This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Annual Consolidated Management Report
Consolidated Corporate Governance Statement
Consolidated Report on Payments to Governments
Annual Consolidated Financial Statements
Independent Auditors’ Report
Bulgarian Energy Holding EAD
31 December 2025
Translation from Bulgarian

Bulgarian Energy Holding EAD
Contents
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Annual consolidated management report ..................... i
Consolidated corporate governance statement............ ii
Consolidated report on payments to
governments.............................................................. iv
Annual Consolidated Financial Statements ............... v
Consolidated Statement of Profit or Loss ................... 1
Consolidated Statement of Comprehensive Income .. 2
Consolidated Statement of Financial Position ............ 3
Consolidated Statement of Changes in Equity ............ 5
Consolidated Statement of Cash Flows ...................... 7
Notes to the Consolidated Financial Statements ....... 8
1. Corporate information ..................................... 8
2. Statement of compliance with IFRS Accounting
Standards and Application of the Going Concern
Principle .................................................................... 10
3. Changes in the accounting policy .................. 12
3.1. New standards, New amendments and
interpretations to IFRS, which came into force as of
1 January 2025. ......................................................... 12
3.2. Standards, amendments and clarifications that
have not yet entered into force and have not been
applied by the Group from an earlier date ................ 12
4. Material Accounting Policy Information ....... 13
5. Segment reporting ......................................... 47
6. Revenue from sales ....................................... 50
7. Other operating income ................................. 54
8. Costs of natural gas, electricity and other current
assets sold ................................................................. 56
9. Costs for acquisition of property, plant and
equipment by economic category ............................. 57
10. Expenses for materials ................................... 57
11. Hired services expenses ................................. 57
12. Reversal of/(losses from) impairment of
financial and other non-financial assets, net ............. 58
13. Personnel expenses ........................................ 58
14. Other operating expenses .............................. 58
15. Finance income.............................................. 60
16. Finance costs ................................................. 61
17. Income tax expenses ...................................... 61
18. Earnings per share and dividends .................. 61
19. Property, plant and equipment ....................... 63
20. Intangible assets ............................................. 75
21. Investment properties ..................................... 76
22. Investments accounted by the equity method 77
23. Trade and other receivables ........................... 83
24. Deferred tax assets and liabilities .................. 88
25. Inventories ..................................................... 90
26. Financial assets at fair value through other
comprehensive income .............................................. 92
27. Cash and short-term deposits ......................... 93
28. Share capital and reserves .............................. 94
29. Loans and lease liabilities .............................. 95
30. Deferred financing ......................................... 99
31. Liabilities related to employee’ retirement
income ..................................................................... 101
32. Provisions .................................................... 103
33. Deferred income .......................................... 107
34. Related party disclosures ............................. 108
35. Trade and other payables ............................. 110
36. Categories of financial assets and liabilities 111
37. Financial Risk Management Objectives and
Policy 112
38. Fair value measurement ............................... 118
39. Capital management policies and procedures ....
..................................................................... 120
40. Contingent assets, contingent liabilities, and
commitments ........................................................... 120
41. Balance of debt arising from financing activities
with the amounts disclosed in the consolidated
statement of cash flows ........................................... 130
42. Events after the reporting period .................. 131
43. Approval of the consolidated financial
statements ................................................................ 136
Independent Auditor’s Report .................................... vi

BULGARIAN ENERGY HOLDING EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
31 December 2025

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
Board of Directors as of the date of issue of the consolidated financial statements
Ivo Ivanov Todorov
Andrey Stefanov Zhivkov
Petar Valeriev Angelov
Vasil Vassilev Vassilev
Ilza Mitkova Chinkova
Address
Bulgaria
Sofia-city, Sofia 1000,
Oborishte District, 16 Veslets Str.
Servicing banks
Allianz Bank Bulgaria AD
Bulgarian-American Credit Bank AD
Bulgarian Development Bank AD
International Asset Bank AD
D Commerce Bank AD
Central Cooperative Bank AD
Citibank Europe AD, Bulgaria Branch
Eurobank Bulgaria AD
European Investment Bank
First Investment Bank AD
ING Bank N.V. – Sofia Branch
ING Bank
OTP Bank – Hungary
Investbank AD
Municipal Bank AD
DSK Bank AD
United Bulgarian Bank AD
UniCredit Bulbank AD
International Investment Bank
National Bank of Greece
Auditor
DZZD Audit BEH, with members of the consortium being the audit firms Grant Thornton OOD and
Zaharinova Nexia EOOD, registered under Reg. No. 032 and Reg. No. 138, respectively, in the Register of
Registered Auditors.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
2
1. General
Company name BULGARIAN ENERGY HOLDING EAD (BEH EAD)
UIC 831373560
Address Bulgaria
Sofia-city, Sofia 1000
Oborishte district
16 Veslets str.
Scope of Business Activity Acquisition, management, evaluation and sale of shares in
commercial companies, operating in the fields of production,
extraction, transmission, transit, storage, management,
distribution, sale and/or purchase of natural gas, electricity,
thermal energy, coal, as well as all kinds of energy and raw
materials for its production, participation in the management of
such companies, their financing, acquisition, evaluation,
issuance and sale of bonds, acquisition, evaluation and sale of
patents, sub-licensing for the use of patents to the above-
mentioned companies, as well as carrying out its own production
or commercial activity.
Directors As of 31 December 2025, the Company is managed by a
Board of Directors (BoD) with members:
Vasil Georgiev Stoynov
Chairperson of the BD
Kalin Boyanov Filipov
Vice-Chairperson of the BD
Valentin Aleksiev Nikolov
Member of the BD and CEO
Diyan Atanasov Ivanov
Member of the BD
Ivo Ivanov Todorov
Member of the BD
The Company is represented by its Executive Director.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
3
Bulgarian Energy Holding EAD (parent company) together with its subsidiaries form an
economic group. The holding structure is presented in the chart below:
Structure of Bulgarian Energy Holding EAD (BEH) as of 31 December 2025 Ministry of Energy
Bulgarian Energy Holding
Electricity Coal Natural gas
Electricity System Operator
EAD
NPP Kozloduy EAD
Natsionalna Electricheska
Kompania EAD
TPP Maritsa East 2 EAD
ESO Engineering
EOOD
HPP Kozloduy EAD
NPP Kozloduy – New
Builds EAD
NPP Construction
Supervision EOOD
NPP Service EOOD
Mini Maritsa-Iztok EAD
ESO Project EOOD
Bulgargaz EAD
Bulgartransgaz EAD
Bulgartel AD
Bulgartel Skopje
DOOEL
Balkan Gas Hub
EAD
National Energy Operator EAD
Minproject EAD
ESO Charge EAD
Bulgargaz North

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
4
NPP Kozloduy EAD
Scope of Business Activity Use of nuclear energy for generation of electricity and thermal
power, which activity is performed in the presence and
maintenance of: valid license for generation of electric and
thermal power by an electric power generation facility specified
in the license, valid licenses for operation of nuclear facilities
pursuant to the Safe Use of Nuclear Energy Act (SUNEA),
issued by the Nuclear Regulatory Agency (a valid authorization
for production activities carried out by the power generation
facility specified in it, issued by the Inspectorate on the Safe Use
of Nuclear Energy for Peaceful Purposes);
Import and export of fresh and spent nuclear fuel;
Investment activity related to the activity of the company,
specified in the scope of activity;
Construction, assembly and repair activities in the field of
electric and thermal power generation;
Sale of high and medium voltage electricity and thermal power;
Operation of radioactive waste management facilities according
to a valid license under the Safe Use of Nuclear Energy Act
(SUNEA).
Directors The Company is managed by a Board of Directors and as at
31.12.2025 it is represented by the Executive Director Ivan
Todorov Andreev.
Licenses The company holds the following licenses:
– Nuclear facility operation license - Series E, Registration
No. 5303 of 03.11.2017, effective from 06.11.2017 (amended
by Order No. AA-04-131/18.07.2022 and Order No. AA-04-
139/26.07.2024) for the operation of Unit 5 of Kozloduy NPP
EAD, issued by the Nuclear Regulatory Agency (NRA) with an
indefinite period of validity;
– Nuclear Facility Operating License – Series E, Registration
No. 5535/27.09.2019, dated October 3, 2019 (as amended by
Order No. AA-04-132/18.07.2022 and Order No. AA-04-
140/26.07.2024) for the operation of Power Unit 6 of Kozloduy
NPP EAD, issued by the Nuclear Regulatory Agency (NRA)
with an indefinite period of validity ;
– Nuclear Facility Operating License – Series E, Registration
No. 6200/20.06.2024, effective as of 26.06.2024, for the
operation of the Spent Nuclear Fuel Storage Facility of
Kozloduy NPP EAD, issued by the Nuclear Regulatory Agency
(NRA), with an indefinite period of validity;
– Nuclear Facility Operating License – Series E, Registration
No. 5016 of 28.01.2016 (as amended by Order No. AA-04-

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
5
138/26.07.2024 and Order No. AA-04-200/26.09.2025) for the
operation of the Dry Spent Fuel Storage Facility for VVER-440
reactors, issued by the Nuclear Regulatory Agency (NRA), with
an indefinite period of validity;
– License Series O, Registration No. 6149/21.03.2024, effective
as of 01.04.2024, for the use of ionizing radiation sources for
business purposes – performance of non-destructive testing
using radiation methods, issued by the Nuclear Regulatory
Agency (NRA). Term of the license - 01.04.2034
– License Series O, Registration No. 6147/20.03.2024, effective
as of 08.04.2024 (as amended by Order No. AA-04-
223/14.10.2025), for the use of ionizing radiation sources for
business purposes – performance of radiochemical control,
environmental radiation monitoring, and metrological control,
issued by the Nuclear Regulatory Agency (NRA). License term
- 08.04.2034;
– License Series T, Reg. No. 6195/19.06.2024, effective as of
12.07.2024, for the transport of radioactive substances, issued
by the NRA. License term - 12.07.2034;
license Series СО, reg. No. 5794, effective as of 05.10.2021, for
conducting specialized training for activities in nuclear facilities
and with ionizing radiation sources having an impact on safety,
and for issuing certificates of competence to persons
professionally engaged in activities in nuclear facilities and with
ionizing radiation sources, other than those under Article 64,
Paragraph 1, Items 1 and 2 of the ASUNE – issued by the
Nuclear Regulatory Agency (NRA). Validity of the license: until
05.10.2026;
– License for the Generation of Electricity and Thermal
Energy No. L-049-03/11.12.2000, issued by the Energy and
Water Regulatory Commission (EWRC) for a term of 30 years;
– License for the Transmission of Thermal Energy No. 050-
05/11.12.2000, issued by the EWRC for a term of 30 years;
– License for Electricity Trading No. L-216-15/18.12.2006,
issued by the EWRC with a validity period until 18.12.2026;
Investments in enterprises NPP Kozloduy EAD is the sole owner of the capital of Kozloduy
HPP EAD, Kozloduy NPP-New Builds EAD, NPP Construction
Supervision EOOD, NPP Service EOOD, and holds a minority
stake of 1.12% in ZAD Energy AD.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
6
Bulgargaz EAD
Scope of Business Activity Public supply of natural gas and natural gas trading, as well as
the related activities of purchase and sale, acquisition of natural
gas for the purpose of its storage in a gas storage facility, market
research and analysis of the domestic natural gas market.
Directors The Company is managed by a Board of Directors and as at
31.12.2025 it is represented by the Executive Director Veselin
Sashev Sinabov.
Licenses
Investments in enterprises
The company holds the following licenses/permits:
– License for the Public Supply of Natural Gas within the
territory of the Republic of Bulgaria No. L-214-14 of
29.11.2006, issued by the EWRC for a term of 35 years;
– License for Natural Gas Trading No. L-548-15 of 16.09.2021,
issued by the EWRC for a term of 10 years;
– License for trading in natural gas on the territory of the
Republic of Greece under Decision No. 247/2020 and Decision
No. 311/2022 for trading in natural gas on the territory of the
Republic of Greece, for a period of 20 years.
– Permit No. 2023P 0370 for carrying out activities in the energy
sector - gas supply, issued by the Regulatory Authority for
Network Industries of the Slovak Republic pursuant to Decision
No. 0024/2023/Р-РЕ of June 20, 2023. The permit is valid
indefinitely;
– Right to participate in the natural gas markets in Romania to
carry out the activity of natural gas supply for a period of 1 (one)
year, according to Decision No. 2274/29.10.2024 of the
President of the National Energy and Water Regulatory Agency
(ANRE). By decisions No. 2079/30.09.2025 and No.
2309/04.11.2025 of the Chairman of ANRE, the right to
participate in the natural gas markets in Romania was extended
until 29.10.2030.
– License for trading in natural gas in Hungary, pursuant to
Decision No. H4955/2024 of 12.12.2024 of the Hungarian
Energy and Utilities Regulatory Authority, valid from the date
of notification for an indefinite period of time.
Bulgargaz EAD is the sole owner of the capital of Bulgargaz
North, which carries out the activity of trading in natural gas on
the territory of Moldova.
Bulgartransgaz EAD
Scope of Business Activity Storage and transmission of natural gas; maintenance,
operation, management and development of gas transmission
grids; maintenance, operation, management and development of

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
7
underground gas storage facilities; development of programs
and activities for ensuring the compliance of the natural gas
transmission and storage activities with the requirements of the
European energy legislation; development of pricing policy for
access to and transmission on the gas grids, storage of natural
gas and connection to gas transmission grids; administration of
natural gas transactions and arranging the balancing of the
natural gas market in compliance with the requirements of the
current legislation; engineering, investment, manufacturing and
service activity; import of goods, machinery and equipment
related to the company's operations; centralized operational
management, coordination and control on the operation of gas
transmission grids.
Directors The company has a two-tier management system - Supervisory
Board and Board of Directors. As of 31.12.2025, the Company
is represented and managed by Executive Director Vladimir
Asenov Malinov.
Licenses The Company holds licenses issued by the Energy and Water
Regulatory Commission (EWRC) as follows:
− License No. Л-214-09 dated 29 November 2006 for
transmission of natural gas on the territory of the Republic of
Bulgaria, for a period of 35 years;
− License No. Л-214-06 dated 29 November 2006 for
transmission of natural gas on the territory of the Republic of
Bulgaria, for a period of 35 years;
− License No. Л-214-10 dated 29 November 2006 for storage
of natural gas on the territory of the Republic of Bulgaria for a
period of 35 years.
Investments in enterprises Bulgartransgaz EAD is the sole owner of the capital of Balkan
Gas Hub EAD and owns 50% of the shares of Bulgartel AD, and
20% of the capital of Gastrade S.A.
Mini Maritsa Iztok EAD
Scope of Business Activity Coal mining and marketing; industrial, commercial, leasing,
repair, and foreign economic activities; training and retraining
of personnel for coal mining for the purpose of income
generation; provision of prevention and rehabilitation activities
at holiday resorts owned by the company; electricity trading;
provision of rail freight transport, as well as any other activities
not prohibited by law.
Directors The Company is managed by a Board of Directors and as of
31.12.2025 it is represented by Executive Director Todor
Dimchev Todorov.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
8
Licenses The company owns:
− License for Rail Freight Transport issued in 2016 by the
Ministry of Transport, Information Technology and
Communications, valid for a period of 5 years. The license was
updated on 14.05.2021 and it is valid until 13.05.2026.
Investments in enterprises Mini Maritsa Iztok EAD holds a minority share of 3.68% in
ZAD Energy.
TPP Maritsa East 2 EAD
Scope of Business Activity Electricity generation; construction and repair activities in the
fields of electric power engineering and thermal power
engineering; investment activities; acquisition and disposal of
copyrights, rights to inventions, trademarks, and industrial
designs, know-how, and other intellectual property objects, as
well as any other activity not prohibited by law or other
regulatory act, and where the issuance of a permit or a license is
required, after obtaining such permit or license.
Directors The Company is managed by a Board of Directors and as of
31.12.2025 it is represented by Executive Director Diyan
Stanimirov Dimitrov.
Licenses The Company holds the following licenses issued by EWRC as
follows:
− License for generation of electric power Л-091-01 dated 21
February 2001 valid for a period of 20 years; By Decision No.
I1-Л-091 of July 2, 2020, the term of the license was extended
by another 20 years, starting from the date of expiration of the
license - 24.03.2021;
− License for trading with electric power No. Л-498-15 dated
31 January 2018 valid for a period of 10 years;
Investments in enterprises The Company holds a minority share of 0.96% in ZAD Energy.
Natsionalna Elektricheska Kompania EAD (NEK EAD)
Scope of Business Activity Generation of electricity, centralized purchase and sale of
electricity, supply of electricity to consumers, connected to the
transmission grid, import and export of electricity, construction
works and repairs in the field of electricity production,
investment activities, implementation and promotion of energy
efficiency in the electricity production.
Directors The Company is managed by a Board of Directors and as of
31.12.2025 it is represented by Executive Director Georgi
Georgiev Dobrev.
Licenses The Company holds licenses issued by EWRC as follows:
− License No. Л-147-13 of December 17, 2004 for public
supply of electricity, which was terminated as of July 1, 2025

