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Evgeniy Kanev: What does a frozen contract for BOTAŞ mean?

International energy organizations (such as Bankwatch Network and ICIS) and the European Commission have long suspected that the initial contract between BOTAŞ and Bulgargaz was actually the operational backbone of a tripartite agreement designed to mask the origin of Russian gas

Jul 9, 2026 16:00 56

Evgeniy Kanev: What does a frozen contract for BOTAŞ mean?  - 1
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Almost everything that concerns Bulgaria comes under pressure from outside. And almost never as a political will to protect real national interests.

(1) The Deal

According to official statements from the Turkish Ministry of Energy and international energy media, BOTAŞ and Bulgargaz signed a new protocol to freeze and restructure their controversial 13-year gas agreement.

Parameters:

(A) 15-month suspension: The original 2023 contract is frozen for a period of 15 months.

(B) Pay-as-you-use capacity: During this freeze window, Bulgaria is completely exempt from paying the heavy fixed daily fees for take-or-pay capacity. Instead, it will only pay when it actually uses Turkey’s LNG (liquefied natural gas) terminals and transmission networks.

(C) Lower fees: Turkish Energy Minister Alparslan Bayraktar confirmed that the protocol establishes “improved commercial terms”. International reports indicate that this includes significantly reduced regasification prices and transit fees if Bulgaria chooses to transport gas through Turkey.

(D) Debt settlement framework: The protocol outlines a roadmap for dealing with accumulated debts (around $360 million) so as not to burden public finances while the contract is optimized.

But! It is necessary to closely monitor where and to whom Bulgaria pays these amounts and whether they will eventually go to Russia, for gas previously delivered to Turkey, which was supposed to go to Bulgaria.

(2) The Russian connection

“Gazprom“ and international media have confirmed that Ukrainian unmanned aerial vehicles (UAVs) are systematically attacking critical compressor stations in the Russian Krasnodar region (such as the Krasnodarskaya and Russkaya stations). These stations act as vital entry points, pushing Russian gas into the “Blue Stream“ and “Turkish Stream“ pipelines under the Black Sea. With the termination of land transit through Ukraine, these sea routes are the last major export arteries for “Gazprom“ to Europe, making them a permanent military target for Ukraine.

International energy organizations (such as Bankwatch Network and ICIS) and the European Commission have long suspected that the original contract between BOTAŞ and Bulgargaz was actually the operational backbone of a tripartite agreement designed to disguise the origin of the Russian gas.

The mechanism works through a process known as gas “washing” or blending. Under the original agreement, Bulgargaz does not buy gas directly from the Turkish grid, but buys the right to offload LNG at Turkish terminals, while BOTAŞ delivers an equivalent volume of gas to the Bulgarian border. Importantly, the contract does not specify

the geographical origin of the gas delivered to the border.

Since Turkey imports about half of its pipeline gas directly from Russia, Russian gas is blended in the Turkish grid with Azerbaijani gas and international LNG. When BOTAŞ pumps gas north to Bulgaria, it is commercially classified as “Turkish blended gas“, bypassing the EU's political bans on direct imports of Russian pipeline gas.

3. EU pressure

It is little known in our country that Bulgaria undertook the renegotiation not at Radev's request, but under pressure from the EU.

This pressure came on two main fronts:

(A) The European Commission's antitrust investigation

At the end of 2023, the EC officially launched an antitrust investigation into the BOTAŞ agreement. The EU's “Competition” Directorate intervened because the contract violated the rules of the single market. It gives BOTAŞ exclusive access to the Bulgarian gas network (and consequently to the wider EU market) through the infrastructure of “Bulgartransgaz“, bypassing the rules for transparent and open capacity auctions. Pressure from Brussels included the threat of catastrophic multi-million euro fines.

(B) “Gas laundering“ check and sanctions

The EU has pressed Bulgaria for the complete lack of transparency about the origin of the gas in the contract, which contradicts the bloc’s geopolitical stance of waiving Russian energy. The European Parliament has asked the Commission for full access to the classified provisions of the contract.

The result: the 15-month freeze serves as a regulatory shield for Bulgaria, temporarily suspending the very anti-competitive mechanisms that the European Commission was preparing to sanction.

4. Why did Turkey agree to the freeze?

At first glance, it seems that Ankara is giving up a guaranteed half a million euros per day for nothing in return. In reality, this is a strategic move:

(A) Saving the ambition of a “Turkish Gas Hub“

If Turkey had strictly enforced the penalties, Bulgargaz would have faced bankruptcy or the EU would have declared the contract completely invalid. By freezing, BOTAŞ keeps the contract legally alive, avoids legal battles with the EU, and preserves its reputation as a flexible partner.

(B) Concessions outside the gas sector (Political barter)

Turkey accepted the payment freeze in exchange for support in other strategic sectors, including commitments to cooperate on border tightening and Bulgaria's lobbying in the EU to update the EU-Turkey Customs Union.

(C) Avoiding a complete bankruptcy on Bulgargaz's debt

Bulgargaz has already accumulated hundreds of millions of dollars in arrears. Turkey realizes that demanding money from a company that has been banned by parliament from paying these fees is a dead end. The protocol provides a structured framework for repaying the debt accumulated to date.

Here is the key:

(1) When, how and to whom will Bulgaria pay these amounts

(2) Are they related to Russia's difficulties in fulfilling its commitments on TurkStream - requesting Turkey to force Ukraine to stop bombing the Russian coast, where TurkStream begins

(3) Are the unclear huge amounts set aside in the draft budget - which I commented on - unrelated to payments on BOTAŞ?