Dimitar Todorov to FACTI: Heating bills remain inflated even after the new regulation, the formula is the same

The changes to the Regulation on Heat Supply, published in the “State Gazette“ on May 5, 2026 and signed by the Minister of Energy Traycho Traykov, have once again put the topic of heating bills at the center of public attention. The main question is whether, after the decision of the Supreme Administrative Court, the formula for calculating energy from the so-called “building installation“ has actually been changed and whether consumers will receive fairer and more transparent bills. Energy expert Dimitar Todorov spoke to FACTI on the topic.

- Mr. Todorov, on May 5, 2026, in the “State Gazette“ issue 41, the Minister of Energy Traycho Traykov signed the changes to the Regulation on Heat Supply. Changes - yes, but is there a new formula for “building installation“?
- After the decision of the Supreme Administrative Court (SAC) on the invalidity of the formula for calculating energy from building installation, the Ministry of Energy (ME) had to make changes to the regulation on heat supply so that this formula would become clear, understandable and transparent for subscribers. In order to implement the court's decision, the ME proposed a draft for changes to the regulation on heat supply and it was submitted for public discussion. Unfortunately, comparing the changes made with the old regulation and its methodology, it can be seen that the formula for the building installation remains the same. The only change is that the heat transfer company will provide monthly information to heat energy consumers for each of the values in the formula.

- Will this change help consumers calculate the energy consumed by the building installation?
- The consumer, knowing the values of the quantities in the formula, will be able to calculate the energy. Simple mathematics. If they tell you to add 20 + 20, you will do just fine, but the truth is that you have to add 2 + 2.

- The question is, do these values correspond to reality?
- No, they do not, they are invented.
Here is why:
1. The capacities of the heating elements in the formula are determined at design temperatures of the heat carrier, which are 90°C at the supply and 70°C at the return. In reality, the district heating system operates at 70°C at the supply and 50°C at the return. This is evident from letter No. G-12341A/22.10.2015 of “Toplofikatsiya – Sofia” EAD. With such parameters, the capacity of the heating elements is 1/3 less than at design temperatures.
2. The value of the day degrees includes the number of days during the entire heating period. In reality, during the heating period there are days with quite high temperatures and then more of the subscribers turn off their radiators, i.e. the building installation does not work. This means that the degrees Celsius are less than those provided by the district heating system.
3. Many subscribers, due to false bills and high prices, have given up using radiators – finding alternative sources of heating. This is the reason why entire sections of the installation do not work. The trouble comes from the fact that the capacities of the heating units are strongly influenced by the subjective factor. It is up to the person to decide how many and which heating units to leave working and which ones to remove from the heating installation altogether. It is up to the person to decide which division to turn the thermostat valve to or turn it off completely. It is up to the person to decide when to go on vacation or go to the hospital and turn off all the heating in their home. With these uncontrollable and unpredictable manipulations, the capacities of the heating units change uncontrollably and unpredictably, and the heat transfer from the pipes of the vertical building installation also changes. All these dependencies make the physical formula invalid and the court rightly overturned it. No matter how you look at it, the calculation of the energy from the building installation is not correct. The formula used for these calculations does not exist in the scientific literature. It is invented and, except for our regulation, you will not find it in the scientific literature, nor in a scientific monograph or abstract journal. It cannot exist, because there cannot be a mathematical formula that is influenced by feelings, mental state, desires and intentions of a person.
4. Anyone can see for themselves that the formula does not give correct results in the following way: Multiply the coefficient 0.15 (or 0.1, if the pipes are insulated and closed) by the heating energy from the equalization bill. It is determined as the energy for hot water is subtracted from the reading of the heat meter in the subscriber's room, which is a commercial device. After the multiplication, you will get the actual energy for the building installation. Then compare the result obtained with the energy for the building installation, which is written in the equalization bill. The big difference will surprise you.

- You have already warned that the new regulation may preserve the inflated bills for subscribers. Where do you think the biggest problem in the new texts is?
- There are no new texts, so the inflated bills for the building installation remain. The changes are written in the regulation textually, but the formula is in the methodology to this regulation and remains hidden, not visible. That is why a visual comparison cannot be made. The Ministry of Energy had a problem how to get out of the situation and came up with this trick, which is intended primarily to deceive the court, as well as the subscribers of the district heating system. The warnings in the media that the new changes do not change the formula and that the problems with high bills remain, went unheeded. The biggest problem is that the Ministry of Energy pretends not to understand where the problem is and therefore does not make any changes. Or rather, it understands, but it is not profitable for the district heating systems and the share distribution companies.

- Why is this not profitable for the district heating systems and the share distribution companies?
- The district heating systems and the share distribution companies have an interest in using the existing formula for calculating the energy from the building installation, because through it they increase the energy consumed by it by more than 30%. This means that the heating energy from the radiators will be less. Therefore, subscribers with radiators will pay less and will not have an interest in giving them up. And this means more distributors sold, more fees for their inspection. Moreover, these fees are raised without any grounds or control, as in banks. And what will happen to them next year, when distributors and hot water meters will have to be replaced with ones with remote reading? According to the law, they are the property of subscribers and they will spend a lot of money on devices for share distribution, for keeping an account and for replacement and reading fees every month.

- The new methodology introduces additional coefficients for energy efficiency and for visible or hidden risers. Will this lead to a more accurate distribution of costs, or will it make the bills even more incomprehensible for consumers?
- Dear Mr. Kamenov, there are no additional coefficients. The coefficients 0.15 and 0.1 to the formula also exist in the methodology in force so far. One would have to be blind not to see that the coefficients remain the same. But, I repeat, the new coefficients are written in the regulation without showing the formula that is in the methodology. Thus, they remain hidden. Only an enlightened person in this field can understand the lie that is being offered to us. There will be no more accurate distribution of costs. The bills will be more understandable, since the district heating companies promise to provide the values of the quantities in the formula every month, but the results will not be correct.