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
9
pursuant to §52 of the previous and final provisions of the
Electricity Act, promulgated SG issue No. 96 of 2023,
respectively §66, item 1 of the Transitional and Final Provisions
of the Act on the Environment, promulgated SG issue No. 39
dated 2024, in force as of 01.07.2019;
− license No.Л-073-01 dated 14 February 2001 for power
generation from HPP and PSHPP, valid for a period of 35 years;
− License No.1-230-15 dated June 4, 2007, for electricity
trading for a term of 10 years, supplemented with the role of a
standard balancing group coordinator. By decision of the
Energy and Water Regulatory Commission (EWRC) No.И2-Л-
230 dated 15 September 2016, the validity of the license for
trading in electricity was extended, including the rights and
obligations of a coordinator of a standard balancing group with
10 years - by 4 June 2027;
− License No. Л-408-17 dated 1 July 2013 for supply of
electricity from a supplier of last resort, valid for a period of 26
years. (Decision No.I1-L-408/29.01.2014 amending
/supplementing License No.L-408-17/01.07.2013, issued for
the activity “supply of electricity from a supplier of last resort”
with the rights and obligations of a coordinator of a special
balancing group).
Internal structural units NEK EAD, Hydroelectric Power Plants Enterprise, city of
Plovdiv – operation and maintenance of HPPs, electricity
generation, construction and repair activities in the field of
electricity generation from HPPs, repair and investment
activities.
NEK EAD, Dams and Cascades Company, Sofia performs
technical operation and maintenance of dams and hydro power
facilities.
NEK EAD, Enterprise „Hidroelektroinvest“, city of Sofia –
carries out activities related to research, development,
preparation and implementation of hydropower projects.
Investments in enterprises NEK EAD holds 27% of the capital of ContourGlobal Maritsa
Iztok 3 AD, 27% of the capital of ContourGlobal Operations
Bulgaria AD, 42% of the capital of ZAD Energy, 34 % of the
capital of Allianz Bulgaria Pension Company AD, and 24% of
the capital of HPC Gorna Arda AD.
Electricity System Operator EAD (ESO EAD)
Scope of Business Activity Transmission of electricity, unitary operational planning,
coordination and management of the electricity system of the
Republic of Bulgaria, provision and management of third party

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
10
access on a non-discriminatory basis to grid users or groups of
grid users, implementation of the joint operation of the
electricity system with the electricity systems of other
countries, coordinated development and interoperability of the
electricity transmission grid with interconnected electricity
transmission grids, expansion, reconstruction, modernization,
operation, maintenance and provision of the reliable operation
of the electricity transmission grid, including the availability of
all necessary ancillary services, maintenance and development
of auxiliary grids, repairs and services in the field of energy,
other commercial activities and services that are not prohibited
by law.
Directors The company has a two-tier management system - Supervisory
Board and Board of Directors. As of 31.12.2025, the Company
is represented and managed by Executive Director Kiril
Georgiev Georgiev.
Licenses The company owns:
− License for electricity transmission No.Л-419-04, dated 18
December 2013, valid for a period of 35 years, issued by
EWRC
Investments in enterprises Electroenergien Sistemen Operator EAD (ESO EAD) is the
sole owner of the capital of ESO Engineering EOOD, ESO
Project EOOD, ESO Charge EAD, holds 50% of the capital of
Bulgartel AD, 50% of the capital of Operator Zagore EAD,
33.33% of the capital of SEleNe CC, and 4% of the allocation
office JAO S.A.
National Energy Operator EAD (NEO EAD)
Scope of Business Activity Construction and operation of electric power facilities
Directors The Company is managed by a Board of Directors and as at 31
December 2025 it is represented by the Executive Director
Aleksandar Zdravkov Mihaylov.
Minproekt EAD
Scope of Business Activity Design and construction, scientific research, engineering and
consulting activities related to coal mining in Bulgaria,
notwithstanding whether by open or underground method.
Tests of explosion-proof equipment and explosives.
Directors The Company is managed by a Board of Directors and as at
December 31, 2025 it is represented by the Executive Director
Kostadin Hristov Hristov.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
11
Basis for preparation of the consolidated financial statement
The Group BEH EAD operates in compliance with the Bulgarian and the European legislation. The
consolidated financial statements of the Group are prepared in accordance with the International Financial
Reporting Standards developed and published by the International Accounting Standards Board and adopted
by the European Union.
Responsibility of the Management
The Management confirms that an adequate accounting policy has been applied in the preparation of the
consolidated financial statements for 2025 and they have been prepared on a going concern basis.
The management is responsible to keep proper accounting records, to carry out appropriate asset
management and to undertake the measures necessary to avoid and detect any possible frauds and other
irregularities.
The Consolidated management report for 2025 is prepared in accordance with art. 45 of the Accountancy
Act and art. 247 of the Commercial Act and is approved by the Board of Directors of Bulgarian Energy
Holding EAD.
2. Incorporation, management and structure
Legal status
Parent company
BEH EAD is a sole owner joint-stock company, established in 2008, following the change of the company
name, statute and subject of activity of Bulgargaz Holding EAD, and the capital of the company being
increased through an in-kind contribution at par value of all shares of the capital of Natsionalna Elektricheska
Kompania EAD, NPP Kozloduy EAD, TPP Maritsa Iztok 2 EAD and Mini Maritsa-Iztok EAD. In this way,
all state energy companies operating in the sphere of production, extraction, transmission and trade with
energy resources, have been integrated in the structure of BEH EAD.
The sole owner of the capital of BEH EAD is the Republic of Bulgaria and the rights of a sole owner are
exercised by the Minister of Energy who has the capacity of a principal and is empowered to make all
decisions within the competence of the sole owner of the capital according to the law and the Articles of
Association of the Company.
The company is managed through a one-tier management system. The management bodies are:
• Sole owner of the capital in its capacity of General Assembly - the Minister of Energy of the
Republic of Bulgaria;
• The Board of Directors.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
12
At the date of preparation of these annual consolidated financial statements, there are no plans for
privatization of the company, it is included in the list of state companies not subject to privatization -
Appendix No. 1 to art. 3, para. 1 of the Privatization and Post-Privatization Control Act.
Subsidiaries within the Group of Bulgarian Energy Holding EAD (BEH EAD)
NPP Kozloduy EAD was established on 28 April 2000 by Decision No.7 dated April 2000, company case
582/2000 of Vratsa District Court. The Company has its headquarters and registered office at: city of
Kozloduy, Vratsa Province, NPP site, telephone code 0973, postal code 3320. The sole owner of the capital
of NPP Kozloduy EAD since 18 September 2008 is BEH EAD.
HPP Kozloduy EAD was registered in Vratsa District Court with company case No.495 dated 2004 with
the purpose of building a hydroelectric plant, generation and distribution of electricity from small
hydroelectric power plant for utilization of the residual resource of the spent water from NPP Kozloduy
EAD. The sole owner of the capital of HPP Kozloduy EAD is NPP Kozloduy EAD.
Kozloduy NPP-New Builds EAD was incorporated on May 9, 2012, with the business purpose of
constructing nuclear power plant units. The sole owner of the capital of NPP Kozloduy - New Builds EAD
is NPP Kozloduy EAD.
NPP Construction Supervision EOOD was entered in the Commercial Register at the Registry Agency
with UIC 206736961, headquarters and registered office: Vratsa province, Kozloduy municipality, town of
Kozloduy, site of "Kozloduy NPP" on November 25, 2021. "Kozloduy NPP" EAD is the sole owner of the
capital of "NPP Construction Supervision" EOOD.
NPP SERVICE EООD was entered in the Commercial Register and the Register of Non-Profit Legal
Entities with the Registry Agency with UIC: 206858488, headquarters and registered office Vratsa province,
Kozloduy municipality, town of Kozloduy, site of Kozloduy on 11.03.2022 with capital BGN 750 thousand.
Kozloduy NPP EAD is the sole owner of the capital of Nuclear Power Plant (NPP) Service EOOD.
Bulgargaz EAD was registered in Bulgaria in accordance with the Commercial Act. The Company was
entered in the Commercial Register under No. 113068, volume 1534, page 35, company case No. 16440/2006
and was registered on the basis of Decision No.1 dated 15 January 2007. The Company has headquarters and
registered office at: Sofia municipality, Sofia 47 Petar Parchevich Str. The sole owner of the capital of
Bulgargaz EAD is BEH EAD.
Bulgargaz North S.R.L. was registered in the Republic of Moldova on 27.06.2025. On 19.08.2025, by
decision of the regulator of the Republic of Moldova, Bulgargaz North S.R.L. received a license to trade in
natural gas on the territory of the republic. The sole owner of the capital of Bulgargaz North S.R.L. is
Bulgargaz EAD.
Bulgartransgaz EAD was registered in accordance with the Commercial Act by Decision No.1 dated 15
January 2007 by Sofia City Court under No.113067, Volume 1543, p. 32, company case No. 16439/2006.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
13
The Company's headquarters and registered office is: Sofia, Lyulin Municipality, Residential Area Lyulin 2,
66 Pancho Vladigerov Blvd. The sole owner of the capital of Bulgartransgaz EAD is BEH EAD.
Balkan Gas Hub EAD is a sole joint stock company with registered office in the Republic of Bulgaria,
incorporated in the Commercial Register and the Register of Non-Profit Organizations with the Registry
Agency under UIC 205478458 on 18 January 2019. The Company’s registered office is in Sofia, res. area
Darvenitsa, Sv. Kliment Ohridski Blvd., next to block 19, Kintex Business Building. The sole owner of the
capital of Gas Hub Balkan EAD is Bulgartransgaz EAD.
Bulgartel EAD was registered under company case No. 13115/2004 in accordance with the Commercial
Act by a decision of the Sofia City Court dated 30 November 2004. The Company's headquarters and
registered office is: Sofia, residential area Darvenitsa, Sv. Kliment Ohridski Blvd., next to block 19, Kintex
Business Building. The owners of the capital of Bulgartel AD are Electricity System Operator EAD and
Bulgartransgaz EAD with a 50% share each.
Bulgartel Skopje DOOEL is a sole owner joint-stock company registered in the Central Registry of the
Republic of Macedonia on 3 December 2008 under No. 643867. The company registered office and address
of management is in Macedonia, city of Skopje, Yane Sandanski 64/3-2. The sole owner of the capital of
Bulgartel Skopje DOOEL is Bulgartel EAD.
Electricity System Operator EAD (ESO EAD) was registered in accordance with the Commercial Act by
Sofia City Court by Decision No.1 of 4 January 2007, under company case No. 16298/2006, lot No. 112765,
volume 1528, register 1, page 53. The Company's registered office and address of management is Sofia,
Vitosha district, 201 Tsar Boris III Blvd. The sole owner of the capital of ESO EAD is BEH EAD.
ESO Engineering EOOD was registered in the Commercial Register and the Register of Non-Profit Legal
Entities with the Registry Agency on 18 February 2021 with UIC/PIC 206401308. The registered office of
the company is. Sofia, 24 Petko Yu. Todorov blvd. The sole owner of the capital of the company is Electricity
System Operator EAD.
ESO Proekt EOOD was registered in the Commercial Register and Register of Non-Profit Entities to the
Registry Agency on 26.04.2022. Its headquarters and registered office is: city of Sofia, postal code 1404, 24
Petko Yu. Todorov blvd. The sole owner of the capital of the company is Electricity System Operator EAD.
ESO Charge EAD was registered in the Commercial Register with the Registry Agency on March 29, 2024,
under Unified Identification Code (UIC) 207774922, with its registered office and management address at:
Sofia, postal code 1404, 24 Petko Yu. Todorov blvd. The sole owner of the capital of the company is
Electricity System Operator EAD.
Natsionalna Elektricheska Kompania EAD was registered in accordance with the Commercial Act by
Sofia City Court under No.196, volume 5, p. 98, under company case No. 29869/1991. The Company has
its registered office and business address in: Sofia, 5 Veslets str. The sole owner of the capital of NEK EAD
is BEH EAD.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
14
Mini Maritsa-Iztok EAD was registered under company case No. 2444/1993, Reg. 1, Vol. 1, p. 12, lot 6 by
Stara Zagora District Court in accordance with the Commercial Law by Decision No.2773 dated 7 July 1993.
The Company headquarters and registered office: Radnevo, Stara Zagora district, 13 Georgi Dimitrov str.
The sole owner of the capital of Mini Maritsa-Iztok EAD is BEH EAD.
TPP Maritsa East 2 EAD was registered by decision No. 2591 dated 30 June 2000 of Stara Zagora Regional
Court in accordance with the Commercial Act under company case 1338/2000, reg. 1, vol. 2, p. 46, lot 23.
The Company has its headquarters and registered office at: Kovachevo, Stara Zagora province The sole
owner of the capital of TPP Maritsa Iztok 2 EAD is BEH EAD.
National Energy Operator EAD is a joint-stock company established on 4 April 2023, as a sole
proprietorship with sole owner Bulgarian Energy Holding EAD. The Company has its headquarters and
registered office at: city of Sofia 1000, Oborishte district, Veslets str. and the address for correspondence is
Sofia 1000, Oborishte district, 5 Stara planina str., office #3.
Minproekt EAD is a joint-stock company with sole owner Bulgarian Energy Holding EAD. The company
joined BEH EAD Group on 07.12.2023 and it registered address is: city of Sofia 1756 Studentski district, 14
Kliment Ohridski Blvd.
No separate branches of the enterprise were set up in the structure of BEH EAD as of 31.12.2025.
History of the parent company
BEH EAD is the successor of the State Oil and Gas Company, founded in 1973, renamed to
Gazosnabdyavane in December 1975. 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.
With a transformation plan dated 27 October 2006 and its annexes, Bulgargaz EAD was transformed into
Bulgargaz Holding EAD by the separation of two separate sole joint-stock companies – Bulgartransgaz EAD
and Bulgargaz EAD pursuant to the provisions of Article 262 (d) of the Commerce 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 of 18 September 2008, the Minister of Economy and Energy changes the
company name, the Articles of Association and the scope of activity of Bulgargaz Holding EAD and
establishes Bulgarian Energy Holding EAD, the capital is increased by 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.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
15
Information under Art. 187e and Art. 247 (2) of the Commercial Act
Share capital
By Decree No. 168/27.08.2025 of the Council of Ministers, amendments to the 2025 budget of the Ministry
of Energy were approved in the amount of BGN 1,500,000 thousand for increasing the capital of Bulgarian
Energy Holding EAD. The funds are intended to be used to finance strategically important projects in the
Energy sector. On 19 September 2025, funds in the amount of BGN 1,500,000 thousand were transferred to
the account of Bulgarian Energy Holding EAD. The capital increase was registered in the Commercial
Register and the Register of Non-Profit Legal Entities on 26 September 2025.
Pursuant to Protocol of the Minister of Energy dated 15 December 2025, the share capital of the Company
was increased through a non-cash asset contribution in the amount of BGN 14,298 thousand, representing
the ownership right to a real estate property - private state property, located in the Republic of Greece, city
of Athens, 12 Akadimias Street, consisting of a land plot with a total area of 196.87 sq. m. and a seven-story
building constructed thereon with a total gross built-up area of 1,424 sq. m. and a total floor area. The increase
was entered in the Commercial Register and the Register of Non-Profit Legal Entities on 29 December 2025.
As at 31 December 2025 the share capital of the parent company BEH EAD is BGN 4,978,239,873
distributed in 4,978,239,873 shares with a nominal value of BGN 1 each. The entire amount of the Company
capital is subscribed and paid in full. The Company's shares are ordinary, registered, non-privileged, with
voting rights.
The Company does not possess any own shares. In 2025, the Company did not acquire or transfer its own
shares.
Information regarding the remuneration of the members of the Board of Directors of Bulgarian
Energy Holding EAD and its subsidiaries under management and control contracts
The remuneration of the members of the Board of Directors of Bulgarian Energy Holding EAD and
its subsidiaries is as follows:
Remuneration of key management personnel
thousand BGN 2025 2024
Remuneration 5,832 5,664
Social security contributions 520 363
Social costs 364 892
Benefits for unused leave 8 -
Total 6,724 6,919

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
16
Information regarding the acquisition and holding of company shares by the members of the Board
of Directors
The members of the Board of Directors do not own shares of the companies. They do not have privileges or
exclusive rights to acquire shares and bonds of the companies. All shares of BEH EAD are owned by the
State, and the shares of NPP Kozloduy EAD, Bulgargaz EAD, Bulgartransgaz EAD, Mini Maritsa-Iztok
EAD, NEK EAD, TPP Maritsa East 2 EAD, Minproekt EAD, NEO EAD and ESO EAD are 100% owned
by BEH EAD.
Information on the participation of members of the Board of Directors in 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 01.01.2025 - 31.12.2025:
Vasil Georgiev Stoynov – Chairperson of the Board of Directors of Bulgarian Energy Holding EAD since
22.05.2025. The latter does not participate as a general partner, does not own more than 25% 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.
Veselina Lachezarova Kanatova-Buchkova – Chairperson of the Board of Directors of Bulgarian Energy
Holding EAD until 22.05.2025 – does not participate as a general 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 31.12.2025. He does not have any participation as an unlimited liability partner, does not own more
than 25% 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 Aleksiev Nikolov – Executive Director of Bulgarian Energy Holding EAD and member of the
Board of Directors as of 31.12.2025. He owns more than 25% of the company capital as follows:
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.
Galina Tsvetanova Todorova – Executive Director of Bulgarian Energy Holding EAD and member of the
Board of Directors until 13.02.2025. 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.
Diyan Atanasov Ivanov - member of the Board of Directors as of 13.02.2025. He owns more than 25% of
the capital of the following commercial companies:
MIHAYLOVI CONSULT EOOD, UIC: 203306709 – sole owner of the capital until 14.02.2025;
Until 14.02.2025, he participates in the management as a Manager of the following company:
MIHAYLOVI CONSULT EOOD, UIC: 203306709

