateral related thereto.
All depreciation expenses are included in the separate profit and loss report in the line “Depreciation expense of non -
financial assets”.
20.Intangible assets
For the year as of
31 December 2024 Software Patents and
licenses Other Acquisition
expenses Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross book value
Balance as of 1 January 2024 305 68 4 195 572
Balance as of 31 December 2024 305 68 4 195 572
For the year as of
31 December 2024 Software Patents and
licenses Other Acquisition
expenses Total
Amortisation
Balance as of 1 January 2024 (263) (56) (3) - (322)
Amortisation charges (18) (4) (1) - (23)
Balance as of 31 December 2024 (281) (60) (4) - (345)
Carrying amount
as of 31 December 2024 24 8 - 195 227
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
38
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
For the year as of
31 December 2023 Software Patents and
licenses Other Acquisition
expenses Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross book value
Balance as of 1 January 2023 338 68 4 195 605
Additions 9 - - - 9
Disposals (42) - - - (42)
Balance as of 31 December 2023 305 68 4 195 572
Amortisation
Balance as of 1 January 2023 (283) (51) (1) - (335)
Amortisation charges (22) (5) (2) - (29)
Disposals 42 - - - 42
Balance as of 31 December 2023 (263) (56) (3) - (322)
Carrying amount
as of 31 December 2023 42 12 1 195 250
Impairment of intangible assets
The Company reviewed intangible assets for indicators of impairment as at 31 December 2024. No indication was
identified that the carrying value of the assets exceeds their recoverable amount, including that no changes need to be
made to the remaining useful lives of the assets. As a result, no impairment loss was recognized in the separate
financial statements.
All depreciation expense is included in the separate profit and loss statement in the line “Depreciation expense on
non-financial assets”.
As at 31 December 2024 and 31 December 2023, the Company had no purchase commitments for intangible assets
and provided no collateral related to them.
21.Deferred tax assets
Deferred tax assets/(liabilities)
1 January
2024
Recognized
in profit or
loss
Recognize
d in other
comprehe
nsive
income
31 December
2024
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Property, plant and equipment (100) (3) (116) (219)
Impairment of debt instruments at amortized cost 180,093 2,349 - 182,442
Investments 34,958 5 - 34,963
Pension and other liabilities to employees 184 19 (38) 165
Unused employee leaves 41 1 - 42
Staff benefits 14 (14) - -
Financial assets at fair value through other
comprehensive income (5) - (17) (22)
215,185 2,357 (171) 217,371
Recognized as:
Deferred tax assets 215,290 217,612
Deferred tax liabilities (105) (241)
Net deferred tax assets 215,185 217,371
Separate financial statements
31 December 2024
38
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
For the year as of
31 December 2023 Software Patents and
licenses Other Acquisition
expenses Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross book value
Balance as of 1 January 2023 338 68 4 195 605
Additions 9 - - - 9
Disposals (42) - - - (42)
Balance as of 31 December 2023 305 68 4 195 572
Amortisation
Balance as of 1 January 2023 (283) (51) (1) - (335)
Amortisation charges (22) (5) (2) - (29)
Disposals 42 - - - 42
Balance as of 31 December 2023 (263) (56) (3) - (322)
Carrying amount
as of 31 December 2023 42 12 1 195 250
Impairment of intangible assets
The Company reviewed intangible assets for indicators of impairment as at 31 December 2024. No indication was
identified that the carrying value of the assets exceeds their recoverable amount, including that no changes need to be
made to the remaining useful lives of the assets. As a result, no impairment loss was recognized in the separate
financial statements.
All depreciation expense is included in the separate profit and loss statement in the line “Depreciation expense on
non-financial assets”.
As at 31 December 2024 and 31 December 2023, the Company had no purchase commitments for intangible assets
and provided no collateral related to them.
21.Deferred tax assets
Deferred tax assets/(liabilities)
1 January
2024
Recognized
in profit or
loss
Recognize
d in other
comprehe
nsive
income
31 December
2024
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Property, plant and equipment (100) (3) (116) (219)
Impairment of debt instruments at amortized cost 180,093 2,349 - 182,442
Investments 34,958 5 - 34,963
Pension and other liabilities to employees 184 19 (38) 165
Unused employee leaves 41 1 - 42
Staff benefits 14 (14) - -
Financial assets at fair value through other
comprehensive income (5) - (17) (22)
215,185 2,357 (171) 217,371
Recognized as:
Deferred tax assets 215,290 217,612
Deferred tax liabilities (105) (241)
Net deferred tax assets 215,185 217,371
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
39
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Deferred tax assets/(liabilities)
1 January
2023
Recognized
in profit or
loss
Recognize
d in other
comprehe
nsive
income
31 December
2023
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Property, plant and equipment (103) 3 - (100)
Impairment of debt instruments at amortized cost 229,937 (49,844) - 180,093
Investments 2,402 32,556 - 34,958
Pension and other liabilities to employees 97 49 38 184
Unused employee leaves 23 18 - 41
Staff benefits - 14 - 14
Financial assets at fair value through other
comprehensive income 1 - (6) (5)
232,357 (17,204) 32 215,185
Recognized as:
Deferred tax assets 232,460 215,290
Deferred tax liabilities (103) (105)
Net deferred tax assets 232,357 215,185
Deferred tax assets and liabilities are recognized in the separated statement of financial position, except for a deferred
tax asset of BGN 8 thousand in relation to lease accounting expenses.
22.Trade and other receivables
31 December
2024
31 December
2023
thousand BGN thousand BGN
Non-current receivables
Advances paid and prepaid expenses 31 25
31 25
Current receivables
Interest on deposit and current accounts 2,031 -
Receivables under litigation 5 5
Impairment of receivables under litigation (5) (5)
Receivables under litigation, net - -
Advances paid and prepaid expenses 138 117
Other receivables 11,022 10,967
Impairment of other receivables (10,907) (10,951)
Other receivables, net 115 16
2,284 133
2,315 158
23.Receivables from Toplofikatsia Sofia EAD
Agreement as of 11 December 2015
On 11 December 2015 an agreement was concluded between Bulgarian Energy Holding EAD and Toplofikatsia Sofia
EAD according to which the debts of the district heating plant to Bulgarian Energy Holding EAD were consolidated
and novated. The debtor fully and unconditionally recognizes liabilities in the amount of BGN 500,465 thousand, to
be repaidover a period of twenty years, with a five-year grace period, and interest on the principal in the amount of
3.25%. The agreement stipulates that upon conclusion of a concession contract between Sofia Municipality and a third
party, the latter undertakes to pay BEH EAD an initial installment of not less than BGN 200,000 thousand within 120
Separate financial statements
31 December 2024
39
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Deferred tax assets/(liabilities)
1 January
2023
Recognized
in profit or
loss
Recognize
d in other
comprehe
nsive
income
31 December
2023
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Property, plant and equipment (103) 3 - (100)
Impairment of debt instruments at amortized cost 229,937 (49,844) - 180,093
Investments 2,402 32,556 - 34,958
Pension and other liabilities to employees 97 49 38 184
Unused employee leaves 23 18 - 41
Staff benefits - 14 - 14
Financial assets at fair value through other
comprehensive income 1 - (6) (5)
232,357 (17,204) 32 215,185
Recognized as:
Deferred tax assets 232,460 215,290
Deferred tax liabilities (103) (105)
Net deferred tax assets 232,357 215,185
Deferred tax assets and liabilities are recognized in the separated statement of financial position, except for a deferred
tax asset of BGN 8 thousand in relation to lease accounting expenses.
22.Trade and other receivables
31 December
2024
31 December
2023
thousand BGN thousand BGN
Non-current receivables
Advances paid and prepaid expenses 31 25
31 25
Current receivables
Interest on deposit and current accounts 2,031 -
Receivables under litigation 5 5
Impairment of receivables under litigation (5) (5)
Receivables under litigation, net - -
Advances paid and prepaid expenses 138 117
Other receivables 11,022 10,967
Impairment of other receivables (10,907) (10,951)
Other receivables, net 115 16
2,284 133
2,315 158
23.Receivables from Toplofikatsia Sofia EAD
Agreement as of 11 December 2015
On 11 December 2015 an agreement was concluded between Bulgarian Energy Holding EAD and Toplofikatsia Sofia
EAD according to which the debts of the district heating plant to Bulgarian Energy Holding EAD were consolidated
and novated. The debtor fully and unconditionally recognizes liabilities in the amount of BGN 500,465 thousand, to
be repaidover a period of twenty years, with a five-year grace period, and interest on the principal in the amount of
3.25%. The agreement stipulates that upon conclusion of a concession contract between Sofia Municipality and a third
party, the latter undertakes to pay BEH EAD an initial installment of not less than BGN 200,000 thousand within 120
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
40
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
days from the date of entry into force of the concession agreement, and the balance will be paid in a manner agreed
between the parties.
Liabilities amounting to BGN 52,311 thousand were challenged by the debtor in 2015 by the submission of six claims.
In 2019 court proceedings were closed, and receivables in the amount of BGN 3,339 thousand were recognized. The
due amounts were paid by Toplofikatsia Sofia EAD in accordance with the agreement of 2020. For the unrecognized
liabilities amounting to BGN 48,972 thousand, the Company recognizedimpairment in full.
As of 31 December 2024, the total amount of the recognized receivable under the agreement of 11 December 2015 is
BGN 391,098 thousand, including principal amounts due of BGN 18,983 thousand, interest overdue of BGN 4,180
thousand and interest in arrears of BGN 265 thousand BGN.
Agreement as of 1 April 2019
A contract was concluded with Bulgargaz EAD on 28 August 2018 for the transfer of receivables from Toplofikatsia
Sofia EAD for consumed natural gas in the total amount on the date of contract conclusion, of BGN 99,193 thousand,
including a principal amounting to BGN 94,967 thousand and an interest amounting to BGN 4,226 thousand. The
receivables are fully overdue. An agreement was concluded with Toplofikatsia Sofia EAD on 1 April 2019, whereby
the debtor agreed that the debt would be paid by the debtor by 31 August 2025, and it would not pay principal
installments until 31 August 2019. The stipulated interest on the principal is at the rate of 4.66%, as of 28 August
2018. At a failure to pay any installment, an interest is due from the debtor for every day o f default to the extent of
the base interest rate, fixed by the Bulgarian National Bank, plus a 10-point margin. The obligations under the
agreement are regularly paid according to the repayment schedule.
As of 31 December 2024, the total amount of receivable under the agreement of 1 April 2019 is BGN 21,087 thousand,
including maturing principal amounts of BGN 9,644 thousand, overdue interest of BGN 294 thousand and overdue
interest in the amount of BGN 127 thousand
Agreement as of 15 September 2022
On 15 September 2022, an agreement was signed with Toplofikatsia Sofia EAD, uniting obligations under assignment
agreements dated 23 December 2020, 28 October 2021, and 18 November 2021, with total amount of
BGN 333,596.905,98. The agreement became effective after approval by the Sofia Municipal Council was obtained
on 16 December 2022. The parties agreed that the due amount would be paid by the creditors until 31 March 2029 in
monthly installments with a grace period for the principal amount until 31 March 2023. The agreed interest on the
principal is 3.525%. To secure the implementation of the obligations, the debtor has established a special pledge in
favor of the creditor covering all present, future, and conditional receivables of the debtor in bank accounts opened at
commercial banks on the territory of the Republic of Bulgaria and under contracts for the sale of energy to Independent
Bulgarian Energy Exchange EAD.
As of 31 December 2024, the total amount of receivables under the agreement of 15 September 2022 amounts to BGN
357,737 thousand, including maturing principal amounts of BGN 85,197 thousand, overdue interest of BGN 16,012
thousand and default interest of BGN 13,065 thousand
Tripartite Agreement of 2023 and Annex of 2024
On 19 July 2023 an agreement was signed between Bulgarian Energy Holding EAD, Toplofikatsia Sofia EAD and
the Electricity System Security Fund, whereby the parties agree that 20% of the monthly premiums due from the Fund
to Toplofikatsia Sofia EAD within the current price period from 01.07.2023 to 30.06.2024 will be credited to the
account of Bulgarian Energy Holding EAD. The proceeds will be used to repay obligations under the Agreements of
2015 and 2019 between Bulgarian Energy Holding EAD and Toplofikatsia Sofia EAD. On 28 June 2024 an annex to
the Agreement was signed, extending its validity for the price period from 01.07.2024 to 30.06.2025.
In 2024, amounts totaling BGN 64,791 thousand have been received from the Electricity System Security Fund for
the repayment of liabilities of Toplofikatsia Sofia EAD:
(1) for the repayment of liabilities under the Agreement of 11 December 2015 in the amount of BGN 45,121
thousand, including BGN 33,844 thousand for the repayment of principal and BGN 11,277 thousand for
the repayment of interest;
(2) for the repayment of obligations under the Agreement of 1 April 2019 an amount of BGN 19,670
thousand, including BGN 17,882 thousand for the repayment of principal and BGN 1,788 thousand for
the repayment of interest.
Receivables as of 31 December 2024 are as follows:
Separate financial statements
31 December 2024
40
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
days from the date of entry into force of the concession agreement, and the balance will be paid in a manner agreed
between the parties.
Liabilities amounting to BGN 52,311 thousand were challenged by the debtor in 2015 by the submission of six claims.
In 2019 court proceedings were closed, and receivables in the amount of BGN 3,339 thousand were recognized. The
due amounts were paid by Toplofikatsia Sofia EAD in accordance with the agreement of 2020. For the unrecognized
liabilities amounting to BGN 48,972 thousand, the Company recognizedimpairment in full.
As of 31 December 2024, the total amount of the recognized receivable under the agreement of 11 December 2015 is
BGN 391,098 thousand, including principal amounts due of BGN 18,983 thousand, interest overdue of BGN 4,180
thousand and interest in arrears of BGN 265 thousand BGN.
Agreement as of 1 April 2019
A contract was concluded with Bulgargaz EAD on 28 August 2018 for the transfer of receivables from Toplofikatsia
Sofia EAD for consumed natural gas in the total amount on the date of contract conclusion, of BGN 99,193 thousand,
including a principal amounting to BGN 94,967 thousand and an interest amounting to BGN 4,226 thousand. The
receivables are fully overdue. An agreement was concluded with Toplofikatsia Sofia EAD on 1 April 2019, whereby
the debtor agreed that the debt would be paid by the debtor by 31 August 2025, and it would not pay principal
installments until 31 August 2019. The stipulated interest on the principal is at the rate of 4.66%, as of 28 August
2018. At a failure to pay any installment, an interest is due from the debtor for every day o f default to the extent of
the base interest rate, fixed by the Bulgarian National Bank, plus a 10-point margin. The obligations under the
agreement are regularly paid according to the repayment schedule.
As of 31 December 2024, the total amount of receivable under the agreement of 1 April 2019 is BGN 21,087 thousand,
including maturing principal amounts of BGN 9,644 thousand, overdue interest of BGN 294 thousand and overdue
interest in the amount of BGN 127 thousand
Agreement as of 15 September 2022
On 15 September 2022, an agreement was signed with Toplofikatsia Sofia EAD, uniting obligations under assignment
agreements dated 23 December 2020, 28 October 2021, and 18 November 2021, with total amount of
BGN 333,596.905,98. The agreement became effective after approval by the Sofia Municipal Council was obtained
on 16 December 2022. The parties agreed that the due amount would be paid by the creditors until 31 March 2029 in
monthly installments with a grace period for the principal amount until 31 March 2023. The agreed interest on the
principal is 3.525%. To secure the implementation of the obligations, the debtor has established a special pledge in
favor of the creditor covering all present, future, and conditional receivables of the debtor in bank accounts opened at
commercial banks on the territory of the Republic of Bulgaria and under contracts for the sale of energy to Independent
Bulgarian Energy Exchange EAD.
As of 31 December 2024, the total amount of receivables under the agreement of 15 September 2022 amounts to BGN
357,737 thousand, including maturing principal amounts of BGN 85,197 thousand, overdue interest of BGN 16,012
thousand and default interest of BGN 13,065 thousand
Tripartite Agreement of 2023 and Annex of 2024
On 19 July 2023 an agreement was signed between Bulgarian Energy Holding EAD, Toplofikatsia Sofia EAD and
the Electricity System Security Fund, whereby the parties agree that 20% of the monthly premiums due from the Fund
to Toplofikatsia Sofia EAD within the current price period from 01.07.2023 to 30.06.2024 will be credited to the
account of Bulgarian Energy Holding EAD. The proceeds will be used to repay obligations under the Agreements of
2015 and 2019 between Bulgarian Energy Holding EAD and Toplofikatsia Sofia EAD. On 28 June 2024 an annex to
the Agreement was signed, extending its validity for the price period from 01.07.2024 to 30.06.2025.
In 2024, amounts totaling BGN 64,791 thousand have been received from the Electricity System Security Fund for
the repayment of liabilities of Toplofikatsia Sofia EAD:
(1) for the repayment of liabilities under the Agreement of 11 December 2015 in the amount of BGN 45,121
thousand, including BGN 33,844 thousand for the repayment of principal and BGN 11,277 thousand for
the repayment of interest;
(2) for the repayment of obligations under the Agreement of 1 April 2019 an amount of BGN 19,670
thousand, including BGN 17,882 thousand for the repayment of principal and BGN 1,788 thousand for
the repayment of interest.
Receivables as of 31 December 2024 are as follows:
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
41
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2024 2023
thousand BGN thousand BGN
Balance on 1 January
Gross amount of receivables 769,922 797,639
Less impairments and modifications (759,928) (736,365)
Net amount of receivables 9,994 61,274
24.Financial assets at fair value through other comprehensive income
2024 2023
thousand BGN thousand BGN
Investment in shares of Transgaz S.A., Romania 883 717
Investment in shares of Balkangaz 2000 AD, Botevgrad 2 2
885 719
In 2024, a dividend of BGN 13 thousand was received from TRANSGAZ S.A., Romania (2023: BGN 27 thousand).
No dividend was received from Balkangaz 2000 AD in 2024 and 2023.
25.Cash
31 December
2024
31 December
2023
thousand BGN thousand BGN
Cash in bank accounts 23,401 220,381
Cash deposits 275,025 -
Blocked funds 15,000 -
Cash 13 22
313,439 220,403
Effect from expected credit losses (398) (391)
313,041 220,012
The cash at bank accounts, where the Company has concluded bank service contracts following a procedure for the
selection of credit institutions, accumulates interest at interest rates determined according to price offers by the credit
institutions.
The blocked funds in the amount of BGN 15,000 thousand are financial collateral established by Bulgarian Energy
Holding EAD, in accordance with the Financial Collateral Contracts Act, under an overdraft agreement between DSK
Bank AD and Mini Maritsa-Iztok EAD with a limit of BGN 50,000 thousand for a period of one year to finance the
current operations of the subsidiary.
As of 31 December, cash is allocated in the following currencies:
31 December
2024
31 December
2023
thousand BGN thousand BGN
BGN 113,317 195,862
EUR 200,122 24,263
USD - 166
Other - 112
313,439 220,403
Separate financial statements
31 December 2024
41
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2024 2023
thousand BGN thousand BGN
Balance on 1 January
Gross amount of receivables 769,922 797,639
Less impairments and modifications (759,928) (736,365)
Net amount of receivables 9,994 61,274
24.Financial assets at fair value through other comprehensive income
2024 2023
thousand BGN thousand BGN
Investment in shares of Transgaz S.A., Romania 883 717
Investment in shares of Balkangaz 2000 AD, Botevgrad 2 2
885 719
In 2024, a dividend of BGN 13 thousand was received from TRANSGAZ S.A., Romania (2023: BGN 27 thousand).
No dividend was received from Balkangaz 2000 AD in 2024 and 2023.
25.Cash
31 December
2024
31 December
2023
thousand BGN thousand BGN
Cash in bank accounts 23,401 220,381
Cash deposits 275,025 -
Blocked funds 15,000 -
Cash 13 22
313,439 220,403
Effect from expected credit losses (398) (391)
313,041 220,012
The cash at bank accounts, where the Company has concluded bank service contracts following a procedure for the
selection of credit institutions, accumulates interest at interest rates determined according to price offers by the credit
institutions.
The blocked funds in the amount of BGN 15,000 thousand are financial collateral established by Bulgarian Energy
Holding EAD, in accordance with the Financial Collateral Contracts Act, under an overdraft agreement between DSK
Bank AD and Mini Maritsa-Iztok EAD with a limit of BGN 50,000 thousand for a period of one year to finance the
current operations of the subsidiary.
