---
title: "How to Protect Yourself in a Dispute with the District Heating Company"
description: "Why disputes with district heating companies in Bulgaria arise and how to protect your rights in cases of incorrect bills, heat cost allocation and court claims."
url: "https://www.da-law.eu/en/insights/disputes-with-the-district-heating-company"
lang: en
author: "Desislava Arsenova"
published: 2025-10-18
updated: 2026-07-29
category: "Civil Law"
---

# How to Protect Yourself in a Dispute with the District Heating Company

Author: Desislava Arsenova · Published: 18 October 2025 · Updated: 29 July 2026

*Why disputes with district heating companies arise and how to protect your rights in cases of incorrect bills, heat cost allocation and court claims.*

## Key points

- A complaint about the annual balancing statement must be filed by 31 August, after which the company is not obliged to revise it.
- Since 5 May 2026, a new building installation formula has applied, taking into account the energy class and the type of heating installation.
- You are entitled to a written statement of the heat cost allocation, the reading records and the meter checks.
- If you receive an order for payment, file an objection in time. In a dispute, you may refer the matter to the Energy and Water Regulatory Commission, the Consumer Protection Commission or the Ombudsman.

**Last updated: 27 July 2026**

In a dispute with a district heating company, you are entitled to request written information on how your bill was calculated and to file a complaint about the meter readings and heat cost allocation **by 31 August** for the reporting period covered by the annual balancing statement. Since **5 May 2026**, a new formula has applied for allocating the energy from the building installation, which takes into account thermal insulation and the type of heating installation. Your rights are protected by the [Energy Act](https://lex.bg/laws/ldoc/2135475623) and [Ordinance No. Е-РД-04-1 of 2020 on Heat Supply](https://lex.bg/laws/ldoc/2137201184), and you may, if necessary, refer the matter to the Energy and Water Regulatory Commission, the Consumer Protection Commission or the court.

## Why Disputes with District Heating Companies Arise

In recent years, more and more consumers have faced unclear bills, estimated charges or unexpected court claims from district heating companies. Disputes most often arise from opaque calculations, heat cost allocation or a lack of proper communication. As a consumer, you have specific rights protected by law and several ways to challenge unlawful conduct.

## The Legal Framework – the Energy Act and Ordinance No. Е-РД-04-1

The principal statute is the [Energy Act](https://lex.bg/laws/ldoc/2135475623). The technical conditions for heat supply, metering and the allocation of heat energy are governed by [Ordinance No. Е-РД-04-1 of 12 March 2020 on Heat Supply](https://lex.bg/laws/ldoc/2137201184), issued by the Minister of Energy.

An important clarification. Until March 2020, the matter was governed by Ordinance No. 16-334 of 2007, which has since been repealed. If you have come across articles or forums still citing that ordinance, bear in mind that it has not been in force since **24 March 2020** and references to it are no longer accurate.

## The New Building Installation Formula (in Force from 2026)

The way each property's share of the total heating bill is calculated has been the subject of ongoing litigation in recent years. The Supreme Administrative Court consistently found that the formula applied for allocating the energy given off by the **building installation** (the common pipes and radiators outside the individual units) was not sufficiently transparent and did not allow consumers genuinely to verify how their bill had been calculated.

Following this prolonged judicial review, the Minister of Energy adopted an amendment to the ordinance, published in the State Gazette, **No. 41 of 5 May 2026**. The new formula now expressly takes into account

- the total installed capacity of the heating units in the building;
- the heating degree days for the locality in the month concerned (a measure linked to how cold it is);
- the type of heating installation, whether concealed or exposed according to the design;
- the energy class of the building, with a lower coefficient for renovated buildings in classes A to B and a higher coefficient for non-renovated buildings or buildings with no established class.

In other words, well-insulated renovated buildings should now bear a lower share of building installation costs than non-renovated ones, a change with a direct bearing on individual bills. The heat transmission company must provide consumers each month with information on the values used in the calculation, so if in doubt you have grounds to request this data in writing.

## Rights and Obligations of the Parties

The district heating company must provide clear, accurate and understandable information about your bills and carry out metering in accordance with the applicable rules. As a consumer, you are entitled to

- access to data on actual consumption and meter readings;
- written information, on request, on replacements, metrological checks or repairs of the billing meters;
- file a written objection to amounts charged which you consider incorrect;
- request an independent technical examination if you doubt the accuracy of the meters.

