Low Water Levels, High Costs and New Rules: Business Priorities Ahead of September

Over the past week, Bulgarian enterprises received several important signals about the environment in which they will plan their production, supplies, digital products and investment projects over the coming months.

The most significant development concerns the Danube. Critically low water levels are no longer affecting only navigation and logistics. On 21 August, the output of Unit 5 at Kozloduy NPP was preventively reduced by approximately 120 MW because of the extreme hydrological conditions. Such a measure has been applied for the first time in the plant's 52-year operating history.

At the same time, fuel prices in Bulgaria have increased by 22.2% year on year. Road transport, which is usually considered an alternative when river navigation is disrupted, is therefore also under strong price pressure.

These operational risks are accompanied by three developments with longer-term significance. Businesses called for substantial changes to the draft national Digital Transformation Strategy. The first reporting obligations under the Cyber Resilience Act begin on 11 September. The National Recovery and Resilience Plan (NRRP) is entering the final week for completing its milestones and targets.

The overall conclusion is that enterprises can no longer manage energy, logistics, financial and digital risks as entirely separate issues. Resilience increasingly depends on their ability to monitor interdependencies, maintain reliable data and prepare procedures in advance for situations involving short deadlines.

Low Water Levels on the Danube Are Now Reaching the Energy Sector

On 21 August, the output of Unit 5 at Kozloduy NPP was preventively reduced by approximately 120 MW. According to the plant, the decision was prompted by the continuing unprecedented and critical decline in the Danube's water level and forecasts of a further decrease upstream.

A reduction in output because of extreme meteorological and hydrological conditions has been applied for the first time in the 52-year operating history of Kozloduy NPP. The plant published the official announcement.

An important distinction must be made. Danube water is used to cool the steam in the condensers located in the conventional part of the plant, not to cool the nuclear reactors. The reduction is a preventive measure for safe and reliable operation. It does not automatically mean an electricity shortage or an immediate risk to the power system.

The development does, however, show that prolonged low water levels now have a second channel of impact on the economy. Until now, the main focus was on restricted draught, smaller cargo loads, delays and higher transport costs. These are now joined by the possibility that hydrological conditions may affect electricity generation.

On 24 August, the water level at Ruse was minus 122 centimetres relative to the conventional zero datum, only 2 centimetres above the previous day's level. This indicates short-term stabilisation around a very low level, but it is not in itself evidence of a sustained recovery. Current data are published by the Executive Agency for Exploration and Maintenance of the Danube River.

For enterprises in Northern Bulgaria, the Danube risk should now be assessed across at least four dimensions:

• direct disruption to river transport;
• higher costs for alternative road and rail routes;
• a possible impact on short-term energy prices;
• the need for larger inventories and more working capital.

The issue was examined in detail in RCCI's analysis “Low Water Levels on the Danube as a Business Risk: Logistics, Costs and Resilience for Companies in Ruse”. The new development shows that the assessment should now cover not only supplies but also the enterprise's energy profile.

A useful first step is to identify the production processes that are most sensitive to the price and availability of electricity. Energy-intensive enterprises can examine options for shifting part of their load outside the more expensive hours, using their own generation and storage systems, and temporarily prioritising orders with the highest added value.

Rising Fuel Prices Are Also Increasing the Cost of Contingency Logistics

In July 2026, prices of fuels and lubricants for personal transport equipment in Bulgaria were 22.2% higher than in July 2025. This was the fourth-largest increase in the European Union after Romania, Germany and Lithuania. The average annual increase for the EU was 16.9%. The data were published by Eurostat.

The indicator is part of the Harmonised Index of Consumer Prices and does not directly measure the costs or invoices of transport enterprises. It does, however, confirm the presence of strong price pressure on road mobility.

This is particularly significant under conditions of low water levels. When river transport is disrupted, enterprises may redirect some cargo to road or rail transport. If fuel and available transport capacity become more expensive at the same time, the contingency route may prove considerably more costly than originally planned.