As of 31 December, cash is allocated in the following currencies:
31 December
2024
31 December
2023
thousand BGN thousand BGN
BGN 113,317 195,862
EUR 200,122 24,263
USD - 166
Other - 112
313,439 220,403
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
42
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
26.Share capital and reserves
26.1 Share capital
The Company's registered share capital consists of 3,463,941,744 ordinary shares with a nominal value of BGN 1
each as of 31 December 2024 (31 December 2023: 3,463,941,744 shares). The Company shares are ordinary,
registered, non-privileged, with voting rights. All ordinary shares are fully paid. Each share gives the right to one vote,
a right to dividend and to a liquidation quota in the Company‘s property. The sole shareholder of Bulgarian Energy
Holding EAD is the Bulgarian state through represented by the Minister of Energy.
The shares issued and authorized for the reporting periods are presented as follows:
2024 2023
Number of shares Number of shares
Number of issued and fully paid shares:
At the beginning of the year 3,463,941,744 3,462,941,744
Capital increase during the year - 1,000,000
Total number of shares authorized at the end of the year 3,463,941,744 3,463,941,744
By a decision of the Minister of Energy of 30 October 2023, a non-monetary contribution of BGN 1,000 thousand
was made to the capital of Bulgarian Energy Holding EAD, the reason being the state’s ownership of 100% of the
shares of Minproekt EAD. The increase was entered into the Commercial Register and the Register of Non-Profit
Legal Entities on 16 November 2023.
26.2 Other reserves
The other reserves are formed by profit distribution according to the Commercial Act and the Articles of Association
of the Company or from other sources by decision of the sole shareholder. These include statutory reserves and general
reserves. Legal reserves are set aside until they reach one tenth or more of the capital. Sources for the formation of
legal reserves are at least one tenth of the net profit, premiums from share issues and funds provided in the Articles of
Association or by decision of the sole shareholder. Statutory reserves can only be used to cover losses from the current
and previous reporting periods. General reserves are formed on the proposal of the board of directors and can be used
to cover losses from previous years and for other purposes. As of 31 December 2024, the statutory reserves amount
to BGN 346,394 thousand (31 December 2023: BGN 346,294 thousand), reserves from merger and replacement of
shares of subsidiaries amount to BGN 102 thousand (31 December 2024: BGN 102 thousand), and general reserves
amounted to BGN 34,095 thousand (31 December 2023: BGN 34,095 thousand).
26.3 Reserve from revaluation of financial assets at fair value through other comprehensive income
In a revaluation reserve at fair value through other comprehensive income, were reported the revaluations of shares
of Transgaz S.A., Romania, and Balkangaz 2000 AD, Botevgrad, classified as financial assets at fair value through
other comprehensive income.
26.4 Revaluation reserve of non-financial assets
The revaluation reserve of non-financial assets includes increases in the fair value of property, plant and equipment
and decreases to the extent that those reductions are related to an increase in the same asset previously recognized in
other comprehensive income. These reserves can be used to cover losses and pay dividends only in limited types of
circumstances.
26.5 Reserve from revaluation of defined benefit plans
The reserve for defined benefit plans includes actuarial gains and losses resulting from the revaluation of defined
benefit plans.
Separate financial statements
31 December 2024
42
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
26.Share capital and reserves
26.1 Share capital
The Company's registered share capital consists of 3,463,941,744 ordinary shares with a nominal value of BGN 1
each as of 31 December 2024 (31 December 2023: 3,463,941,744 shares). The Company shares are ordinary,
registered, non-privileged, with voting rights. All ordinary shares are fully paid. Each share gives the right to one vote,
a right to dividend and to a liquidation quota in the Company‘s property. The sole shareholder of Bulgarian Energy
Holding EAD is the Bulgarian state through represented by the Minister of Energy.
The shares issued and authorized for the reporting periods are presented as follows:
2024 2023
Number of shares Number of shares
Number of issued and fully paid shares:
At the beginning of the year 3,463,941,744 3,462,941,744
Capital increase during the year - 1,000,000
Total number of shares authorized at the end of the year 3,463,941,744 3,463,941,744
By a decision of the Minister of Energy of 30 October 2023, a non-monetary contribution of BGN 1,000 thousand
was made to the capital of Bulgarian Energy Holding EAD, the reason being the state’s ownership of 100% of the
shares of Minproekt EAD. The increase was entered into the Commercial Register and the Register of Non-Profit
Legal Entities on 16 November 2023.
26.2 Other reserves
The other reserves are formed by profit distribution according to the Commercial Act and the Articles of Association
of the Company or from other sources by decision of the sole shareholder. These include statutory reserves and general
reserves. Legal reserves are set aside until they reach one tenth or more of the capital. Sources for the formation of
legal reserves are at least one tenth of the net profit, premiums from share issues and funds provided in the Articles of
Association or by decision of the sole shareholder. Statutory reserves can only be used to cover losses from the current
and previous reporting periods. General reserves are formed on the proposal of the board of directors and can be used
to cover losses from previous years and for other purposes. As of 31 December 2024, the statutory reserves amount
to BGN 346,394 thousand (31 December 2023: BGN 346,294 thousand), reserves from merger and replacement of
shares of subsidiaries amount to BGN 102 thousand (31 December 2024: BGN 102 thousand), and general reserves
amounted to BGN 34,095 thousand (31 December 2023: BGN 34,095 thousand).
26.3 Reserve from revaluation of financial assets at fair value through other comprehensive income
In a revaluation reserve at fair value through other comprehensive income, were reported the revaluations of shares
of Transgaz S.A., Romania, and Balkangaz 2000 AD, Botevgrad, classified as financial assets at fair value through
other comprehensive income.
26.4 Revaluation reserve of non-financial assets
The revaluation reserve of non-financial assets includes increases in the fair value of property, plant and equipment
and decreases to the extent that those reductions are related to an increase in the same asset previously recognized in
other comprehensive income. These reserves can be used to cover losses and pay dividends only in limited types of
circumstances.
26.5 Reserve from revaluation of defined benefit plans
The reserve for defined benefit plans includes actuarial gains and losses resulting from the revaluation of defined
benefit plans.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
43
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
27.Issued bonds
31 December
2024
31 December
2023
thousand BGN thousand BGN
2021 bond issue maturing in 2028
Non-current portion 1,171,640 1,171,146
Current portion 12,760 12,761
2018 bond issue maturing in 2025
Non-current portion - 1,172,116
Current portion 1,193,971 20,930
2,378,371 2,376,953
Bond issue 2018
On 28 June 2018, in the context of period of volatile financial markets caused by a number of negative news on the
international political scene, Bulgarian Energy Holding EAD successfully sold its third issue of Eurobonds in the
amount of EUR 400 million on the Irish Stock Exchange (Euronext Dublin). The parameters of the Eurobond issue
are as follows:
- amount of the bond issue of EUR 400 million;
- Maturity 28 June 2025;
- Fixed interest rate of 3.5% per annum;
- the interest is payable once a year on 28 June, with a first payment due on 28 June 2019;
- ISIN code XS1839682116 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin);
- BEH EAD should observe certain financial indicators, as follows:
• So long as any obligations are outstanding, the Issuer will not, and will not permit any of the larger
subsidiaries to, directly or indirectly, incur any financial indebtedness, except that, if the Issuer and any
of the larger subsidiaries may incur a financial indebtedness, if, after the incurrence of such financial
indebtedness and the receipt and application of the proceeds thereof: (1) no Event of Default has
occurred and is continuing or would continue; (2) the EBITDA Coverage Ratio is not less than 4. 0 to
1.0; and (3) the Consolidated Leverage Ratio is not more than 4.5 to 1.0.
• As long as there are obligations under issued bonds, in case NEK EAD is declared by a Bulgarian court
as over-indebted within the meaning of the Bulgarian Commerce Act, the Issuer will not and will not
allow (as permitted by law) its larger subsidiaries, directly or indirectly, to assume financial obligations.
On 31 July 2018, Bulgarian Energy Holding EAD successfully increased its third Eurobond issue, listed on the Irish
Stock Exchange (Euronext Dublin), from EUR 400 million to EUR 550 million.
On 12 October 2018, Bulgarian Energy Holding EAD recorded a second increase of its third Eurobond issue, listed
on the Irish Stock Exchange (Euronext Dublin), from EUR 550 million to EUR 600 million.
The proceeds from the issue were designated for general corporate purposes and for the refinancing of Eurobonds
issued by the Company in 2013, with its maturity date in November 2018.
On 27 June 2019 - the first interest payment, on 24 June 2020 - the second interest payment, on 25 June 2021 - the
third interest payment, on 28 June 2022 - the fourth interest payment, on 27 June 2023 – the fifth interest payment, on
25 June 2024 – the sixth interest payment. The annual interest amounts to BGN 41,072 thousand (EUR 21,000
thousand).
Bond issue 2021
On 15 July 2021, Bulgarian Energy Holding EAD successfully placed its fourth bond issue amounting to EUR 600
million at an annual interest rate of 2.45%. Given the extremely strong interest from investors, the bond was re -
subscribed 2.3 times, and the interest rate respectively is the lowest achieved by Bulgarian Energy Holding EAD since
the Company entered in the international financial markets. The parameters of the Eurobond issue are as follows:
- amount of the bond issue of EUR 600 million;
- maturity date on 22 July 2028;
- fixed interest rate 2.45% per annum;
Separate financial statements
31 December 2024
43
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
27.Issued bonds
31 December
2024
31 December
2023
thousand BGN thousand BGN
2021 bond issue maturing in 2028
Non-current portion 1,171,640 1,171,146
Current portion 12,760 12,761
2018 bond issue maturing in 2025
Non-current portion - 1,172,116
Current portion 1,193,971 20,930
2,378,371 2,376,953
Bond issue 2018
On 28 June 2018, in the context of period of volatile financial markets caused by a number of negative news on the
international political scene, Bulgarian Energy Holding EAD successfully sold its third issue of Eurobonds in the
amount of EUR 400 million on the Irish Stock Exchange (Euronext Dublin). The parameters of the Eurobond issue
are as follows:
- amount of the bond issue of EUR 400 million;
- Maturity 28 June 2025;
- Fixed interest rate of 3.5% per annum;
- the interest is payable once a year on 28 June, with a first payment due on 28 June 2019;
- ISIN code XS1839682116 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin);
- BEH EAD should observe certain financial indicators, as follows:
• So long as any obligations are outstanding, the Issuer will not, and will not permit any of the larger
subsidiaries to, directly or indirectly, incur any financial indebtedness, except that, if the Issuer and any
of the larger subsidiaries may incur a financial indebtedness, if, after the incurrence of such financial
indebtedness and the receipt and application of the proceeds thereof: (1) no Event of Default has
occurred and is continuing or would continue; (2) the EBITDA Coverage Ratio is not less than 4. 0 to
1.0; and (3) the Consolidated Leverage Ratio is not more than 4.5 to 1.0.
• As long as there are obligations under issued bonds, in case NEK EAD is declared by a Bulgarian court
as over-indebted within the meaning of the Bulgarian Commerce Act, the Issuer will not and will not
allow (as permitted by law) its larger subsidiaries, directly or indirectly, to assume financial obligations.
On 31 July 2018, Bulgarian Energy Holding EAD successfully increased its third Eurobond issue, listed on the Irish
Stock Exchange (Euronext Dublin), from EUR 400 million to EUR 550 million.
On 12 October 2018, Bulgarian Energy Holding EAD recorded a second increase of its third Eurobond issue, listed
on the Irish Stock Exchange (Euronext Dublin), from EUR 550 million to EUR 600 million.
The proceeds from the issue were designated for general corporate purposes and for the refinancing of Eurobonds
issued by the Company in 2013, with its maturity date in November 2018.
On 27 June 2019 - the first interest payment, on 24 June 2020 - the second interest payment, on 25 June 2021 - the
third interest payment, on 28 June 2022 - the fourth interest payment, on 27 June 2023 – the fifth interest payment, on
25 June 2024 – the sixth interest payment. The annual interest amounts to BGN 41,072 thousand (EUR 21,000
thousand).
Bond issue 2021
On 15 July 2021, Bulgarian Energy Holding EAD successfully placed its fourth bond issue amounting to EUR 600
million at an annual interest rate of 2.45%. Given the extremely strong interest from investors, the bond was re -
subscribed 2.3 times, and the interest rate respectively is the lowest achieved by Bulgarian Energy Holding EAD since
the Company entered in the international financial markets. The parameters of the Eurobond issue are as follows:
- amount of the bond issue of EUR 600 million;
- maturity date on 22 July 2028;
- fixed interest rate 2.45% per annum;
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
44
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- the interest is payable once a year on 22 July, with the first payment due on 22 July 2022;
- ISIN code XS2367164576 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin);
- BEH EAD should comply with certain covenants as follows:
• For as long as any Bond remains outstanding, the Issuer shall not, and shall not permit any of its Material
Subsidiaries to, directly or indirectly incur any Financial Indebtedness, unless the Issuer and any
Material Subsidiary may incur Financial Indebtedness, if, after giving effect to the incurrence of such
Financial Indebtedness and the receipt and application of the proceeds therefrom: (1) no Event of
Default has or would have occurred and is or would be continuing; (2) the EBITDA Coverage Ratio is
not less than 4.0 to 1.0; and (3) the Consolidated Leverage Ratio is not more than 4.5 to 1.0.
• As long as there are obligations under issued bonds, in case NEK EAD is declared by a Bulgarian court
as over-indebted within the meaning of the Bulgarian Commerce Act, the Issuer will not and will not
allow (as permitted by law) its larger subsidiaries, directly or indirectly, to assume financial obligations.
The proceeds from the newly issued bonds were used to refinance the Company second bond issue with a face value
of EUR 550 million, sold in 2016, at an annual interest rate of 4.875%, with a maturity date August 2, 2021, as well
as for general corporate purposes, except of coal-related activities.
A first interest payment was made on 22 July 2022 and a second interest payment was made on 21 July 2023 and a
third interest payment was made on 19 July 2024. The annual interest payable amounts to BGN 28,751 thousand (EUR
14,700 thousand).
Credit rating
• Moody’s Rating Agency
On 27 November 2024, Moody's changed the credit outlook of Bulgarian Energy Holding EAD from positive to
stable, affirming the Group's long-term rating at Ba1 and the rating of the unsubordinated unsecured bond issues
placed by the Holding at Ba2. The outlook changes to stable reflects the uncertainty arising from the planned
construction of the two new nuclear units at the NPP Kozloduy site, which would significantly increase Bulgarian
Energy Holding's risk profile given the inherent risks in the implementation of such a project.
• Fitch Ratings rating agency
On 20 March 2024, Fitch Ratings upgraded the outlook of Bulgarian Energy Holding EAD from stable to positive
and affirmed the issuer’s long-term foreign and local currency rating at ‘BB+’. The change in outlook is driven by the
company's improved business profile and increased profitability as a result of progress in the electricity market
liberalisation process.
28.Loan from the European Investment Bank
In October 2019, Bulgarian Energy Holding EAD and the European Investment Bank concluded a Financing
Agreement for the construction of the IGB gas pipeline amounting to EUR 109.9 million with a state financial
guarantee security from the Republic of Bulgaria, the Guarantee Agreement for which is ratified by the National
Assembly. The loan is provided to Bulgarian Energy Holding EAD as a shareholder in ICGB AD (project company).
On its part, BEH EAD transfers the loan financing to the project company through a Shareholder Loan Contract in the
same amount, under the same financial conditions set in the agreement with the European Investment Bank and
without additional margin for Bulgarian Energy Holding EAD. The repayment of the loan granted by the European
Investment Bank will be carried out using a grace period for repayment of the principal of the utilized tranches, which,
according to the Contract concluded with the bank, may last up to 7 years from the date of utilization of a tranche.
The first tranche amounting to EUR 30 million was utilized on 17 August 2020 under the following terms: payment
of interest twice a year in the amount of 0.259%, five-year grace period for principal payments, payment of principal
twice a year, the last installment being due on 17 August 2045.
The second tranche amounting to EUR 30 million was utilized on 18 January 2021 under the following terms: payment
of interest twice a year in the amount of 0.237%, five-year grace period for principal payments, payment of principal
twice a year. The deadline for the last installment is 18 January 2046.
Separate financial statements
31 December 2024
44
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- the interest is payable once a year on 22 July, with the first payment due on 22 July 2022;
- ISIN code XS2367164576 of the bond issue quoted on the Irish Stock Exchange (Euronext Dublin);
- BEH EAD should comply with certain covenants as follows:
• For as long as any Bond remains outstanding, the Issuer shall not, and shall not permit any of its Material
Subsidiaries to, directly or indirectly incur any Financial Indebtedness, unless the Issuer and any
Material Subsidiary may incur Financial Indebtedness, if, after giving effect to the incurrence of such
Financial Indebtedness and the receipt and application of the proceeds therefrom: (1) no Event of
Default has or would have occurred and is or would be continuing; (2) the EBITDA Coverage Ratio is
not less than 4.0 to 1.0; and (3) the Consolidated Leverage Ratio is not more than 4.5 to 1.0.
• As long as there are obligations under issued bonds, in case NEK EAD is declared by a Bulgarian court
as over-indebted within the meaning of the Bulgarian Commerce Act, the Issuer will not and will not
allow (as permitted by law) its larger subsidiaries, directly or indirectly, to assume financial obligations.
The proceeds from the newly issued bonds were used to refinance the Company second bond issue with a face value
of EUR 550 million, sold in 2016, at an annual interest rate of 4.875%, with a maturity date August 2, 2021, as well
as for general corporate purposes, except of coal-related activities.
A first interest payment was made on 22 July 2022 and a second interest payment was made on 21 July 2023 and a
third interest payment was made on 19 July 2024. The annual interest payable amounts to BGN 28,751 thousand (EUR
14,700 thousand).
Credit rating
• Moody’s Rating Agency
On 27 November 2024, Moody's changed the credit outlook of Bulgarian Energy Holding EAD from positive to
stable, affirming the Group's long-term rating at Ba1 and the rating of the unsubordinated unsecured bond issues
placed by the Holding at Ba2. The outlook changes to stable reflects the uncertainty arising from the planned
construction of the two new nuclear units at the NPP Kozloduy site, which would significantly increase Bulgarian
Energy Holding's risk profile given the inherent risks in the implementation of such a project.
• Fitch Ratings rating agency
On 20 March 2024, Fitch Ratings upgraded the outlook of Bulgarian Energy Holding EAD from stable to positive
and affirmed the issuer’s long-term foreign and local currency rating at ‘BB+’. The change in outlook is driven by the
company's improved business profile and increased profitability as a result of progress in the electricity market
liberalisation process.
28.Loan from the European Investment Bank
In October 2019, Bulgarian Energy Holding EAD and the European Investment Bank concluded a Financing
Agreement for the construction of the IGB gas pipeline amounting to EUR 109.9 million with a state financial
guarantee security from the Republic of Bulgaria, the Guarantee Agreement for which is ratified by the National
Assembly. The loan is provided to Bulgarian Energy Holding EAD as a shareholder in ICGB AD (project company).
On its part, BEH EAD transfers the loan financing to the project company through a Shareholder Loan Contract in the
same amount, under the same financial conditions set in the agreement with the European Investment Bank and
without additional margin for Bulgarian Energy Holding EAD. The repayment of the loan granted by the European
Investment Bank will be carried out using a grace period for repayment of the principal of the utilized tranches, which,
according to the Contract concluded with the bank, may last up to 7 years from the date of utilization of a tranche.
The first tranche amounting to EUR 30 million was utilized on 17 August 2020 under the following terms: payment
of interest twice a year in the amount of 0.259%, five-year grace period for principal payments, payment of principal
twice a year, the last installment being due on 17 August 2045.
The second tranche amounting to EUR 30 million was utilized on 18 January 2021 under the following terms: payment
of interest twice a year in the amount of 0.237%, five-year grace period for principal payments, payment of principal
twice a year. The deadline for the last installment is 18 January 2046.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
45
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
On 1 December 2021, the third tranche of EUR 30 million was utilized under the following conditions: payment of
interest twice a year in the amount of 0.612%, five-year grace period for principal payments, payment of principal
twice a year. The deadline for the last due installment is 1 December 2046.
