Bulgaria

Article 222(1) of the Закон за лекарствените продукти в хуманната медицина gives the right to conduct retail trade in medicines to a natural or legal person registered as a trader under Bulgarian law or the law of a member state, which has concluded an employment or management contract for the pharmacy with a магистър-фармацевт, a master pharmacist, and which may open no more than four pharmacies in Bulgaria.

Three things follow. A legal entity may own a pharmacy, with no pharmacist-only rule, and a foreign EU-registered company qualifies on the face of the text. There is a hard statutory chain cap of four. And the cap is drafted per person, which is why large Bulgarian retail groups visibly exist: the obvious reading is that groups hold pharmacies through multiple entities.

Compared with Romania next door, which has no ownership restriction and no cap but binding urban population ratios, Bulgaria inverts the constraint. If you want scale in retail pharmacy, Romania is the buildable market. If you want a small number of good outlets, four is survivable.

This is the most developed parallel-export control regime in the atlas, and its statutory basis is worth setting out because it bears on any European supply plan.

Chapter Nine b of the ZLPHM, articles 217a to 217e, provides that export may be carried out only by a holder of a wholesale or manufacturing authorisation, and that for these purposes export expressly includes intra-Community supply. That is the provision that makes the regime bite on Western Europe rather than only on third countries.

Article 217b creates СЕСПА, a specialised electronic tracking system fed by manufacturers, wholesalers, pharmacies reporting daily, the health fund and the Ministry. A shortage exists, quantitatively, when quantities available in Bulgaria fall below 65% of one month’s national demand, calculated on the average of the preceding six months. Article 217c requires the IAL to compile and publish the shortage list, updated weekly, transmit it to the Customs Agency, and prohibits export of listed products for the duration of listing. That article was struck down as unconstitutional in 2015 and re-enacted in 2018.

The limitation matters: the ban reaches only products on the Positive Drug List. Whether any semaglutide presentation is on that list could not be confirmed, so whether GLP-1s are currently export-restricted in Bulgaria is unresolved. It is a cheap check and it is the hinge for the whole Bulgarian picture, because the same fact determines reimbursement.

Article 234(4) bans internet sale of prescription medicines. Article 234(6) permits online sale of non-prescription medicines by an authorised pharmacy or drogerie, with the EU common logo required under 234(7) and (8).

The IAL register, whose title states the over-the-counter limitation on its face, has 152 entries as at 17 July 2026. Named operators include sopharmacy.bg from the Sopharma group, four BENU listings, framar.bg registered as far back as April 2012, remedium.bg, e-apteka.bg, sanita.bg and a dozen more. Eleven entries are Glovo storefronts, registered on 19 February 2026, covering BENU and Farmavision outlets among others.

So Bulgaria has a real, regulated, rapidly modernising online pharmacy channel, complete with rapid-delivery platform integration, and it is legally incapable of dispensing a GLP-1. Any Bulgarian consumer-facing model terminates at a physical counter.

Bulgaria stacks four restrictions that together make most GLP-1 marketing structures unworkable.

Article 247 permits public advertising only of medicines dispensed without prescription. Article 248a separately prohibits internet advertising of prescription medicines, with a narrow vaccination-campaign exception. Article 245a limits advertising to products holding a Bulgarian marketing authorisation. And article 246(5) prohibits a medical specialist, or a person presenting themselves as a medical specialist, from carrying out direct or indirect advertising of medicines in print, electronic media or on the internet.

That last one is aimed squarely at the standard telehealth playbook of clinician-fronted content. A Bulgarian-language campaign using doctor faces or doctor endorsement runs into it directly.

Procedurally, public advertising requires prior authorisation from the IAL executive director on the opinion of an Expert Council on Advertising, decided within a month, with tacit approval if the month passes without a decision. Advertising to healthcare professionals needs only prior notification.

No GLP-1 advertising enforcement action was found, though the absence is weakly evidenced. What the IAL has published on GLP-1s is safety communication: Ozempic shortage notices, a Rybelsus medication-error warning about the higher-bioavailability reformulation, and EMA alerts on falsified Ozempic pens.