- Many people complain that they pay high bills, even when their radiators are turned off. In your opinion, is there a real way for a person not to pay for heat that he does not use?
- Regardless of whether the radiators are turned off or there are no radiators at all, the subscriber is obliged to pay for the energy for the building installation. He uses some heat emitted by it and it must be paid for. The question is whether this energy is determined correctly. Using the formula from the energy calculation methodology gives inflated results and that is what people complain about. It is correct to use the heating energy from the equalization account by multiplying it by a factor of 0.15 or 0.1. In Art. 10, item 1 of Directive 2012/27 it is written that “the billing information shall be accurate and based on actual consumption“. In Art. 155, paragraph 2 of the Energy Act it is also written that “the heat transfer company or the heat supplier shall invoice the consumed amount of heat energy based on actual consumption at least once a year“. That is, it is stated very clearly that the actual consumption must be invoiced. The equalization accounts give the heating energy of the condominium. It is obtained by subtracting the energy for hot water from the total energy consumption for the site (according to the readings of the heat meter in the subscriber station). The resulting energy for heating can be considered actual. Multiplying this energy by 0.15, we will obtain the energy of the building installation. The formula should look like this.
Qси = 0.15 Qот
where:
Qси = the energy of the building installation for the district heating system;
Qот = the heating energy from the equalization account;
0.15 = coefficient indicating the share of the energy of the building installation in relation to the heating energy from the equalization account. In cases specified by the regulation, a coefficient of 0.1 may also be used.
A simple, clear, understandable, accessible and transparent formula!

- Do you expect the new rules to lead to more lawsuits between consumers and district heating companies, as has happened so far?
- There are no new rules, nothing changes. Court cases will remain at the same level as before.

- What should and most importantly can the state do to ensure more transparency in the formation of heating bills and for people to actually be able to check whether the charges are correct?
- The question is very general, it applies to the entire regulatory framework, not just to building installation bills. The first thing that needs to be done is to put the regulatory framework in order. This is not easy, because as a member of the European Union, Bulgaria is obliged to implement European directives, and they are not in line with our laws. For example, heat allocators are illegal because:
a) they do not meet the requirements of the Measurements Act;
b) the requirement of the BDS/EN 834 standard for the distribution of measured, not calculated (according to our methodology) heat energy is not observed;
c) they are not subject to inspection by the Bulgarian Institute of Metrology;
d) during installation, a technician introduces coefficients into them, which creates an opportunity for corruption.
The methodology in the heat supply regulation provides for the risers to be charged ex officio share units, which together with the units from the radiator distributors form a total sum of share units. The heating energy divided by this total shows the energy value of one share unit. This mixing of radiators with distributors and risers without share distribution devices is a violation of the BDS/EN 834 standard for distributors. The subscriber cannot understand what energy the units of his radiator correspond to.
An amendment to the Energy Act was published in the State Gazette No. 54/17.07.2012, according to which the words consumer, users, consumer, etc. everywhere should be replaced with the words client, clients, client, etc. Later, this was also done in the regulation on heat supply. Interestingly, this only applied to this law. Why was the amendment not made to all laws? Why do the Consumer Protection Act, the Consumer Protection Commission, the Consumer Protection Federation, the Consumer Protection Association continue to exist, but we do not have a Customer Protection Act, a Customer Protection Commission, etc.? This term “client“ in the Energy Act deprives consumers of district heating companies of protection under the Consumer Protection Act (CPA), because they are not consumers, but customers. You cannot not pay for an unsolicited service (see Art. 62, para. 1) and therefore you pay for a building installation, even if you do not want it.
In Art. 156, para. 1 of the ZE it is stated very clearly: “Thermal energy is measured with commercial metering devices - owned by the heat transfer company, installed at the property boundary of the facilities”. In para. 2 an explanation follows: “The property boundary of the facilities between the heat transfer company and the heat energy customers in a separate building or in a building - condominium ownership is the last shut-off valve before the distribution network of the building installations”. If the heat meter is installed there, i.e. after the heat exchanger for heating the building, it will be possible to say that the requirement of the BDS EN 834 standard for measuring heating energy is fulfilled. The heat meter, however, is not installed there, at the property boundary, but is installed at the beginning of the subscriber station - where the pipes from the heat transfer company enter.

The responsible officials in the Ministry of Energy, the heads of the District Heating Company, and the share distribution companies believe that this is permissible, because for lobbying reasons

In the same article 156 of the ZE, a paragraph 3 was added, according to which “When thermal energy is measured with commercial measuring devices installed in a place other than the property boundary under paragraph 2, the method of reporting thermal energy is regulated in accordance with the regulation”. This means calculating the energy for heating. The astute reader will immediately notice that the added paragraph 3 in article 156 completely eliminates the mandatory provision of paragraph 1.
In simple words, it is legal, but if it is not, it is still legal. And if this is legal... Should you laugh or cry? However, Toplofikatsiya has skillfully taken advantage of the situation, and therefore, it is hardly possible to find a subscriber station in which there is a heat meter installed at the property boundary. When using only one heat meter, all types of energy (for technological needs, for hot water, for building installation and for heating the properties) are calculated according to formulas from the heat supply regulation and its methodology. The law, however, requires that the energy actually consumed be invoiced, and this is achieved by measurement, not by calculation.
There are many problems, they have been written about in parliament and in the Ministry of Economy and to the Prosecutor General, but... a voice in the wilderness. As can be seen, nothing changes with this new regulation.