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RLF - Bulgartransgaz Strategic Gas Reserve Financing



Project number:


Business sector:

Natural resources

Notice type:


Environmental category:


Approval date:

15 Nov 2022


Passed Final Review, Pending Approval

PSD disclosed:

21 Sep 2022

As permitted by paragraph 2.6 of Section III of the Access to Information Policy, disclosure of this PSD was deferred in accordance with paragraph 1.4.4 of the Directive on Access to Information.

Project Description

Provision of a four-year senior revolving loan of up to EUR 125.4 million to Bulgartransgaz EAD under the Resilience and Livelihoods Framework for 1) refinancing of the bridge loan received from the Government of Bulgaria; and 2) for acquisition of natural gas for the accumulation and/or replenishing of the national gas reserve. The loan will be guaranteed by the Republic of Bulgaria.

This project was approved in the context of the Bank's response to the Russian-led invasion of Ukraine in February 2022. To avoid delays to the delivery of this project, the Bank's President granted a deviation from the ordinary timelines for PSD disclosure, as contemplated by Section V of the Directive on Access to Information. Details of this deviation, and the Bank's response to this situation, can be found on our website.

Project Objectives

The strategic importance of the transaction is driven by the energy security objective to ensure continued and uninterrupted gas supply in Bulgaria during the 2022 winter season and the following years. This is essential to safeguard basic needs and economic livelihoods of the local population. The financing will enable procurement of gas from the Balkan Gas Hub to build and maintain the country's national strategic gas reserve and compensate for the discontinuation of deliveries under the pipeline gas contract with Gazprom.

Transition Impact

ETI score: 65

The Project will support the Resilient and Green TI qualities:

Resilient: The operation will support the accumulation of strategic gas reserve to meet the country's minimum 80% gas storage level obligation for the coming winter in order to ensure continuity and safety of supply and price affordability for domestic market, while helping to achieve the EU's requirement for its Member States to ensure that their underground storages are filled up to at least 80% of capacity by 1 November 2022, rising to 90% for the following 5 years. Currently storage capacity is bellow the required level and among the lowest levels within the EU states.

Green: EBRD will provide technical support to Bulgaria to draft the amendments to the licensing and permitting procedures to simplify and expedite the process for a new Renewable Energy Sources Policy (RES) in Bulgaria, thus reducing the administrative burden for new investments from renewable sources. The policy engagement is part of a broader technical assistance, to be provided by EBRD under the Recovery and Resilient Plan, and the outcome of the assignment will be tendering and installation of 1,425 MW of RES and 350MW of co-located storage within the next 4 years.

Client Information


Bulgartransgaz EAD is an independent natural gas transmission and storage system operator of Bulgaria, 100% owned by Bulgarian Energy Holding EAD, a state owned energy holding company 100% owned by the Ministry of Energy of Bulgaria. The client owns and operates 3,276 km of gas transmission network and 550 mcm of underground gas storage.

EBRD Finance Summary

EUR 125,400,000.00

Total Project Cost

EUR 125,400,000.00


Sources of additionality under the Project are (i) Financing Structure, which effectively bridges a financing gap due to adverse market conditions with a longer than available tenor on the market; (ii) Policy, sector, institutional and regulatory change aimed to enhance the practices at the sector and country level by providing technical support to the Bulgarian state to draft the amendments to the licensing and permitting procedures to simplify and expedite the process for new RES in Bulgaria; (iii) Standard-setting aimed to support the client to develop and adopt CCG Plan and climate reporting standards; and (iv) Risk mitigation helping Bulgaria to mitigate energy security risks and provide predictability of funding and stable pricing.

