Highways in Bulgaria's neighboring countries and in developed countries of the European Union are built according to different models, but there is one thing in common: there is rarely a single approach. In the region and in the EU, road infrastructure is financed through a combination of the state budget, European funds, public procurement, concessions and public-private partnerships, and the rules for awarding are subject to European legislation on concessions and public procurement.
The European Commission emphasizes that concessions allow for the mobilization of private capital and expertise, without necessarily directly increasing public debt, and the scope of the European directive also includes concessions for roads, highways, maintenance and management of infrastructure. For construction and service concessions above a certain threshold, specific rules on award and transparency apply.
The region: a mixed model, not a single recipe
Croatia is one of the clearest examples of a mixed model. According to the Ministry of the Sea, Transport and Infrastructure and the national operator Hrvatske autoceste, the motorway network is managed by the state-owned company HAC and several concessionaires, including BINA-ISTRA and Autocesta Zagreb-Macelj, while open tenders are also used for new activities and supplies. In 2024, HAC signed a contract following a public procurement procedure for a new electronic toll system for the entire network, including concession sections.
In Poland and Hungary, concession sections are also part of the picture, but the state remains an active participant in the construction and management of a significant part of the routes. In Poland, the state road administration GDDKiA continues to manage key sections and implement its own toll solutions, while private concessionaires operate individual motorways. In Hungary, the model also combines state construction and concessions, including long-term operation and maintenance contracts.
In Poland, some motorways are state-owned, while others are concessioned. According to the Directorate-General for Roads, sections of the A2 and A4 are no longer tolled by cars on the state-owned sections, while the A2 "Nowy Tomysl - Konin" in Poland and the A4 "Katowice - Kraków" are examples of long-standing concession regimes in the region. The Bulgarian approach in recent years has also relied on design and construction tenders, and public-private models are being discussed for some sections.
How the EU works: public procurement and competition
In more developed EU countries, highway construction most often goes through public procurement and tenders, rather than through classic concessions. The European Commission points out that the public procurement and concessions directives provide a common framework for awarding contracts, and member states submit regular reports on these rules. The EU public procurement market itself is huge, worth hundreds of billions of euros annually.
This means that in Germany, France, Austria, Spain and other Western European countries, highways are usually built and maintained through open procedures, in which the state sets the parameters and private companies participate as contractors. Concessions are used more limitedly and most often for management, maintenance, toll collection or for specific sections with higher investment risk.
The European Commission also reminds that for some transport projects, state aid and the regulatory framework are key, especially when it comes to large infrastructure projects with a long payback period. This is why the “state + tender + private contractor” model remains dominant in the EU, while the concession is a tool used according to the specific project, not a universal solution.
Why concessions are not the same everywhere
Practice shows that concessions work well where traffic is predictable, contracts are stable, and the risk is clearly distributed between the state and the private operator. The World Bank points out that in road concessions, key factors are traffic, toll revenues, the legal framework and the state's willingness to share the risk. Otherwise, it leads to contract revisions, higher fees or political disputes.
This explains why there are different solutions in the region. In some countries, concession is the main model for specific highways, in others it is only a supplement to state construction, and in still others it was mainly used in the past and today new sections are awarded through public procurement.
The general trend is clear: in the EU, motorways are not built according to a single scheme, but through a combination of instruments selected according to length, traffic, financial risk and the role of the state. In Bulgaria's neighboring countries there is also no single model, but almost everywhere the same rule is visible - the larger the project, the more complex the combination between budget, tender and, under certain conditions, concession.
Sources: European Commission, DG “Roads“, Ministry of the Sea, Transport and Infrastructure of Croatia, Hrvatske autoceste, World Bank