The fourth tranche amounting to EUR 19.9 million was utilized on 29 September 2022 under the following terms:
payment of interest twice a year in the amount of 2.888%, five-year grace period for principal payments, payment of
principal twice a year. The deadline for returning the last installment due is by 29 September 2047.
As of 31 December 2024, the debt to the European Investment Bank amounts to BGN 215,380 thousand, including
BGN 214,946 thousand principal and BGN 434 thousand interest (31 December 2023: BGN 215,380 thousand). The
debt shall be serviced in a timely manner.
29.Reconciliation of liabilities arising from financial activities
Reconciliation between the opening and closing balances in the separate statement of the financial position of
liabilities arising from financial activities and their reconciliation to the separate statement of cash flows, is presented
in the following tables:
Changes in liabilities
from:
Liabilities arising from financial activities Total
liabilities
from
financing
activities
Bond issue
2018
Bond issue
2021 Bank loan
Loans from
related
parties
As of 1 January 2024 1,193,046 1,183,907 215,380 27,269 2,619,602
Cash flows from financial
activities, net (41,072) (28,751) (1,774) 13,857 (57,740)
Proceeds - - - 25,000 25,000
Principal payments - - - (10,772) (10,772)
Interest payments (41,072) (28,751) (1,774) (371) (71,968)
Non-monetary changes,
non-cash 41,997 29,244 1,774 458 73,473
Interest expenses 41,072 28,751 1,774 458 72,055
Discount and amortization
of expenses 925 493 - - 1,418
As of 31 December 2024 1,193,971 1,184,400 215,380 41,584 2,635,335
Changes in liabilities
from:
Liabilities arising from financial activities
Total liabilities
from financing
activities Bond issue
2018
Bond issue
2021 Bank loan
Loans from
related
parties
As of 1 January 2023 1,192,154 1,183,425 215,379 213,228 2,804,186
Cash flows from financial
activities, net (41,072) (28,751) (1,774) (186,993) (258,590)
Principal payments - - - (185,959) (185,959)
Interest payments (41,072) (28,751) (1,774) (1,034) (72,631)
Non-monetary changes,
non-cash 41,964 29,233 1,775 1,034 74.006
Interest expenses 41,072 28,751 1,774 1,034 72,631
Effect of changes in
exchange rates - - 1 - 1
Discount and amortization
of expenses 892 482 - - 1,374
As of 31 December 2023 1,193,046 1,183,907 215,380 27,269 2,619,602
Separate financial statements
31 December 2024
45
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
On 1 December 2021, the third tranche of EUR 30 million was utilized under the following conditions: payment of
interest twice a year in the amount of 0.612%, five-year grace period for principal payments, payment of principal
twice a year. The deadline for the last due installment is 1 December 2046.
The fourth tranche amounting to EUR 19.9 million was utilized on 29 September 2022 under the following terms:
payment of interest twice a year in the amount of 2.888%, five-year grace period for principal payments, payment of
principal twice a year. The deadline for returning the last installment due is by 29 September 2047.
As of 31 December 2024, the debt to the European Investment Bank amounts to BGN 215,380 thousand, including
BGN 214,946 thousand principal and BGN 434 thousand interest (31 December 2023: BGN 215,380 thousand). The
debt shall be serviced in a timely manner.
29.Reconciliation of liabilities arising from financial activities
Reconciliation between the opening and closing balances in the separate statement of the financial position of
liabilities arising from financial activities and their reconciliation to the separate statement of cash flows, is presented
in the following tables:
Changes in liabilities
from:
Liabilities arising from financial activities Total
liabilities
from
financing
activities
Bond issue
2018
Bond issue
2021 Bank loan
Loans from
related
parties
As of 1 January 2024 1,193,046 1,183,907 215,380 27,269 2,619,602
Cash flows from financial
activities, net (41,072) (28,751) (1,774) 13,857 (57,740)
Proceeds - - - 25,000 25,000
Principal payments - - - (10,772) (10,772)
Interest payments (41,072) (28,751) (1,774) (371) (71,968)
Non-monetary changes,
non-cash 41,997 29,244 1,774 458 73,473
Interest expenses 41,072 28,751 1,774 458 72,055
Discount and amortization
of expenses 925 493 - - 1,418
As of 31 December 2024 1,193,971 1,184,400 215,380 41,584 2,635,335
Changes in liabilities
from:
Liabilities arising from financial activities
Total liabilities
from financing
activities Bond issue
2018
Bond issue
2021 Bank loan
Loans from
related
parties
As of 1 January 2023 1,192,154 1,183,425 215,379 213,228 2,804,186
Cash flows from financial
activities, net (41,072) (28,751) (1,774) (186,993) (258,590)
Principal payments - - - (185,959) (185,959)
Interest payments (41,072) (28,751) (1,774) (1,034) (72,631)
Non-monetary changes,
non-cash 41,964 29,233 1,775 1,034 74.006
Interest expenses 41,072 28,751 1,774 1,034 72,631
Effect of changes in
exchange rates - - 1 - 1
Discount and amortization
of expenses 892 482 - - 1,374
As of 31 December 2023 1,193,046 1,183,907 215,380 27,269 2,619,602
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
46
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
30.Liabilities related to employee’ retirement income
Employee retirement benefit liabilities to the personnel include the present value of the Company’s liability as at the
end of the reporting period to pay benefits to employees upon retirement.
In accordance with the Bulgarian Labor Code and the Collective Labor Agreement, the Company is obliged to pay its
employees on retirement between six and eleven gross monthly salaries depending on their length of service with the
Group. If an employee has acquired the right to a retirement pension, regardless of the reason for termination, he shall
be entitled to compensation in the amount of his gross remuneration for a period of six months, and if an employee
has acquired nine years of service with the BEH Group in the last twenty years, he shall be entitled to compensation
in the amount of his gross remuneration for a period of eleven months, in the event that the same is terminated within
two months after receipt of notification. If the employment relationship is terminated after the expiry of two months
from the receipt of the notification, the employee shall be entitled to compensation at the statutory rate under Article
222, para. 3 of the Labor Code.
The defined benefit plan for staff on retirement is not funded. To determine these liabilities, the Company has
performed an actuarial valuation as of 31 December 2024, using the services of a certified actuary.
31 December
2024
31 December
2023
thousand BGN thousand BGN
Current value of the retirement benefit payable:
Non-current portion 1,382 1,521
Current portion 245 304
Total retirement benefit payables recognized in the separate statement of
financial position 1,627 1,825
The change in the present value of Employee retirement benefit liabilities is as follows:
2024 2023
thousand BGN thousand BGN
Liabilities related to employee’ retirement income at the beginning of the year 1,825 958
Current services cost 261 116
Past services cost - 362
Interest expenses 91 57
Payments made (107) (70)
Actuarial (profit)/loss (443) 402
Liabilities related to employee’ retirement income at the end of the year 1,627 1,825
The main assumptions used in determining the retirement income of employees are set out below:
2024 2023
Discount rate 4.0% 4.5%
Future increase of the remunerations for the next year 2.4% 19.87%
Future increase of the remunerations for the years after the next year 2.0% 10.00%
Staff turnover: 18-30 years 5.0% 5.0%
31-40 years 3.0% 3.0%
41-50 years 2.0% 2.0%
51-60 years 1.0% 1.0%
Over 60 years old 0.0% 0.0%
The management of the Company has made these assumptions with the help of an independent appraiser actuary.
These assumptions have been used in determining the amount of employee benefit obligations in retirement for the
reporting periods and are considered to be management’s best judgment.
Separate financial statements
31 December 2024
46
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
30.Liabilities related to employee’ retirement income
Employee retirement benefit liabilities to the personnel include the present value of the Company’s liability as at the
end of the reporting period to pay benefits to employees upon retirement.
In accordance with the Bulgarian Labor Code and the Collective Labor Agreement, the Company is obliged to pay its
employees on retirement between six and eleven gross monthly salaries depending on their length of service with the
Group. If an employee has acquired the right to a retirement pension, regardless of the reason for termination, he shall
be entitled to compensation in the amount of his gross remuneration for a period of six months, and if an employee
has acquired nine years of service with the BEH Group in the last twenty years, he shall be entitled to compensation
in the amount of his gross remuneration for a period of eleven months, in the event that the same is terminated within
two months after receipt of notification. If the employment relationship is terminated after the expiry of two months
from the receipt of the notification, the employee shall be entitled to compensation at the statutory rate under Article
222, para. 3 of the Labor Code.
The defined benefit plan for staff on retirement is not funded. To determine these liabilities, the Company has
performed an actuarial valuation as of 31 December 2024, using the services of a certified actuary.
31 December
2024
31 December
2023
thousand BGN thousand BGN
Current value of the retirement benefit payable:
Non-current portion 1,382 1,521
Current portion 245 304
Total retirement benefit payables recognized in the separate statement of
financial position 1,627 1,825
The change in the present value of Employee retirement benefit liabilities is as follows:
2024 2023
thousand BGN thousand BGN
Liabilities related to employee’ retirement income at the beginning of the year 1,825 958
Current services cost 261 116
Past services cost - 362
Interest expenses 91 57
Payments made (107) (70)
Actuarial (profit)/loss (443) 402
Liabilities related to employee’ retirement income at the end of the year 1,627 1,825
The main assumptions used in determining the retirement income of employees are set out below:
2024 2023
Discount rate 4.0% 4.5%
Future increase of the remunerations for the next year 2.4% 19.87%
Future increase of the remunerations for the years after the next year 2.0% 10.00%
Staff turnover: 18-30 years 5.0% 5.0%
31-40 years 3.0% 3.0%
41-50 years 2.0% 2.0%
51-60 years 1.0% 1.0%
Over 60 years old 0.0% 0.0%
The management of the Company has made these assumptions with the help of an independent appraiser actuary.
These assumptions have been used in determining the amount of employee benefit obligations in retirement for the
reporting periods and are considered to be management’s best judgment.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
47
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The total expenses of defined benefit plans of the Company recognized in profit or loss, may be presented as follows:
2024 2023
thousand
BGN
thousand
BGN
Current services cost 261 116
Past services cost - 362
Interest expenses 91 57
Net actuarial (profit)/loss recognized in the period (59) 25
Total expenses recognized in the profit or loss 293 560
The total amount of defined benefit plan expenses of the Company recognized in other comprehensive income, can
be presented as follows:
2024 2023
thousand
BGN
thousand
BGN
Revaluation of defined benefit payments – actuarial (profit)/loss (384) 377
Total expenses recognized in other comprehensive income (384) 377
The weighted average duration of the defined benefit obligation as of 31 December 2024 is 12.5 years (31 December
2022: 12.6 years).
Significant actuarial assumptions in determining liabilities under defined benefit plans are related to the discount rate
and the expected percentage increase in salaries.
The following table presents a sensitivity analysis and summarizes the effects of changes in these actuarial
assumptions on defined benefit plan obligations as of 31 December 2024.
Increase
by 1%
Decrease
by 1%
thousand BGN thousand BGN
Salary growth 254 (216)
Change in the interest rate (205) (246)
Change in the average life expectancy 25 (26)
The sensitivity analysis is based on a change in only one of the assumptions. It may differ from the actual change in
defined benefit obligations because changes in assumptions are often interrelated.
The plan exposes the Company to actuarial risks such as interest rate risk, risk from changes in life expectancy, and
inflation risk:
• Interest rate risk – the present value of the defined benefit payable is calculated at a discount rate, determined
on the basis of the yield on government securities issues (with 10-year maturity). Given that the average time
to retirement is longer than 10 years, it is necessary to determine the effective annual discount rate by
extrapolation following the requirements of IAS 19 §86. A decline in the market yield of government
securities will lead to increase of the liabilities under plans with defined incomes of the Company.
• Risk of change in life expectancy – an increase in the life expectancy of employees would lead to an increase
in liabilities under defined benefit plans.
• Inflation risk – an increase in inflation would lead to an increase in liabilities under defined benefit plans.
Separate financial statements
31 December 2024
47
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The total expenses of defined benefit plans of the Company recognized in profit or loss, may be presented as follows:
2024 2023
thousand
BGN
thousand
BGN
Current services cost 261 116
Past services cost - 362
Interest expenses 91 57
Net actuarial (profit)/loss recognized in the period (59) 25
Total expenses recognized in the profit or loss 293 560
The total amount of defined benefit plan expenses of the Company recognized in other comprehensive income, can
be presented as follows:
2024 2023
thousand
BGN
thousand
BGN
Revaluation of defined benefit payments – actuarial (profit)/loss (384) 377
Total expenses recognized in other comprehensive income (384) 377
The weighted average duration of the defined benefit obligation as of 31 December 2024 is 12.5 years (31 December
2022: 12.6 years).
Significant actuarial assumptions in determining liabilities under defined benefit plans are related to the discount rate
and the expected percentage increase in salaries.
The following table presents a sensitivity analysis and summarizes the effects of changes in these actuarial
assumptions on defined benefit plan obligations as of 31 December 2024.
Increase
by 1%
Decrease
by 1%
thousand BGN thousand BGN
Salary growth 254 (216)
Change in the interest rate (205) (246)
Change in the average life expectancy 25 (26)
The sensitivity analysis is based on a change in only one of the assumptions. It may differ from the actual change in
defined benefit obligations because changes in assumptions are often interrelated.
The plan exposes the Company to actuarial risks such as interest rate risk, risk from changes in life expectancy, and
inflation risk:
• Interest rate risk – the present value of the defined benefit payable is calculated at a discount rate, determined
on the basis of the yield on government securities issues (with 10-year maturity). Given that the average time
to retirement is longer than 10 years, it is necessary to determine the effective annual discount rate by
extrapolation following the requirements of IAS 19 §86. A decline in the market yield of government
securities will lead to increase of the liabilities under plans with defined incomes of the Company.
• Risk of change in life expectancy – an increase in the life expectancy of employees would lead to an increase
in liabilities under defined benefit plans.
• Inflation risk – an increase in inflation would lead to an increase in liabilities under defined benefit plans.
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
48
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31.Trade and other payables
31 December
2024
31 December
2023
thousand BGN thousand BGN
Non-current liabilities
Leasing 613 1,100
Financial liabilities, non-current 613 1,100
Current liabilities
Amount received in connection to project activities 2,165 2,165
Liabilities to suppliers 1,747 132
Retained guarantees under contracts 57 44
Leasing 264 430
Financial liabilities, current 4,233 2,771
Liabilities to staff 421 901
Payables to the budget 73 284
Other liabilities 127 60
Non-financial liabilities, current 621 1,245
Total trade and other payables, current 4,854 4,016
5,467 5,116
The terms of trade and other liabilities are as follows:
- Trade liabilities are not interest-bearing and are usually settled within ten days;
- The tax liabilities are not interest-bearing and are settled within the legally established terms;
- Other liabilities are not interest-bearing and are usually settled within ten days;
32.Related party disclosures
Related parties of the Company include the sole shareholder – the Ministry of Energy, subsidiaries, associates and
joint ventures, key management personnel.
The Company discloses the following related parties:
Sole shareholder of the capital:
The Bulgarian State through the Minister of Energy
Subsidiaries and undertakings under common control of BEH Group:
Natsionalna Elektricheska Kompania EAD
NPP Kozloduy EAD
TPP Maritsa East 2 EAD
Mini Maritsa Iztok EAD
Bulgargaz EAD
Bulgartransgaz EAD
Electricity System Operator EAD
National Energy Operator EAD
Minproekt EAD
Bulgartel AD
NPP Kozloduy - New Builds EAD
HPP Kozloduy EAD
NPP Construction Supervision OOD
NPP Servicing EOOD
Interpriborservice OOD - in bankruptcy
Bulgartel Skopje DOOEL
Separate financial statements
31 December 2024
48
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31.Trade and other payables
31 December
2024
31 December
2023
thousand BGN thousand BGN
Non-current liabilities
Leasing 613 1,100
Financial liabilities, non-current 613 1,100
Current liabilities
Amount received in connection to project activities 2,165 2,165
Liabilities to suppliers 1,747 132
Retained guarantees under contracts 57 44
Leasing 264 430
Financial liabilities, current 4,233 2,771
Liabilities to staff 421 901
Payables to the budget 73 284
Other liabilities 127 60
Non-financial liabilities, current 621 1,245
Total trade and other payables, current 4,854 4,016
5,467 5,116
The terms of trade and other liabilities are as follows:
- Trade liabilities are not interest-bearing and are usually settled within ten days;
- The tax liabilities are not interest-bearing and are settled within the legally established terms;
- Other liabilities are not interest-bearing and are usually settled within ten days;
32.Related party disclosures
Related parties of the Company include the sole shareholder – the Ministry of Energy, subsidiaries, associates and
joint ventures, key management personnel.
The Company discloses the following related parties:
Sole shareholder of the capital:
The Bulgarian State through the Minister of Energy
Subsidiaries and undertakings under common control of BEH Group:
Natsionalna Elektricheska Kompania EAD
NPP Kozloduy EAD
TPP Maritsa East 2 EAD
Mini Maritsa Iztok EAD
Bulgargaz EAD
Bulgartransgaz EAD
Electricity System Operator EAD
National Energy Operator EAD
Minproekt EAD
Bulgartel AD
NPP Kozloduy - New Builds EAD
HPP Kozloduy EAD
NPP Construction Supervision OOD
NPP Servicing EOOD
Interpriborservice OOD - in bankruptcy
Bulgartel Skopje DOOEL
Bulgarian Energy Holding EAD
Separate financial statements
31 December 2024
49
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Balkan Gas Hub EAD
ESO Engineering EOOD
ESO Project EOOD
ECO CHARGE EAD
Associated and joint ventures of BEH Group
ICGB AD
South Stream Bulgaria AD
ContourGlobal Maritsa East 3 AD
ContourGlobal Operations Bulgaria AD
ZAD Energy
POD Allianz Bulgaria AD
Hydro Power Company Gorna Arda AD
Gastrade S.A., Greece
Southeast Electricity Network Coordination Center (SEleNe CC), Greece
Key management personnel of the Company as of 31 December 2024
Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors
Kalin Boyanov Filipov – Deputy Chairperson of the Board of Directors
Valentin Aleksiev Nikolov – Executive Member
Galina Tsvetanova Todorova – Executive Member
Ivo Ivanov Todorov – Member of the Board of Directors
Terms of transactions with related parties
Sales and purchases from related parties are made under market conditions. End -of-year outstanding balances are
unsecured (excluding part of the loans), interest-free (excluding loans) and settled with cash. The Company has not
taken/provided guarantees for receivables from or liabilities to related parties.
As of 31 December 2024 the Company has accrued impairment for expected credit losses on receivables from related
parties in the amount of BGN 1,066,643 thousand. (31 December 2023: BGN 1,104,974 thousand).
An impairment review is performed each financial year based on an analysis of the related party's financial position
and the market in which it operates.
Separate financial statements
31 December 2024
49
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Balkan Gas Hub EAD
ESO Engineering EOOD
ESO Project EOOD
ECO CHARGE EAD
Associated and joint ventures of BEH Group
ICGB AD
South Stream Bulgaria AD
ContourGlobal Maritsa East 3 AD
ContourGlobal Operations Bulgaria AD
ZAD Energy
POD Allianz Bulgaria AD
Hydro Power Company Gorna Arda AD
Gastrade S.A., Greece
Southeast Electricity Network Coordination Center (SEleNe CC), Greece
Key management personnel of the Company as of 31 December 2024
Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors
Kalin Boyanov Filipov – Deputy Chairperson of the Board of Directors
Valentin Aleksiev Nikolov – Executive Member
Galina Tsvetanova Todorova – Executive Member
Ivo Ivanov Todorov – Member of the Board of Directors
Terms of transactions with related parties
Sales and purchases from related parties are made under market conditions. End -of-year outstanding balances are
unsecured (excluding part of the loans), interest-free (excluding loans) and settled with cash. The Company has not
taken/provided guarantees for receivables from or liabilities to related parties.
As of 31 December 2024 the Company has accrued impairment for expected credit losses on receivables from related
parties in the amount of BGN 1,066,643 thousand. (31 December 2023: BGN 1,104,974 thousand).