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
17
Ivo Ivanov Todorov - Member of the Board of Directors of Bulgarian Energy Holding EAD as of
31.12.2025. He does not have any participation as an unlimited liability partner, does not own more than
25% 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 Commerce 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.
Personnel
Number of personnel:
2025
report
2024
report
% change
2025/2024
18,613 19,066 (2.38%)
Labor productivity - revenue/number of employees (in thousand BGN)
2025
report
2024
report
% change
2025/2024
496.71 463.73 7.11%
Related parties
As of 31 December 2025, the economic group of BEH holds interests in the following joint ventures, reported
in the consolidated financial statements using the equity method:
Company Country of
incorporation Core Business 2025 Amount of
investments
% thousand BGN
Joint ventures
ICGB AD Bulgaria construction and operation of
a gas transmission system 50.00% 72,772
South Stream Bulgaria
AD Bulgaria construction and operation of
a gas transmission system 50.00% 9,856
SEleNe CC Greece
coordinating the security of
the electricity network in
Southeast Europe
33.33% 4,881
Operator Zagore AD Bulgaria
distribution network,
distribution of electricity and
natural gas within a closed
distribution network,
provision of energy services
50.00% 50
Gastrade S.A. Greece construction of a liquefied
natural gas terminal 20.00% 40,831
Total joint ventures 128,390

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
18
As at 31 December 2025, the economic group of BEH holds interests in the following associated companies,
reported in the consolidated financial statements using the equity method:
Company Country of
incorporation Core Business 2025 Amount of
investments
% thousand BGN
Associated companies
ContourGlobal
Maritsa Iztok 3 AD Bulgaria generation of electricity 27.00% 48,283
Contour Global
Operations Bulgaria
AD
Bulgaria operation and maintenance of
a thermal power plant 27.00% 2,967
ZAD Energy Bulgaria insurance company 48.08% 12,229
Allianz Bulgaria
Pension Company AD Bulgaria pension insurance company 34.00% 37,462
Hydro Power
Company Gorna Arda
AD
Bulgaria hydroelectric company 24.00% -
Total associated companies 100,941
Information on the main intangible resources according to Art. 39, para. 6 of the Accountancy Act
The main intangible resources of BEH Group are related to the licenses held by the subsidiaries in the field
of production and trade in electricity and heat and transmission and trade in natural gas. The licenses are
described in detail for each company separately in Section 1. "General Information" of this consolidated
activity report.
3. Main results for 2025
3.1. Financial result
The reported net financial result of the Group for 2025 is a profit of BGN 108,660 thousand, with an annual
decrease of BGN 137,517 thousand compared to the result in 2024 (BGN 246,177 thousand). An analysis of
the financial performance of BEH Group by business segments, as well as the main factors affecting the
activities of the Holding companies, is presented below in this section.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
19
The change in the main components forming the financial result:
Financial results 2025 2024 Change 2025/2024
thousand
BGN
thousand
BGN
thousand
BGN %
Total revenue 9,245,301 8,841,436 403,865 4.57%
Book value of natural gas, electricity and
other current assets sold (3,590,218) (3,405,516) (184,702) (5.42%)
Operating expenses (5,278,012) (4,979,592) (298,420) (5.99%)
Finance costs, net (115,462) (103,751) (11,711) (11.29%)
Profit from investments accounted for using
the equity method 27,711 3,716 23,995 645.72%
Tax expenses (180,660) (110,116) (70,544) (64.06%)
Net profit 108,660 246,177 (137,517) (55.86%)
BEH EAD was established as a corporate structure that combines the state-owned energy companies. The
Group’s principal revenues relate to the generation, transmission, supply and sale of electricity; the
transmission, storage and sale of natural gas; and the mining and sale of coal.
Taking into account the characteristics of the current market model, the activities of the companies and their
financial results depend on the influence of external factors related to the macroeconomic factors and market
trends, as well as to the market regulation models applied by the independent regulatory authority – Energy
and Water Regulatory Commission (EWRC/the Commission).
By 30.06.2025, the current market model provided for the existence of companies carrying out the functions
of a public supplier of electricity and natural gas. As of 31.12.2025, Bulgargaz EAD is still a public supplier
of natural gas and is subject to regulation by the Energy Regulatory Commission, with the commission
determining the selling prices of natural gas at which the company sells them to end suppliers, while the role
of National Electric Company EAD as a public supplier of electricity was eliminated with amendments to
the Energy Act, effective from 01.07.2025.
In 2025, the BEH Group's Earnings Before Interest, Taxes, Depreciation, and Amortization (EBITDA)
decreased by 1.95% year-on-year, amounting to BGN 1,361,685 thousand, compared to the BGN 1,388,833
thousand reported in 2024. The Group's operating financial result before interest and taxes (EBIT) for 2025
was a profit of BGN 377,071 thousand, which is BGN 79,257 thousand less than the operating profit reported
a year earlier.
The total amount of assets increases from BGN 30,091,566 thousand at the end of 2024 to BGN 31,175,313
thousand as of 31.12.2025. The reported increase is mainly due to a higher carrying amount of property,
plant and equipment, as well as the increased value of current trade and other receivables during the period
under review.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
20
By the end of 2025, the company's working capital increased to BGN 3,887,689 thousand, which indicates
the formation of a significant buffer of liquid resources, ensuring coverage of short-term liabilities with
current assets.
The table below provides information on the key performance indicators of the Group's financial position as
at 31 December 2025.
Main indicators 2025 2024 Change 2025/2024
thousand BGN thousand BGN thousand
BGN %
Total revenue 9,245,301 8,841,436 403,865 4.57%
Total expenses (8,868,230) (8,385,108) (483,122) (5.76%)
EВIТDA 1) 1,361,685 1,388,833 (27,148) (1.95%)
EВIТ 2) 377,071 456,328 (79,257) (17.37%)
EВТ 3) 289,320 356,293 (66,973) (18.80%)
EВIТDA margin 14.73% 15.71% (0.98 p.p.) -
Total assets 31,175,313 30,091,566 1,083,747 3.60%
PPE 4) 21,580,085 21,083,539 496,546 2.36%
Working capital 5) 3,887,689 3,291,871 595,818 18.10%
Cash 2,581,365 3,699,884 (1,118,519) (30.23%)
Equity 19,928,554 19,946,205 (17,651) (0.09%)
1) EВIТDA – earnings before interest, taxes, depreciation and amortization and profit in
associates and jointly controlled companies;
2) EВIТ – earnings before interest, taxes and profit in associates and jointly controlled
companies;
3) EВТ – earnings before taxes;
4) PPE – property, plant and equipment;
5) Working capital – current assets minus current liabilities

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
21
The reported financial results by different types of segments are presented below:
• Electricity segment
Electricity 2025 2024 Change 2025/2024
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 6,739,485 6,267,236 472,249 7.54%
- other segments 1,782,626 1,657,716 124,910 7.54%
Segment Revenue 8,522,111 7,924,952 597,159 7.54%
Changes in production and WIP balances 15,422 14,089 1,333 9.46%
Costs for acquisition of property, plant
and equipment 68,957 61,858 7,099 11.48%
Book value of natural gas, electricity and
other current assets sold (3,743,620) (3,431,763) (311,857) (9.09%)
Expenses for materials (1,000,595) (683,787) (316,808) (46.33%)
Hired services expenses (483,886) (430,287) (53,599) (12.46%)
Depreciation and amortization expenses (557,825) (521,841) (35,984) (6.90%)
Personnel expenses (955,460) (901,771) (53,689) (5.95%)
Impairment of sales receivables, net 36,943 17,082 19,861 116.27%
Impairment of property, plant and
equipment, net (23,814) 2,173 (25,987) (1,195.90
%)
Costs for provisions (267,720) (466,288) 198,568 42.58%
Other operating expenses (1,112,266) (946,502) (165,764) (17.51%)
Operating profit from the segment 498,247 637,915 (139,668) (21.89%)
Within the Group, operations in the Electricity segment are carried out by the following companies: NEK
EAD, ESO EAD, NPP Kozloduy EAD, TPP Maritsa East 2 EAD and the National Energy Operator EAD.
In compliance with the legal regulations, the companies are holders of licenses for generation, sale,
transmission and trade of electricity. They carry out their operations in compliance with the requirements of
the EU directives and regulations in the field of energy, the Energy Act and the Ordinance on regulating the
prices of electricity. The regulation of their operations is carried out by the independent specialized authority
– EWRC.
The main changes in the environment in which they operate and which had an impact on the activities of the
companies in the "Electricity" segment are the following:
• Regulatory interventions in the free electricity market, manifested primarily in setting revenue caps for
electricity generators, as well as determining compensations for non-household end-users;

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
22
• Termination of the license of NEK EAD for Public Electricity Supply, effective from 01.07.2025. From
the same date, the new mechanism "Tenders - End Supplier" will be launched through the IBEX platforms,
as NEK EAD, in its role as coordinator of a standard balancing group and through its trading license, supplies
end suppliers with electricity;
• Normalization of prices on the European electricity markets compared to the peak prices from the end of
2021 and during 2022. In 2025, the average baseload price on the 'Day-Ahead' market segment of IBEX
recorded a moderate year-on-year growth of 4.6% to EUR 107.2/MWh;
• The increased construction of solar power generation and consumption installations in 2025, with the
same reaching a 32.7% share of the total generation capacities in the country, resulting in a decline in
generation from conventional sources in 2025 compared to the previous year 2024;
• The share of electricity produced by RES in the electricity mix of the Republic of Bulgaria in 2025
reached 28% (2024: 25%). The growth in supply from this type of producer affected the competitiveness and
volumes of electricity sold by other types of producers.
In 2025, the total gross production of electrical energy in the country increased with 5.2% compared to the
previous year and amounted to 40,198,090 MWh, compared to 38,227,519 MWh a year earlier. The reason
for the reported growth on an annual basis is mainly the higher demand for electricity in the region. As a
result, the country's net commercial exports increase compared to the previous year – by 33.9%, reaching
1,321,792 MWh in 2025.
In 2025, the gross electricity generation of the generating companies within the BEH Group amounted to
21,820,460 MWh (representing a 54% share of the total gross generation in the country), marking a 1.39%
decline compared to the generation reported in 2024 (22,124,462 MWh).
In 2025, Kozloduy NPP EAD produced 15,362,268 MWh of electricity, and the net active electricity supplied
by the company, according to the current regulations, amounted to 14,603,368 MWh. The amount of
electricity generated is 3% less than in 2024, due to reduced production due to shutdowns with a total duration
of 23.21 days of nuclear power unit No. 6 outside the planned annual maintenance. The sale of electricity on
the regulated market for the period until 30.06.2025 is based on the electricity price and monthly quantities
for the sale of electricity of the Public Supplier "National Electricity Company" EAD (NEK) approved by
the EWRC. Electricity supplies in the first half of the year at regulated prices amounted to 3,188,001 MWh
and were 25% more than in the same period of 2024, due to the increased quota from 01.01.2025, which is
reflected in a corresponding decrease in the quantities for the free market. On an annual basis, electricity
sales at regulated prices are 39% lower than in 2024, due to changes in the Energy Act, published in the State
Gazette, issue. 44 of 2025, which, as of 01.07.2025, brings into force full liberalization of the wholesale
electricity market and the abolition of the obligation of the public supplier to purchase electricity from
producers for the needs of household consumers.
A new mechanism has been created, which is implemented through NEK EAD, in its capacity as balancing
group coordinator. After the quota was abolished, it was replaced by a legally imposed obligation for
participation of Kozloduy NPP EAD in the new mechanism and provision of quantities for bidding by NEK
EAD on the new exchange segment, for the purposes of satisfying household consumption and protecting it
from the predicted high prices on the free market. In 2025, Kozloduy NPP EAD sold a total of 11,370,962

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
23
MWh on the free market (including sales to the balancing group coordinator - NEK EAD) compared to
9,789,905 MWh a year earlier. The remaining quantities (44,406 MWh) are sold by the power plant on the
balancing market and through sales under Art. 119 of the Energy Law and delivery to its own sites under
Art. 119, para. 1 of the Energy Law.
The average selling price of electricity produced by Kozloduy NPP EAD in all directions in 2025 is 152.10
BGN/MWh and marks an increase of 11.9% compared to the average selling price achieved in 2024. The
higher average selling price of electricity compensates for the moderate decline in the quantities realized by
the plant, as in 2025, revenues from the sale of electricity increase to 2,219,851 thousand BGN. (by 9%
annually). Despite the reported sales growth, the significant increase in operating expenses during the period
under review, mainly as a result of the significant increase in targeted contributions to the Electricity System
Security Fund (ESSF) and higher nuclear fuel costs, led to a decline in the company's net profit, which for
2025 amounted to BGN 12,739 thousand compared to BGN 221,913 thousand.
In 2025, Maritsa Iztok 2 TPP EAD reported gross electricity generation of 4,613,702 MWh, which is 2.8%
more compared to the generation a year earlier (4,486,222 MWh). In 2025, the company generated 3,923,551
MWh of electricity, which is 6,746 MWh more than in 2024 (3,916,805 MWh).
Pursuant to Order No. E-RD-16-310 of 31.05.2024, pursuant to Art. 4, para. 2, item 8 of the Energy Act and
Art. 25, para. 4 of the Administration Act, in view of the security of electricity supply on the territory of the
country, the Minister of Energy has assigned to "TEC Maritsa Iztok 2" EAD a total annual quota of 2,628,000
MWh for mandatory purchase of electricity during the regulatory period from 01.07.2024 to 30.06.2025,
produced from local primary fuel sources, representing approximately 9.35% of all primary energy necessary
for the production of electricity consumed in the country in the calendar year 2023. By Order No. E-RD-16-
2729 of 13.12.2024, the total annual quota of 2,628,000 MWh was replaced with "up to 3,155,000 MWh".
Pursuant to Art. 93a, para. 1, item 3 of the Energy Act, the quantities determined by Order No. E-RD-16-
2729 of 13.12.2024 for the period 01.01.2025-30.06.2025 should be purchased by the Public Supplier (NEK
EAD) and sold to satisfy the requests of the end suppliers to cover the consumption of household consumers.
With the amendments to the Energy Act, in force from 10.06.2025, as of 01.07.2025, the functions of NEK
EAD as a public supplier for purchasing energy under quotas determined by the Energy Regulatory
Commission under Art. 93a, para. 1 for the purpose of selling to end suppliers of household end customers
were abolished. With the same amendments to Art. 100, para. 8 and para. 9 of the Energy Act, a mechanism
was created for supplying end-user customers through transactions with non-standard long-term products on
an organized exchange market. On the basis of Art. 100, para. 9 item 2 in connection with Art. 100 para. 8
of the Energy Act, on 16.06.2025, the company concluded with NEK EAD (balancing group coordinator) a
contract for the purchase and sale of electricity for participation through a balancing group coordinator in
auctions on an organized exchange market for sale to end suppliers. The contract is in force from 01.07.2025
and is valid until the mechanism introduced in Art. 100, para. 8 of the Law on Economic Activities is
repealed. For the period from 01.07.2025 to 30.06.2026, the purchase and sale of 3,155,000 MWh of active
electricity with estimated monthly distribution of quantities and load modulation have been agreed.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
24
As a result of the changes in the functioning of the electricity market and the elimination of the production
quota for "THP Maritsa East 2" EAD, as of 01.07.2025, in 2025 the plant sold 2,524,050 MWh on the free
market (compared to 604,617 MWh sold on the free market in 2024), while sales at regulated prices, carried
out only in the first half of 2025, decreased to 1,348,028 MWh (compared to 3,233,217 MWh for 2024).
The average selling price of electricity produced by Maritsa East 2 TPP EAD in all directions in 2025 is
294.32 BGN/MWh, which represents a decrease of 3.5% compared to the average selling price reached in
the previous year. The lower average selling price and the quantities of electricity sold result in a moderate
decrease of 2.8% on an annual basis in revenues from electricity sales, which in 2025 amount to BGN
1,172,644 thousand. The company's net financial result during the period under review was negative -
216,150 thousand BGN compared to a loss of 101,595 thousand BGN reported a year earlier. The
deterioration in the result is largely due to higher costs for greenhouse gas emissions in 2025.
With the owned hydroelectric plants and PSHPP, NEK EAD is the largest producer of energy from renewable
energy sources in the country, which actively participates in the regulated and free market and in the control
and regulation of the electricity system. The production of electricity from its own hydroelectric power plants
and combined hydropower plants in 2025 was typical of a dry year, with the hydroelectric power plants in
the structure of NEK EAD producing 1,839,773 MWh compared to 1,861,165 MWh of production reported
for 2024. Compared to last year (when production was also typical of a dry year), a minimal decrease in the
quantities produced by hydroelectric power plants was reported by 1.1% or 21,392 MWh less. The trend
from the previous year persists, with water resources in the reservoirs managed by NEK EAD remaining at
insufficient volumes due to the dry period, in connection with which the company has been endeavoring to
conserve the water resource. Despite the low production during the year, the hydroelectric power plants in
the structure of NEK EAD actively participate in the balancing market and are an important part of the
management and regulation of the electricity system in the country.
During the period under review, NEK EAD fulfilled its obligations in accordance with its licensing activities
and provided the necessary amount of electricity to the End Suppliers in 2025. Until 30.06.2025, the company
sold electricity to the End Suppliers through the Public Supply license, and from 01.07.2025, it continues to
supply them with electricity through the trading license through the Auctions - End Supplier Mechanism.
With the amendments to the Energy Act dated May 30 and June 10, 2025, the Public Supply license of NEK
EAD was terminated, and a full liberalization of the wholesale electricity market was implemented, effective
as of July 1, 2025. This full liberalization applies solely to wholesale trading, whereas retail liberalization
for household consumers has been postponed with no fixed deadline. In accordance with the amendments to
the Energy Law of 01.07.2025, end suppliers purchase electricity on market principles through the Tenders-
End Supplier Mechanism (from NEK EAD through the trading license) and sell it to household consumers
at prices containing a regulated component.
In 2025, NEK EAD sold 15,496,625 MWh of electricity on the regulated market and on the platforms of
IBEX and the free market, including through the Auction Mechanism - End Supplier. Reported electricity
sales are 2.7% higher than the reported sales by NEK EAD for the previous year 2024, when they were at a
level of 15,096,485 MWh. The increase in electricity sales in quantitative terms is 400,140 MWh in 2025
and is entirely due to the growth in sales to End Suppliers, as their relative share (90.1% in 2025) continues