## The Most Common Causes of Disputes with District Heating Companies

- **Incorrectly calculated bills** – often due to technical errors, old meters or an incorrectly applied allocation formula.
- **Problems with meters** – discrepancies in readings, no actual reading or an expired metrological check.
- **Disputes over the building installation** – the most frequent source of friction, since this component is not measured directly but calculated by formula.
- **Ownership and contracts** – disputes over whether a new owner is liable for the previous owner's debts.

## How to Respond to an Incorrect Bill

First, check the invoice. Compare the consumption recorded with previous periods and the actual readings. If you notice discrepancies, you are entitled to request in writing from the heat transmission company a full statement of the heat cost allocation, the calculations and copies of the reading records.

**Note** – the procedure for handling complaints is set out specifically in your contract with the heat transmission company or supplier (under Art. 40(1)(7) of the ordinance), so first check the general terms applicable to your building, which may provide additional facilities for consumers.

### Deadline for Complaints about the Annual Balancing Statement – 31 August

Under the ordinance, complaints about meter readings and the allocation of heat energy in the annual balancing statement for the previous heating season must be filed **by 31 August**. After that date, the company is not obliged to accept new complaints requiring the balancing statement to be revised, so it is important to check your bill promptly in the summer rather than wait for the next heating season.

## When and How to Seek an Independent Examination

If you suspect the meters are inaccurate, you may request a technical check by an independent expert or an accredited laboratory. Such an examination may serve as evidence in court proceedings, particularly where you are disputing specific readings rather than the general allocation formula.

## How to File a Complaint – Institutions and Steps

If dialogue with the district heating company does not resolve the matter, you may refer it to

- **the Energy and Water Regulatory Commission**, which monitors the lawfulness of charges and compliance with the ordinance;
- **the Consumer Protection Commission**, which accepts complaints about unfair treatment and unclear contract terms;
- **the Ombudsman of the Republic of Bulgaria**, who may mediate between you and the institutions, including on systemic problems with a particular supplier.

## How to Defend Yourself in Court Proceedings Brought by the District Heating Company

If you receive an order for payment on an application by the company, you are entitled to file a written objection with the court within the statutory time limit after service. It is important to submit evidence, such as payment documents, records, correspondence and, if necessary, a technical examination. Case law in recent years shows that objections to building installation charges have a real prospect of success precisely because of the lack of transparency in the previous formula established by the courts.

## Useful Documents and Preventive Measures

Keep systematic records of

- copies of invoices and payment documents;
- all correspondence with the company, including written requests for information;
- meter reading records and records of technical checks of the meters.

To avoid future problems,

- check your bills regularly and compare them with actual readings and previous periods;
- take part in the general meetings of the condominium, including when the method for determining the building installation share is chosen;
- request the monthly information on the values used in the new formula from the heat transmission company.

Problems with district heating companies are not inevitable, and the rules now require greater transparency than before. With the right information, documents requested in good time and knowledge of the specific time limits, every consumer can protect their rights. If the matter turns into a court dispute or you would like help challenging a specific bill, our [civil law](https://www.da-law.eu/en/services/civil-law) team can assist you at every stage.

## Legal basis

- [Energy Act (Закон за енергетиката)](https://lex.bg/laws/ldoc/2135475623)
- [Ordinance No. Е-РД-04-1 of 12 March 2020 on Heat Supply (Наредба № Е-РД-04-1 от 12.03.2020 г. за топлоснабдяването), as amended in State Gazette No. 41 of 5 May 2026](https://lex.bg/laws/ldoc/2137201184)

## Frequently asked questions

### Can I avoid paying if I do not use the heating?

Not entirely. You owe a share of the building installation costs under the new formula, unless the entire building entrance has been disconnected from heating.

### By when can I file a complaint about the annual bill?

By 31 August of the year following the reporting period. After that date, the company is not obliged to revise the balancing statement.

### Has the building installation charge changed since May 2026?

Possibly. The new formula takes into account the energy class and the type of heating installation of the building, so the building installation share is no longer the same for all buildings.

### What should I do if the company does not respond to my request for information?

File a complaint with the Consumer Protection Commission, the Energy and Water Regulatory Commission or the Ombudsman, depending on the nature of the problem.

### Can I request an independent examination of the meters?

Yes. A technical check may be carried out at your request and at your expense if you doubt the accuracy of the meters.

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*The information on this website is not legal advice and does not create an attorney–client relationship. Every case has its specifics and requires an individual approach. For a professional opinion and a tailored strategy, please contact us.*

Source: https://www.da-law.eu/en/insights/disputes-with-the-district-heating-company