An impairment review is performed each financial year based on an analysis of the related party's financial position
and the market in which it operates.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
50
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
32.1 Loans granted to related parties
In 2024 and the comparative period, the receivables under the loans granted to related parties are as follows:
Receivables from loans
granted to related
parties
Loan
receivables
Fair value
adjustment
and discount
Loss from
modification
Interest rate
adjustment Impairment
Receivables
from loans
granted, net
of impairment
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Subsidiaries
NEK EAD 2024 1,839,666 (420,828) - - (43,613) 1,375,225
2023 2,089,527 (523,572) - - (64,139) 1,501,816
Bulgartel EAD 2024 1,936 - (17) - (1,817) 102
2023 1,941 - (26) - (1,738) 177
Bulgargaz EAD 2024 630,564 - - (512) (568,590) 61,462
2023 630,000 - - - (494,173) 135,827
Bulgartransgaz EAD 2024 104,037 - - - (1) 104,036
2023 114,807 - - - - 114,807
Minproekt EAD 2024 2,120 - - - (1,980) 140
2023 - - - - - -
Mini Maritsa Iztok EAD 2024 107,823 - - - (7,798) 100,025
2023 - - - - - -
Joint ventures
ICGB AD 2024 215,379 - - - - 215,379
2023 215,379 - - - (1) 215,378
2024 2,901,525 (420,828) (17) (512) (623,799) 1,856,369
2023 3,051,654 (523,572) (26) - (560,051) 1,968,005
Separate financial statement
31 December 2024
50
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
32.1 Loans granted to related parties
In 2024 and the comparative period, the receivables under the loans granted to related parties are as follows:
Receivables from loans
granted to related
parties
Loan
receivables
Fair value
adjustment
and discount
Loss from
modification
Interest rate
adjustment Impairment
Receivables
from loans
granted, net
of impairment
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Subsidiaries
NEK EAD 2024 1,839,666 (420,828) - - (43,613) 1,375,225
2023 2,089,527 (523,572) - - (64,139) 1,501,816
Bulgartel EAD 2024 1,936 - (17) - (1,817) 102
2023 1,941 - (26) - (1,738) 177
Bulgargaz EAD 2024 630,564 - - (512) (568,590) 61,462
2023 630,000 - - - (494,173) 135,827
Bulgartransgaz EAD 2024 104,037 - - - (1) 104,036
2023 114,807 - - - - 114,807
Minproekt EAD 2024 2,120 - - - (1,980) 140
2023 - - - - - -
Mini Maritsa Iztok EAD 2024 107,823 - - - (7,798) 100,025
2023 - - - - - -
Joint ventures
ICGB AD 2024 215,379 - - - - 215,379
2023 215,379 - - - (1) 215,378
2024 2,901,525 (420,828) (17) (512) (623,799) 1,856,369
2023 3,051,654 (523,572) (26) - (560,051) 1,968,005
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
51
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
In 2023 and the comparative period, the movements under the loans granted to related parties are as follows:
Change in loans to related parties
for the period
Loans
granted
Novated
obligations Repaid loans Interest
income
Interest rate
adjustment
Amortization
of fair value
adjustment
and discount
through
financial
income
Amortization
of
modification
loss through
finance
income
Accrued
impairment
for the
period
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Subsidiaries
NEK EAD 2024 - - 296,966 47,106 - 102,744 - 20,526
2023 - 224,657 294,730 45,577 - 105,438 - 141,111
TPP Maritsa Iztok 2 EAD 2024 - - - - - - - -
2023 - - 82,317 128 1,174 - -
Bulgartel EAD 2024 - - 68 63 - - 9 (80)
2023 - - 338 69 - 30 234
Bulgargaz EAD 2024 - - 20,178 20,742 (512) - - (74,417)
2023 405,000 - 514,392 21,321 - - 199,888
Bulgartransgaz EAD 2024 - - 14,024 3,254 - - - (1)
2023 87,527 - 13,101 2,516 - - - -
Minproekt EAD 2024 2,120 - 45 45 - - - (1,980)
2023 - - - - - - - -
Mini Maritsa Iztok EAD 2024 110,000 - 2,967 790 - - (7,798)
2023 - - - - - - - -
Joint ventures
ICGB AD 2024 - - 1,774 1,774 - - - 1
2023 - - 1,774 1,774 - - - -
Separate financial statement
31 December 2024
51
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
In 2023 and the comparative period, the movements under the loans granted to related parties are as follows:
Change in loans to related parties
for the period
Loans
granted
Novated
obligations Repaid loans Interest
income
Interest rate
adjustment
Amortization
of fair value
adjustment
and discount
through
financial
income
Amortization
of
modification
loss through
finance
income
Accrued
impairment
for the
period
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Subsidiaries
NEK EAD 2024 - - 296,966 47,106 - 102,744 - 20,526
2023 - 224,657 294,730 45,577 - 105,438 - 141,111
TPP Maritsa Iztok 2 EAD 2024 - - - - - - - -
2023 - - 82,317 128 1,174 - -
Bulgartel EAD 2024 - - 68 63 - - 9 (80)
2023 - - 338 69 - 30 234
Bulgargaz EAD 2024 - - 20,178 20,742 (512) - - (74,417)
2023 405,000 - 514,392 21,321 - - 199,888
Bulgartransgaz EAD 2024 - - 14,024 3,254 - - - (1)
2023 87,527 - 13,101 2,516 - - - -
Minproekt EAD 2024 2,120 - 45 45 - - - (1,980)
2023 - - - - - - - -
Mini Maritsa Iztok EAD 2024 110,000 - 2,967 790 - - (7,798)
2023 - - - - - - - -
Joint ventures
ICGB AD 2024 - - 1,774 1,774 - - - 1
2023 - - 1,774 1,774 - - - -
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
52
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Terms of the loans granted to related parties
Natsionalna Elektricheska Kompania EAD
On 21 August 2014, a loan agreement was signed consolidating the loans of NEK EAD to BEH EAD and the assigned
receivable from NPP Kozloduy EAD from 1 April 2014 in the total amount of BGN 1,209,148 thousand. The term of
the new loan is 10 years, with a four-month grace period and an annual interest rate of 4.49%. Part of the claim in the
amount of BGN 170,784 thousand was rescheduled with an agreement from 2018. On July 28, 2021, the obligation
was renegotiated under the following conditions:
- Loan amount – BGN 973,777,456.64
- Repayment term – 10 years starting from 28.07.2021;
- Loan repayment – monthly annuity installments
- Interest – 3.225% per year;
- Legal interest for principal overdue - standard interest rate of the Bulgarian National Bank + 10%.
As of 31 December 2024, the receivable amounted to BGN 548,671 thousand and there were no overdue receivables.
On 25 April 2016, an agreement was signed for the provision of an earmarked loan in the amount of EUR 521,625
thousand (BGN 1,020,210 thousand) for the repayment of the amounts owed by NEK EAD to AES 3C Maritsa East
1 EOOD and ContourGlobal Maritsa East 3 AD, which is a necessary condition for the entry into force of the signed
agreements for the amendment of the long-term power purchase agreements of the two power plants. The term of the
loan is twelve months and at an annual interest rate of 6.65%. The contract contains a clause to renegotiate the terms
in the event of a successful placement of the bond issue. On 20 December 2016, the terms of the contract for the
provision of a target loan to NEK EAD dated 25 April 2016 were changed as follows:
• Amount of principal – EUR 535,672,538 (BGN 1,047,684,419);
• Interest rate on the loan – 5.575% on an annual basis;
• Duration of the contract – 59 months and 26 days;
• Principal maturity – 28 July 2021;
• Effective date – 2 August 2016.
On 28 July 2021, the debt was renegotiated under the following conditions:
- Loan amount – BGN 1,047,684,419.40
- Repayment term – 7 years starting from 28.07.2021;
- Loan repayment – monthly installments for interest and single principal payment on 28.07.2028;
- Interest – 3.225% per year.
- The debtor shall have the right to make a partial early repayment of the outstanding principal. Following each
early repayment, the parties will sign an updated repayment plan, taking into account the reduced amount of
the outstanding principal.
As of 31 December 2024 the receivable amounted to BGN 247,729 thousand and there were no overdue receivables.
On 28 July 2021, an agreement was concluded for deferring the unpaid interest liabilities for the total amount of BGN
550,720 thousand. The interest liabilities initially arose from an agreement dated 21 August 2014 (BGN 241,612
thousand) and an agreement dated 25 April 2016 (BGN 309,108 thousand). As of 31 December 2024, the amount
receivable is BGN 362,556 thousand and payments are being made on time.
On 14 April 2022, a loan agreement in the amount of BGN 700,000 thousand was concluded in connection with
decision № 142 of the Council of Ministers of 10 March 2022. The term of the loan is thirty -three months and at an
annual interest rate of 2.44% and a grace period of 12 months for the principal payment. On 18 July 2023, an additional
agreement was concluded that renegotiates and extends the term of the contract to 86 months from the date of
conclusion (14 April 2022) and the principal repayment term to 72 months. As of 31 December 2024, the receivable
amounted to BGN 476,053 thousand and there were no overdue receivables.
On 16 February 2024, a loan contract in the amount of BGN 224,657 thousand offsetting NEK EAD’s obligations for
a dividend representing 50% of the Company’s retained earnings for 2022. The dividend is determined by a protocol
of the Board of Directors of BEH EAD of 20 December 2023 in connection with Order No. 7/14.12.2023 of the
Council of Ministers. The time period of the contract is 60 months with an annual interest rate of 3.275% and payment
of principal installments at the end of each calendar year for the time period of the contract. As of 31 December 2024,
the receivable amounted to BGN 204,657 thousand and there were no overdue receivables.
Separate financial statement
31 December 2024
52
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Terms of the loans granted to related parties
Natsionalna Elektricheska Kompania EAD
On 21 August 2014, a loan agreement was signed consolidating the loans of NEK EAD to BEH EAD and the assigned
receivable from NPP Kozloduy EAD from 1 April 2014 in the total amount of BGN 1,209,148 thousand. The term of
the new loan is 10 years, with a four-month grace period and an annual interest rate of 4.49%. Part of the claim in the
amount of BGN 170,784 thousand was rescheduled with an agreement from 2018. On July 28, 2021, the obligation
was renegotiated under the following conditions:
- Loan amount – BGN 973,777,456.64
- Repayment term – 10 years starting from 28.07.2021;
- Loan repayment – monthly annuity installments
- Interest – 3.225% per year;
- Legal interest for principal overdue - standard interest rate of the Bulgarian National Bank + 10%.
As of 31 December 2024, the receivable amounted to BGN 548,671 thousand and there were no overdue receivables.
On 25 April 2016, an agreement was signed for the provision of an earmarked loan in the amount of EUR 521,625
thousand (BGN 1,020,210 thousand) for the repayment of the amounts owed by NEK EAD to AES 3C Maritsa East
1 EOOD and ContourGlobal Maritsa East 3 AD, which is a necessary condition for the entry into force of the signed
agreements for the amendment of the long-term power purchase agreements of the two power plants. The term of the
loan is twelve months and at an annual interest rate of 6.65%. The contract contains a clause to renegotiate the terms
in the event of a successful placement of the bond issue. On 20 December 2016, the terms of the contract for the
provision of a target loan to NEK EAD dated 25 April 2016 were changed as follows:
• Amount of principal – EUR 535,672,538 (BGN 1,047,684,419);
• Interest rate on the loan – 5.575% on an annual basis;
• Duration of the contract – 59 months and 26 days;
• Principal maturity – 28 July 2021;
• Effective date – 2 August 2016.
On 28 July 2021, the debt was renegotiated under the following conditions:
- Loan amount – BGN 1,047,684,419.40
- Repayment term – 7 years starting from 28.07.2021;
- Loan repayment – monthly installments for interest and single principal payment on 28.07.2028;
- Interest – 3.225% per year.
- The debtor shall have the right to make a partial early repayment of the outstanding principal. Following each
early repayment, the parties will sign an updated repayment plan, taking into account the reduced amount of
the outstanding principal.
As of 31 December 2024 the receivable amounted to BGN 247,729 thousand and there were no overdue receivables.
On 28 July 2021, an agreement was concluded for deferring the unpaid interest liabilities for the total amount of BGN
550,720 thousand. The interest liabilities initially arose from an agreement dated 21 August 2014 (BGN 241,612
thousand) and an agreement dated 25 April 2016 (BGN 309,108 thousand). As of 31 December 2024, the amount
receivable is BGN 362,556 thousand and payments are being made on time.
On 14 April 2022, a loan agreement in the amount of BGN 700,000 thousand was concluded in connection with
decision № 142 of the Council of Ministers of 10 March 2022. The term of the loan is thirty -three months and at an
annual interest rate of 2.44% and a grace period of 12 months for the principal payment. On 18 July 2023, an additional
agreement was concluded that renegotiates and extends the term of the contract to 86 months from the date of
conclusion (14 April 2022) and the principal repayment term to 72 months. As of 31 December 2024, the receivable
amounted to BGN 476,053 thousand and there were no overdue receivables.
On 16 February 2024, a loan contract in the amount of BGN 224,657 thousand offsetting NEK EAD’s obligations for
a dividend representing 50% of the Company’s retained earnings for 2022. The dividend is determined by a protocol
of the Board of Directors of BEH EAD of 20 December 2023 in connection with Order No. 7/14.12.2023 of the
Council of Ministers. The time period of the contract is 60 months with an annual interest rate of 3.275% and payment
of principal installments at the end of each calendar year for the time period of the contract. As of 31 December 2024,
the receivable amounted to BGN 204,657 thousand and there were no overdue receivables.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
53
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Bulgartel AD
On 21 December 2016, liabilities under loan agreements of Bulgartel AD in the total amount of BGN 2,882 thousand,
including principal in the amount of BGN 2,492 thousand and interest in the amount of BGN 390 thousand were
merged and novated. As of 31 December 2020, nine additional agreements for extension were signed. The repayment
term of the novated liabilities is until 1 November 2027. The annual interest rate is 3.225% and the default interest on
the principal is BIR + 10%. As of 31 December 2024, the amount receivable is BGN 1,936 thousand and there are no
overdue receivables.
Bulgargaz EAD
On 6 July 2022 an agreement was signed for granting a short-term credit line to Bulgargaz EAD in the amount of
BGN 60,000 thousand. The purpose of the loan is to repay obligations under contracts for the supply of natural gas
for the Republic of Bulgaria, concluded between Bulgargaz EAD and natural gas suppliers. The validity period is
twelve months from the date of conclusion of the contract, with an annual interest rate of 3.23%. The funds are
disbursed at the request of the borrower, repeatedly, within the agreed term. The principal is repaid at the end of the
period. On 6 July 2023, a supplemental agreement was executed to change the term of the agreement to twenty-four
months from the date of execution and the interest rate of 3.275% per annum to be applied to the drawn amount
commencing 7 July 2023. By agreement dated 2 August 2024, the term of a loan agreement (short-term credit line) in
the amount of BGN 60,000 thousand with Bulgargaz EAD was extended until 6 July 2025. As of 31 December 2024,
the amount receivable is BGN 60,000 thousand and there are no overdue receivables.
On 21 December 2022, a loan agreement was signed, which provided funds to Bulgargaz EAD in the amount of BGN
457,515 thousand to cover the subsidiary's operating needs and to pay the dividend due from the company from the
2021 profit. The repayment period is twelve months from the draw down of the amount, with the principal repayable
in one lump sum at the end of the period. The interest rate on the loan is 3.275% per annum. On 21 December 2023,
a supplementary agreement was concluded, which converted the liability into a credit line, changed the amount to
BGN 370,000 thousand and extended the term of the agreement until 21 December 2028. As of 31 December 2024,
the amount receivable is BGN 370,000 thousand and there are no overdue receivables.
On 3 April 2023, a credit agreement was concluded between Bulgarian Energy Holding EAD and Bulgargaz EAD in
the form of a credit line to secure the servicing of the Company's obligations to supply natural gas to Bulgaria, under
the following conditions:
- Limit: BGN 200,000,000;
- Validity: 12 months from the date of contract conclusion for a short-term credit line;
- Interest rate: 3.275% per annum on the utilized amount.
On 26 June 2024, a new agreement was entered into extending the facility until 26 June 2027 on the same terms. As
of 31 December 2024, the receivable amounted to BGN 200,564 thousand and there were no overdue receivables.
Bulgartransgaz EAD
On 5 July 2022, an agreement was concluded for the provision of a loan to Bulgartransgaz EAD in the amount of
BGN 37,865 thousand. The loan was granted for the purpose of financing additional tasks assigned to Bulgartransgaz
EAD to serve the public under the orders of the Minister of Energy. The term of the agreement is until 30 June 2026
with a six-month grace period for principal payments. The annual interest rate is 1.735%. As of 31 December 2024,
the receivable amounts to BGN 16,510 thousand.
On 17 February 2023, a loan contract was concluded between Bulgarian Energy Holding EAD and Bulgartransgaz
EAD for the purpose of financing the execution of a public procurement with the name: “Organizational planning,
investment design, supply of the necessary materials and equipment, construction and commissioning of construction:
“Expansion of the capacity of the Chiren underground gas storage facility – drilling fund” initiated by a decision of
8 August 2022. The terms of the contract are as follows:
- Amount of the loan (principal) – BGN 65,156,525;
- Utilization period: Up to 6 months from the date of the contract, upon submission of a request;
- Grace period for payment of the principal: 24 months from the date of utilizing the respective amount;
- Repayment term for the utilized amount: 60 months after the expiration of the grace period for principal
payment;
- Interest rate: 3.275% per annum.
On 10 March 2023, a request was made by Bulgartransgaz EAD to provide additional financing of up to BGN
22,370,675, representing the difference between the financial resources originally provided under the contract of 17
February 2023 and the price offered by the second-ranked tenderer. The reason is the refusal of the first-ranked
tenderer to conclude a performance contract with Bulgartransgaz EAD due to objective impossibility to perform the
Separate financial statement
31 December 2024
53
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Bulgartel AD
On 21 December 2016, liabilities under loan agreements of Bulgartel AD in the total amount of BGN 2,882 thousand,
including principal in the amount of BGN 2,492 thousand and interest in the amount of BGN 390 thousand were
merged and novated. As of 31 December 2020, nine additional agreements for extension were signed. The repayment
term of the novated liabilities is until 1 November 2027. The annual interest rate is 3.225% and the default interest on
the principal is BIR + 10%. As of 31 December 2024, the amount receivable is BGN 1,936 thousand and there are no
overdue receivables.
Bulgargaz EAD
On 6 July 2022 an agreement was signed for granting a short-term credit line to Bulgargaz EAD in the amount of
BGN 60,000 thousand. The purpose of the loan is to repay obligations under contracts for the supply of natural gas
for the Republic of Bulgaria, concluded between Bulgargaz EAD and natural gas suppliers. The validity period is
twelve months from the date of conclusion of the contract, with an annual interest rate of 3.23%. The funds are
disbursed at the request of the borrower, repeatedly, within the agreed term. The principal is repaid at the end of the
period. On 6 July 2023, a supplemental agreement was executed to change the term of the agreement to twenty-four
months from the date of execution and the interest rate of 3.275% per annum to be applied to the drawn amount
commencing 7 July 2023. By agreement dated 2 August 2024, the term of a loan agreement (short-term credit line) in
the amount of BGN 60,000 thousand with Bulgargaz EAD was extended until 6 July 2025. As of 31 December 2024,
the amount receivable is BGN 60,000 thousand and there are no overdue receivables.
On 21 December 2022, a loan agreement was signed, which provided funds to Bulgargaz EAD in the amount of BGN
457,515 thousand to cover the subsidiary's operating needs and to pay the dividend due from the company from the
2021 profit. The repayment period is twelve months from the draw down of the amount, with the principal repayable
in one lump sum at the end of the period. The interest rate on the loan is 3.275% per annum. On 21 December 2023,
a supplementary agreement was concluded, which converted the liability into a credit line, changed the amount to
BGN 370,000 thousand and extended the term of the agreement until 21 December 2028. As of 31 December 2024,
the amount receivable is BGN 370,000 thousand and there are no overdue receivables.
On 3 April 2023, a credit agreement was concluded between Bulgarian Energy Holding EAD and Bulgargaz EAD in
the form of a credit line to secure the servicing of the Company's obligations to supply natural gas to Bulgaria, under
the following conditions:
- Limit: BGN 200,000,000;
- Validity: 12 months from the date of contract conclusion for a short-term credit line;
- Interest rate: 3.275% per annum on the utilized amount.
On 26 June 2024, a new agreement was entered into extending the facility until 26 June 2027 on the same terms. As
of 31 December 2024, the receivable amounted to BGN 200,564 thousand and there were no overdue receivables.