Logistics and manufacturing enterprises can review:

• the validity period of transport quotations;
• fuel surcharge clauses;
• the price index used and the frequency of adjustment;
• profitability by route, customer and product;
• opportunities to consolidate cargo;
• the allocation of additional costs between the carrier, supplier and customer;
• the conditions for changing prices under exceptional market circumstances.

The fuel surcharge should not be an arbitrary percentage added after a problem has arisen. A more reliable approach is a formula agreed in advance, with a base price, a publicly verifiable index, an activation threshold and a clear recalculation frequency.

Manufacturing enterprises would benefit from developing several scenarios for changes in transport costs. This can establish which products, routes or customers lose profitability first and when a quotation needs to be updated.

Businesses Called for a More Ambitious Digital Strategy

The public consultation on the draft Digital Transformation Strategy of the Republic of Bulgaria for 2026-2030 and its implementation roadmap ended on 22 August. Nine comments were published on the Public Consultation Portal.

The Bulgarian Association of Information Technologies (BAIT) presented a position supported by the Bulgarian Industrial Capital Association, the Bulgarian Industrial Association, the Bulgarian Chamber of Commerce and Industry, and the Confederation of Employers and Industrialists in Bulgaria. BAIT also supported the separate position of the Bulgarian Employers Association Innovative Technologies (BRAIT).

The main criticism is that the draft is too heavily oriented towards the digitalisation of public administration and does not set sufficiently ambitious and measurable objectives for enterprises, productivity and industrial development.

BRAIT's position calculates that the amounts allocated to the strategic objectives total approximately EUR 1.93 billion in public resources. This is not a separately announced official overall budget, but the sum of the values stated in the draft. The scale of the resources makes expenditure traceability, coordination between measures and the use of measurable indicators particularly important.

The questions raised by the business community include:

• why the target for the use of artificial intelligence by enterprises in 2030 is 11% when the European target is 75%;
• why some target values are close to or below the reported baseline levels;
• how micro, small and medium-sized enterprises, which lag furthest behind, will be supported;
• how the continuity of schemes for adopting artificial intelligence and cloud technologies will be ensured;
• how the impact on productivity and administrative burden will be measured;
• how businesses will participate in the governance and monitoring of the measures.

The published positions propose that the draft be revised with substantial participation from the representative business organisations and then submitted again to a full 30-day consultation. The documents and positions are available on the Public Consultation Portal.

The strategy does not create an immediate financial or regulatory obligation for enterprises. Its significance is that it may determine future measures for technology adoption, digital skills development, cybersecurity, data infrastructure and electronic administrative services.

The next important stage is the publication of the final document and the report on the accepted and rejected proposals. They will show whether the criticism raised has led to changes in the objectives, budgets, indicators and mechanisms for business participation.

For regional enterprises, it is important to monitor not only the overall national document, but also whether it creates genuine access to services and infrastructure outside the main technology centres.

The First Cyber Resilience Act Obligations Begin on 11 September

The reporting obligations under the European Cyber Resilience Act begin to apply on 11 September 2026. Manufacturers must report actively exploited vulnerabilities and severe incidents affecting the security of products with digital elements.

The requirement provides for:

• an early warning within 24 hours of becoming aware;
• a full notification within 72 hours;
• a final report within 14 days after a corrective or mitigating measure becomes available in the case of an actively exploited vulnerability;
• a final report within one month of the 72-hour notification in the case of a severe incident.

Reporting will be carried out once through the single reporting platform being developed and maintained by the European Union Agency for Cybersecurity, ENISA. The platform is expected to become operational on 11 September. The European Commission has published specific guidance on the procedure and deadlines.

The main requirements of the Cyber Resilience Act become fully applicable on 11 December 2027. The reporting obligations, however, enter into force earlier and cover all products with digital elements made available on the EU market, including products placed on the market before December 2027. The European Commission has summarised the scope and transitional rules.

