On July 22, 2026, the National Assembly of Bulgaria adopted at second reading the 2026 budget of the National Health Insurance Fund (NHIF, NZOK), alongside the 2026 State Social Security budget, according to the parliament's official release. For pharma marketing authorisation holders (MAHs) selling into Bulgaria, the decisive line is the EUR 1.334bn envelope the law earmarks for medicinal products, medical devices and related payments, the single NHIF appropriation from which reimbursed-medicine revenue in the country is drawn.
The NHIF budget fixes total revenue, transfers and expenditure at EUR 5.256bn for 2026, up EUR 412.3m, or 8.5%, against the 2025 NHIF budget law. The health-insurance contribution rate stays at 8%. Having passed second reading, the bill now goes to the President of the Republic for promulgation in the State Gazette (Darzhaven vestnik); it enters into force three days after promulgation unless the act itself provides otherwise.
What is in the 2026 NHIF budget for medicines and devices?
The law allocates EUR 1.334bn to payments for medicinal products, medical devices and related items, the appropriation that funds Positive Drug List reimbursement. Hospital care receives EUR 2.342bn, specialised outpatient care EUR 351.2m and primary outpatient care EUR 345.6m. Health-insurance revenue is budgeted at EUR 5.138bn, split into EUR 3.187bn from contribution income and EUR 1.95bn in transfers for health insurance. Contribution income is projected to grow EUR 249.2m year on year, transfer revenue EUR 156.2m.
Why does this matter for pharma market access in Bulgaria?
The EUR 1.334bn medicines-and-devices envelope is the pool every reimbursed MAH draws on, so its size and the mechanism that allocates it directly move product revenue. The exposed audience spans domestic manufacturers such as Sopharma and Actavis/Balkanpharma-Teva alongside research-based MAHs including Pfizer, Novartis, Sanofi, GSK, AstraZeneca, Roche and Bayer, all of which sell reimbursed products into the Bulgarian market. The reimbursement mechanism itself has been contested since April 2024, when the Supreme Administrative Court ruled the 2021 NHIF reimbursement method for Positive Drug List medicines unconstitutional, finding that it shifted the fund's deficit onto MAHs. The Bulgarian Generic Pharmaceutical Association and the Association of Research-Based Pharmaceutical Manufacturers in Bulgaria have since pressed for a lawful annual mechanism.
The adopted budget confirms the 2026 financing envelope but the press release does not, by itself, re-enact the reimbursement methodology. Whether the promulgated law restates or replaces the annulled 2021 mechanism must be verified against the State Gazette text once published. Until a lawful mechanism is in force, reimbursement continues to carry the legal uncertainty the court identified.
What should market-access and pricing teams do now?
Track promulgation in the State Gazette and read the adopted articles on the reimbursement mechanism, not only the headline totals. Confirm whether your products' Positive Drug List status and margin assumptions still hold under the 2026 envelope and any new methodology. Update Bulgaria revenue forecasts for the 8.5% NHIF uplift and the held 8% contribution rate, and brief pricing and regulatory affairs on the court-driven legal risk if the mechanism question is left open.
| NHIF 2026 budget line | Amount | Change vs 2025 |
|---|---|---|
| Total revenue, transfers and expenditure | EUR 5.256bn | +EUR 412.3m (+8.5%) |
| Health-insurance contribution revenue | EUR 3.187bn | +EUR 249.2m |
| Transfers for health insurance | EUR 1.95bn | +EUR 156.2m |
| Medicinal products, devices and related payments | EUR 1.334bn | envelope set for 2026 |
| Health-insurance contribution rate | 8% | unchanged |
Take advantage of this real-time watch
Next steps: watch the State Gazette for promulgation and the exact reimbursement-mechanism articles, re-check Positive Drug List exposure against the EUR 1.334bn envelope, and re-baseline 2026 Bulgaria forecasts against the 8.5% NHIF rise. Obsidian's continuous, per-jurisdiction monitoring surfaces a change like this the moment parliament votes, before the text reaches the gazette.