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
25
to be the highest of all electricity sold by the company. The average selling price of electricity achieved by
NEK EAD in all directions in 2025 amounts to 172.86 BGN/MWh, which is 27.35% more than the
company's average selling price a year earlier (135.74 BGN/MWh). The reported significant growth on an
annual basis is a result of the full liberalization of the wholesale electricity market, effective from 01.07.2025.
The higher average selling price, as well as the higher quantities of electricity sold, led to a significant
increase (30.73% on an annual basis) in the company's sales revenue, which in 2025 amounted to BGN
2,678,824 thousand compared to BGN 2,049,146 thousand reported in 2024. In 2025, NEK EAD's net profit
increased to BGN 281,231 thousand, reporting an annual growth of 102.19% compared to a net profit of
BGN 139,090 thousand reported a year earlier. It should be borne in mind that the growth in the reported
financial result of NEK EAD on an annual basis in 2025 is in conditions of less reported revenues from the
FSES compared to those of the previous year, which is due to the changed compensation structure from the
fund according to the price decisions for the regulatory periods 2024-2025 and 2025-2026 and the
elimination of the reimbursed costs for consumed electricity from the End Suppliers, which was the largest
item in the revenues from the FSES in 2024.
In 2025, ESO EAD continued to carry out the activities of operation, maintenance, expansion, reconstruction,
modernization and ensuring the reliable functioning of the electricity transmission network, including the
availability of all necessary additional services, maintenance and development of auxiliary networks, repair
activities and services in the field of energy.
For the period January – December 2025, the volume of electricity sustained in the country, for which the
transmission system operator ESO EAD is owed an access fee for end-users and transmission, amounted to
33,663,561 MWh, which is 872,535 MWh, or 3% more compared to 2024 (32,791,026 MWh). In 2025, the
volume of electricity for which an access fee is owed by generators, excluding solar and wind energy
generators, amounted to 28,709,894 MWh, which is 484,148 MWh, or 2%, more compared to the previous
year (28,225,746 MWh), while the volume for which an access fee is owed by solar and wind electricity
generators was 7,528,466 MWh, which is 1,006,829 MWh (15%) more compared to 2024 (6,521,637 MWh).
In 2025, ESO EAD reported a net profit of BGN 262,006 thousand, representing a 1.2% decrease compared
to the result achieved a year earlier (2024: BGN 265,184 thousand). The reported moderate decline in the
company's financial result for 2025 is mainly due to higher costs for purchasing energy for the balancing
market and for purchasing energy for technological transmission costs, due to the higher reported purchase
price for 2025. It should be noted that the financial condition of the transmission operator depends largely
on external factors such as electricity consumption and production, the price of electricity on European
exchange markets and in the region, amendments to the Energy Act, as well as the decisions of the Bulgarian
Electricity Regulatory Commission.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
26
• Natural Gas Segment
Natural gas 2025 2024 Change 2025/2024
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 2,300,093 2,341,614 (41,521) (1.77%)
- other segments 231,430 242,327 (10,897) (4.50%)
Segment Revenue 2,531, 523 2,583,941 (52,418) (2.03%)
Changes in production and WIP balances (48) 15 (63) (420.00%)
Carrying amount of natural gas,
electricity and other assets sold (1,635,672) (1,654,435) 18,763 1.13%
Expenses for materials (6,734) (7,633) 899 11.78%
Hired services expenses (52,550) (44,805) (7,745) (17.29%)
Depreciation and amortization expenses (338,642) (305,660) (32,982) (10.79%)
Personnel expenses (93,216) (87,290) (5,926) (6.79%)
Impairment of sales receivables, net (43,819) (71,895) 28,076 39.05%
Impairment of property, plant and
equipment, net - 431 (431) (100.00%)
Other operating expenses (68,118) (126,074) 57,956 45.97%
Costs for provisions (48,812) (34,351) (14,461) (42.10%)
Technological costs of natural gas (152,576) (140,208) (12,368) (8.82%)
Operating profit from the segment 91,336 112,036 (20,700) (18.48%)
The operations of transmission, transit, storage and public supply of natural gas are carried out based on
licenses issued to Bulgartransgaz EAD and Bulgargaz EAD in compliance with the Energy Act and the
secondary legislation which follows the European legislation in the field and the regulatory requirements of
EWRC.
In 2025, the amount of natural gas transmitted to consumers on the territory of the country is 27,655,910
MWh (2024: 27,850,701 MWh), which is comparable to the levels of the previous year, with a slight decrease
of 194,791 MWh (0.7%). Traditionally, the seasonality in natural gas transmission persisted in 2025, with
the highest volumes being transmitted in December – 3,261,275 MWh, and the lowest volumes transmitted
in August – 1,519,698 MWh. The dynamics of the monthly change in transported natural gas shows that the
most significant increase in 2025 compared to 2024 was recorded in the months of February, April and
December.
The deviation in the quantities of natural gas transported to exit points in the country is due to a complex of
factors, including changes in natural gas consumption, influenced by temperature conditions during the

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
27
period, as well as by the dynamics of consumption by the main customer groups. The largest decrease was
recorded in August – by 17.22% or 316,211 MWh, while the smallest decrease was recorded in July – by
1.71% or 27,162 MWh.
In 2025, the total amount of transited natural gas to neighbour countries was 194,874,041 MWh (2024:
174,925,007 MWh), with a steady increase of 19,949,034 MWh, or 11.4% compared to 2024. The growth is
mainly due to increased flows to Romania and Serbia, which reinforce the importance of Bulgarian
infrastructure as a strategic supply route in the Southeastern Europe region. The reported changes to
neighboring countries are as follows:
• The most significant increase is reported in the direction of Romania, with 74.4%, or 17,981,717 MWh
more compared to 2024;
• In the direction of Serbia, an increase of 4.0% was reported, or 4,413,431 MWh more compared to
2024;
• In the direction of Greece, a decrease of 5.7% was reported, or 2,129,311 MWh less compared to
2024;
• In the direction of North Macedonia, a decrease of 8.4% was reported, or 316,802 MWh less compared
to 2024.
The quantities transmitted in the direction of Serbia have the largest share in the total transit of natural gas
in 2025 – 58.5%, followed by the direction of Romania with a share of almost 21.6%. The least transited
quantities were to North Macedonia - only 1.8% of the total transit.
No cross-border transmission of natural gas to the Republic of Turkey took place during the period 2022-
2025, as the commissioning of the Turkish Stream gas pipeline, through which Turkey supplies its own
natural gas, started in early January 2020.
The activity "Natural gas storage" is carried out in the only underground gas storage facility on the territory
of the country - Chiren, owned by Bulgartransgaz EAD. The technological process related to the natural gas
storage service is seasonal (cyclic) and is expressed in the extraction and injection of gas from/into the
underground gas storage. In 2025, the volume of extracted natural gas amounted to 4,285,760 MWh, which
is 701,517 MWh (14.1%) less compared to the volumes in 2024 (4,987,277 MWh). The reported natural gas
injected into the Chiren UGS facility in 2025 amounted to 4,791,466 MWh, which is 334,465 MWh (7.5%)
more than the gas injected during the same period of 2024 (4,457,001 MWh).
In 2025, the trend of maintaining a high level of gas storage capacity utilization in line with European
measures to ensure security of supply continues. As of 31.12.2025, the natural gas stored for customers at
Chiren UGS was 4,657,744 MWh compared to 4,079,062 MWh stored in 2024.
Gas Hub Balkan (GHB) EAD was established as an operator of a natural gas trading platform in accordance
with the Bulgarian Energy Law. In 2025, GHB offered the following services for access to its e-commerce
platform: i) Short-term (spot) segment, which offers short-term standardized products "within the day", "day
ahead", as well as time and local products for the needs of balancing the network of the transmission system
operator. Trading is conducted on an anonymous basis, in accordance with the provisions of Regulation (EU)
No. 312/2014; ii) Long-term segment, where products traded on a medium-term and long-term basis are
offered – weekly, monthly, Balance of Month, quarterly, seasonal (summer and winter half-year), and annual.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
28
iii) Brokerage service, which enables the conclusion of gas purchase contracts by end-users/end-suppliers
directly connected to the gas transmission system of Bulgaria, without incurring membership costs on the
trading platform and without the need to obtain access to the access and transmission services through the
network of the transmission system operator Bulgartransgaz EAD.
In 2025, the volumes under transactions on the short-term segment increased by 1.94% year-on-year, or by
313,379 MWh, reaching 16,466,760 MWh compared to those reported in 2024 (16,153,381 MWh). The
volumes under transactions on the long-term segment in 2025 amounted to 21,634,395 MWh, which is 17.2%
less compared to the same period of the previous year (2024: 26,123,714 MWh).
At the end of 2025, there were 126 registered participants in the BGH, of which three transmission network
operators and one mining company.
The activity of Bulgargaz EAD (public supply of natural gas) is regulated by the Energy Act and the bylaws.
With the amendment of Art. 30 par. 1 item 7 of the Energy Act (EE) promulgated in SG No. 79 of 2019,
effective as of 01.01.2020, Bulgargaz EAD, in its capacity as a public supplier, sells natural gas at regulated
prices solely to: i) end-suppliers of natural gas; ii) persons who have been issued a license for the generation
and transmission of thermal energy. All other customers directly connected to the gas transmission network
are excluded from the regulated market.
After the changes in the legislation, Bulgargaz EAD conducts its activities as follows: i) on the regulated
market under contracts at an exit point of the gas transmission system of Bulgaria – at prices regulated by
the EWRC; ii) on the free market under contracts with customers directly connected to the gas transmission
system – at freely negotiated prices; iii) on the organized exchange market in the country and in the countries
where the company holds a trading license – at freely negotiated prices; iv) others, outside the organized
exchange market (on the domestic and international markets) – at freely negotiated prices (most frequently
applying the formula 'TTFfm price + premium', where TTFfm is the main reference virtual trading
marketplace for gas in Europe, based in Amsterdam, the Netherlands); v) sale of services (SWAP operations
and others) and extraordinary sales.
In June 2025, Bulgargaz EAD registered its subsidiary under the name 'Bulgargaz North', through which it
conducts natural gas trading activities within the territory of Moldova. On 19.08.2025, by Decision of the
regulator of the Republic of Moldova, "Bulgargaz North" received a license for trading in the Republic of
Moldova. In July 2025 Bulgargaz EAD concluded a standardized supply agreement (EFET agreement) with
the Moldovan company Energocom S.A. The purpose of the concluded contract is access and provision of
an opportunity for Bulgargaz EAD to participate in the tenders organized by “Energocom” S.A., financed
within the framework of the loan granted to them by the EBRD for the purchase of natural gas or own funds.
As of January 1, 2025, the transit contract for the transmission of Russian natural gas through Ukraine to
Europe expired. Almost a third of Russian gas sold in Europe was transported through the territory of
Ukraine. As a result, Ukraine, like other European countries, is suffering serious economic, social and
geopolitical consequences. The resolution of the emerging energy crisis, combined with the availability of
reserved capacity for access to the Greek and Turkish terminals by Bulgargaz EAD, represents a potential
business opportunity for expanding the activities of Bulgargaz EAD through its entry into the Ukrainian
market. On 24.07.2025, Bulgargaz EAD concluded a framework EFET agreement with the state-owned
company Naftogaz Ukraine, which enabled Bulgargaz EAD to participate in the auctions organized by it

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
29
with a delivery point and exit points of the gas transmission networks of countries neighboring Ukraine.
After participating in several tenders, it was found that Bulgargaz's costs for transmission to such points
significantly exceed the costs of other companies located in close proximity to Ukraine and Bulgargaz EAD's
prices are not competitive. In order to make sales in Romania, Moldova and Ukraine, Bulgargaz EAD
reserves annual capacities on the relevant routes. Subsequently, however, these capacities became
uncompetitive due to decisions by the regulatory authorities of Greece, Bulgaria, Romania, Moldova and
Ukraine to introduce route capacity products from VTT Greece to Ukraine, offered at a significant discount
compared to the established standard capacity products.
For 2025, the reported quantities of natural gas sold are 17,552,950 MWh, and compared to those for 2024
(17,806,287 MWh), they decrease by 253,337 MWh, or 1.42%.
In 2025, the following trends were reported:
• the main consumers of natural gas remained enterprises in the Energy sector, as well as
Distribution companies, with these sectors experiencing a growth in consumption of 4.7%
(Energy) and 18.2% (Distribution companies) respectively compared to the reporting period of
2024;
• A decline in sales was reported in the remaining sectors, with the exception of Building Materials
and Construction, with the most significant decrease being reported in the Metallurgy (63%) and
Glass and Porcelain (35%) sectors compared to 2024.
In 2025, the largest relative share in the structure of natural gas sales had those on the regulated market -
14,124,844 MWh or about 80.5% of the total sales. In second place in terms of relative share are the sales at
free prices on the local and regional market (VTP) - respectively 2,768,793 MWh, or 15.8% of the total
quantities. The lowest share is the sales of the Anonymous/non-anonymous segment for the regional
exchange market – 659,913 MWh, or 3.8% of total sales.
To meet the natural gas needs of its customers, as of 31.12.2025, Bulgargaz EAD has delivered 18,006,026
MWh of natural gas (for 2024: 17,738,287 MWh). In 2025, the company purchased pipeline natural gas in
the volume of 10,095,664 MWh, liquefied natural gas (LNG) in the volume of 7,034,028 MWh, purchased
volumes at a virtual trading point (VTP) in the volume of 668,431 MWh, and natural gas purchased under
balancing contracts in the volume of 207,903 MWh.
The main supplies of natural gas, guaranteeing the consumption of the company's customers, are provided
through:
• concluded contracts for the supply of liquefied natural gas for 2025 as a result of tender procedures
for liquefied gas supply terminals in Turkey and Greece (Alexandroupolis);
• a long-term contract concluded with Azerbaijan Gaz Supply Company (AGSC), which is
implemented in full from 01.10.2022 with the launch of the IGB interconnection;
• natural gas purchase and sale agreement with BOTAŞ providing capacity for regasification and
transmission through interconnection point Strandzha 1 - Malkochlar.
• the terminal in Alexandroupolis, which was put into commercial operation on October 1, 2024,
through which supplies of liquefied natural gas (LNG) were made to the Bulgarian market. The
capacity reserved by Bulgargaz EAD for the next 10 years amounts to 10,600,000 MWh per year.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
30
At the end of January 2025, an accident occurred at the terminal in the city. Alexandroupolis, causing
it to suspend operationswork until 01.08.2025.
To ensure the security and continuity of natural gas supplies and to cover the seasonality for its customers,
Bulgargaz EAD uses the capacity of the underground gas storage facility at Chiren UGS, owned by the
combined operator Bulgartransgaz EAD. The operation of the gas storage is cyclical, with the natural gas
injection period being "May-October" and the withdrawal period being "November-April".
In line with the Emergency Action Plan regarding the storage on natural gas quantities with a view to making
up for seasonal variations for its clients, Bulgargaz EAD is obliged to pressurize, store and extract certain
quantities of natural gas by taking part in the public procedure of Bulgartransgaz EAD for distributing
capacities to be stored with Chiren UGS. The quantities of natural gas produced by Bulgargaz EAD as of
31.12.2025, amounted to 1,126,801 MWh, which is 1,072,874 MWh or 48.77% less than in the previous
period (31.12.2024: 2,199,675 MWh). The higher production in 2024 was related to the condition that the
quantities of natural gas subject to compensation must be produced and delivered to final customers and/or
final suppliers in the European Economic Area, according to the application of the compensation mechanism
under the Compensation Program for companies that pressurized natural gas into the underground gas storage
between 01.05.2022 - 11.10.2022.
In 2025, the injected volumes of natural gas amounted to 1,221,102 MWh, which is 335,421 MWh less
compared to 2024, when they stood at 1,556,523 MWh. As of December 31, 2025, the Company has a stock
of 2,664,535 MWh of gas in the Chiren UGS facility, representing an increase of 94 301 MWh, or 3.67%,
compared to the previous period.
The development of the natural gas market in 2025 continued the trend of increasing the share of LNG
deliveries started in 2022 and 2023, in view of the reduced pipeline gas deliveries from Russia to Europe.
Since the beginning of 2025, there has been a trend of high natural gas prices on European gas markets, due
to the faster emptying of gas storage facilities and the relatively cold winter.
In January 2025, the terminal in Alexandroupolis suffered serious damage, suspending operations until
August 2025. This forced LNG supplies to be redirected to terminals in Turkey. As a result, in 2025, capacity
utilization under the agreement with BOTAŞ reached nearly 23%.
In 2025, there is a trend of increased demand for natural gas from Bulgargaz EAD customers, compared to
the quantities declared in their annual programs. This is due to three main reasons:
✓ the suspension of Russian gas transit through Ukraine and the associated increased demand;
✓ competitive prices outside the regulated market, thanks to a flexible pricing policy;
✓ The current delivery prices at which Bulgargaz EAD receives the quantities under its long-term
contract with the Azerbaijani company are lower than the current prices of European gas hubs, which
enables the company to form a mix between the quantities under the long-term contract and spot
supply contracts for liquefied natural gas at prices close to market levels.
Bulgargaz EAD supplies liquefied natural gas within the reserved slots for regasification at the terminal in
the town of Alexandroupolis and according to a signed Agreement with BOTAŞ for regasification, storage

