The commitment to reduce carbon emissions from electricity electricity production by 40% by 2026 compared to 2019 in the energy section of the Recovery and Sustainability Plan includes binding short-term steps. 

According to the Confederation of Independent Syndicates in Bulgaria (CISB), these commitments raise concerns for the country's energy security as they cannot realistically contribute to recovery and sustainability in the sector. Moreover, it is not clear what the reforms in the sector will be after 2030. The trade union insists that the commitment should be reviewed as it binds the country to conditions for deep changes in Maritsa East Mines as soon as the next 3 years.

On the other hand, the separation of the state-owned companies in the energy sector from the Bulgarian Energy Holding, scrapping NEK EAD as a public supplier and the liberalization of the retail market will lead to the alignment of household prices with those on the free market, which will be beyond the means of the majority of households, the trade union predicts. 

• Bulgaria is expected to receive the first grant under the Recovery and Resilience Plan in mid-2022
• Will the Recovery and Resilience Plan be able to boost Bulgaria’s economy?

According to the syndicate's experts, the "battery arrays" project has not been included as an option in any strategic analysis of the sector's development in the country discussed in recent months and it is therefore appropriate to limit its scale.