Bulgartransgaz EAD
On 5 July 2022, an agreement was concluded for the provision of a loan to Bulgartransgaz EAD in the amount of
BGN 37,865 thousand. The loan was granted for the purpose of financing additional tasks assigned to Bulgartransgaz
EAD to serve the public under the orders of the Minister of Energy. The term of the agreement is until 30 June 2026
with a six-month grace period for principal payments. The annual interest rate is 1.735%. As of 31 December 2024,
the receivable amounts to BGN 16,510 thousand.
On 17 February 2023, a loan contract was concluded between Bulgarian Energy Holding EAD and Bulgartransgaz
EAD for the purpose of financing the execution of a public procurement with the name: “Organizational planning,
investment design, supply of the necessary materials and equipment, construction and commissioning of construction:
“Expansion of the capacity of the Chiren underground gas storage facility – drilling fund” initiated by a decision of
8 August 2022. The terms of the contract are as follows:
- Amount of the loan (principal) – BGN 65,156,525;
- Utilization period: Up to 6 months from the date of the contract, upon submission of a request;
- Grace period for payment of the principal: 24 months from the date of utilizing the respective amount;
- Repayment term for the utilized amount: 60 months after the expiration of the grace period for principal
payment;
- Interest rate: 3.275% per annum.
On 10 March 2023, a request was made by Bulgartransgaz EAD to provide additional financing of up to BGN
22,370,675, representing the difference between the financial resources originally provided under the contract of 17
February 2023 and the price offered by the second-ranked tenderer. The reason is the refusal of the first-ranked
tenderer to conclude a performance contract with Bulgartransgaz EAD due to objective impossibility to perform the
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
54
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
activities of the subject of the contract within the timeframe specified in the draft contract. On 7 April 2023, an annex
was signed to increase the funds under the loan in the amount of BGN 88,527,200. The loan funds were drawn down
on 26 April 2023. As at 31 December 2024 the receivable amounted to BGN 87,527 thousand.
Mini Maritsa-Iztok EAD
In 2024, framework financing agreements have been concluded between Bulgarian Energy Holding EAD and Mini
Maritsa-Iztok EAD with an available amount of BGN 100,000 thousand each. On the basis of these framework
agreements, the following loan agreements have been concluded:
On 16 August 2024, a loan agreement was concluded between Bulgarian Energy Holding EAD and Mini Maritsa -
Iztok EAD for the financing of the operations of Mini Maritsa-Iztok EAD, under the following conditions:
- Loan amount: BGN 28,000 thousand;
- Validity: until 30 November 30 2025;
- Principal repayment grace period: Until 30 November 2024;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the receivable amounted to BGN 25,702 thousand and there were no arrears.
On 18 September 2024, a loan agreement was signed between Bulgarian Energy Holding EAD and Mini Maritsa -
Iztok EAD to finance the operations of Mini Maritsa-Iztok EAD under the following conditions:
- Loan amount: BGN 28,000 thousand;
- Validity: until 31 December 2025;
- Principal repayment grace period: until 31 December 2024;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the receivable amounted to BGN 28,000 thousand and there were no arrears.
On 17 October 2024, a loan agreement was signed between Bulgarian Energy Holding EAD and Mini Maritsa -Iztok
EAD to finance the operations of Mini Maritsa-Iztok EAD under the following conditions:
- Loan amount: BGN 44,000 thousand;
- Validity: until 31 January 2026;
- Principal repayment grace period: until 31 January 2025;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the receivable amounted to BGN 44,110 thousand and there were no arrears.
On 17 December 2024 a credit line agreement was signed between Bulgarian Energy Holding EAD and Mini Maritsa-
Iztok EAD to finance the operations of Mini Maritsa-Iztok EAD under the following conditions:
- Loan amount: up to BGN 50,000 thousand;
- Validity: 12 months from the date of the first drawdown of the loan;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the amount drawn down under the credit line is BGN 10,011 thousand and there are no
arrears.
ICGB AD
In October 2019, Bulgarian Energy Holding EAD and the European Investment Bank signed a Financing Agreement
for the construction of an IGB gas pipeline worth EUR 109.9 million, secured by a state financial guarantee from the
Republic of Bulgaria, the Guarantee Agreement for which has been ratified by the National Assembly. The loan is
provided to Bulgarian Energy Holding EAD as a shareholder in ICGB AD (project company). For its part, BEH EAD
transferred the loan financing to the project company through a Shareholder Loan Agreement dated October 2019 in
the same amount, under the same financial terms set out in the agreement with the European Investment Bank and
without additional margin for Bulgarian Energy Holding EAD.
- The first tranche amounting to EUR 30 million was utilized on 17 August 2020 under the following terms:
payment of interest twice a year in the amount of 0.259%, five-year grace period for principal payments,
payment of principal twice a year, the last installment being due on 17 August 2045.
- The second tranche amounting to EUR 30 million was utilized on 18 January 2021 under the following terms:
payment of interest twice a year in the amount of 0.237%, five-year grace period for principal payments,
payment of principal twice a year. The deadline for the last installment is 18 January 2046.
Separate financial statement
31 December 2024
54
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
activities of the subject of the contract within the timeframe specified in the draft contract. On 7 April 2023, an annex
was signed to increase the funds under the loan in the amount of BGN 88,527,200. The loan funds were drawn down
on 26 April 2023. As at 31 December 2024 the receivable amounted to BGN 87,527 thousand.
Mini Maritsa-Iztok EAD
In 2024, framework financing agreements have been concluded between Bulgarian Energy Holding EAD and Mini
Maritsa-Iztok EAD with an available amount of BGN 100,000 thousand each. On the basis of these framework
agreements, the following loan agreements have been concluded:
On 16 August 2024, a loan agreement was concluded between Bulgarian Energy Holding EAD and Mini Maritsa -
Iztok EAD for the financing of the operations of Mini Maritsa-Iztok EAD, under the following conditions:
- Loan amount: BGN 28,000 thousand;
- Validity: until 30 November 30 2025;
- Principal repayment grace period: Until 30 November 2024;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the receivable amounted to BGN 25,702 thousand and there were no arrears.
On 18 September 2024, a loan agreement was signed between Bulgarian Energy Holding EAD and Mini Maritsa -
Iztok EAD to finance the operations of Mini Maritsa-Iztok EAD under the following conditions:
- Loan amount: BGN 28,000 thousand;
- Validity: until 31 December 2025;
- Principal repayment grace period: until 31 December 2024;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the receivable amounted to BGN 28,000 thousand and there were no arrears.
On 17 October 2024, a loan agreement was signed between Bulgarian Energy Holding EAD and Mini Maritsa -Iztok
EAD to finance the operations of Mini Maritsa-Iztok EAD under the following conditions:
- Loan amount: BGN 44,000 thousand;
- Validity: until 31 January 2026;
- Principal repayment grace period: until 31 January 2025;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the receivable amounted to BGN 44,110 thousand and there were no arrears.
On 17 December 2024 a credit line agreement was signed between Bulgarian Energy Holding EAD and Mini Maritsa-
Iztok EAD to finance the operations of Mini Maritsa-Iztok EAD under the following conditions:
- Loan amount: up to BGN 50,000 thousand;
- Validity: 12 months from the date of the first drawdown of the loan;
- Interest rate: 3.275% per annum on the utilized amount.
As of 31 December 2024, the amount drawn down under the credit line is BGN 10,011 thousand and there are no
arrears.
ICGB AD
In October 2019, Bulgarian Energy Holding EAD and the European Investment Bank signed a Financing Agreement
for the construction of an IGB gas pipeline worth EUR 109.9 million, secured by a state financial guarantee from the
Republic of Bulgaria, the Guarantee Agreement for which has been ratified by the National Assembly. The loan is
provided to Bulgarian Energy Holding EAD as a shareholder in ICGB AD (project company). For its part, BEH EAD
transferred the loan financing to the project company through a Shareholder Loan Agreement dated October 2019 in
the same amount, under the same financial terms set out in the agreement with the European Investment Bank and
without additional margin for Bulgarian Energy Holding EAD.
- The first tranche amounting to EUR 30 million was utilized on 17 August 2020 under the following terms:
payment of interest twice a year in the amount of 0.259%, five-year grace period for principal payments,
payment of principal twice a year, the last installment being due on 17 August 2045.
- The second tranche amounting to EUR 30 million was utilized on 18 January 2021 under the following terms:
payment of interest twice a year in the amount of 0.237%, five-year grace period for principal payments,
payment of principal twice a year. The deadline for the last installment is 18 January 2046.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
55
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- On 1 December 2021, a third tranche of EUR 30 million was drawn down under the following conditions:
payment of interest twice a year in the amount of 0.612%, five-year grace period for principal payments,
payment of principal twice a year. The deadline for the last due installment is 1 December 2046.
- The fourth tranche amounting to EUR 19.9 million was utilized on 29 September 2022 under the following
terms: payment of interest twice a year in the amount of 2.888%, five-year grace period for principal
payments, payment of principal twice a year. The deadline for the last due installment is 29 September 2047.
As of 31 December 2024, the receivable amounted to BGN 215,379 thousand and there were no overdue receivables.
32.2 Loans received from related parties
NPP Kozloduy EAD
On 5 July 2022 a loan agreement was signed with NPP Kozloduy EAD in the amount of BGN 37,865 thousand. The
loan was granted for the purpose of financing additional tasks assigned to Bulgartransgaz EAD to serve the public
under the orders of the Minister of Energy. The term of the contract is until 30 June 2026 with a six-month grace
period for principal payments. The annual interest rate is 1.66%. As of 31 December 2024, the liability amounts to
BGN 16,497 thousand.
On 18 October 2024 a loan agreement was signed with Kozloduy NPP in the amount of BGN 25,000 thousand. The
loan was granted for the purpose of repayment of a loan for the financial year 2023 in accordance with Order № 3 of
the Council of Ministers of 16 October 2024. The term of the agreement is three months and the final payment date is
19 January 2025. The annual interest rate is 1.66%. As of 31 December 2024, the liability amounted to BGN 25,087
thousand.
32.3 Trade receivables from and payables to related parties
The total amount of outstanding balances with related parties for the current and prior reporting periods is presented
in the table below.
Trade receivables
31 December
2024 г.
31 December
2023
thousand BGN thousand BGN
Sole owner
Ministry of Energy 2 -
Subsidiaries and companies under common joint control
NPP Kozloduy EAD 27 61
Bulgargaz EAD 18 20
Bulgartransgaz EAD 257,705 295
Bulgartransgaz EAD – impairment (13) (285)
257,692 10
Mini Maritsa Iztok EAD 8,619 8,377
Mini Maritsa Iztok EAD – impairment (6,077) (5,958)
2,542 2,419
NEK EAD 16,384 79
TPP Maritsa East 2 EAD 21,116 21,167
TPP Maritsa East 2 EAD – impairment (15,383) (15,080)
5,733 6,087
282,398 8,676
On 11 September 2024 the Board of Directors of Bulgarian Energy Holding EAD determined the dividend payable
by Bulgartransgaz EAD for 2021 and 2022 in the total amount of BGN 257,251 thousand and conditions for its
rescheduling. On 9 December 2024, an agreement was concluded between the companies for the payment of the
obligation in three annual installments in December for the period 2025 - 2027, together with accrued interest. The
Separate financial statement
31 December 2024
55
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
- On 1 December 2021, a third tranche of EUR 30 million was drawn down under the following conditions:
payment of interest twice a year in the amount of 0.612%, five-year grace period for principal payments,
payment of principal twice a year. The deadline for the last due installment is 1 December 2046.
- The fourth tranche amounting to EUR 19.9 million was utilized on 29 September 2022 under the following
terms: payment of interest twice a year in the amount of 2.888%, five-year grace period for principal
payments, payment of principal twice a year. The deadline for the last due installment is 29 September 2047.
As of 31 December 2024, the receivable amounted to BGN 215,379 thousand and there were no overdue receivables.
32.2 Loans received from related parties
NPP Kozloduy EAD
On 5 July 2022 a loan agreement was signed with NPP Kozloduy EAD in the amount of BGN 37,865 thousand. The
loan was granted for the purpose of financing additional tasks assigned to Bulgartransgaz EAD to serve the public
under the orders of the Minister of Energy. The term of the contract is until 30 June 2026 with a six-month grace
period for principal payments. The annual interest rate is 1.66%. As of 31 December 2024, the liability amounts to
BGN 16,497 thousand.
On 18 October 2024 a loan agreement was signed with Kozloduy NPP in the amount of BGN 25,000 thousand. The
loan was granted for the purpose of repayment of a loan for the financial year 2023 in accordance with Order № 3 of
the Council of Ministers of 16 October 2024. The term of the agreement is three months and the final payment date is
19 January 2025. The annual interest rate is 1.66%. As of 31 December 2024, the liability amounted to BGN 25,087
thousand.
32.3 Trade receivables from and payables to related parties
The total amount of outstanding balances with related parties for the current and prior reporting periods is presented
in the table below.
Trade receivables
31 December
2024 г.
31 December
2023
thousand BGN thousand BGN
Sole owner
Ministry of Energy 2 -
Subsidiaries and companies under common joint control
NPP Kozloduy EAD 27 61
Bulgargaz EAD 18 20
Bulgartransgaz EAD 257,705 295
Bulgartransgaz EAD – impairment (13) (285)
257,692 10
Mini Maritsa Iztok EAD 8,619 8,377
Mini Maritsa Iztok EAD – impairment (6,077) (5,958)
2,542 2,419
NEK EAD 16,384 79
TPP Maritsa East 2 EAD 21,116 21,167
TPP Maritsa East 2 EAD – impairment (15,383) (15,080)
5,733 6,087
282,398 8,676
On 11 September 2024 the Board of Directors of Bulgarian Energy Holding EAD determined the dividend payable
by Bulgartransgaz EAD for 2021 and 2022 in the total amount of BGN 257,251 thousand and conditions for its
rescheduling. On 9 December 2024, an agreement was concluded between the companies for the payment of the
obligation in three annual installments in December for the period 2025 - 2027, together with accrued interest. The
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
56
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
debtor shall pay interest on the principal amount of 3.275% if, on the first day of December of the year in which
payment is due, the amount of the same is lower than the value of the 1-month EURIBOR interest index.
On 5 December 2024 between Bulgarian Energy Holding EAD and Mini Maritsa-Iztok EAD an agreement for transfer
of receivable (cession) to the subsidiary from AES-3C Maritsa East I EOOD in the amount of 27,642 thousand BGN
representing compensation for unaccepted coal quantities in 2023 was concluded, part of the price of BGN 25,172
thousand was paid to Kauchuk AD to repay an obligation of Mini Maritsa-Iztok EAD and the balance of BGN 2,420
thousand was set off against a counter-obligation of the subsidiary under a loan agreement dated 16 August 2024. The
debt will be repaid to Bulgarian Energy Holding EAD by NEK EAD pursuant to a Tripartite Agreement between NEK
EAD, Mini Maritsa-Iztok EAD and AES-3C Maritsa East I EOOD pursuant to which NEK EAD will repay to Mini
Maritsa-Iztok EAD the debt of AES-3C Maritsa East I EOOD for unaccepted coal quantities in 2023 in exchange for
NEK EAD's obligation to AES-3C Maritsa-East I EOOD under the Power Purchase Agreement. As of 31 December
2024, the receivable of Bulgarian Energy Holding EAD from NEK EAD amounts to BGN 16,384 thousand, which
includes the receivable under the cession in the amount of BGN 16,124 thousand and a price discount in the amount
of BGN 13 thousand, and the receivable under the holding agreement in the amount of BGN 273 thousand.
There are no trade payables to related parties.
32.4 Related party transactions
The total amount of transactions with related parties for the current and prior reporting periods is presented in the
tables below. The income charged from dividends and the interest charged on overdue liabilities for dividends are
presented in note 5.
Sales to related parties Type of transactions 2024 2023
thousand
BGN
thousand
BGN
Sole owner
Ministry of Energy Motor vehicle costs 59 8
Subsidiaries and companies under common joint control
NPP Kozloduy EAD holding agreement services 513 532
other commercial 43 -
Bulgargaz EAD holding agreement services 111 283
bank guarantee fees - 351
other commercial - 8
Mini Maritsa Iztok EAD holding agreement services 554 211
late payment interest 6 -
NEK EAD services under a holding agreement 629 652
other commercial - 12
TPP Maritsa Iztok 2 EAD Greenhouse gas emission allowances 228,190 303,187
agency service for the sale of CO 2
emissions 35 36
holding agreement services 196 305
asset sale 2 -
National Energy Operator
(NEO)/(Natsionalen Energien
Operator) EAD
other commercial sales 1 -
holding agreement services 1 -
Minproekt EAD holding agreement services 34 -
Bulgartransgaz EAD other commercial - 8
230,374 305,602
Separate financial statement
31 December 2024
56
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
debtor shall pay interest on the principal amount of 3.275% if, on the first day of December of the year in which
payment is due, the amount of the same is lower than the value of the 1-month EURIBOR interest index.
On 5 December 2024 between Bulgarian Energy Holding EAD and Mini Maritsa-Iztok EAD an agreement for transfer
of receivable (cession) to the subsidiary from AES-3C Maritsa East I EOOD in the amount of 27,642 thousand BGN
representing compensation for unaccepted coal quantities in 2023 was concluded, part of the price of BGN 25,172
thousand was paid to Kauchuk AD to repay an obligation of Mini Maritsa-Iztok EAD and the balance of BGN 2,420
thousand was set off against a counter-obligation of the subsidiary under a loan agreement dated 16 August 2024. The
debt will be repaid to Bulgarian Energy Holding EAD by NEK EAD pursuant to a Tripartite Agreement between NEK
EAD, Mini Maritsa-Iztok EAD and AES-3C Maritsa East I EOOD pursuant to which NEK EAD will repay to Mini
Maritsa-Iztok EAD the debt of AES-3C Maritsa East I EOOD for unaccepted coal quantities in 2023 in exchange for
NEK EAD's obligation to AES-3C Maritsa-East I EOOD under the Power Purchase Agreement. As of 31 December
2024, the receivable of Bulgarian Energy Holding EAD from NEK EAD amounts to BGN 16,384 thousand, which
includes the receivable under the cession in the amount of BGN 16,124 thousand and a price discount in the amount
of BGN 13 thousand, and the receivable under the holding agreement in the amount of BGN 273 thousand.
There are no trade payables to related parties.
32.4 Related party transactions
The total amount of transactions with related parties for the current and prior reporting periods is presented in the
tables below. The income charged from dividends and the interest charged on overdue liabilities for dividends are
presented in note 5.
Sales to related parties Type of transactions 2024 2023
thousand
BGN
thousand
BGN
Sole owner
Ministry of Energy Motor vehicle costs 59 8
Subsidiaries and companies under common joint control
NPP Kozloduy EAD holding agreement services 513 532
other commercial 43 -
Bulgargaz EAD holding agreement services 111 283
bank guarantee fees - 351
other commercial - 8
Mini Maritsa Iztok EAD holding agreement services 554 211
late payment interest 6 -
NEK EAD services under a holding agreement 629 652
other commercial - 12
TPP Maritsa Iztok 2 EAD Greenhouse gas emission allowances 228,190 303,187
agency service for the sale of CO 2
emissions 35 36
holding agreement services 196 305
asset sale 2 -
National Energy Operator
(NEO)/(Natsionalen Energien
Operator) EAD
other commercial sales 1 -
holding agreement services 1 -
Minproekt EAD holding agreement services 34 -
Bulgartransgaz EAD other commercial - 8
230,374 305,602
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
57
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Purchases from related parties Type of transactions 2024 2023
thousand
BGN
thousand
BGN
Subsidiaries
NEK EAD property purchase 272 -
other commercial 1 -
NPP Kozloduy EAD other commercial 4 5
capital instalment - 1,500,000
Bulgartransgaz EAD capital instalment 200,000 -
Mini Maritsa Iztok EAD purchased receivable (assignment) 27,642 -
other commercial 1 1
Bulgartel AD rent of fiber optic line and Internet 9 9
National Energy Operator (NEO) /
(Natsionalen Energien Operator)
EAD
capital instalment - 30,000
227,929 1,530,015
32.5 Remuneration of key management staff
2024 2023
thousand BGN thousand BGN
Remuneration (542) (519)
Social security costs (18) (21)
Social costs (121) (157)
Unused annual leave and related social security expenses (18) (19)
Royalties (payment) - (154)
(699) (870)
33.Non-cash transactions
During the reporting period, the Company carried out the following investment and financial transactions, in which
cash and cash equivalents were not used, and which are not reflected in the cash flow statements:
• Partial set-off of an amount due from Bulgarian Energy Holding EAD to Mini Maritsa-Iztok EAD under a
receivable transfer (cession) agreement in the amount of BGN 2,420 thousand against an installment under a
loan agreement of Mini Maritsa-Iztok EAD (explanatory notes 32).