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
31
and subsequent transmission to the Bulgarian border. The conclusion of the Agreement provided three
interchangeable sources, contributing to increasing security of supply.
In January 2025, due to temporary supply disruptions, Bulgargaz EAD received only 60% of the volume
under the Azerbaijani contract, and at the end of the same month, an accident occurred at the terminal in
Alexandroupolis. In order to meet this month's consumption, the quantities planned for delivery under the
long-term contract with the Azerbaijani company, as well as those from the terminal, were replaced with
supplies from Turkey from previous liquefied gas deliveries made by Bulgargaz EAD, which are stored on
the territory of Turkey. Considering that the FSRU Alexandroupolis terminal was not operating, Bulgargaz
EAD had to redirect all contracted supplies of liquefied natural gas from Alexandroupolis to Turkey, taking
into account the terms of the signed contracts with suppliers.
• Coal Segment
Coal 2025 2024 Change 2025/2024
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 201,732 227,996 (26,264) (11.52%)
- other segments 160,014 153,277 6,737 4.40%
Segment Revenue 361,746 381,273 (19,527) (5.12%)
Changes in finished goods, work in
progress and costs for overburden removal 22,426 38,236 (15,810) (41.35%)
Costs for acquisition of property, plant and
equipment 11,923 9,637 2,286 23.72%
Carrying amount of natural gas, electricity
and other assets sold (10,020) (9,176) (844) (9.20%)
Expenses for materials (105,890) (96,051) (9,839) (10.24%)
Hired services expenses (50,414) (32,590) (17,824) (54.69%)
Depreciation and amortization expenses (63,222) (86,597) 23,375 26.99%
Personnel expenses (374,425) (386,055) 11,630 3.01%
Impairment of sales receivables, net (142) (132) (10) (7.58%)
Impairment of property, plant and
equipment, net - (19,572) 19,572 100.00%
Other operating expenses (30,000) (6,166) (23,834) (386.54%)
Costs for provisions (3,547) (70,575) 67,028 94.97%
Operating loss for the segment (241,565) (277,768) 36,203 13.03%
The lignite coal extracted by Mini Maritsa-Iztok EAD is intended for the supply of the thermal power plants
in the Maritsa East complex (TPP Maritsa East 2 EAD, ContourGlobal Maritsa East 3 AD, AES Maritsa –
3C Maritsa East 1 EOOD and Brikel EAD), with which the subsidiary is linked in terms of technology and
market.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
32
One of the priorities in the activity of Mini Maritsa-Iztok EAD is the implementation of the planned
overburden activities aimed at stabilization of the mining horizons and the increase of the land resistance
coefficient. Therefore, the production levels are consistent on one hand with the extraction opportunities
provided by the land, and on the other hand with the needs of the plants that the company supplies. The
extracted and sold coal in 2025 amounts to 15,549 thousand tons, 1,804 thousand tons (13.1%) more than
the quantity in 2024 (13,745 thousand tons), due to the reported growth in demand from almost all thermal
power plants in the Maritsa East complex, with the exception of ContourGlobal Maritsa East 3 AD, where
the decrease in lignite coal consumption is from 838 thousand tons in 2024 to 628.6 thousand tons in 2025
or by 209.4 thousand tons (25%). After the expiration of the lignite coal supply agreement between "Mini
Maritsa-Iztok" EAD and "ContourGlobal Maritsa Iztok 3" AD (ContourGlobal) on 21.02.2024, a new lignite
coal supply agreement was concluded between the same parties on 15.10.2025 with a term of two years.
The extraction volume for the period 01.01.2025 - 31.12.2025 amounts to 32,433 thousand cubic meters. It
is higher compared to the same period in 2024 by 2,366 thousand cubic meters (7.87% increase).
The reported mining volume for 2025 is 45,196 thousand cubic meters and is 3,867 thousand cubic meters
more (9.36% increase compared to 2024).
The selling prices of the lignite coal volumes sold by the company to counterparties within the country during
the reporting period were based on a price of BGN 87.35/TCF, maintaining the same price levels from 2023.
• Administrative Activity Segment
Administration activity 2025 2024 Change 2025/2024
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 3,991 4,590 (599) (13.05%)
- other segments 807,294 625,342 181,952 29.10%
Segment Revenue 811,285 629,932 181,353 28.79%
Expenses for materials (249) (237) (12) (5.06%)
Hired services expenses (8,027) (7,826) (201) (2.57%)
Depreciation and amortization expenses (1,276) (1,490) 214 14.36%
Personnel expenses (13,592) (12,450) (1,142) (9.17%)
Impairment of sales receivables, net 10,894 (62,677) 73,571 117.38%
Impairment of property, plant and
equipment, net - (13) 13 100.00%
Other operating expenses (925) (1,315) 390 29.66%
Operating profit from the segment 798,110 543,924 254,186 46.73%
Administrative activities are mainly carried out by the parent company BEH EAD, as this segment also
includes the activities of Minproekt EAD. The financial situation of its subsidiaries is the primary factor that

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
33
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 2025, the recognized income from dividends and equity interests (including income from
interest on arrears) amounted to BGN 817,472 thousand compared to BGN 632,297 thousand of received
income from dividends and equity interests in 2024. The most significant portion thereof consists of dividend
income from ESO EAD in the amount of BGN 370,184 thousand, followed by dividend income from NPP
Kozloduy EAD and NEK EAD, amounting to BGN 199,722 thousand and BGN 139,091 thousand,
respectively. The recognized dividend income in 2025 is higher on a year-on-year basis because, during the
period under review, the dividend distribution rate for commercial companies with state participation in the
capital was increased to 100% of the companies' net profits, after deducting unrecovered losses from prior
years and allocations to the Reserve fund, pursuant to Council of Ministers Decree No. 1 dated May 2, 2025
on the determination and payment to the benefit of the State of deductions from the profit of state enterprises
and commercial companies with state participation in the capital. For comparison, in 2024, the dividend
deduction was set at 50% of the companies' net profits, after deducting unrecovered losses from prior years
and allocations to the Reserve fund.
At the profit before tax level, the result reported in 2025 for BEH EAD was BGN 909,813 thousand and was
higher by BGN 235,935 thousand than the reported profit before tax in 2024 in the amount of BGN 673,878
thousand. This result was influenced by the reported net finance income in 2025 in the amount of BGN
97,214 thousand (for comparison, in 2024, net finance income amounted to BGN 119,332 thousand). A
significant portion of the company's financial income is from interest on loans granted to subsidiaries. In
2025, the reported financial expenses of the company amounted to BGN 127,437 thousand (BGN 73,623
thousand in 2024) and mainly reflect the accrued interest on the non-matured bond issues of BEH EAD, as
well as the effect of an agreement for rescheduling of interest obligations with NEK EAD.
3.2. Ratios
• Profitability of revenue - net profit/operating income
2025
report
2024
report
% change
2025/2024
0.012 0.028 (57.14%)
This indicator summarizes the overall efficiency of the operations of BEH-group.
• Return on Equity (ROE)
2025
report
2024
report
% change
2025/2024
0.005 0.012 (58.33%)
The ratio indicates the efficiency of turning the equity into profit.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
34
• Return on Assets (ROA)
2025
report
2024
report
% change
2025/2024
0.003 0.008 (62.50%)
The ratio provides information about the efficiency in turning the assets into profit.
3.3. Compliance with the covenants according to the terms and conditions of the bond issues of
BEH EAD
The values of the covenants that BEH EAD is obliged to observe on a consolidated basis according to the
terms of the bond issues placed are as follows:
Covenants as of 31.12.2025 as of 31.12.2024
EBITDA Coverage ratio > 4.0 6.48 8.44
Debt Coverage ratio < 4.5 1.06 (0.18)
3.4. Commitments, contingent liabilities and other significant events
Litigation and claims arise during the normal course of business of the Company. The Company's
management is of the opinion that the costs necessary to resolve these disputes and claims will not have a
material effect on the financial status and cash flows in future financial periods.
Bulgarian Energy Holding EAD
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 the natural gas storage facility) in Bulgaria, such as explicitly or tacitly denying access to third
parties or delaying it;
• 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 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.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
35
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 September 30, BEH Group provided an answer.
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.
On December 10, 2025, an oral hearing of the parties in Case C-14/24 P was held before the Court of Justice
of the European Union in Luxembourg.
On April 23, 2026, the Advocate General presented their opinion on the case. A final judgment of the CJEU
is expected to be rendered by the end of 2026, and therefore the provision has been reclassified as a current
liability.
As of 31.12.2025, the Group recognized a provision in connection with case COMP/B1/АТ.39849 – BEH
gas in the amount of BGN 161,145 thousand (31 December 2024: BGN 161,145 thousand).
4. Risk factors
The Group's risk management policies identify and analyse the risks affecting the Group, set risk limits for
individual types of risks, define rules for risk control and compliance with the established limits. Risk
management policies and systems are subject to regular review in order to identify the changes occurred in
the market and activities. By trainings and application of the established standards and procedures, the Group
aims to develop discipline and constructive control environment where all employees understand their role
and obligations. The main types of risks to which the Group is exposed in the course of its business are as
follows:
4.1. Interest rate risk
Interest rate risk is the risk of adverse change in interest rates leading to an increase in interest expenses
and/or a decrease in the company's interest income.
The Group is exposed to the risk of changes in market interest rates mainly in relation to the financial assets
and liabilities with a variable (floating) interest rate, as well as in relation to defined staff benefit plans,
calculated on the basis of a discount factor which is determined at the basis of the market yield of government
securities.
The interest-bearing assets in the structure of the Group's assets are represented by bank deposits and loans
granted, the majority of which have a fixed interest rate. The Group also has loans granted with a
combined structure of the borrowing rates, which contains two components – fixed and variable. The
borrowings of the Group are in the form of long-term and short-term loans and predominantly have a
fixed interest rate. This minimizes the likelihood of a change in the unfavorable direction of cash flows.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
36
4.2. Currency risk
The Group carries out purchases, sales, lending and borrowing operations in foreign currencies – US Dollars,
Japanese Yen, British Pounds, Swiss Francs and Macedonian Denars. The bulk of these transactions are
carried out in US dollars, such as payments for construction, deliveries of goods and assets under
construction. In this regard, there is a risk of changes in exchange rates. Consequently, the Group is exposed
to the risk of changes in the exchange rate of the US dollar. In the event of material fluctuations in the future,
the Group may hedge its exposure through derivative instruments such as foreign currency swaps.
4.3. Liquidity risk
Liquidity risk arises if the Group fails to meet its obligations when they become due. The group carries out
ongoing monitoring and control of cash outflows and applies an approach that ensures the necessary liquidity
resource to meet the obligations incurred under normal or stressful conditions without realizing unacceptable
losses.
One of the objectives of the parent company is to provide, if necessary, financial resources to its subsidiaries
in order to maintain their operations and to implement certain strategic projects.
The parent 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 in the corporate structure,
coordinating the conditions between them and monitoring for the execution of transactions at market
levels. The interest rates on cash loans and foreign currency deposits are tied to a rate that is the market
rate for such transactions during the transaction period (floating or fixed).
• External financing – in case of shortage 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. The holding has successfully implemented 5 (five) bond issues from 2013 to date. The funds
raised were used to implement investment projects, repay and refinance loans, as well as for general
corporate purposes, with the exception of coal-related activities.
4.4. Market risk
The manifestation of the risk is expressed in a change in market conditions in terms of prices, exchange rates,
interest rates or capital instruments and their impact on the Group's income from the investments made. The
purpose of market risk management is to exercise control over the exposure to market risk within acceptable
parameters by optimizing returns.
The Group undertakes periodic analyses of the macroeconomic environment in the country and in-depth
analysis of specific macro-indicators, including information on interest rates, which are submitted to the
Board of Directors. The Board is responsible for assessing the future risks faced by the Group. In the event
of deteriorating market conditions, hedging instruments may be used.
4.5. Credit risk
In the course of its activities, the Group is exposed to credit risk, which is associated with the risk for some
of the counterparties not to be able to fulfill their obligations in full and within the usual deadlines. In this
regard, the credit quality of the customers is assessed taking into account financial status, past experience

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
37
and other factors. Regular monitoring of the evaluation results is carried out, on the basis of which, if
necessary, impairment is charged, according to the applicable international accounting standards.
The Group's receivables are presented in the consolidated statement of financial position in net amount in
net amount, after deducting the accrued impairment for the expected credit loss.
In relation to the credit risk of uncollectability of receivables from counterparties, the Group takes the
following precautionary measures:
• 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 other contracts that are not secured, the following usual measures are taken in advance in case of
overdue payment by the debtor company – offsetting liabilities to the Group against overdue
receivables of the debtor, and if the amount of the liabilities is not big enough to cover the
receivables, then other out-of-court options for settling the claims are sought.
The Group is currently monitoring and analysing the servicing of the receivables, the reasons for the defaults
and the changes in the financial capacity of the debtor companies and the status and quality of the collaterals
received.
The group has a significant concentration of credit risk in respect of receivables from Toplofikatsia Sofia
EAD.
Credit risk arising from other financial assets of the Group, such as cash and other financial assets, is the
credit exposure of the Group arising from the likelihood that its contractors may fail to meet their obligations.
The Group's maximum credit exposure with respect to its financial assets amounts to their respective carrying
amount in the consolidated statements of the financial position as of 31 December 2025.
4.6. Regulatory risk
Regulatory risk is determined by the specifics of the business activity. Pursuant to Art. 21, paragraph 1, item
8a, item 8b, item 8c, 8d, 8g, 8h, 8i, Art. 30, para. 1 and Art. 33a of the Energy Act, the following prices are
subject to regulation by the EWRC:
o determines for each price period a limit value of the costs of the electricity transmission network
operator for purchasing availability for additional services by the order of art. 105, para. 2;
o determines annually by June 30 premiums for electricity from renewable sources and from high-
efficiency combined production of electricity and heat, generated by power plants with a total installed
electrical capacity of 500 kW and over 500 kW
o determines a monthly compensation to cover part of the costs of household final customers for
purchased electricity from a final supplier;
o for the purposes of pricing, determines annually by June 30 an estimated market price of electricity to
cover the technological costs of the transmission system operator and the distribution system
operators;
o monitors market developments, assesses risks that may arise from new products and services, and
takes measures against abuse;

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
38
o controls the possibility for transmission system operators to impose limits on the capacity provided or
operational restrictions, based on transparent and non-discriminatory procedures that do not create
barriers to market entry;
o may allow the transmission network operator and distribution network operators to carry out activities
other than those provided for in this law and in Regulation (EU) 2019/943 of the European Parliament
and of the Council of 5 June 2019 on the internal electricity market (OJ, L 158/54 of 14 June 2019),
hereinafter referred to as "Regulation (EU) 2019/943", if these activities are necessary to fulfill their
obligations under this law or Regulation (EU) 2019/943;
o at which the producers sell thermal energy to the heat transmission company and to directly connected
customers;
o at which the heat transmission company sells thermal energy to customers;
o at which the public supplier sells natural gas to the end suppliers of natural gas and to a person who
has been issued a license for production and transmission of heat energy; the prices are approved on
monthly basis and are applied from the first day of the month for which they are approved;
o at which end suppliers sell natural gas to customers connected to the respective gas distribution
networks;
o for access and/or transmission through the transmission grid;
o to connection to the grids;
o for access and transmission of natural gas through transmission and/or distribution networks, except
in the cases where the Commission at its discretion approves a methodology for setting a price for
access and transmission through the transmission grid;
o for access and/or transmission through the electricity distribution grids;
o for access and storage of natural gas in a storage facility;
o for distribution of traction electricity on the distribution grids of the railway transport;
o For the provision of services to customers, as determined by the Commission, related to the licensing
activity;
o including the price or the price component at which all end customers connected to the electricity
system, including the electricity transmission system operator and the electricity distribution network
operators, shall contribute for compensation of the costs under Art. 34 and Art. 35.
o The Commission sets premiums for power plants with a total installed electrical capacity of 500 kW
and over 500 kW for the electricity produced from highly efficient combined heat and electrical energy
production;
o the premiums are determined annually until June 30 as the difference between the producers'
preferential prices and the estimated market price determined for that period for electricity produced
in a highly efficient combined manner.
Price regulation has a significant impact on revenues, expenses, and hence on the overall economic and
financial condition of the Group.
4.7. Cash flow risk
The cash flow risk depends on fluctuations in the amount of future cash flows associated with a possessed
financial instrument. The Group plans its cash flows and floating rate financial instruments are of a short-
term nature of less than 1 year.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
39
Detailed information regarding the Group's financial risk management objectives and policy and the main
categories of financial assets and liabilities, is included in the consolidated financial statements of BEH EAD
for 2025.
5. Future development, investments, forthcoming significant transactions and other information
under Art. 247 of the Commercial Act
5.1. Future development of BEH Group
The objectives of BEH Group are focused on the following main and priority areas:
Financial sustainability of BEH Group
• Improving corporate management practices
- Increasing the transparency and sustainability of BEH Group in accordance 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 the capital markets in order to attract external financing from international
financial institutions under competitive terms;
- Using the advantages that result from the scale of the holding structure (economy of scale);
- Securing the necessary credit resources under optimal conditions to finance projects of particular
importance to the Group's companies, in the context of climate change mitigation and the
sustainable development of a low-carbon economy.
• Cost Optimization within the BEH Group:
- Forecasting and planning the expenses of BEH Group;
- Transparency and predictability of expenses;
- Increasing the efficiency of the business activities.
• Decarbonization of BEH Group
- Integration of decarbonization goals with the strategic direction and development framework of
the energy sector in Bulgaria;
- Identifying possible solutions for sustainable development and decarbonization;
Ensuring the security of the energy system in the country
• 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;