Affected businesses may include manufacturers that sell under their own name or trademark:

• software and mobile applications;
• industrial controllers and automation systems;
• IoT devices and connected sensors;
• network and communications equipment;
• smart appliances;
• hardware and software components offered separately.

An enterprise that only uses another party's product does not automatically become a manufacturer within the meaning of the Regulation. The first task is to determine the organisation's exact role and which of its own products fall within the scope.

The minimum preparation before 11 September includes:

1. Creating a list of products with digital elements and their versions.
2. Appointing a primary person responsible for notifications and a deputy.
3. Establishing an internal procedure for receiving, assessing and escalating reports.
4. Defining criteria for distinguishing between an ordinary technical failure, a vulnerability and a severe incident.
5. Preparing a template containing the information required for the 24-hour and 72-hour notifications.
6. Coordinating with external developers, component suppliers and maintenance partners.
7. Conducting a trial run of the process using a sample incident.

The short deadlines mean that the procedure cannot depend on the presence of a single employee or on improvised information gathering after a problem arises. Enterprises must know in advance who makes the reporting decision, where the technical data are obtained and how the corrective measure taken is documented.

Fewer Registrations and Bankruptcies Do Not Send a Clear-Cut Signal

In the second quarter of 2026, 11,334 new legal entities were registered in Bulgaria and 966 were declared bankrupt.

Compared with the first quarter, new registrations decreased by 8.9% and bankruptcies by 5.9%. Year on year, registrations were 9.2% lower, while declared bankruptcies fell by 17.7%. The data were published by the National Statistical Institute.

At European Union level, the picture is different. New registrations decreased by only 0.5% compared with the previous quarter, while bankruptcies increased by 5.7%.

The largest decline in registrations in the EU was recorded in industry, at 3.6%. For bankruptcies, the strongest increase was in education and social activities, followed by transport with an increase of 11.4%. The sectoral data were presented by Eurostat.

The Bulgarian data do not show an increase in immediate insolvency. The decrease in new registrations is, however, a negative signal for entrepreneurial activity and willingness to start new business operations.

The two indicators should be interpreted carefully. A smaller number of bankruptcies does not automatically mean an improvement in the financial position of all enterprises. Insolvency data reflect formal proceedings that may lag behind actual difficulties with liquidity, orders and payments.

It is more useful for enterprises to monitor early warning indicators among their customers and suppliers:

• an increase in overdue payments;
• more frequent requests to extend payment terms;
• a decrease or unusual change in orders;
• an accumulation of disputed receivables;
• changes of owners, managers or addresses;
• the emergence of public liabilities, attachments or legal proceedings;
• excessive dependence on a single customer, supplier or carrier.

In an environment of higher transport and energy costs, a review of credit limits, trade credit insurance and revenue concentration is justified. The objective is not to terminate relationships at the first negative signal, but to adjust payment terms and exposure at an early stage.

The NRRP Enters Its Final Week of Implementation

On 25 August, the Working Party of Financial Counsellors at the Council of the EU will review the proposal for the final amendment to Bulgaria's Recovery and Resilience Plan. The meeting and the item concerning Bulgaria are included in the official agenda.

The proposed amendments affect 47 measures. One project for a unified information system for spatial planning, investment design and construction permitting is being removed because of delays defined as being beyond Bulgaria's control.

Two new investments for the digitalisation of the Customs Agency and the National Revenue Agency are being added to the plan. Following the amendments, measures supporting digital objectives represent 21.2% of the plan's total resources. The total financial contribution remains approximately EUR 6.17 billion. The amendments and the European Commission's assessment are presented in the proposal to the Council.

The deadline by which Member States must complete all milestones and targets under their plans expires on 31 August 2026. The European Commission must make the final payments by the end of the year. The rules and deadlines are summarized by the European Commission..