34. Commitments, lease and contingent liabilities
Litigation and claims arise in the Company’s normal course of activity. According to the Company’s Management,
the costs required to resolve these disputes and claims will not have a material impact on the financial position and
cash flows in future financial periods.
Bulgarian Energy Holding EAD, as the parent company, is committed to providing financial and operational support
to the group companies and has no plans or intentions to cease operations so that they will continue to operate as going
concerns and will settle their obligations in accordance with their due dates and related terms.
Separate financial statement
31 December 2024
57
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Purchases from related parties Type of transactions 2024 2023
thousand
BGN
thousand
BGN
Subsidiaries
NEK EAD property purchase 272 -
other commercial 1 -
NPP Kozloduy EAD other commercial 4 5
capital instalment - 1,500,000
Bulgartransgaz EAD capital instalment 200,000 -
Mini Maritsa Iztok EAD purchased receivable (assignment) 27,642 -
other commercial 1 1
Bulgartel AD rent of fiber optic line and Internet 9 9
National Energy Operator (NEO) /
(Natsionalen Energien Operator)
EAD
capital instalment - 30,000
227,929 1,530,015
32.5 Remuneration of key management staff
2024 2023
thousand BGN thousand BGN
Remuneration (542) (519)
Social security costs (18) (21)
Social costs (121) (157)
Unused annual leave and related social security expenses (18) (19)
Royalties (payment) - (154)
(699) (870)
33.Non-cash transactions
During the reporting period, the Company carried out the following investment and financial transactions, in which
cash and cash equivalents were not used, and which are not reflected in the cash flow statements:
• Partial set-off of an amount due from Bulgarian Energy Holding EAD to Mini Maritsa-Iztok EAD under a
receivable transfer (cession) agreement in the amount of BGN 2,420 thousand against an installment under a
loan agreement of Mini Maritsa-Iztok EAD (explanatory notes 32).
34. Commitments, lease and contingent liabilities
Litigation and claims arise in the Company’s normal course of activity. According to the Company’s Management,
the costs required to resolve these disputes and claims will not have a material impact on the financial position and
cash flows in future financial periods.
Bulgarian Energy Holding EAD, as the parent company, is committed to providing financial and operational support
to the group companies and has no plans or intentions to cease operations so that they will continue to operate as going
concerns and will settle their obligations in accordance with their due dates and related terms.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
58
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Proceedings by the European Commission against Bulgarian Energy Holding EAD – Case
COMP/B1/АТ.39849 – BEH gas
The case concerns a possible violation of Article 102 TFEU in relation to alleged actions by BEH EAD and its
subsidiaries Bulgargaz EAD and Bulgartransgaz EAD aimed at:
• preventing their competitors from gaining access to key gas infrastructure (gas transmission network and natural
gas storage facility) in Bulgaria, explicitly or implicitly denying access to third parties or causing delays;
• preventing competitors from receiving access to a main gas import transmission network by reserving a
capacity, which remains unused.
The proceedings were instituted in 2013 with a view to adopting a decision under Chapter 3 (Articles 7 to 10) of
Regulation 1/2003.
On 23 March 2015, the EC issued a Statement of Objections. Bulgarian Energy Holding EAD and its gas subsidiaries
submitted their respective responses to the European Commission on 9 July 2015 (Bulgargaz EAD), 10 July 2015
(Bulgarian Energy Holding EAD) and 17 July 2015 (Bulgartransgaz EAD).
On 24 November 2017, a decision was made by the 44th National Assembly of the Republic of Bulgaria to take the
necessary action for the termination of Case COMP/B1/AT.39849 – BEH Gas, by which the National Assembly
supports the termination of the case under the procedure of Art. 7 of Regulation (EU) No. 1/2003 without admission
of the alleged infringements and without taking responsibility for them, fulfilling the obligations resulting from any
prohibitive decision, including any financial penalties. Currently, the European Commission has not made any official
decision to close the case, including regarding the possible amount of the financial sanction.
On 26 July 2018, the 44th National Assembly (NA) of the Republic of Bulgaria adopted a decision to take action to
close Case COMP/B1/AT.39849 - BEH Gas pursuant to Article 9 of Regulation (EC) No 1/2003 by entering into
commitments on the Bulgarian side and reaching an agreement with the European Commission. The second decision
of the National Assembly is justified by the development of case COMP/B1/AT.39816 between the EC and Gazprom,
where on 24 May 2018 the Commission announced that an agreement had been reached and it was terminated pursuant
to Art. 9 of Regulation (EC) No. 1/2003 without a financial penalty.
On 17 December 2018, the European Commission notified the adoption of Decision C(2018)8806 in Case AT.39849
BEH-Gas by which the European Commission imposed a fine of EUR 77,068,000 on Bulgarian Energy Holding EAD
(BEH), its gas supply subsidiary Bulgargaz EAD and its gas infrastructure subsidiary Bulgartransgaz EAD (the BEH
Group) for blocking competitors' access to key gas infrastructure in Bulgaria in breach of EU antitrust rules. The
decision was received in the offices of the three companies on 19 December 2018, which set the start of the appeal
period of the EC Decision (two months and ten days after notification of the Decision to the parties), and for payment
of the fine (three months after the notification of the Decision to the parties) set therein. An appeal against the decision
shall not delay payment of the fine.
On 18 March 2019, ING Bank NV issued two unsecured bank guarantees in favor of the EU with a total amount equal
to the amount of the fine of EUR 77,068,000, as follows:
- a bank guarantee in the amount of EUR 51,379 thousand, covering 2/3 of the total amount of the fine, securing
the liabilities of Bulgarian Energy Holding EAD and Bulgargaz EAD;
- bank guarantee in the amount of EUR 25,689 thousand, which guarantees the liability of Bulgartransgaz
EAD for the imposed sanction.
On 4 July 2019, the Bulgarian State, through the Ministry of Foreign Affairs, filed an application to intervene in the
case in support of BEH EAD and its gas subsidiaries.
On 26 August 2019, the European Commission presented before the General Court its Defense in response to the
complaint lodged by Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD.
Separate financial statement
31 December 2024
58
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Proceedings by the European Commission against Bulgarian Energy Holding EAD – Case
COMP/B1/АТ.39849 – BEH gas
The case concerns a possible violation of Article 102 TFEU in relation to alleged actions by BEH EAD and its
subsidiaries Bulgargaz EAD and Bulgartransgaz EAD aimed at:
• preventing their competitors from gaining access to key gas infrastructure (gas transmission network and natural
gas storage facility) in Bulgaria, explicitly or implicitly denying access to third parties or causing delays;
• preventing competitors from receiving access to a main gas import transmission network by reserving a
capacity, which remains unused.
The proceedings were instituted in 2013 with a view to adopting a decision under Chapter 3 (Articles 7 to 10) of
Regulation 1/2003.
On 23 March 2015, the EC issued a Statement of Objections. Bulgarian Energy Holding EAD and its gas subsidiaries
submitted their respective responses to the European Commission on 9 July 2015 (Bulgargaz EAD), 10 July 2015
(Bulgarian Energy Holding EAD) and 17 July 2015 (Bulgartransgaz EAD).
On 24 November 2017, a decision was made by the 44th National Assembly of the Republic of Bulgaria to take the
necessary action for the termination of Case COMP/B1/AT.39849 – BEH Gas, by which the National Assembly
supports the termination of the case under the procedure of Art. 7 of Regulation (EU) No. 1/2003 without admission
of the alleged infringements and without taking responsibility for them, fulfilling the obligations resulting from any
prohibitive decision, including any financial penalties. Currently, the European Commission has not made any official
decision to close the case, including regarding the possible amount of the financial sanction.
On 26 July 2018, the 44th National Assembly (NA) of the Republic of Bulgaria adopted a decision to take action to
close Case COMP/B1/AT.39849 - BEH Gas pursuant to Article 9 of Regulation (EC) No 1/2003 by entering into
commitments on the Bulgarian side and reaching an agreement with the European Commission. The second decision
of the National Assembly is justified by the development of case COMP/B1/AT.39816 between the EC and Gazprom,
where on 24 May 2018 the Commission announced that an agreement had been reached and it was terminated pursuant
to Art. 9 of Regulation (EC) No. 1/2003 without a financial penalty.
On 17 December 2018, the European Commission notified the adoption of Decision C(2018)8806 in Case AT.39849
BEH-Gas by which the European Commission imposed a fine of EUR 77,068,000 on Bulgarian Energy Holding EAD
(BEH), its gas supply subsidiary Bulgargaz EAD and its gas infrastructure subsidiary Bulgartransgaz EAD (the BEH
Group) for blocking competitors' access to key gas infrastructure in Bulgaria in breach of EU antitrust rules. The
decision was received in the offices of the three companies on 19 December 2018, which set the start of the appeal
period of the EC Decision (two months and ten days after notification of the Decision to the parties), and for payment
of the fine (three months after the notification of the Decision to the parties) set therein. An appeal against the decision
shall not delay payment of the fine.
On 18 March 2019, ING Bank NV issued two unsecured bank guarantees in favor of the EU with a total amount equal
to the amount of the fine of EUR 77,068,000, as follows:
- a bank guarantee in the amount of EUR 51,379 thousand, covering 2/3 of the total amount of the fine, securing
the liabilities of Bulgarian Energy Holding EAD and Bulgargaz EAD;
- bank guarantee in the amount of EUR 25,689 thousand, which guarantees the liability of Bulgartransgaz
EAD for the imposed sanction.
On 4 July 2019, the Bulgarian State, through the Ministry of Foreign Affairs, filed an application to intervene in the
case in support of BEH EAD and its gas subsidiaries.
On 26 August 2019, the European Commission presented before the General Court its Defense in response to the
complaint lodged by Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
59
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
On 29 November 2019, Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD filed an
Opposition against the European Commission Defense.
On 20 February 2020, the Republic of Bulgaria filed through the Ministry of Foreign Affairs, within the period
specified by the General Court of the European Union, the official position of the Republic of Bulgaria on Case Т -
136/19, submitted by the Ministry of Energy and the Ministry Foreign Affairs, whereby the State intervened in support
of Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD against the European Commission,
before the General Court of the European Union. The General Court examines additional documents and requested
information in order to clarify all the circumstances involved in the case. By letter of 14 March 2022, the Court
requested the European Commission to provide non-confidential versions of the documents listed by the Court.
On 29 September 2022, the court session ended with oral hearings under the BEH Gas case, within which the parties
summarized their positions and the court asked questions that were addressed by the parties.
On 25 October 2023, the court of first instance rendered a Decision in favor of Bulgarian Energy Holding EAD,
Bulgartransgaz EAD and Bulgargaz EAD, with which it completely annulled the fine imposed by the European
Commission on the three BEH Group companies in the amount of EUR 77,068,000.
On 11 January 2024, the European Commission filed an appeal against the decision of the court of first instance,
requesting the annulment of the Decision of the General Court in its entirety.
Based on the appeal, case C-14/24 R was brought before the Court of Justice of the European Union - European
Commission against Bulgarian Energy Holding EAD and others.
On 29 March 2024, BEH-Group filed a reply to the European Commission's complaint with the Court of Justice of
the European Union.
On 22 July 2024, the European Commission submitted a counter-answer to the Court of Justice of the European Union.
On 30 September, BEH-Group provided a response.
On 30 September 2024, Bulgarian Energy Holding EAD, Bulgartransgaz EAD and Bulgargaz EAD, and the State,
filed replies to the European Commission's complaint in Case C-14/24 before the Court of Justice of the European
Union.
On 5 November 2024, the Court of Justice of the EU notified the parties that the written procedure was closed.
The Bulgarian side has also submitted a justification for the Court to allow oral hearings as at first instance. Oral
hearings in the case are expected in the second quarter of 2025.
The Company has recognized a provision in relation to case COMP/B1/AT.39849 - BEH gas of BGN 53,715 thousand.
(31 December 2023: BGN 53,715 thousand).
Lease contracts
The lease liabilities of the Company are as follows:
31 December 2024 31 December 2023
Minimum
lease
installments
Discounting
Present
value of the
installments
Minimum
lease
installments
Discounting
Present
value of the
installments
thousand BGN thousand BGN thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Within one year 281 (17) 264 487 (57) 430
Between two and five
years 503 (29) 474 981 (78) 903
Over five years 144 (4) 140 206 (8) 198
Total minimum lease
installments under lease
agreements
928 (50) 878 1,674 (143) 1,531
Separate financial statement
31 December 2024
59
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
On 29 November 2019, Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD filed an
Opposition against the European Commission Defense.
On 20 February 2020, the Republic of Bulgaria filed through the Ministry of Foreign Affairs, within the period
specified by the General Court of the European Union, the official position of the Republic of Bulgaria on Case Т -
136/19, submitted by the Ministry of Energy and the Ministry Foreign Affairs, whereby the State intervened in support
of Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD against the European Commission,
before the General Court of the European Union. The General Court examines additional documents and requested
information in order to clarify all the circumstances involved in the case. By letter of 14 March 2022, the Court
requested the European Commission to provide non-confidential versions of the documents listed by the Court.
On 29 September 2022, the court session ended with oral hearings under the BEH Gas case, within which the parties
summarized their positions and the court asked questions that were addressed by the parties.
On 25 October 2023, the court of first instance rendered a Decision in favor of Bulgarian Energy Holding EAD,
Bulgartransgaz EAD and Bulgargaz EAD, with which it completely annulled the fine imposed by the European
Commission on the three BEH Group companies in the amount of EUR 77,068,000.
On 11 January 2024, the European Commission filed an appeal against the decision of the court of first instance,
requesting the annulment of the Decision of the General Court in its entirety.
Based on the appeal, case C-14/24 R was brought before the Court of Justice of the European Union - European
Commission against Bulgarian Energy Holding EAD and others.
On 29 March 2024, BEH-Group filed a reply to the European Commission's complaint with the Court of Justice of
the European Union.
On 22 July 2024, the European Commission submitted a counter-answer to the Court of Justice of the European Union.
On 30 September, BEH-Group provided a response.
On 30 September 2024, Bulgarian Energy Holding EAD, Bulgartransgaz EAD and Bulgargaz EAD, and the State,
filed replies to the European Commission's complaint in Case C-14/24 before the Court of Justice of the European
Union.
On 5 November 2024, the Court of Justice of the EU notified the parties that the written procedure was closed.
The Bulgarian side has also submitted a justification for the Court to allow oral hearings as at first instance. Oral
hearings in the case are expected in the second quarter of 2025.
The Company has recognized a provision in relation to case COMP/B1/AT.39849 - BEH gas of BGN 53,715 thousand.
(31 December 2023: BGN 53,715 thousand).
Lease contracts
The lease liabilities of the Company are as follows:
31 December 2024 31 December 2023
Minimum
lease
installments
Discounting
Present
value of the
installments
Minimum
lease
installments
Discounting
Present
value of the
installments
thousand BGN thousand BGN thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Within one year 281 (17) 264 487 (57) 430
Between two and five
years 503 (29) 474 981 (78) 903
Over five years 144 (4) 140 206 (8) 198
Total minimum lease
installments under lease
agreements
928 (50) 878 1,674 (143) 1,531
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
60
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The Company has entered into the following lease agreements:
Bulgarian Energy Holding EAD has rented parts of a real estate for administrative purposes for a period of five years
with an option for extension. The monthly installment under the rental contract is in the amount of BGN 5 thousand,
excl. VAT. To determine the present value of the lease liabilities, Bulgarian Energy Holding EAD has used a discount
rate of 2.45%, which is the interest rate received by the company when financing its activities in the last year and
corresponding to market levels. As of 31 December 2024, the current value of the liability is BGN 414 thousand.
The Company has leased 10 motor vehicles under lease agreements. The term of the contracts is from 2 to 4.5 years.
The calculated annual interest rates for vehicle leases range from 0.98% to 24.05%. As of 31 December 2024, the
current value of the liability is BGN 463 thousand.
The assets are used only by the Company and there are no sublease agreements in place.
Amounts, recognized in the profit or loss statement:
- Depreciation expense of BGN 455 thousand;
- The interest expenses amounting to BGN 41 thousand.
The total leasing cash flow in 2024 is as follows:
- Payments related to lease contracts – BGN 437 thousand.
Other
The latest tax inspections of the Company were carried out by the tax administration as follows:
• Corporate tax – until 31 December 2022;
• VAT – until 31 October 2022;
• Personal income tax – check for the month of November 2022;
• Social security insurance – until 31 December 2008.
The Company Management does not believe that there are any material risks as a result of the dynamic fiscal and
regulatory environment in Bulgaria that would require adjustments to the financial statements for the year ending 31
December 2024.
35. Financial Risk Management Objectives and Policy
The Company owns financial assets consisting of trade receivables, loans granted to subsidiaries, cash and short-term
deposits that arise directly from the activity.
The Company's financial liabilities include bond issue, bank loan, borrowings from related parties and trade payables.
The main purpose of the loans is to provide financing to the Company activity.
The main risks arising from the Company’s financial instruments are liquidity risk, currency risk and credit risk.
Current risks are identified, measured and monitored using various control mechanisms introduced to determine
adequate prices for the services offered by the Company, as well as to adequately assess the market circumstances of
the investments made by it and the forms of maintenance of the free liquidity, without allowing an unjustified
concentration of risk and others. The Company’s risk manage ment is currently conducted by the management and the
relevant structural units, depending on the type and specificity of the different kind of risk to which the Company is
exposed in its activities.
Separate financial statement
31 December 2024
60
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The Company has entered into the following lease agreements:
Bulgarian Energy Holding EAD has rented parts of a real estate for administrative purposes for a period of five years
with an option for extension. The monthly installment under the rental contract is in the amount of BGN 5 thousand,
excl. VAT. To determine the present value of the lease liabilities, Bulgarian Energy Holding EAD has used a discount
rate of 2.45%, which is the interest rate received by the company when financing its activities in the last year and
corresponding to market levels. As of 31 December 2024, the current value of the liability is BGN 414 thousand.
The Company has leased 10 motor vehicles under lease agreements. The term of the contracts is from 2 to 4.5 years.
The calculated annual interest rates for vehicle leases range from 0.98% to 24.05%. As of 31 December 2024, the
current value of the liability is BGN 463 thousand.
The assets are used only by the Company and there are no sublease agreements in place.
Amounts, recognized in the profit or loss statement:
- Depreciation expense of BGN 455 thousand;
- The interest expenses amounting to BGN 41 thousand.
The total leasing cash flow in 2024 is as follows:
- Payments related to lease contracts – BGN 437 thousand.
Other
The latest tax inspections of the Company were carried out by the tax administration as follows:
• Corporate tax – until 31 December 2022;
• VAT – until 31 October 2022;
• Personal income tax – check for the month of November 2022;
• Social security insurance – until 31 December 2008.
The Company Management does not believe that there are any material risks as a result of the dynamic fiscal and
regulatory environment in Bulgaria that would require adjustments to the financial statements for the year ending 31
December 2024.
35. Financial Risk Management Objectives and Policy
The Company owns financial assets consisting of trade receivables, loans granted to subsidiaries, cash and short-term
deposits that arise directly from the activity.
The Company's financial liabilities include bond issue, bank loan, borrowings from related parties and trade payables.
The main purpose of the loans is to provide financing to the Company activity.
The main risks arising from the Company’s financial instruments are liquidity risk, currency risk and credit risk.
Current risks are identified, measured and monitored using various control mechanisms introduced to determine
adequate prices for the services offered by the Company, as well as to adequately assess the market circumstances of
the investments made by it and the forms of maintenance of the free liquidity, without allowing an unjustified
concentration of risk and others. The Company’s risk manage ment is currently conducted by the management and the
relevant structural units, depending on the type and specificity of the different kind of risk to which the Company is
exposed in its activities.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
61
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
35.1 Categories of financial instruments
The carrying amounts of financial assets and liabilities of the Company may be presented in the following categories:
31 December 31 December
Financial assets 2024 2023
thousand BGN thousand BGN
Financial assets at fair value through other comprehensive income:
Stock traded shares 885 719
Debt instruments at amortized cost
Loans granted to related parties 1,856,369 1,968,005
Trade receivables from Associated parties 282,398 8,676
Trade and other receivables, incl. from Toplofikatsia Sofia EAD 12,140 61,290
2,150,907 2,037,971
Cash 313,041 220,012
2,464,833 2,258,702
31 December 31 December
Financial liabilities 2024 2023
thousand BGN thousand BGN
Financial liabilities, reported at amortized cost:
Bond issues 2,378,371 2,376,953
Loan from the European Investment Bank 215,380 215,380
Loans from related parties 41,584 27,269
Trade and other payables 4,846 3,871
2,640,181 2,623,473
Refer to note 4.8 for information on the accounting policy for each class of financial instruments. The methods used
to evaluate the fair values of financial assets and liabilities at fair value are disclosed in note 4.9. A description of the
policy and the purposes for the risk management of the Company regarding financial instruments is presented below.