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
40
- Increasing the technical capacity of the intersystem gas connection Greece-Bulgaria upon proven
binding market interest in accordance with the Exemption Decision for the IGB project issued by
the Regulatory Authorities EWRC and RAE dated 25.07.2018 and approved by the European
Commission.
• 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;
- Research of the possibilities and expediency of possible participation in other new investment
intentions to build terminals for liquefied natural gas in the region;
- Securing regasification and storage capacity for liquefied natural gas (LNG) at 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 electricity 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 life 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;
• 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.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
41
- A major ongoing project in this direction – Vertical Gas Corridor, which will expand the natural
gas transmission network in Southeastern and Central Europe in a south-north direction;
- Development and modernization of the electricity transmission network by increasing its capacity
with a view to the successful integration of renewable energy sources (RES) capacity.
5.2. Expected investments
Gas interconnector Greece-Bulgaria
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 the project, put into operation on 1 October 2022, the
construction of a gas pipeline with a capacity of 3 billion cubic meters per year from Komotini to Stara
Zagora town, with a length of 182 km, 151 km of which on Bulgarian territory, was carried out.
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.
The project for expanding the pipeline's capacity to 5 bcm/y is part of the Vertical Gas Corridor initiative
and is of significance for enhancing regional security of supply and diversification of sources and routes for
both the Bulgarian and neighboring gas markets.
Expansion of the capacity of Chiren underground gas storage
The only underground gas storage facility in the country Chiren is owned by Bulgartransgaz EAD. The
project for expansion of the capacity of Chiren UGS consists of step-by-step increasе of the capacity gas
storage facility on the territory of Bulgaria with the purpose of achieving larger volumes of stored gas,
increased pressures in the gas tank and higher average withdrawal and injection capacity. The project
provides for increasing the working gas volume to 1 billion cubic meters and increasing the withdrawal and
injection flow rates to 8 - 10 million cubic meters per day.
On 22 June 2022, a grant agreement was signed with the European Executive Agency for Climate,
Infrastructure and Environment (CINEA) for the co-financing of the expansion of the Chiren UGS with the
following identification number and name: Project 101069718 - 6.20.2-BG-W-M-21-Extension of the Chiren
UGS. The total value of the costs, according to the decision of the EC to approve the financing, is in the
amount of EUR 155,820 thousand. The amount of the non-repayable financial assistance is 50% of the value
under the grant agreement – up to EUR 77,910 thousand. As of the date of preparation of the financial
statements, Bulgartransgaz EAD has received EUR 38,955 thousand as an advance payment, or 50% of the
grant funding amount. In March 2025, Amendment No. 1 to the grant agreement was signed, according to
which the project implementation period was extended until 07.12.2027.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
42
For the purpose of supporting the Chiren UGS expansion project, the State Budget Act for 2026 provides for
a state guarantee in the amount of EUR 207.6 million in favor of Bulgartransgaz EAD.
Vertical Gas Corridor
On 19 January 2024, the Vertical Corridor Memorandum was renewed in Athens, Greece, in the framework
of the Interconnection Initiative - CESEC, which was joined by the gas transmission operators of Ukraine,
Moldova and Slovakia. The Vertical Corridor is a strategic route for the transmission of additional volumes
of natural gas from south to north from alternative sources for the region, including liquefied natural gas
(LNG) via the existing and future LNG terminals in Greece.
Participants in the Vertical Corridor initiative are the gas transmission operators of Bulgaria, Greece,
Romania, Hungary, Slovakia, Ukraine, and Moldova. Pursuant to a decision of the National Assembly dated
March 14, 2024 (published in State Gazette No. 23 of 2024), Bulgartransgaz EAD participates in the Vertical
Corridor initiative through the expansion of the gas transmission infrastructure and the implementation of
the following projects:
Project 1: Increasing the natural gas transmission capacity at the Kulata/Sidirokastro interconnection point
in the direction from Greece to Bulgaria;
Project 2: Increasing the natural gas transmission capacity at the Negru Voda/Kardam interconnection point
in the direction from Bulgaria to Romania;
Project 3: “High-pressure gas transmission infrastructure to supply consumers in the East Maritsa region”.
In implementation of the aforementioned decision of the National Assembly of the Republic to take action
in connection with the Vertical Gas Corridor initiative, BEH EAD increased the capital of Bulgartransgaz
EAD by a cash contribution in the amount of BGN 200,000,000 through the issuance of 200,000,000 new
ordinary registered voting shares with a nominal value of BGN 1 each. The entry in the Commercial Register
and the Register of the National Commercial and Commercial Center was made on 20 June 2024. The funds
from the capital increase are used by Bulgartransgaz EAD, specifically for the preparation and
implementation of the project initiative.
On December 2, 2025, a new capital increase of Bulgartransgaz EAD was registered in the Commercial
Register and the Register of Non-Profit Legal Entities by a cash contribution in the amount of BGN
95,292,033, through the issuance of 95,292,033 new ordinary registered voting shares with a nominal value
of BGN 1 each, with BEH EAD subscribing and acquiring the entire new share issue. The funds from the
capital increase are used by Bulgartransgaz EAD for the targeted implementation of projects in connection
with the Vertical Gas Corridor initiative.
The state-guaranteed financing under the Vertical Gas Corridor initiative was initially included in the State
Budget Act of the Republic of Bulgaria for 2025 in the amount of up to the currency equivalent of BGN 625
million. During the implementation of the project in 2025, state guarantees were issued with a total amount

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
43
of BGN 249 million. For the remaining, unrealized part of the planned financing of the project in the amount
of BGN 376 million. (EUR 192.3 million), the State Budget Act for 2026 provides for the issuance of state
guarantees under new loan agreements of Bulgartransgaz EAD.
Construction and installation activities under Project 1 and Project 2 began in 2025, and the Vertical Gas
Corridor project on Bulgarian territory is expected to be completed by the end of 2026.
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
In fulfillment of the Decision of the National Assembly of the Republic of Bulgaria dated July 21, 2023 (SG,
issue No. 63/2023) to conduct negotiations on the terms and conditions for Bulgarian Energy Holding EAD
to acquire an equity interest of up to 20% in the consortium holding the Oil and Natural Gas Exploration
Permit and Agreement for the ‘Block 1-21 Han Asparuh’ area, and following the technical, financial, and
legal consultations and negotiations conducted during the second half of 2025, at the end of December 2025
Bulgarian Energy Holding EAD started a process of acquiring a 10% interest in the rights and obligations
under the Oil and Natural Gas Exploration Permit and Agreement for the ‘Block 121 Han Asparuh’ area.
Effective from March 2025, the holders of 50% of the exploration rights and obligations are OMV Offshore
Bulgaria GmbH - Branch Office Bulgaria (acting as the Operator) and NewMed Energy Balkan Limited -
Bulgaria Branch. In December 2025, drilling operations commenced on the first of the two exploration wells
in accordance with the 2025 budget and work programme. Depending on the drilling results, a new work
program and budget are anticipated.
Initiating actions for the construction of a New Nuclear Power Capacity
On December 18, 2023, the National Assembly passed a Decision on initiating actions for the construction
of Units 7 and 8 at Site No. 2 of the NPP Kozloduy using AP1000 technology, including an indicative time
line of priority activities pursuant to Appendix No. 1 to the decision (promulgated, SG, issue No. 105/2023).
In fulfillment of this decision a number of concrete steps have been taken since 2023 for the construction of
two new nuclear units with a total installed capacity of up to 2,300 MW. A contract has been signed with
Westinghouse Energy Systems LLC Bulgarian Branch to provide initial engineering and design services to
support the implementation of a new nuclear power project based on AP1000 technology, which is scheduled
for completion by the end of 2025.
In implementation of a Decision adopted by the 49th National Assembly on February 23, 2024, at the end of
2024, a contract for engineering services was concluded with the consortium "WESTINGHOUSE - HDC"
DZZD with a performance period of one year. The contract is for engineering phase 1, which lays the
foundation for the contract for the supply of equipment and construction (EPC contract). Negotiations have
been initiated to conclude an amendment to the Engineering Contract, Phase 1 to expand the scope of

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
44
activities. As of the date of approval of the consolidated activity report, no decision has been made to assign
additional activities to the consortium.
In accordance with the Decision of January 12, 2023 of the National Assembly, after a procedure, a contractor
was selected to whom the environmental impact assessment activities were assigned in accordance with the
Environmental Protection Act, by notifying the competent environmental authority of the existence of an
investment proposal for the construction of a new nuclear power plant - Unit 8. In October 2024, a contract
was signed with the Deacon - Abmerit consortium with a completion period of 2 years.
On August 12, 2025, a contract was signed with Ernst & Young Bulgaria EOOD in its capacity as a financial
consultant for the financial structuring and modeling process, including during interactions and negotiations
with project lenders and other key stakeholders.
On September 2, 2025, in connection with the development and implementation of the design, construction
and commissioning of an AP1000 nuclear power plant, a contract was concluded with LEP-BWXT-CNPSA
CONSORTIUM as the owner's engineer with the subject "Engineering and consulting services for the
development of the project for a new nuclear capacity at the Kozloduy NPP site.
A mandatory stage in the process of preparing the project for the construction of new nuclear capacities at
the Kozloduy NPP site is the notification to the European Commission, with the main addressee of the
notification being the Directorate-General for Competition (DG COMP). The need for notification is due to
the fact that the implementation of such a large-scale energy project implies the provision of various forms
of state support, the implementation of which requires prior approval under the European Union's state aid
rules. A pre-notification was submitted in 2025, and the notification procedure continues in 2026.
In order to successfully implement the procedures for spatial planning, investment design and construction
on the territory of Site No. 2, it is necessary for the Group, through the subsidiary "Kozloduy NPP - New
Power Plants" EAD, to acquire the right of ownership and/or construction on the land properties. Those
falling within the scope of the approved site are 545,722 sq. m., with a total affected area of 608,015 sq. m.
On January 8, 2026, in connection with Order No. RD-02-15-96/22.12.2025 of the Minister of Regional
Development and Public Works, a draft detailed development plan – amendment to the regulation and
construction plan (Detailed Development Plan – Amendment to the Regulation and Construction Plan /DDP-
ARCP) was approved for the construction of the following facility: Construction of the 7th and 8th units at
site No. 2 of the NPP Kozloduy EAD with the AP1000 technology. For the implementation of the above-
mentioned project, the Group must acquire real rights (right of ownership or right of construction) over the
entire or affected parts of 19 real estate properties - private property. The Energy Act (EA) regulates a special
procedure for settling the property rights over the land necessary for the implementation of energy facilities
by the persons who will build and operate them, in implementation of the state policy in the field of energy.
In this specific case, the Group is unable to voluntarily acquire from the owners the necessary rights for the
construction of the energy facility. Therefore, it is necessary to carry out expropriation proceedings under
Chapter Three of the State Property Act for the forced expropriation of properties - private property, for state
needs. Valuation reports were prepared by an independent appraiser to determine the market price under the
State Property Act, establishing equivalent cash compensation for the owners of the affected properties. On

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
45
June 5, 2026, a request was submitted to the Ministry of Energy to initiate a procedure for the expropriation
of the specified properties pursuant to Article 34a of the Energy Act.
GREENABLER Project
The project "Sustainable adaptation of the national transmission grid for full integration of the potential for
renewable energy production" (Bulgarian Grid REinforcement ENABLing Full-Fledged Clean Energy
Rollout) aims to adapt Bulgaria's existing electricity transmission grid to the massive deployment of RES,
observed both nationally and regionally. It includes the reconstruction of about 720 km of existing power
lines to increase their nominal voltage from 220 kV to 400 kV and the synchronized reconstruction of their
adjacent substations from 220/110 kV to 400/110 kV.
On December 23, 2024, a Grant Agreement was signed between the Ministry of Energy and ESO EAD for
the allocation of funding from the Modernization Fund in the amount of EUR 630,809,624, 90% of which is
a grant. Technical implementation is underway, with pre-investment activities being carried out. By the end
of 2025, the EIA procedures for all overhead line reconstructions included in the project have been
completed. Activities are being carried out under the applicable procedures for the detailed development plan
for all sites, as well as the procedures under the Environmental Protection Act for substations and new
diversions for connecting power lines.
‘Digital transformation of the electricity transmission grid under the National Plan for Recovery and
Sustainability’ Project
ESO EAD is implementing investment C4.I4 “Digital transformation of the electricity transmission
network”, part of the Recovery and Resilience Plan of the Republic of Bulgaria, with an approved budget of
BGN 611 million (co-financing of BGN 370 million from the Recovery and Resilience Facility and BGN
241 million from own funds). The investment is being implemented in accordance with an operational
agreement signed by the Ministry of Finance, the Ministry of Energy and ESO EAD. The project completion
is expected to be by the end of 2026.
5.3. Future developments in 2026 by segments
• Electricity segment
Significant dynamics and unpredictability of the market environment are expected in the current and
upcoming years as a result of significant external factors, such as ongoing military conflicts, a highly volatile
electricity market in terms of prices, and a significant impact of supply from renewable sources. Internal
factors also have an impact, such as measures to protect businesses from high electricity prices, the
participation of BEH Group companies in the mechanism for a smooth transition to full liberalization of the
retail market for household end customers, as well as frequent changes in the regulatory framework.
Sustainable development and diversification of the energy mix will be essential to address existing challenges
and ensure stability and security in the energy sector.
With the amendments and supplements of the Energy Act (EA) as of May 30, 2025 (prom. SG issue No. 44
of 30.05.2025) changed the previous model of parallel functioning of a regulated and free market and moved
to the next stage of the liberalization of the electricity market, with full liberalization of the wholesale
electricity market from July 1, 2025, while maintaining household consumers on a regulated market. The

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
46
adopted changes extended the transitional period of functioning of the electricity market, and the introduction
of liberalization of the retail market was postponed to a later stage, when adequate mechanisms for the
protection of household consumers have been developed.
In the new market model, the figure and functions of the public supplier (PS) were eliminated, as was the
obligation of EWRC to annually determine the estimated monthly availability for electricity production of
the producers from which the PS should purchase electricity. In accordance with the adopted changes, in
order to ensure the security of electricity supplies to households after July 1, 2025 and given the withdrawal
of NEK EAD as a public supplier, in order to ensure the needs of end suppliers to cover household electricity
consumption, a new mechanism (segment) was created on the exchange market, which includes long-term
products. This segment is open to all sellers (i.e. electricity producers and traders) and includes a newly
created non-standard product (traded on an organized exchange market) that is tailored to the specific
consumption profile of end suppliers. In accordance with the amendments to the Energy Act, end-suppliers
purchase electricity on a market basis and sell it to household consumers at prices containing a regulated
component.
The strategic goals of NPP Kozloduy EAD are related to ensuring the highest level of safety, efficient and
competitive production, maintaining qualified, competent and motivated personnel and preserving the
financial stability of the company. In order to meet the requirements of EURATOM, an Agency for
diversification of fresh nuclear fuel (FNF) supplies, the activities under the contracts concluded with
Westinghouse for supply of fresh nuclear fuel cartridges for Unit 5 and with Framatom for supply of FNF
for Unit 6 will be carried out.
From the second half of 2025, Kozloduy NPP EAD concludes transactions with electricity on an organized
exchange market, with the exception of sales under Article 119 of the Energy Act, as well as sales of
electricity to NEK EAD, in its capacity as coordinator of a balancing group for the sale of electricity to end
suppliers. A priority for a basic nuclear producer such as NPP Kozloduy EAD, operating entirely in market
conditions, is to ensure the operation of the units with nominal power (base load) in the long term, in strict
compliance with the characteristic technological requirements and limitations. In this regard, the commercial
activity of the company in the future will be aimed at ensuring the full realization of the produced electricity.
The company's price policy for free supply will be oriented towards ensuring secure and rhythmic sales
revenue, in line with market conditions.
The main challenge for NPP Kozloduy EAD is the implementation of the Decision of the National Assembly
(NA) for undertaking specific steps on the construction of units 7 and 8 at site No. 2 of NPP Kozloduy EAD
with AR1000 technology. The implementation of new nuclear capacity is related to the need for the
Bulgarian state to take action to ensure long-term base capacity in connection with the green deal and the
ongoing energy transformation, given the advantages and opportunities of nuclear energy as a safe, reliable,
sustainable and low-emission alternative. Currently, NPP Kozloduy-New Builds EAD is conducting
negotiations with international financing institutions and export credit banks of the United States and South
Korea, respectively US EXIM and KEXIM, for the provision of long-term financing under favorable
financial conditions, secured by state guarantees. In July 2025, a contract was signed with the American bank
Citibank for a lead coordinating and organizing bank to structure the loan financing for the implementation
of the project and commissioning of the nuclear units and to assist NPP Kozloduy - New Builds EAD in the
processes of applying for and approving financing, in accordance with the terms of export crediting, market

