PIL.OT / DEVELOPMENT
PIL.OTv0.62.2
Angel A. Ganev examines whether and how a foreign arbitral award can be recognised and enforced in Bulgaria against a sovereign, against the background of the Partial Award of 22 February 2019 and the Final Award of 12 April 2023 rendered under the Russia–Ukraine Bilateral Investment Treaty. The analysis follows the Bulgarian stages of exequatur, interim relief and forcible execution.
Ganev concludes that enforcement against a sovereign in Bulgaria is not a legal fiction, but neither is it straightforward or predictable. The result will depend on how Bulgarian courts reconcile a thin and partly contradictory body of case law with treaty obligations, customary international law on state immunity and the European Union sanctions regime.
Recognition, enforcement and forcible execution in Bulgaria of arbitral awards rendered under the Russia–Ukraine BIT against the Russian Federation, including the effects of state immunity and EU sanctions.
The article treats recognition and enforcement against a sovereign in Bulgaria not as a single application, but as a connected sequence of exequatur, interim relief and forcible execution. That framing makes clear the hurdles facing a creditor and the extent to which the result turns on the relationship between Bulgarian case law and treaty obligations.
Journal of International Arbitration · 2026
DOI 10.54648/joia2026030