35.2 Liquidity risk
Liquidity risk arises if the Company fails to meet its obligations when they become due. The Company applies an
approach that provides the necessary liquidity to meet the obligations under normal or stressful conditions, without
incurring unacceptable losses.
One of the objectives of the holding is to provide, if necessary, financial resources to the subsidiaries to maintain their
operating activities, as well as to implement strategic projects.
The Company finances the operating activities of the companies in the Group in two ways:
• Internal financing, within the economic group, by redistribution of the free cash resource. Bulgarian Energy
Holding EAD acts as an intermediary between the companies by coordinating the relations between them, or
accepting free-cash resources and granting such to the Company in need by monitoring the transactions at
market levels. Granting cash (loans) to companies is made under the same conditions under which the resources
have been received from the subsidiaries plus, a relevant spread.
Interest rates on cash loans and deposits are based on market levels. The interest rates on cash loans and foreign
currency deposits are linked to a rate that is the market rate for such transactions during the transaction period
(floating or fixed).
• External financing – in case of lack of funds in the economic group, Bulgarian Energy Holding EAD may take
actions for external financing. This is a preferred way to raise funds for investment projects.
Separate financial statement
31 December 2024
61
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
35.1 Categories of financial instruments
The carrying amounts of financial assets and liabilities of the Company may be presented in the following categories:
31 December 31 December
Financial assets 2024 2023
thousand BGN thousand BGN
Financial assets at fair value through other comprehensive income:
Stock traded shares 885 719
Debt instruments at amortized cost
Loans granted to related parties 1,856,369 1,968,005
Trade receivables from Associated parties 282,398 8,676
Trade and other receivables, incl. from Toplofikatsia Sofia EAD 12,140 61,290
2,150,907 2,037,971
Cash 313,041 220,012
2,464,833 2,258,702
31 December 31 December
Financial liabilities 2024 2023
thousand BGN thousand BGN
Financial liabilities, reported at amortized cost:
Bond issues 2,378,371 2,376,953
Loan from the European Investment Bank 215,380 215,380
Loans from related parties 41,584 27,269
Trade and other payables 4,846 3,871
2,640,181 2,623,473
Refer to note 4.8 for information on the accounting policy for each class of financial instruments. The methods used
to evaluate the fair values of financial assets and liabilities at fair value are disclosed in note 4.9. A description of the
policy and the purposes for the risk management of the Company regarding financial instruments is presented below.
35.2 Liquidity risk
Liquidity risk arises if the Company fails to meet its obligations when they become due. The Company applies an
approach that provides the necessary liquidity to meet the obligations under normal or stressful conditions, without
incurring unacceptable losses.
One of the objectives of the holding is to provide, if necessary, financial resources to the subsidiaries to maintain their
operating activities, as well as to implement strategic projects.
The Company finances the operating activities of the companies in the Group in two ways:
• Internal financing, within the economic group, by redistribution of the free cash resource. Bulgarian Energy
Holding EAD acts as an intermediary between the companies by coordinating the relations between them, or
accepting free-cash resources and granting such to the Company in need by monitoring the transactions at
market levels. Granting cash (loans) to companies is made under the same conditions under which the resources
have been received from the subsidiaries plus, a relevant spread.
Interest rates on cash loans and deposits are based on market levels. The interest rates on cash loans and foreign
currency deposits are linked to a rate that is the market rate for such transactions during the transaction period
(floating or fixed).
• External financing – in case of lack of funds in the economic group, Bulgarian Energy Holding EAD may take
actions for external financing. This is a preferred way to raise funds for investment projects.
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
62
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
As of 31 December 2024, the maturity structure of the Company's financial liabilities, based on agreed undiscounted
payments, is set out below:
As of 31 December
2024
Carrying
amount
Agreed
cash flows
6 months
or less
6-12
months
1-2
years 2-5 years over 5
years
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Bond issues 2,378,371 2,503,072 1,214,570 28,751 28,751 1,231,000 -
Loan from EIB 215,380 237,135 886 2,318 8,921 35,492 189,518
Loans from related
parties 41,584 41,738 30,595 5,571 5,572 - -
Trade and other
payables 4,846 4,896 1,911 2,308 255 273 149
2,640,181 2,786,841 1,247,962 38,948 43,499 1,266,765 189,667
As of 31 December
2023
Carrying
amount
Agreed
cash flows
6 months
or less
6-12
months
1-2
years 2-5 years over 5
years
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Bond issues 2,376,953 2,572,895 41,072 28,751 1,243,321 1,259,751 -
Loan from EIB 215,380 238,914 887 887 3,206 32,350 201,584
Loans from related
parties 27,269 27,858 5,572 5,572 11,143 5,572 -
Trade and other
payables 3,871 4,016 400 2,415 383 612 206
2,623,473 2,843,683 47,931 37,625 1,258,053 1,298,285 201,790
35.3 Interest rate risk
The Company is exposed to risks from changes in market interest rates primarily on financial assets and liabilities
with variable (floating) interest rate.
In the structure of the Company’s assets, interest -bearing assets are represented by cash, bank deposits and loans
granted, the majority of which have a fixed interest rate. The Company also has loans with a combined structure of
interest rates on loans, which contains two components – fixed and variable. The policy of the Company is to grant
cash at a fixed interest rate higher than that of the borrowed funds, including renegotiation of interest rates on existing
loans. This minimizes the likelihood of a change in the unfavorable direction of cash flows.
The borrowings of the Company are in the form of long-term and short-term loans and have a fixed interest rate.
The following table illustrates the sensitivity of the annual net financial result after tax and of equity to a possible
change in interest rates on loans with a floating rate based on BIR in Bulgaria, amounting to +/- 0.01 % (for 2023 +/-
0.01%). These changes are determined to be likely based on observations of current market conditions. The
calculations are based on the change in the average market interest rate and the financial instruments held by the
Company at the end of the reporting period, which are sensitive to changes in the interest rate. All other parameters
are assumed to be constant. There is no effect on other components of the Company’s equity.
Effect on net financial result after taxes
Interest rate increase Interest rate decrease
thousand BGN thousand BGN
2024
Receivables from Toplofikatsia Sofia EAD,
bound by the BIR 13 (13)
2023
Receivables from Toplofikatsia Sofia EAD,
bound by the BIR 6 (6)
Separate financial statement
31 December 2024
62
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
As of 31 December 2024, the maturity structure of the Company's financial liabilities, based on agreed undiscounted
payments, is set out below:
As of 31 December
2024
Carrying
amount
Agreed
cash flows
6 months
or less
6-12
months
1-2
years 2-5 years over 5
years
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Bond issues 2,378,371 2,503,072 1,214,570 28,751 28,751 1,231,000 -
Loan from EIB 215,380 237,135 886 2,318 8,921 35,492 189,518
Loans from related
parties 41,584 41,738 30,595 5,571 5,572 - -
Trade and other
payables 4,846 4,896 1,911 2,308 255 273 149
2,640,181 2,786,841 1,247,962 38,948 43,499 1,266,765 189,667
As of 31 December
2023
Carrying
amount
Agreed
cash flows
6 months
or less
6-12
months
1-2
years 2-5 years over 5
years
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
thousand
BGN
Bond issues 2,376,953 2,572,895 41,072 28,751 1,243,321 1,259,751 -
Loan from EIB 215,380 238,914 887 887 3,206 32,350 201,584
Loans from related
parties 27,269 27,858 5,572 5,572 11,143 5,572 -
Trade and other
payables 3,871 4,016 400 2,415 383 612 206
2,623,473 2,843,683 47,931 37,625 1,258,053 1,298,285 201,790
35.3 Interest rate risk
The Company is exposed to risks from changes in market interest rates primarily on financial assets and liabilities
with variable (floating) interest rate.
In the structure of the Company’s assets, interest -bearing assets are represented by cash, bank deposits and loans
granted, the majority of which have a fixed interest rate. The Company also has loans with a combined structure of
interest rates on loans, which contains two components – fixed and variable. The policy of the Company is to grant
cash at a fixed interest rate higher than that of the borrowed funds, including renegotiation of interest rates on existing
loans. This minimizes the likelihood of a change in the unfavorable direction of cash flows.
The borrowings of the Company are in the form of long-term and short-term loans and have a fixed interest rate.
The following table illustrates the sensitivity of the annual net financial result after tax and of equity to a possible
change in interest rates on loans with a floating rate based on BIR in Bulgaria, amounting to +/- 0.01 % (for 2023 +/-
0.01%). These changes are determined to be likely based on observations of current market conditions. The
calculations are based on the change in the average market interest rate and the financial instruments held by the
Company at the end of the reporting period, which are sensitive to changes in the interest rate. All other parameters
are assumed to be constant. There is no effect on other components of the Company’s equity.
Effect on net financial result after taxes
Interest rate increase Interest rate decrease
thousand BGN thousand BGN
2024
Receivables from Toplofikatsia Sofia EAD,
bound by the BIR 13 (13)
2023
Receivables from Toplofikatsia Sofia EAD,
bound by the BIR 6 (6)
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
63
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
35.4 Currency risk
As of 31 December 2024, the Company has liabilities in currencies, other than BGN. During the year, the Company
also performed transactions in EUR in connection with absorbed bond issues, purchase of greenhouse gas emission
allowances, technical and other services received. The currency risk for these transactions related to possible
fluctuations in the foreign exchange rate is minimal due to the existence of a fixed exchange rate of the EUR to the
BGN, set by BNB. Bulgarian Energy Holding EAD also owns financial assets at fair value through other
comprehensive income, including stock exchange traded shares of a Romanian company, but due to the amount of the
capital investment, the management believes that currency risk is insignificant.
35.5 Credit risk
In performing its activities, the Company is exposed to credit risk, which is related to the risk that some of its
counterparties will not be able to fully meet their obligations in the usual timeframe. The receivables of the Company
are presented in the statement of financial position in net amount, after deduction of impairment charges. Such
impairments are made for those receivables where and when there were events identifying losses from uncollectibility
based on previous experience.
The Company has a significant concentration of credit risk associated with receivables from related companies and
commercial counterparties under cession contracts. The Company undertakes the following precautionary measures:
• under the loan contracts – lien of machinery and equipment, mortgages on property and others;
• for trade and other receivables that are overdue and were not secured upon their origination, deferred payment
arrangements are concluded and a collateral of not less than the initially recognized amount of the claim is
negotiated;
• for the remaining contracts, which are not secured in advance, the following usual actions are taken in cases
of default in due payment - set-off of liabilities to the Company against overdue receivables from the same,
and if the amount of the liabilities does not cover the receivable, other out-of-court settlement options are
sought.
The Company is currently monitoring and analyzing the servicing of the receivables, the reasons for the defaults and
the changes in the financial capacity of debtor companies, and the status and quality of the collaterals received is
controlled.
Exposure to credit risk
The Company's maximum credit exposure in respect of recognised financial assets is their respective carrying amount
in the standalone statement of financial position at 31 December 2024:
31 December 31 December
Financial assets 2024 2023
thousand BGN thousand BGN
Financial assets at fair value through other comprehensive income 885 719
Debt instruments at amortized cost, that are not purchased or
originally created assets with credit impairment 1,396,667 1,273,886
Debt instruments at amortized cost that are purchased or originally
created assets with credit impairment 754,240 764,085
Cash 313,041 220,012
2,464,833 2,258,702
The Company has a significant concentration of credit risk due to receivables from loans granted to related entities
and receivables from Toplofikatsia Sofia EAD under long-term cession contracts.
The following table sets forth information regarding the credit risk exposure on the Company's related party and non -
related party commercial loans as of 31 December 2024 and 31 December 2023, respectively:
Separate financial statement
31 December 2024
63
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
35.4 Currency risk
As of 31 December 2024, the Company has liabilities in currencies, other than BGN. During the year, the Company
also performed transactions in EUR in connection with absorbed bond issues, purchase of greenhouse gas emission
allowances, technical and other services received. The currency risk for these transactions related to possible
fluctuations in the foreign exchange rate is minimal due to the existence of a fixed exchange rate of the EUR to the
BGN, set by BNB. Bulgarian Energy Holding EAD also owns financial assets at fair value through other
comprehensive income, including stock exchange traded shares of a Romanian company, but due to the amount of the
capital investment, the management believes that currency risk is insignificant.
35.5 Credit risk
In performing its activities, the Company is exposed to credit risk, which is related to the risk that some of its
counterparties will not be able to fully meet their obligations in the usual timeframe. The receivables of the Company
are presented in the statement of financial position in net amount, after deduction of impairment charges. Such
impairments are made for those receivables where and when there were events identifying losses from uncollectibility
based on previous experience.
The Company has a significant concentration of credit risk associated with receivables from related companies and
commercial counterparties under cession contracts. The Company undertakes the following precautionary measures:
• under the loan contracts – lien of machinery and equipment, mortgages on property and others;
• for trade and other receivables that are overdue and were not secured upon their origination, deferred payment
arrangements are concluded and a collateral of not less than the initially recognized amount of the claim is
negotiated;
• for the remaining contracts, which are not secured in advance, the following usual actions are taken in cases
of default in due payment - set-off of liabilities to the Company against overdue receivables from the same,
and if the amount of the liabilities does not cover the receivable, other out-of-court settlement options are
sought.
The Company is currently monitoring and analyzing the servicing of the receivables, the reasons for the defaults and
the changes in the financial capacity of debtor companies, and the status and quality of the collaterals received is
controlled.
Exposure to credit risk
The Company's maximum credit exposure in respect of recognised financial assets is their respective carrying amount
in the standalone statement of financial position at 31 December 2024:
31 December 31 December
Financial assets 2024 2023
thousand BGN thousand BGN
Financial assets at fair value through other comprehensive income 885 719
Debt instruments at amortized cost, that are not purchased or
originally created assets with credit impairment 1,396,667 1,273,886
Debt instruments at amortized cost that are purchased or originally
created assets with credit impairment 754,240 764,085
Cash 313,041 220,012
2,464,833 2,258,702
The Company has a significant concentration of credit risk due to receivables from loans granted to related entities
and receivables from Toplofikatsia Sofia EAD under long-term cession contracts.
The following table sets forth information regarding the credit risk exposure on the Company's related party and non -
related party commercial loans as of 31 December 2024 and 31 December 2023, respectively:
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
64
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2024
Gross exposure to
credit risk
Impairment of
expected credit loss and
corrective interest
Net exposure Impairment
rate for credit
losses
thousand BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,742,569 (624,329) 1,118,240 35.83%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
412,185 (402,191) 9,994 97.58%
31 December 2024 Nominal
exposure to
credit risk
Impairment
of expected
credit loss
and
corrective
interest
Fair value
adjustment
and discount
Net exposure Rate of fair
value
adjustment,
discount and
impairment
for expected
credit losses
thousand BGN thousand
BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,158,957 - (420,828) 738,129 36.31%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
357,738 (304,372) (56,366) - 100.00%
31 December 2023
Gross exposure to
credit risk
Impairment of
expected credit loss and
corrective interest
Net exposure Impairment
rate for credit
losses
thousand BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,763,998 (560,077) 1,203,921 31.75%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
460,836 (399,562) 61,274 86.70%
31 December 2023 Nominal
exposure to
credit risk
Impairment
of expected
credit loss
and
corrective
interest
Adjustment to
fair value and
discount
Net exposure Rate of fair
value
adjustment,
discount, and
impairment
for expected
credit losses
thousand BGN thousand
BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,287,656 - (523,572) 764,084 40.66%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
336,803 (256,191) (80,612) - 100.00%
Separate financial statement
31 December 2024
64
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31 December 2024
Gross exposure to
credit risk
Impairment of
expected credit loss and
corrective interest
Net exposure Impairment
rate for credit
losses
thousand BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,742,569 (624,329) 1,118,240 35.83%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
412,185 (402,191) 9,994 97.58%
31 December 2024 Nominal
exposure to
credit risk
Impairment
of expected
credit loss
and
corrective
interest
Fair value
adjustment
and discount
Net exposure Rate of fair
value
adjustment,
discount and
impairment
for expected
credit losses
thousand BGN thousand
BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,158,957 - (420,828) 738,129 36.31%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
357,738 (304,372) (56,366) - 100.00%
31 December 2023
Gross exposure to
credit risk
Impairment of
expected credit loss and
corrective interest
Net exposure Impairment
rate for credit
losses
thousand BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,763,998 (560,077) 1,203,921 31.75%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
460,836 (399,562) 61,274 86.70%
31 December 2023 Nominal
exposure to
credit risk
Impairment
of expected
credit loss
and
corrective
interest
Adjustment to
fair value and
discount
Net exposure Rate of fair
value
adjustment,
discount, and
impairment
for expected
credit losses
thousand BGN thousand
BGN thousand BGN thousand BGN %
Loans granted to related parties that were
assets originally created with credit
impairment
1,287,656 - (523,572) 764,084 40.66%
Receivables from Toplofikatsia Sofia EAD,
that are not assets originally created with
credit impairment
336,803 (256,191) (80,612) - 100.00%
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
65
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
As of 31 December 2024, the Company has a significant concentration of trade receivables and loans to the following
counterparties:
As of 31 December 2023
Internal categorization
of the credit risk
Expected credit
losses (IFRS 9)
Relative share
of the
receivable to
the carrying
amount of all
receivables, %
Natsionalna Electricheska Kompania EAD Phase 3
For the whole
term 30%
Natsionalna Electricheska Kompania EAD
Assets originally
created with credit
impairment
For the whole
term 34%
Bulgargaz EAD Phase 3
For the whole
term 3%
Toplofikatsia Sofia EAD Phase 3
For the whole
term 0%
Toplofikatsia Sofia EAD
Assets originally
created with credit
impairment
For the whole
term 0%
The high concentration of trade receivables and loans to Natsionalna Elektricheska Kompania EAD is due to the
support provided by BEH EAD in its capacity as a parent company and financial holding engaged in stabilizing the
financial position of the two companies, in view of its key position in the security and stability of the Bulgarian power
system. Given the importance and strategic significance of the activities performed by Natsionalna Elektricheska
Kompania EAD, Bulgarian Energy Holding will continue its actions aimed at stabilizing its financial condition.
As of 31 December 2023
Internal categorization
of the credit risk
Expected credit
losses (IFRS 9)
Relative share
of the
receivable to
the carrying
amount of all
receivables, %
Natsionalna Electricheska Kompania EAD Phase 3
For the whole
term 36%
Natsionalna Electricheska Kompania EAD
Assets originally
created with credit
impairment
For the whole
term 37%
Bulgargaz EAD Phase 3
For the whole
term 7%
Toplofikatsia Sofia EAD Phase 3
For the whole
term 3%
Toplofikatsia Sofia EAD
Assets originally
created with credit
impairment
For the whole
term 0%
Separate financial statement
31 December 2024
65
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
As of 31 December 2024, the Company has a significant concentration of trade receivables and loans to the following
counterparties:
As of 31 December 2023
Internal categorization
of the credit risk
Expected credit
losses (IFRS 9)
Relative share
of the
receivable to
the carrying
amount of all
receivables, %
Natsionalna Electricheska Kompania EAD Phase 3
For the whole
term 30%
Natsionalna Electricheska Kompania EAD
Assets originally
created with credit
impairment
For the whole
term 34%
Bulgargaz EAD Phase 3
For the whole
term 3%
Toplofikatsia Sofia EAD Phase 3
For the whole
term 0%
Toplofikatsia Sofia EAD
Assets originally
created with credit
impairment
For the whole
term 0%
The high concentration of trade receivables and loans to Natsionalna Elektricheska Kompania EAD is due to the
support provided by BEH EAD in its capacity as a parent company and financial holding engaged in stabilizing the
financial position of the two companies, in view of its key position in the security and stability of the Bulgarian power
system. Given the importance and strategic significance of the activities performed by Natsionalna Elektricheska
Kompania EAD, Bulgarian Energy Holding will continue its actions aimed at stabilizing its financial condition.