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
47
conditions, and the amount of the required loan capital. In August 2025, NPP Kozloduy-New Builds EAD
entered into a contract with Ernst & Young Bulgaria EOOD, a financial and economic consultant, for the
preparation of a comprehensive financial model covering the entire life cycle of the new Power Units 7 and
8.
The future development of NEK EAD will be in accordance with the licenses held by the company and will
be determined by the future model for full liberalization of the electricity market. The activity of the company
will be aimed at fulfilling the main obligations of NEK EAD to satisfy the consumption of the End Suppliers
until this activity ceases as a result of the legislative changes. In parallel with this, the company's goal is not
to allow a price deficit and to demand from the EWRC a mechanism for recovery of the one accumulated to
NEK EAD until now to be developed. In the field of production, the company will strive to use the available
water resources as efficiently as possible, as well as to gradually refurbish the facilities to ensure their safe
and reliable operation. On the free electricity market, NEK EAD will strive to expand its market share
through the hydro facilities at its disposal providing vital services for balancing the electricity system of the
country.
NEK EAD, in its capacity as coordinator of a standard balancing group, provided the necessary quantities of
electricity for end suppliers to satisfy the consumption of household consumers for the price period from
01.07.2025 to 30.06.2026, after auctions were held on the newly created mechanism of the IBEX platforms.
For this purpose, NEK EAD formed a mix of Kozloduy NPP EAD, Maritsa East 2 TPP EAD, AES-3C
Maritsa East 1 TPP EOOD, NEK's hydroelectric power plant, supplemented by purchases from IBEX.
In the event of the possible discontinuation of the currently operating model, in which NEK EAD is the
coordinator of a standard balancing group and ensures the consumption of end suppliers, the company will
continue to sell on the IBEX platforms the electricity produced by its own hydroelectric power plants and
hydroelectric power plants through the trading license, and will continue the process of developing the
commercial activities of NEK EAD. To this end, the company has focused its efforts on strengthening its
commercial activities by developing the activities of the analytical unit established within the company,
optimizing the operation of the implemented algorithmic trading, registering with the EEX, and creating a
team for trading in CO2 allowances.
In line with the European requirements to achieve zero carbon neutrality, NEK EAD is actively exploring
possibilities for construction of renewable energy sources, electricity storage systems (through batteries and
PSHPP), modernization and expansion of the existing capacities and other projects in this direction.
In order to ensure the adequacy of the energy sector in Bulgaria in the long-term perspective, it is of key
importance to preserve the power generation capacities, which have a key role on the one hand for generation,
and on the other for the regulation of the electricity system, as well as building new ones, by using innovative,
low-carbon and sustainable technologies.
The strategy of TPP Maritza East 2 EAD includes the implementation of investment projects, the main
objective of which is the modernization of the Power Plant and the limitation of environmental pollution.
The completion of already started projects and the implementation of new ones is a prerequisite for TPP
Maritza East 2 EAD to maintain its key position as one of the main producers of electricity in the country.
A higher capacity utilization with a lower emergency rate, higher efficiency and environmental friendliness

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
48
of the plant, ensuring energy security in the country, is achieved as a result of the implementation of the
investment and repair programs.
In order to ensure the adequacy of the energy sector in Bulgaria in the long-term perspective, it is of key
importance to preserve the power generation capacities, which have a key role on the one hand for generation,
and on the other for the regulation of the electricity system, as well as building new ones, by using innovative,
low-carbon and sustainable technologies. In this regard, the role of the transmission system operator in the
process of transition to a low-carbon market model is of key importance and covers directions such as the
integration of new renewable capacities through implementation of innovations contributing to the flexibility
and development of the transmission network, increasing and efficient distribution of intersystem capacity
and last but not least - ensuring the necessary level of security of supply.
• Natural Gas Segment
The market goals of Bulgargaz EAD are related to maintaining market positions in the country and entering
new regional gas markets. To achieve these goals, Bulgargaz EAD has obtained licenses for natural gas trade
in Greece and Hungary, as well as permits for the supply of natural gas to Slovakia and Romania. The
company is a registered user of the gas transmission networks of Bulgartransgaz EAD and ICGB (Bulgaria),
DESFA SA (Greece), TRANSGAZ SA (Romania), GASTRANS d.o.o. (Serbia), FGSZ (Hungary) and Gas
Transmission System Operator of Ukraine (Ukraine).
In June 2025, Bulgargaz EAD registered its subsidiary under the name 'Bulgargaz North', through which it
conducts natural gas trading activities within the territory of Moldova. On 8/19/2025, by Decision of the
Regulator of the Republic of Moldova, Bulgargaz North received a license to trade in the Republic of
Moldova. In July 2025, Bulgargaz EAD concluded an EFET (European Federation of Energy Traders)
standardized contract with the Moldovan company Energocom S.A. The purpose of the concluded contract
is to grant access and ensure the opportunity for Bulgargaz EAD to participate in the tenders organized by
Energocom S.A.
The expiration of the transit contract for the transmission of Russian natural gas through Ukraine to Europe
as of January 1, 2025 created a potential opportunity to expand the company's activities by entering the
Ukrainian market. In this regard, on July 24, 2025, Bulgargaz EAD concluded a framework EFET agreement
with the state-owned company Naftogaz Ukraine, which enables Bulgargaz EAD to participate in the tenders
organized by them.
Diversification of supply sources
Bulgargaz EAD ensures the supply of natural gas through a long-term contract for supply of Azerbaijani
natural gas from the Shah Deniz field through the IGB (Greece-Bulgaria intersystem connection) gas pipeline
with Azerbaijan Gas Supply Company (AGSC), concluded in 2013, with validity period 25 years from the
date of the first delivery - 31.12.2020. Bulgargaz EAD has reserved a long-term capacity in the IGB gas
pipeline, corresponding to the quantities of Azeri gas agreed for delivery.
Pursuant to the state strategy for diversification of natural gas supply routes and sources for the country and
Decision No. 166 of 10 March 2020 of the Council of Ministers, Bulgargaz EAD has reserved capacity at
the liquefied natural gas terminal to Alexandroupolis for the supply of 5,300,000 MWh/year for a period of

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
49
10 years. Pursuant to Decision No. 661 of 15 September 2022 of the Council of Ministers (CoM), Bulgargaz
EAD has reserved an additional capacity at the liquefied natural gas terminal near the town of
Alexandroupolis, Republic of Greece - Gastrade S.A., for 5,300,000 MWh/year (≈ 500 million cubic meters
per year) for a period of 10 years, starting from the year of commercial operation of the terminal (from 2024),
with which the total reserved capacity is 10,600,000 MWh/year.
At the end of 2022, an Agreement was signed between Bulgargaz EAD and the Turkish state gas company
BOTAŞ, whereby Bulgargaz EAD is granted access to the regasification terminals of liquefied natural gas
in the Republic of Turkey for 1.5 billion cubic meters per year and the subsequent transfer of quantities of
natural gas to the interconnection point between the Bulgarian and Turkish gas transmission networks -
Strandja/Malkochlar, for the period 2023 - 2035. The signing of the Agreement with BOTAŞ provides a
strategic partnership and makes it possible to balance the supply portfolio of Bulgargaz EAD, providing three
entry points from LNG terminals located in the Aegean Sea - BOTAŞ Revitousa and Alexandroupolis. The
agreement entered into force after its approval by Decision No. 26 of 12.01.2023 of the Council of Ministers
of the Republic of Bulgaria. Currently, Bulgargaz EAD and BOTAŞ are in active negotiations to renegotiate
the Agreement, with the Ministry of Energy providing the necessary institutional and political support.
Diversification of delivery routes
The Republic of Bulgaria has a strategic geographical location, a well-developed gas infrastructure with a
high level of interconnection and significant capacity. With the implementation of new infrastructure
projects, the country is developing its potential of being an increasingly significant factor in ensuring energy
independence and diversification of sources and routes for the supply of natural gas for the region.
At the end of 2025, the Council of the European Union and the European Parliament reached an agreement
on a concrete timetable for an effective and permanent cessation of Russian gas imports in 2027. The
agreement ensures a gradual but permanent cessation of Russian gas imports into the European Union, with
liquefied natural gas to be stopped by 31 December 2026 and pipeline gas by 30 September 2027.
In this regard, ensuring the security of supplies of natural gas and mainly liquefied natural gas from
alternative, reliable sources are priorities both at the national level and in a regional aspect.
These factors determine the future development of Bulgartransgaz EAD, which will be aimed at ensuring
the security of natural gas supplies, diversifying sources and supply routes, building a competitive pan-
European gas market and, at the same time, at activities in the implementation of climate and energy policies.
With the implementation of the projects for new gas infrastructure in the country and the region, it is expected
that there will be a significant increase in the quantities of natural gas from alternative sources, which will
be transported through the gas transmission infrastructure of Bulgartransgaz EAD both for Bulgaria and for
the countries of the region.
Priority projects for Bulgartransgaz EAD are projects to increase transmission capacities along the Vertical
Gas Corridor and to improve interconnection, to modernize and expand the gas infrastructure with a
contribution to guaranteeing LNG-related services. Contributing to achieving the goals for reducing carbon
emissions are projects in the field of hydrogen, aimed at building an entirely new infrastructure for the
transmission of pure hydrogen and at adapting the existing gas transmission network for the transportation
of hydrogen-gas mixtures.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
50
In this regard, Bulgartransgaz EAD will continue its consistent work on the implementation of the
infrastructure of the Vertical Gas Corridor as the main highway for the transport of liquefied natural gas to
the region. The vertical gas corridor is a strategic project for ensuring security of supply and diversification
of natural gas supplies for Bulgaria and the countries of South-Eastern, Eastern and Central Europe. The
projects, developed by Bulgartransgaz EAD, to increase transmission capacities from Greece to Bulgaria and
from Bulgaria to Romania are a key part of the overall vision of the Vertical corridor, as their implementation
and the already available infrastructure in Bulgaria are the basis for achieving the set goals for diversification
and improving the security of supplies.
A project in the conceptual phase is the construction of a second gas interconnector between the Republic of
Bulgaria and the Republic of Northern Macedonia with Petrich - Strumica route. The development of
intersystem connectivity between the Republic of Bulgaria and the Republic of North Macedonia will
contribute to increasing the energy security and integration of the energy markets.
Also important for the development and expansion of the gas infrastructure is the project for the construction
of a supply gas transmission infrastructure to supply consumers in the East Marija region, and it is expected
to make a significant contribution to the decarbonization of the energy sector in Bulgaria and achieve
economic and environmental benefits for the region.
Natural gas storage
Strategic importance for the Republic of Bulgaria has the project to increase the capacity of Chiren UGS
facility and its turning into a commercial storage facility. Chiren USG plays a major role in compensating
for the seasonal irregularity in the consumption of natural gas in the country and providing an emergency
reserve in unforeseen and force majeure situations. The increased storage, extraction and injection capacities
will give the market an additional flexibility and will ensure the security of natural gas supplies and will
contribute to improving competition and access to natural gas from alternative sources. In this way, the
project will help increase the liquidity of the gas markets in Bulgaria and the region.
The expansion of the Chiren UGS is in synergy with the LNG terminal project near Alexandroupolis, in
which Bulgaria participates through Bulgartransgaz EAD with a 20% shareholding. In this way gas traders
and users in the region will be enables to take full advantage of the dynamic development and competitive
advantages provided by the liquefied natural gas market.This will enable gas traders and users in the region
to take full advantage of the dynamic development and competitive advantages provided by the liquefied
natural gas market. The Bulgarian participation in the project is strategically important for the diversification
and security of energy supply for Bulgaria and other countries in the region.
• Coal Segment
The climate neutrality road map of Bulgaria, adopted by decision No. 59 of 26.01.2024 of the Council of
Ministers, considers both the risks associated with climate change and the changing realities regarding the
electricity industry in Bulgaria and the interacting economic, environmental and social factors.
Based on the conclusions in the Report of the Energy Transition Commission, the final date for the gradual
cessation of the use of coal is 31.12.2038, and subsequent implementation of measures to restore the
disturbed areas and preparation for new economic activities in the Company.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
51
In response to the challenges faced by Mini Maritza - East EAD, actions are taken to preserve the energy
profile of the region, through investments in the field of clean technologies, low-emission productions and
scientific research and development activities, using the potential of the available infrastructure, human
capital and land.
Mini Maritza - East EAD also plans actions aimed at developing projects and adapting financing programs
using sources such as:
➢ The Just Transition Fund, which is a financial instrument within the Cohesion Policy and aims to
provide support to territories facing serious socio-economic challenges arising from the transition to
climate neutrality;
➢ The Modernization Fund, which is funded by the from the emissions allowances auctions as per the
EU Emissions Trading Scheme, with the aim of supporting the transition to climate neutrality;
➢ The Cohesion Fund, the purpose of which is to strengthen the economic, social and territorial
cohesion of the European Union to promote sustainable development;
➢ The Social Climate Fund, established by Regulation (EU) 2023/955 of the European Parliament.
By a decision of the National Assembly in 2024 (promulgated in SG No. 38/30.04.2024), it was mandated
that all necessary actions be taken, in compliance with applicable Bulgarian and Community legislation, to
ensure funds from the state budget for Mini Maritsa-iztok EAD in the amount of BGN 250,000 thousand
annually for a period of four years for the purpose of securing technical reclamation activities of the disturbed
terrains of the 'Iztochnomarishki Coal Basin' deposit. The funds will be provided exclusively on the condition
that the reclamation activities will be carried out only by Mini Maritsa-Iztok EAD, and it is not allowed to
assign or subcontract the activities to private companies and/or companies with state or municipal
participation.
• Corporate governance
BEH EAD will actively continue its activities on the implementation of effective management practices
within the Group. The aim of the management is to provide a long-term vision for the development of the
Group companies which is in line with the Energy Strategy of Bulgaria.
The management of BEH EAD works in close cooperation and takes advantage of the necessary support
from the State represented by the Minister of Energy. In the process of management of the holding and its
subsidiaries, all important decisions regarding the management strategy and their future development are
taken after being agreed and approved by the principal – the Minister of Energy.
Directly affecting the activities of BEH EAD is one of the activities envisaged in the National Recovery and
Resilience Plan (NRRP) of the Republic of Bulgaria. Bulgaria reforms, namely Reform 11 (C4.R11) –
Improving the corporate governance of state-owned companies in the energy sector. The aim of the reform
is to improve the transparency and competitiveness of state-owned companies in the energy sector.
According to the version of the NLP adopted by the EC in November 2025, the measure consists of separating
the ownership of companies related to coal activities from the corporate structure of Bulgarian Energy
Holding EAD and separating them into a separate holding structure, with 100% state ownership of the capital.
In this regard, by Decision of the Council of Ministers No. 443 of 10.06.2026, the Minister of Energy was

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
52
assigned to work on the relevant acts in connection with the corporate restructuring of "Bulgarian Energy
Holding" EAD for the implementation of Reform 11 (C4.R11) of the National Energy Strategy.
6. Credit rating
6.1. Credit rating of Bulgarian Energy Holding EAD
Moody’s Rating Agency
On June 10, 2025, Moody’s assigned a „Ba2“ credit rating to an unsecured and unsubordinated 5-year bond
issue of Bulgarian Energy Holding EAD, placed on June 12, 2025.
On 30 June 2025, in its credit opinion, Moody’s maintained its long-term credit rating at „Ba1“ for BEH
EAD with a stable outlook. BEH EAD's rating reflects both its own creditworthiness (Baseline Credit
Assessment – ba3) and the high probability of support from the sole owner of the company's capital – the
Government of Bulgaria (rating „Baa1“, with a stable outlook) in the event of financial difficulties.
Fitch Ratings
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.
On June 10, 2025, Fitch Ratings assigned a „BB“ rating to the unsecured and senior 5-year bond issue of
BEH EAD, successfully placed on June 12, 2025.
6.2. Credit rating of Natsionalna Elektricheska Kompania EAD
Standard&Poor`s rating agency
On August 7, 2025, the S&P rating agency affirmed the credit rating of the subsidiary NEK EAD at the "BB"
level and revised its outlook from positive to stable mainly due to the expected higher indebtedness of BEH
EAD in connection with the development of the new nuclear capacity project and the postponement of the
liberalization of the retail electricity market for an indefinite period. S&P considers NEK EAD as a strategic
subsidiary, given its key role in the country's energy system.
7. Events after the reporting period
No adjusting events or significant non-adjusting events have occurred since the date of the reporting period
to the date of approval of the consolidated financial statements for publication, except for the following non-
adjusting events:
Introduction of the euro in the Republic of Bulgaria
Following the official decision of the EU Council of July 8, 2025, on the admission of Bulgaria to the
eurozone, our country has officially been admitted to the monetary union, effective January 1, 2026, with a
fixed exchange rate of 1 EUR = 1.95583 BGN, approved without the possibility of change. In order to ensure

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
53
a smooth and transparent process, the responsible institutions enacted the Act on the Introduction of the Euro
in the Republic of Bulgaria. Reports with a reporting date after January 1, 2026 shall be prepared and
presented in euro. In the annual financial statements for the transition year, the comparative information for
the previous reporting period (which was in BGN) must also be restated and presented in EUR. The reason
for the change in reporting currency must be disclosed in the notes to the annual financial statements.
The military conflict in the Middle East
The complicated international situation and escalation of tensions since the end of February 2026, related to
military actions in Iran, contribute to increased geopolitical uncertainty in the region and at the global level.
The potential consequences of these events include increased volatility in energy markets, further
fluctuations in the macroeconomic environment, and increased uncertainty about future economic
conditions. Management is monitoring the development of the situation and has taken into account the
available information when preparing the accounting estimates and assumptions. At present, no need for
adjustments to the financial statements has been identified, beyond the disclosures made.
Target contributions to the Security of the Electricity System Fund
In 2026, the mechanism for raising targeted contributions to the "Security of the Electricity System" fund is
extended. The targeted contribution represents the positive difference between the market revenues and the
determined revenue cap for the respective type of producer, with a delivery period from January 1, 2026, to
December 31, 2026. By Council of Ministers Decision No.165/12.02.2026, the values serving to calculate
the revenue cap for the individual electricity producers concerning the BEH Group were determined for the
period from January 1, 2026, to December 31, 2026, as follows:
a) for a producer of electricity from a nuclear power plant – EUR 61.36/MWh;
b) for electricity from hydro power plants owned by the Natsionalna Elektricheska Kompania EAD
– EUR 71.58/MWh;
c) for producers of electricity from coal-fired condensing power plants, including lignite-fired power
plants – EUR 204.52, increased by the average monthly price per ton of CO 2 emission allowances for one
MWh multiplied by 1.32;
Bulgarian Energy Holding EAD
Change in the Board of Directors of Bulgarian Energy Holding EAD
On May 21, 2026, an application for a change in the Board of Directors of Bulgarian Energy Holding EAD
was submitted to the Commercial Register and the Register of Non-Profit Legal Entities. By decision of the
Minister of Energy, Ivo Ivanov Todorov, Kalin Boyanov Filipov, Valentin Aleksiev Nikolov, Diyan
Atanasov Ivanov, and Vasil Georgiev Stoynov were released, and Ivo Ivanov Todorov, Andrey Stefanov
Zhivkov, and Petar Valeriev Angelov were appointed as state representatives, with Vasil Vasilev Vasilev
and Ilza Mitkova Chinkova appointed as independent members. Andrey Stefanov Zhivkov was elected as
Executive Member. The change was entered in the register on May 28, 2026.
‘Block 1-21 Han Asparuh’ Project
By virtue of Council of Ministers Decision No. 15 dated January 14, 2026, Bulgarian Energy Holding EAD
acquired a 10 per cent interest in the rights and obligations under the permit and the agreement for oil and

