Two banks offer a loan for the same home. One has a lower rate, the other fewer conditions. Which one is cheaper is rarely obvious from the first line of the offer. Bulgaria's Consumer Real Estate Credit Act (ЗКНИП) gives you the tools for a fair comparison – as long as you know where to look. Information verified October 2026.
For the general terms of mortgage lending, see our guide to mortgages in 2026. Here we focus on the comparison alone.
The European Standardised Information Sheet (ESIS; Annex 2 to the Act) is the document designed precisely for comparison. The bank provides it:
For a fair comparison, ask both banks for an ESIS for the same amount, the same term and the same type of rate. Different parameters make the numbers incomparable.
The bank makes a binding offer after assessing your creditworthiness (Art. 9(2)). A draft contract containing all the individually agreed terms counts as a binding offer, and from receiving it you have 14 days to decide (Art. 9(3)). During that period the offer binds the bank and you may accept it at any time (Art. 9(4)).
Use those days to check the draft against the ESIS line by line. If the terms of the binding offer differ from the ESIS you received earlier, the bank must attach a new one (Art. 9(1)).
The annual percentage rate of charge (APR, ГПР) expresses the total cost of the credit as an annual percentage of the total loan amount (Art. 29(1)). It is the best single number for comparison – but you need to know what is in it.
The APR includes (Supplementary Provisions, § 1(17)):
The APR excludes notary fees, registration fees for the transfer of ownership, and costs arising from default (late payment and the like).
Two caveats. First, with a variable rate the APR is a snapshot at today's levels – the ESIS carries a warning that the actual APR may differ if the rate changes. Second, the APR only compares fairly between offers with the same amount and term.
The variable component is the reference rate. It may be a market benchmark (such as Euribor), an index published by the Bulgarian National Bank or the National Statistical Institute, or a combination (§ 1(24)). The bank applies it under a methodology that forms part of the contract and cannot be changed unilaterally after signing (Art. 25(1)–(3)). The methodology and the current value are published on the bank's website, and information on the indices used must go back 20 years (Art. 25(4)–(5)).
The questions for every offer are the same: what is the reference rate and what is it today; what is the margin; how long is the fixed period, and what follows it.
The Act is clear:
If an offer shows a "processing fee" or "management fee", ask exactly what it is for and where the contract specifies it. The property valuation is usually a separate cost – check who commissions it, what it costs and whether it is included in the APR.
A bundled sale (пакетна продажба) is a loan sold together with other products where the loan is also available on its own, though not necessarily on the same terms; a tied sale (обвързваща практика) is one where it is not available separately (§ 1(14) and (19)). Bundling is allowed (Art. 12(1)). Tying is permitted only for an account or savings product linked to servicing the loan, and for certain investment or pension products (Art. 12(2)).
If the bank requires insurance, it must also accept a policy from another insurer offering equivalent cover (Art. 12(3)). What banks typically require for property insurance is covered in our home insurance guide.
For a "rate discount in exchange for a package" (salary account, insurance, cards), ask for two numbers – the rate with the package and without it – and what happens if you later drop one of the products.
This example is invented and simplified – it is not an offer from any bank. Insurance is assumed at a constant annual amount, and the APR is our approximation. The actual APR is calculated by the bank under Annex 1 to the Act.
A loan of €150,000 over 30 years, annuity repayments:
| Offer A | Offer B | |
|---|---|---|
| Interest rate (assumed for the whole term) | 2.69% | 2.49% |
| Property valuation | paid by the bank | €200 |
| Mandatory property insurance | €120 a year | €120 a year |
| Mandatory life insurance | none | €300 a year |
| Mandatory account | €2 a month | none |
| Monthly loan payment | €607.61 | €591.90 |
| Monthly incl. all mandatory costs | €619.61 | €626.90 |
| Total paid over 30 years | ≈ €223,060 | ≈ €225,890 |
| APR (approximate) | ≈ 2.88% | ≈ 2.98% |
Offer B has the lower rate and the lower loan payment, but once the mandatory life insurance is added it is the more expensive one. If B's rate is variable and is one percentage point higher from the start, the payment rises to about €672.73. You can run the numbers for your own case with our mortgage calculator.
The terms for early repayment belong in the comparison, especially if you expect a larger sum in a few years. What the law says and when the bank may ask for compensation is explained in our refinancing guide.
When you buy with a loan, we sit down with you over the offers, put them into one table and align the bank's timeline with the deal's deadlines.
If you have two offers and want a second look before you sign, call us or visit our office.
This is general information, not financial or legal advice for a specific case. Rates and fees change – the bank's ESIS and contract are what count.