This is not a new application deadline for enterprises. For current beneficiaries, its practical significance concerns the completion and substantiation of activities already commissioned, in accordance with their individual contracts and the instructions of the managing institutions.

The priority review should cover:

• acceptance protocols and evidence of completed deliveries;
• achieved indicators and technical results;
• consistency between contracts, invoices and payments made;
• contractor selection procedures;
• visibility and other mandatory requirements;
• corrections to interim and final reports;
• archiving documentation for subsequent checks.

Enterprises should not interpret 31 August as a signal of a new general opportunity under the NRRP. The next digital opportunities will be linked more closely to programmes under the regular European budget.

Until 1 October, for example, seven calls under the Digital Europe Programme are open, with a total budget of EUR 63.2 million. They cover artificial intelligence, health data, advanced digital skills, digital solutions for regulatory compliance and technology deployment. The European Commission presents the open calls and the conditions for participation.

These are primarily consortium projects, rather than vouchers for the individual technological modernisation of separate SMEs. For business organisations, universities and innovation centres, more appropriate roles may include recruiting enterprises, providing training, supporting pilot deployment, evaluating results and disseminating the solutions developed.

A Practical 90-Day Framework for SMEs

Enterprises can use the next three months to take six specific actions:

1. Complete the evidence for projects funded under the NRRP. By 31 August, check the acceptance protocols, indicators, payments and reporting documentation. Follow the individual contract and the instructions of the relevant institution, rather than general assumptions about the deadline.
2. Prepare the reporting procedure under the Cyber Resilience Act. By 11 September, identify the products within scope, the responsible persons, the method for assessing reports and the information required for the 24-hour and 72-hour notifications. Conduct at least one trial simulation.
3. Map the combined Danube risk. Within 30 days, determine which supplies use the river, which processes are most sensitive to electricity prices and what level of stock is required for critical materials. Check the actual availability and capacity of contingency routes.
4. Update transport and pricing mechanisms. Review fuel surcharges, the validity of quotations and the conditions for price changes. Develop scenarios for the impact of higher logistics costs on margins by product and customer.
5. Check the financial resilience of key counterparties. Within 60 days, update credit limits, overdue receivables, customer concentration and dependence on critical suppliers. Define early indicators that will trigger an additional review or a change in terms.
6. Organise the digital investment portfolio. After the final strategy is published, compare the changes with the business positions and determine which future measures may be relevant. If the organisation is considering participation in the Digital Europe calls with a deadline of 1 October, the decision on a partnership role and consortium must be made immediately.

Conclusion

Developments over the past week show how climate risk, energy, logistics, digital regulation and public funding are beginning to intertwine within a single operating environment.

Low water levels on the Danube are now affecting not only cargo and supplies, but also electricity generation. Higher fuel prices increase the cost of contingency transport solutions. The Cyber Resilience Act turns vulnerability management into a process with specific and short deadlines. The debate on the Digital Transformation Strategy shows that public resources must be linked to measurable results for enterprises. The final stage of the NRRP is a reminder that funding has value only when implementation can be reliably demonstrated.

For SMEs, the first step is not to predict every future development accurately. It is more important to identify critical dependencies, responsible persons, the necessary data and actions agreed in advance for an adverse scenario.

The Ruse Chamber of Commerce and Industry publishes analyses of this kind to support regional enterprises in assessing new requirements, managing operational risks and preparing practical solutions for greater resilience and competitiveness.

If you would like to discuss the impact of low water levels and transport costs, preparation for the Cyber Resilience Act, or opportunities to participate in European digital projects, please contact me at sminchev@rcci.bg or 0895 890 123.

Note: This publication was prepared with the assistance of generative artificial intelligence, which supported the structuring, verification of sources and formulation of the content. The final text is the result of the author's expert contribution, which ensures its accuracy and practical focus. The information is current as of 24 August 2026 and does not constitute legal or financial advice.