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
54
natural gas exploration, from the project for oil and natural gas exploration in the ‘Block 1-21 Han Asparuh’
area, located in the exclusive economic zone of the Republic of Bulgaria.
Capital Increase via Non-Cash Contribution
On February 19, 2026, an increase in the capital of Bulgarian Energy Holding EAD was registered in the
Commercial Register and the Register of Non-Profit Legal Entities through a non-cash contribution
amounting to EUR 2,931,747.75, representing the ownership right to real estate – private state property,
located in the city of Sofia, Oborishte region, 8 Veslets Street, and consisting of a building with a built-up
area of 369 sq. m. The newly issued 5,748,525 shares for the registration of the contribution in kind were
acquired by the State, through the Minister of Energy.
Corporate restructuring of Bulgarian Energy Holding EAD
In connection with the implementation of Reform C4.R11 "Improving the corporate governance of state-
owned enterprises in the energy sector" with Decision No. 443 of June 10, 2026, the Council of Ministers
(CoM) of the Republic of Bulgaria approved the restructuring of "Bulgarian Energy Holding" EAD, for
which purpose a new public enterprise (holding company) with the sole owner being the Bulgarian state
should be established. The newly established company is planned to be the sole owner of coal-related
enterprises that were previously owned by Bulgarian Energy Holding EAD.
Credit rating of Bulgarian Energy Holding EAD
On April 28, 2026, Fitch Ratings affirmed the long-term foreign- and local-currency issuer credit ratings of
Bulgarian Energy Holding EAD at 'BB+' with a stable outlook. The rating reflects the holding company's
stable financial position, as well as its position as a leading integrated operator in the electricity sector in
Bulgaria and the region.
On June 10, 2026, Moody's presented an updated credit opinion, in which the credit rating of BEH EAD
remains unchanged - at the "Ba1" level, with a stable outlook. The credit opinion reflects the dominant
position of BEH Group as the main supplier of electricity in Bulgaria and its extremely important role in the
implementation of the country's energy policy. The rating agency notes that the company has a strong
financial profile, which puts it in a good position to cope with rising capital expenditures.
Extension of the Tripartite Agreement between Bulgarian Energy Holding EAD, Toplofikacia Sofia EAD,
and the Security of the Electricity System Fund
On July 28, 2026, Amendment No. 3 to Tripartite Agreement No. 58-2023/19.07.2023 was signed between
Bulgarian Energy Holding EAD, Toplofikacia Sofia EAD, and the Security of the Electricity System Fund,
extending its validity for the regulatory price period from July 1, 2026, to June 30, 2027, whereby 20% of
the monthly premiums due to Toplofikacia Sofia EAD from the Fund shall be transferred to the account of
Bulgarian Energy Holding EAD within the current price period. The proceeds will be used to repay
obligations under the Agreements of 2015 and 2019 between Bulgarian Energy Holding EAD and
Toplofikatsia Sofia EAD.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
55
Natsionalna Elektricheska Kompania EAD
Reduction of the capital of Contour Global Maritsa Iztok 3 EAD
By Decision under item I. 1 of Minutes No. 16/21.04.2026 of the Board of Directors of NEK EAD, the
Executive Director of NEK EAD was assigned to vote at an extraordinary general meeting of shareholders
of Contour Global Maritsa Iztok 3 AD on a reduction in capital and changes to the articles of association.
The reduction of the capital of Contour Global Maritsa East 3 AD was entered in the commercial register
and was carried out on May 19, 2026.
Power Purchase Agreement between NEK EAD and AES-3C Maritsa Iztok 1 EOOD
On 09.05.2026, the term of the Purchase Power Agreement between NEK EAD and AES-3C Maritsa Iztok
1 EOOD expired, as a result of which the obligation of NEK EAD to purchase electricity from the power
plant ceased.
Chaira PSHPP
As of the beginning of April 2026, hydro unit No. 3 had successfully passed all pre-commissioning tests,
including the successful completion of 72-hour trial runs. On June 10, 2026, hydro unit No. 3 of the Chaira
PSHPP successfully passed the State Acceptance Commission, and a permit for use and introduction into
regular operation was received.
Memorandum of Understanding with Toshiba
On April 8, 2026, NEK EAD and Toshiba International (Europe) signed a memorandum of understanding
aimed at the long-term rehabilitation and sustainable operation of Chaira PSHPP. Through the memorandum,
the parties express their desire to explore and develop a common vision for future joint projects related to a
long-term solution for all hydro units of the Chaira PSHPP and a comprehensive approach to sustainable
operation of the plant.
TPP Maritsa Iztok 2 EAD
European Union Emissions Trading System (EU ETS)
On March 18, 2026, the 51st National Assembly adopted and promulgated in the State Gazette, issue 28 of
March 20, 2026, a Decision to mandate the Council of Ministers to state the position of the Republic of
Bulgaria within the framework of the meeting of the European Council on March 19 –20, 2026 on the need
to temporarily suspend the implementation of the European Union Emissions Trading System (EU ETS)
until the completion of its current review at the European Union level and the development of a derogation
mechanism.
Court cases with the Association For the Land - Access to Justice
By Decision No. 5324/18.05.2026, the Supreme Administrative Court leaves in force Decision No.
918/15.03.2024 of the Administrative Court - Stara Zagora, which repealed Decision No. 50-НО-ИО-
A5/2018. In compliance with the instructions of the ExEa (letter with ref. No. КР 2410/26.06.2026,
registered in the registry of TPP Maritsa East 2 EAD under No. 22912/26.06.2023) The company begins a
procedure for reviewing КР No. 50/2005, last updated with decision No. 50 НО-ИО-A6/26.03.2020.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
56
NPP Kozloduy EAD
Conclusion of a contract for consulting services under Art. 166 of the Spatial Planning Act (SPA)
On January 30, 2026, a contract was signed between NPP Kozloduy - New Builds EAD and NPP Control
DZZD for consulting services under Art. 166 of the SDA for the preparation of an Assessment of the
compliance of investment projects with the basic requirements for construction under Art. 142 of the SDA ,
exercise of construction supervision pursuant to Art. 166 and Art. 168 of the SDA , preparation of an energy
certificate and technical passport of the construction pursuant to Art. 176a of the SDA for the site:
construction of units No. 7 and No. 8 on Site No. 2 of Kozloduy NPP EAD with AP1000 technology, as well
as the sites of the Staff Housing Complex and the Workers Housing Complex in the village of Harlets and
the Workers Complex - town of Kozloduy. The implementation of the services is divided into two main
stages: before the Final Investment Decision for the Project and after the Final Investment Decision for the
Project.
Extension of the term of the Electricity Trading License
By Decision No. И2-Л-216 of 04.03.2026 of the EWRC, the term of the Electricity Trading License No. Л-
216-15/18.12.2006, issued to NPP Kozloduy EAD, was extended by 10 years.
Conclusion of additional agreement No. 1 to a bank credit-overdraft agreement
The Board of Directors of BEH EAD, with a decision from Minutes No. 39-2026/08.06.2026, grants
permission to NPP Kozloduy EAD to conclude Supplementary Agreement No. 1 to the bank credit-overdraft
agreement dated 16.07.2025, concluded between NPP Kozloduy EAD and International Asset Bank with the
subject: "Provision of a bank credit-overdraft in the amount of BGN 50 million to NPP Kozloduy EAD, to
extend the term of the contract by 12 months and increase its maximum value to EUR 1,745,000, without
changing the remaining clauses of the contract, according to an approved draft additional agreement, with a
decision under item 7.2.1 of Minutes No. 7/23.04.2026 of the Board of Directors of NPP Kozloduy EAD .
Preventive reduction of the power of the 5th power unit of NPP Kozloduy
On August 21, 2026, the power of Unit 5 of the NPP Kozloduy was preventively reduced by about 120 MW.
The decision is part of the measures to ensure the safe operation of the NPP Kozloduy, as a result of the
ongoing unprecedented and critical lowering of the Danube River level.
Bulgargaz EAD
Conclusion of overdraft agreements with banking institutions
After an announced procedure for selecting a financial service provider to provide a loan to cover operating
expenses, in the form of an overdraft, in January 2026, Bulgargaz EAD concluded contracts with four
commercial banks, with a total limit of EUR 111 million.
"Natural Gas Purchase and Sale Agreement with Bulgargaz North"
Bulgargaz has concluded a contract with Bulgargaz North for the sale of quantities of natural gas, in which
Bulgargaz is in the role of Seller, respectively Bulgargaz North SRL - Buyer. In January 2026, Bulgargaz
EAD's subsidiary in Moldova - Bulgargaz North SRL started selling natural gas through the electronic
platform Bursa Română de Mărfuri (BRM) in Moldova.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
57
Tripartite agreement with Sofia District Heating EAD
On July 13, 2026, a tripartite agreement was signed between Bulgargaz EAD, Toplofikatsiya Sofia EAD and
the Security of the Electricity System Fund to settle the financial relations between the companies.
Protocol with BOTAŞ BORU HATLARI İLE PETROL TAŞIMA A.Ş,
On July 6, 2026, a protocol was signed between Bulgargaz EAD and the Turkish company BOTAŞ BORU
HATLARI İLE PETROL TAŞIMA A.Ş, , by which the contract between the companies was frozen for 15
months, starting from July 2026. During this period, Bulgargaz will pay only for the capacity used on the
Bulgarian side under improved conditions.
Obtained a trading license in the Republic of Serbia
On 09.07.2026, Bulgargaz was issued a license by the Energy Agency of the Republic of Serbia for trading
on the territory of the Republic of Serbia.
Mini Maritsa-Iztok EAD
Signing of an agreement for cooperation in the exploration of critical raw materials and rare earth materials
An agreement for cooperation in the exploration of critical raw materials and rare earth metals was signed
on January 15, 2026 between Mini Maritsa-Iztok EAD, the Geological Institute of the Bulgarian Academy
of Sciences and Bulgarian Energy Holding EAD. The signed document marks the beginning of a targeted
partnership to explore the possibilities for extracting critical raw materials, rare earth metals and their
analysis from lignite coal on the territory of the Maritsa-Iztok complex.
Registration of a new subsidiary
A new company with a sole owner Mini Maritsa-Iztok EAD has been established, with the name MMI -
Restoration of Mining Areas EOOD, registered on 09.04.2026, with the address in the town of Radnevo, 13
Georgi Dimitrov str. The main subject of the company is socio-economic transformation of mining areas;
design, construction and restoration of mining areas; commercial representation and brokerage; commission,
forwarding and transportation transactions; warehouse transactions, license transactions; stock control; repair
and service activities, leasing and all other activities permitted by the Law and unrelated to coal mining, as
the activities for which a license (permit) is required will be carried out after obtaining a license - after
obtaining the relevant permit and/or after completing the required registration.
Coal supply agreement with AES Maritza East 1 EOOD
In May 2026, the coal supply contract with one of the main customers of Mini Maritsa-Iztok EAD - AES
Maritsa Iztok 1 EOOD ended.
Bulgartransgaz EAD
Approval of an investment project for hydrogen transmission
In January 2026, Bulgartransgaz EAD received an official notification from the European Climate,
Infrastructure and Environment Executive Agency (CINEA) regarding the approval of the project proposal
and the launch of the grant agreement preparation process, which includes activities under the 'studies'
category related to the implementation of PCI 10.3.2 'Internal hydrogen infrastructure in Bulgaria towards
the border with Greece'. The project envisages the construction of a bidirectional hydrogen transmission

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
58
infrastructure between Bulgaria and Greece, including a linear section with a length of approximately 250
km and two new compressor stations with an indicative total compressor capacity of around 48 MW. The
project aims to provide hydrogen transmission capacity of approximately 0.9 Mt/y (80 GWh/d). The
approved project has the number 101287437 – 10.3.2-BG-S-M-25-PCI 10.3.2 – Studies, with the maximum
amount of the grant amounting to EUR 4,561 thousand, representing 50% of the total eligible costs of EUR
9,123 thousand.
On June 8, 2026, the Grant Agreement (GA) was signed between Bulgartransgaz EAD and CINEA for a
project with identification number 101287437 - 10.3.2-BG-S-M-25-PCI 10.3.2 - Studies - CEF-E-2025-PCI-
PMI, which includes activities from the "studies" category related to the implementation of PCI 10.3.2
"Internal hydrogen infrastructure in Bulgaria towards the border with Greece". On June 18, 2026, an advance
payment of EUR 2,281 thousand or 50% of the grant value was received.
Financial collateral
In connection with an agreement concluded between Bulgartransgaz EAD and Gastrade S.A. for the
regasification of liquefied natural gas at FSRU Alexandroupolis in June 2026, the Group provided financial
collateral in the form of a pledge of cash in the amount of USD 29,513 thousand at ING Bank N.V., at a
fixed interest rate of 3.20% securing an issued bank guarantee in favor of Gastrade S.A. in the amount of
EUR 24,357 thousand.
On July 20, 2026, the Management Board of the Company adopted a decision to conclude Annex No. 1 to
Agreement No. 7434/08.06.2026 for a guarantee loan and Annex No. 1 to Agreement No. 7435/08.06.2026
for a pledge of funds concluded with ING Bank N.V. – Sofia branch, which increases the amount of the bank
guarantee from EUR 24,357 thousand to EUR 52,554 thousand. On July 30, 2026, the Supervisory Board
approved the decision of the Management Board to conclude the aforementioned annexes. The annexes were
signed on August 4, 2026.
Elektroenergien Sistemen Operator EAD
Sale of the shares of Operator Zagore AD
By decision under Minutes No. 8/02.03.2026 of the Management Board, confirmed by decision under
Minutes No. 8/04.03.2026 of the Supervisory Board of ESO EAD, a decision was made to sell the shares of
„Operator Zagore“ AD to „Industrial Zone Zagore“ AD at a price equal to the nominal value of the shares.
The change was entered in the Commercial Register and the Register of Non-Profit Legal Entities on
21.07.2026.
EWRC pricing decision
By Decision No. Ts-13 of 01.07.2026, EWRC approved the following prices for Electricity System Operator
EAD, effective from 01.07.2026:
• Price for access to the electricity transmission network for end customers in the amount of EUR
0.18/MWh;
• Price for access to the electricity transmission network for producers, with the exception of producers
of electricity from renewable sources with dynamically changing generation – from solar and wind

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
59
energy, connected to the electricity transmission and distribution networks, in the amount of EUR
2.19/MWh;
• Price for access to the electricity transmission network for producers of electricity from renewable
sources with dynamically changing generation – from solar and wind energy, connected to the
electricity transmission and distribution networks, for the entire amount of electricity produced, in
the amount of EUR 2.72/MWh;
• Price for transmission of electricity through the electricity transmission network in the amount of
EUR 8.01/MWh;
Termination of ESO Engineering EOOD
On July 25, 2026, a transformation through a merger by acquisition of ESO Engineering EOOD into the sole
owner of its capital – Elektroenergien Sistemen Operator EAD (ESO EAD), was registered with the
Commercial Register. As a result of the registration, the company was terminated without liquidation, and
its entire assets, all rights and obligations were transferred to ESO EAD by virtue of universal succession.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2025
This document is a translation of the original Bulgarian text in case of divergence the Bulgarian text shall prevail
60
8. NON-FINANCIAL INFORMATION
This consolidated non-financial information has been prepared in accordance with the requirements of Art.
29, Para. 4 of the Public Enterprises Act and contains a description of the policies of the companies within
the Bulgarian Energy Holding EAD with regard to the activities carried out in the field of ecology, social
issues and those related to employees, human rights and the fight against corruption.
8.1. Brief description of the business model and general information
Bulgarian Energy Holding Group (BEH) EAD includes companies operating in production and transmission
of electricity, transmission, transit and storage of natural gas, as well as lignite mining. The Group occupies
a leading position in the natural gas and electricity market in Bulgaria. The Group owns the main electricity
generation companies in the country, as well as the electricity transmission network and the natural gas
transmission and transit networks. The Group is also the public supplier of both electricity and gas in Bulgaria
and is therefore a strategically important state-owned company.
Main activities. Mission and goals
BEH EAD and the companies within BEH Group carry out their operations in compliance with the Bulgarian
and European legislation and in accordance with the licenses issued to them by the Energy and Water
Regulatory Commission (EWRC) and the Nuclear Regulatory Agency.
Brief description of the main activities Mission and goals
Bulgarian Energy Holding EAD is a financial
holding company with the companies within its
corporate structure retaining their operational
independence.
The services provided to the subsidiaries are in
the areas of financial management, project
management, corporate governance and
business planning, legal and regulatory issues,
public relations and communication. These
activities ensure the application of a unified
approach within the group regarding the future
development of the energy companies, which is
in line with the directions set out in the Energy
Strategy of Bulgaria.
The goals of Bulgarian Energy Holding EAD are
focused on the following main areas and priority
areas:
• Financial sustainability of BEH Group and the
electricity sector in the country through:
⁻ Improving of corporate management
practices
⁻ Providing funding for key activities and
projects;
⁻ Cost optimization at BEH Group;
⁻ Decarbonization of BEH Group
• Ensuring the security of the energy system through
project management for:
⁻ Diversification of sources and routes;
⁻ Security, reliability and continuity of gas
supplies;