Environmental and Social Summary

Categorised B (ESP 2019). The independent environmental and social due diligence, consisting of the review of the EIA documents for key storage and transmission facilities and a site visit to selected facilities, that are crucial for the transportation and storage of the purchased gas, is ongoing. Key issues, identified to date, are associated with the excessive CO2 equivalent emissions (above permitted levels in some instances) most probably from the Chiren gas storage and outdated compressor stations. Chiren underground storage is the only available gas storage facility and is subject to the ongoing modernisation funded by the EU. Key issues associated with the Chiren UGS include landtake and compensation of affected people; compliance with SEVESO, IED and ATEX Directives. Some of the gas transmission facilities seem to traverse or be adjacent to protected areas and the Bank will review the Company's approach to managing biodiversity issues. The ESAP for identified risks and impacts will be agreed as a Condition Precedent to Disbursement.

Technical Cooperation and Grant Financing


Company Contact Information

Petya Todorova
66 P. Vladigerov Blvd. 1336 Sofia, PO Box 3

PSD last updated

21 Sep 2022

Understanding Transition

Further information regarding the EBRD’s approach to measuring transition impact is available here.

Business opportunities

For business opportunities or procurement, contact the client company.

For business opportunities with EBRD (not related to procurement) contact:

Tel: +44 20 7338 7168

For state-sector projects, visit EBRD Procurement:

Tel: +44 20 7338 6794

General enquiries

Specific enquiries can be made using the EBRD Enquiries form.

Environmental and Social Policy (ESP)

The ESP and the associated Performance Requirements (PRs) set out the ways in which the EBRD implements its commitment to promoting “environmentally sound and sustainable development”.  The ESP and the PRs include specific provisions for clients to comply with the applicable requirements of national laws on public information and consultation as well as to establish a grievance mechanism to receive and facilitate resolution of stakeholders’ concerns and grievances, in particular, about environmental and social performance of the client and the project. Proportionate to the nature and scale of a project’s environmental and social risks and impacts, the EBRD additionally requires its clients to disclose information, as appropriate, about the risks and impacts arising from projects or to undertake meaningful consultation with stakeholders and consider and respond to their feedback.

More information on the EBRD’s practices in this regard is set out in the ESP.

Integrity and Compliance

The EBRD's Office of the Chief Compliance Officer (OCCO) promotes good governance and ensures that the highest standards of integrity are applied to all activities of the Bank in accordance with international best practice. Integrity due diligence is conducted on all Bank clients to ensure that projects do not present unacceptable integrity or reputational risks to the Bank. The Bank believes that identifying and resolving issues at the project assessment approval stages is the most effective means of ensuring the integrity of Bank transactions. OCCO plays a key role in these protective efforts, and also helps to monitor integrity risks in projects post-investment.

OCCO is also responsible for investigating allegations of fraud, corruption and misconduct in EBRD-financed projects. Anyone, both within or outside the Bank, who suspects fraud or corruption should submit a written report to the Chief Compliance Officer by email to All matters reported will be handled by OCCO for follow-up. All reports, including anonymous ones, will be reviewed. Reports can be made in any language of the Bank or of the Bank's countries of operation. The information provided must be made in good faith.

Access to Information Policy (AIP)

The AIP sets out how the EBRD discloses information and consults with its stakeholders so as to promote better awareness and understanding of its strategies, policies and operations following its entry into force on 1 January 2020. Please visit the Access to Information Policy page to find out what information is available from the EBRD website.

Specific requests for information can be made using the EBRD Enquiries form.

Independent Project Accountability Mechanism (IPAM)

If efforts to address environmental, social or public disclosure concerns with the Client or the Bank are unsuccessful (e.g. through the Client’s Project-level grievance mechanism or through direct engagement with Bank management), individuals and organisations may seek to address their concerns through the EBRD’s Independent Project Accountability Mechanism (IPAM).

IPAM independently reviews Project issues that are believed to have caused (or to be likely to cause) harm. The purpose of the Mechanism is: to support dialogue between Project stakeholders to resolve environmental, social and public disclosure issues; to determine whether the Bank has complied with its Environmental and Social Policy or Project-specific provisions of its Access to Information Policy; and where applicable, to address any existing non-compliance with these policies, while preventing future non-compliance by the Bank.

Please visit the Independent Project Accountability Mechanism webpage to find out more about IPAM and its mandate; how to submit a Request for review; or contact IPAM  via email to get guidance and more information on IPAM and how to submit a request.


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