As of 31 December 2023
Internal categorization
of the credit risk
Expected credit
losses (IFRS 9)
Relative share
of the
receivable to
the carrying
amount of all
receivables, %
Natsionalna Electricheska Kompania EAD Phase 3
For the whole
term 36%
Natsionalna Electricheska Kompania EAD
Assets originally
created with credit
impairment
For the whole
term 37%
Bulgargaz EAD Phase 3
For the whole
term 7%
Toplofikatsia Sofia EAD Phase 3
For the whole
term 3%
Toplofikatsia Sofia EAD
Assets originally
created with credit
impairment
For the whole
term 0%
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
66
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Age analysis of the debt instruments at amortized cost as of 31 December 2023 is presented below:
31 December 2024 Not due From 0-180
days
From 180-360
days Over 360 days Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross value of related party loans
granted 2,901,525 - - - 2,901,525
Fair value adjustment and discount (421,340) - - - (421,340)
Loss from modification (17) - - - (17)
Impairment (623,799) - - - (623,799)
1,856,369 1,856,369
Gross value of related party trade
receivables 303,871 303,871
Impairment (21,473) - - - (21,473)
282,398 282,398
Gross value of trade and other
receivables 13,058 - - - 13,058
Impairment (10,912) - - - (10,912)
2,146 2,146
Gross value of receivables from
Toplofikatsia Sofia EAD 635,220 69,524 30,884 34,294 769,922
Adjustments for impairments and
modifications (625,226) (69,524) (30,884) (34,294) (759,928)
9,994 - - - 9,994
-
Net value of loans and receivables 2,150,907 - - - 2,150,907
31 December
2023 Not due From 0-180
days
From 180-360
days Over 360 days Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross value of related party loans
granted 3,051,654 - - - 3,051,654
Fair value adjustment and discount (523,572) - - - (523,572)
Loss from modification (26) - - - (26)
Impairment (560,051) - - - (560,051)
1,968,005 1,968,005
Gross value of related party trade
receivables 29,999 29,999
Impairment (21,323) - - - (21,323)
8,676 8,676
Gross value of trade and other
receivables 10,972 - - - 10,972
Impairment (10,956) - - - (10,956)
16 16
Gross value of receivables from
Toplofikatsia Sofia EAD 724,295 59,278 14,066 - 797,639
Adjustments for impairments and
modifications (663,021) (59,278) (14,066) - (736,365)
61,274 - - - 61,274
Net value of loans and receivables 2,037,971 - - - 2,037,971
Separate financial statement
31 December 2024
66
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Age analysis of the debt instruments at amortized cost as of 31 December 2023 is presented below:
31 December 2024 Not due From 0-180
days
From 180-360
days Over 360 days Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross value of related party loans
granted 2,901,525 - - - 2,901,525
Fair value adjustment and discount (421,340) - - - (421,340)
Loss from modification (17) - - - (17)
Impairment (623,799) - - - (623,799)
1,856,369 1,856,369
Gross value of related party trade
receivables 303,871 303,871
Impairment (21,473) - - - (21,473)
282,398 282,398
Gross value of trade and other
receivables 13,058 - - - 13,058
Impairment (10,912) - - - (10,912)
2,146 2,146
Gross value of receivables from
Toplofikatsia Sofia EAD 635,220 69,524 30,884 34,294 769,922
Adjustments for impairments and
modifications (625,226) (69,524) (30,884) (34,294) (759,928)
9,994 - - - 9,994
-
Net value of loans and receivables 2,150,907 - - - 2,150,907
31 December
2023 Not due From 0-180
days
From 180-360
days Over 360 days Total
thousand BGN thousand BGN thousand BGN thousand BGN thousand BGN
Gross value of related party loans
granted 3,051,654 - - - 3,051,654
Fair value adjustment and discount (523,572) - - - (523,572)
Loss from modification (26) - - - (26)
Impairment (560,051) - - - (560,051)
1,968,005 1,968,005
Gross value of related party trade
receivables 29,999 29,999
Impairment (21,323) - - - (21,323)
8,676 8,676
Gross value of trade and other
receivables 10,972 - - - 10,972
Impairment (10,956) - - - (10,956)
16 16
Gross value of receivables from
Toplofikatsia Sofia EAD 724,295 59,278 14,066 - 797,639
Adjustments for impairments and
modifications (663,021) (59,278) (14,066) - (736,365)
61,274 - - - 61,274
Net value of loans and receivables 2,037,971 - - - 2,037,971
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
67
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The change in the allowance for expected credit losses on loans and receivables, net of expected credit losses on cash,
during the year was:
31 December
2024 г.
31 December
2023
thousand BGN thousand BGN
Impairment as of 1 January 1,257,734 1,696,046
Reintegration of impairments (note 0) (26,929) (663,461)
Impairment charge (note 0) 89,530 225,149
Impairment as at December 31 1,320,335 1,257,734
36.Fair value measurement
The Company classifies assets and liabilities at fair value into three levels based on the significance of the inputs used
in determining the fair value of financial assets and liabilities. The fair value hierarchy includes the following levels:
- Level 1: market prices (unadjusted) on active markets for identical assets or liabilities;
- Level 2: input other than market prices included in Level 1 that can be monitored in respect of an asset or liability
either directly (i.e. as prices) or indirectly (i.e. derived from prices); and
- Level 3: input for an asset or liability that is not based on observable market data.
An asset or liability is classified to the lowest level of significant input used to determine its fair value.
36.1 Fair value measurement of financial instruments
Financial assets measured at fair value in the stand-alone statement of financial position are grouped into the following
categories according to the fair value hierarchy:
Level 1
31 December
2024
31 December
2023
thousand BGN thousand BGN
Financial assets at fair value
through other comprehensive income
Stock traded shares 883 717
The measurement methods and techniques used in determining fair value have not changed compared to the previous
reporting period. The Company owns 96,656 shares of Transgaz S.A., Romania, which are traded on the Romanian
Stock Exchange. The investment is classified as a financial asset at fair value through other comprehensive income,
and is presented in BGN. The fair values as of 31 December 2024 and 31 December 2023 were determined based on
quoted prices in an active market.
Level 3
31 December
2024
31 December
2023
thousand BGN thousand BGN
Financial assets at fair value
through other comprehensive income
Shares that are not traded on an exchange and are not based on
observed market prices 2 2
Separate financial statement
31 December 2024
67
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The change in the allowance for expected credit losses on loans and receivables, net of expected credit losses on cash,
during the year was:
31 December
2024 г.
31 December
2023
thousand BGN thousand BGN
Impairment as of 1 January 1,257,734 1,696,046
Reintegration of impairments (note 0) (26,929) (663,461)
Impairment charge (note 0) 89,530 225,149
Impairment as at December 31 1,320,335 1,257,734
36.Fair value measurement
The Company classifies assets and liabilities at fair value into three levels based on the significance of the inputs used
in determining the fair value of financial assets and liabilities. The fair value hierarchy includes the following levels:
- Level 1: market prices (unadjusted) on active markets for identical assets or liabilities;
- Level 2: input other than market prices included in Level 1 that can be monitored in respect of an asset or liability
either directly (i.e. as prices) or indirectly (i.e. derived from prices); and
- Level 3: input for an asset or liability that is not based on observable market data.
An asset or liability is classified to the lowest level of significant input used to determine its fair value.
36.1 Fair value measurement of financial instruments
Financial assets measured at fair value in the stand-alone statement of financial position are grouped into the following
categories according to the fair value hierarchy:
Level 1
31 December
2024
31 December
2023
thousand BGN thousand BGN
Financial assets at fair value
through other comprehensive income
Stock traded shares 883 717
The measurement methods and techniques used in determining fair value have not changed compared to the previous
reporting period. The Company owns 96,656 shares of Transgaz S.A., Romania, which are traded on the Romanian
Stock Exchange. The investment is classified as a financial asset at fair value through other comprehensive income,
and is presented in BGN. The fair values as of 31 December 2024 and 31 December 2023 were determined based on
quoted prices in an active market.
Level 3
31 December
2024
31 December
2023
thousand BGN thousand BGN
Financial assets at fair value
through other comprehensive income
Shares that are not traded on an exchange and are not based on
observed market prices 2 2
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
68
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The Company holds 10,000 registered shares in Balkangaz 2000 AD, Botevgrad, Botevgrad, with a nominal value of
BGN 1 (one) per share. The Company has a registered and paid-in capital of BGN 903 thousand. Bulgarian Energy
Holding EAD (previously, Bulgargaz EAD) is a shareholder since the incorporation of the Company in 2000. The
investment of Bulgarian Energy Holding EAD in Balkangaz 2000 AD was impaired and derecognized from the
financial statements prepared prior to 2007 due to the Company’s deteriorated financial position.
As of 31 December 2023 and 31 December 2022, the investment in the shares of Balkangaz 2000 AD is presented in
the financial statement according to IFRS 13 by using level 3 of the hierarchy of the fair values.
36.2 Fair value measurement of non-financial instruments
The following table presents the levels in the hierarchy of non-financial assets as of 31 December, measured
periodically at fair value:
31 December
2024
31 December
2023
Level 3 Level 3
thousand
BGN
thousand
BGN
Property, plant and equipment:
- land 4,224 3,174
- built-up properties 3,865 3,724
8,089 6,898
The fair value of the Company’s real property was determined based on a report of independent licensed appraisers
(note 19) as of 31 December 2024.
Land and built-up properties (Level 3)
Land and built-up properties have been valued by applying two methods: (1) the comparative market analogue method,
adjusting for derived comparable market prices and (2) the income method. The valuation of real property does not
reflect the main factors affecting the value:
➢ General value relations in the real estate market, such as: the general economic situation, market prices and
demand in the areas;
➢ Qualities and actual characteristics of the property: location and transport accessibility of the land, degree of
development and construction of the infrastructure.
As of 31 December 2024, the fair value of land and buildings is BGN 8,089 thousand.
37.Capital management policies and procedures
The policy of the Board of Directors is to maintain a strong capital base so as to maintain the trust of clients, creditors
and the market as a whole and to be able to provide conditions for business development in the future. The aim of the
management is to provide balance between higher return that may be possible with higher levels of indebtedness, and
its benefits from a strong capital position. The Company’s objective is to achieve a return on equity of more than 5%.
As of 31 December 2024, the return on equity is 14.82% (31 December 2023: 26.19%). There were no changes in the
Company's capital management during the year.
38.Events after the reporting period
There were no adjusting events or other significant non-adjusting events between the date of the separate financial
statements and the date of approval for issue, except for the following non-adjusting events:
Repayment of liabilities of Bulgarian Energy Holding EAD under a loan received from NPP Kozloduy EAD
On 20 January 2025, Bulgarian Energy Holding EAD's obligation in the amount of BGN 25,000 thousand under the
loan agreement of 18 October 2024 with NPP Kozloduy EAD was repaid.
Change in the management of Bulgarian Energy Holding EAD
By a protocol decision of 7 February 2025 of the Minister of Energy Galina Tsvetanova Todorova was dismissed as
a member of the Board of Directors of Bulgarian Energy Holding EAD and Diyan Atanasov Ivanov was elected in
Separate financial statement
31 December 2024
68
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
The Company holds 10,000 registered shares in Balkangaz 2000 AD, Botevgrad, Botevgrad, with a nominal value of
BGN 1 (one) per share. The Company has a registered and paid-in capital of BGN 903 thousand. Bulgarian Energy
Holding EAD (previously, Bulgargaz EAD) is a shareholder since the incorporation of the Company in 2000. The
investment of Bulgarian Energy Holding EAD in Balkangaz 2000 AD was impaired and derecognized from the
financial statements prepared prior to 2007 due to the Company’s deteriorated financial position.
As of 31 December 2023 and 31 December 2022, the investment in the shares of Balkangaz 2000 AD is presented in
the financial statement according to IFRS 13 by using level 3 of the hierarchy of the fair values.
36.2 Fair value measurement of non-financial instruments
The following table presents the levels in the hierarchy of non-financial assets as of 31 December, measured
periodically at fair value:
31 December
2024
31 December
2023
Level 3 Level 3
thousand
BGN
thousand
BGN
Property, plant and equipment:
- land 4,224 3,174
- built-up properties 3,865 3,724
8,089 6,898
The fair value of the Company’s real property was determined based on a report of independent licensed appraisers
(note 19) as of 31 December 2024.
Land and built-up properties (Level 3)
Land and built-up properties have been valued by applying two methods: (1) the comparative market analogue method,
adjusting for derived comparable market prices and (2) the income method. The valuation of real property does not
reflect the main factors affecting the value:
➢ General value relations in the real estate market, such as: the general economic situation, market prices and
demand in the areas;
➢ Qualities and actual characteristics of the property: location and transport accessibility of the land, degree of
development and construction of the infrastructure.
As of 31 December 2024, the fair value of land and buildings is BGN 8,089 thousand.
37.Capital management policies and procedures
The policy of the Board of Directors is to maintain a strong capital base so as to maintain the trust of clients, creditors
and the market as a whole and to be able to provide conditions for business development in the future. The aim of the
management is to provide balance between higher return that may be possible with higher levels of indebtedness, and
its benefits from a strong capital position. The Company’s objective is to achieve a return on equity of more than 5%.
As of 31 December 2024, the return on equity is 14.82% (31 December 2023: 26.19%). There were no changes in the
Company's capital management during the year.
38.Events after the reporting period
There were no adjusting events or other significant non-adjusting events between the date of the separate financial
statements and the date of approval for issue, except for the following non-adjusting events:
Repayment of liabilities of Bulgarian Energy Holding EAD under a loan received from NPP Kozloduy EAD
On 20 January 2025, Bulgarian Energy Holding EAD's obligation in the amount of BGN 25,000 thousand under the
loan agreement of 18 October 2024 with NPP Kozloduy EAD was repaid.
Change in the management of Bulgarian Energy Holding EAD
By a protocol decision of 7 February 2025 of the Minister of Energy Galina Tsvetanova Todorova was dismissed as
a member of the Board of Directors of Bulgarian Energy Holding EAD and Diyan Atanasov Ivanov was elected in
Bulgarian Energy Holding EAD
Separate financial statement
31 December 2024
69
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
her place until a new tender procedure is held. The change was entered in the Commercial Register and the Register
of Non-Profit Legal Entities on 13 February 2025.
Credit rating of Bulgarian Energy Holding EAD
On 17 March 2025, Fitch Ratings revised the outlook on Bulgarian Energy Holding EAD's long-term rating (BB+) to
stable from positive and affirmed the rating on its unsubordinated and unsecured debt at BB+. The outlook revision
reflects the expected increase in leverage and high capital expenditure associated with the construction of the new
nuclear units.
Conclusion of Annex to Loan Agreement with Bulgartransgaz EAD
On 31 March 2025, Annex № 2 was concluded with Bulgartransgaz EAD to amend the terms of the loan agreement
dated 17 February 2023 in the amount of BGN 87,527 thousand, in connection with the financing provided by BEH
EAD for the implementation of the project “Expansion of the capacity of the Chiren underground gas storage facility”,
with a repayment term of 31 March 2030. Until 31 December 2026, Bulgartransgaz EAD shall have the right to
repeatedly draw down and repay (revolve), in whole or in part, amounts from the loan, after which date the parties
shall sign a repayment plan for the remaining principal obligation.
On 31 March 2025, under the terms of the annex, an amount of BGN 87,527 thousand was transferred by the subsidiary
to Bulgarian Energy Holding EAD.
Extension of the loan agreement with Minproekt EAD
On 24 April 2025, an additional agreement was signed to extend the term of the loan agreement between Bulgarian
Energy Holding EAD and Minproekt EAD until 12 February 2027, approved by the Protocol decision of the Board of
Directors of Bulgarian Energy Holding EAD of 6 February 2025 and Protocol of the Minister of Energy of 23 April
2025.
Early partial repayment of Bulgartransgaz EAD's dividend obligation
On 25 April 2025, Annex No. 1 was concluded with Bulgartransgaz EAD to the Agreement of 9 December 2024 with
BEH EAD for the rescheduling of Bulgartransgaz EAD's obligations in the amount of BGN 257,251 thousand arising
from the dividends due by the company for 2021 and 2022. The annex formalizes the possibility of Bulgartransgaz
EAD to make an early partial repayment of its obligation.
Decisions on the establishment and payment to the state of profit deductions from state-owned enterprises and
commercial companies with state participation in capital
The Council of Ministers (CoM), by Order № 1 of 2 May 2025, has determined that state -owned enterprises and
commercial companies with state participation in the capital, with the exception of hospitals, mental health centers
and companies in the water supply and sewerage sector, shall distribute a dividend for the financial year 2024, subject
to the requirements of Article 247a of the Commercial Act, after deduction of the deductions for the Reserve Fund,
where the Reserve Fund is not replenished, in accordance with Article 101 of the State Budget Act of the Republic of
Bulgaria for 2025 - 100 percent.
Pursuant to the Order, Bulgarian Energy Holding EAD shall distribute and pay a 6 -month (interim) dividend based
on the adopted 6-month financial statements as of 30 June 2025 in the amount of 100 percent of the reported profit,
subject to the relevant application of Article 247a of the Commercial Law.
Separate financial statement
31 December 2024
69
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
her place until a new tender procedure is held. The change was entered in the Commercial Register and the Register
of Non-Profit Legal Entities on 13 February 2025.
Credit rating of Bulgarian Energy Holding EAD
On 17 March 2025, Fitch Ratings revised the outlook on Bulgarian Energy Holding EAD's long-term rating (BB+) to
stable from positive and affirmed the rating on its unsubordinated and unsecured debt at BB+. The outlook revision
reflects the expected increase in leverage and high capital expenditure associated with the construction of the new
nuclear units.
Conclusion of Annex to Loan Agreement with Bulgartransgaz EAD
On 31 March 2025, Annex № 2 was concluded with Bulgartransgaz EAD to amend the terms of the loan agreement
dated 17 February 2023 in the amount of BGN 87,527 thousand, in connection with the financing provided by BEH
EAD for the implementation of the project “Expansion of the capacity of the Chiren underground gas storage facility”,
with a repayment term of 31 March 2030. Until 31 December 2026, Bulgartransgaz EAD shall have the right to
repeatedly draw down and repay (revolve), in whole or in part, amounts from the loan, after which date the parties
shall sign a repayment plan for the remaining principal obligation.
On 31 March 2025, under the terms of the annex, an amount of BGN 87,527 thousand was transferred by the subsidiary
to Bulgarian Energy Holding EAD.
Extension of the loan agreement with Minproekt EAD
On 24 April 2025, an additional agreement was signed to extend the term of the loan agreement between Bulgarian
Energy Holding EAD and Minproekt EAD until 12 February 2027, approved by the Protocol decision of the Board of
Directors of Bulgarian Energy Holding EAD of 6 February 2025 and Protocol of the Minister of Energy of 23 April
2025.
Early partial repayment of Bulgartransgaz EAD's dividend obligation
On 25 April 2025, Annex No. 1 was concluded with Bulgartransgaz EAD to the Agreement of 9 December 2024 with
BEH EAD for the rescheduling of Bulgartransgaz EAD's obligations in the amount of BGN 257,251 thousand arising
from the dividends due by the company for 2021 and 2022. The annex formalizes the possibility of Bulgartransgaz
EAD to make an early partial repayment of its obligation.
Decisions on the establishment and payment to the state of profit deductions from state-owned enterprises and
commercial companies with state participation in capital
The Council of Ministers (CoM), by Order № 1 of 2 May 2025, has determined that state -owned enterprises and
commercial companies with state participation in the capital, with the exception of hospitals, mental health centers
and companies in the water supply and sewerage sector, shall distribute a dividend for the financial year 2024, subject
to the requirements of Article 247a of the Commercial Act, after deduction of the deductions for the Reserve Fund,
where the Reserve Fund is not replenished, in accordance with Article 101 of the State Budget Act of the Republic of
Bulgaria for 2025 - 100 percent.
Pursuant to the Order, Bulgarian Energy Holding EAD shall distribute and pay a 6 -month (interim) dividend based
on the adopted 6-month financial statements as of 30 June 2025 in the amount of 100 percent of the reported profit,
subject to the relevant application of Article 247a of the Commercial Law.