Latest development Jan 21, 2026
The European Commission opened an in-depth state aid investigation into the award.
The award
- Amount awarded
- €61.04M plus pre-award and post-award interest, legal costs of €264,834 and $5.21M, and $480,766 in tribunal and ICSID costs
- Current estimate
- GAR reported the award at about €70M (January 2024).
- Award holder
- ACF Renewable Energy Limited (Malta)
- Respondent
- Republic of Bulgaria
- Forum
- ICSID ARB/18/1 · ECT
Challenges
Bulgaria did not apply for annulment, and the deadline has passed. The European Commission opened an in-depth investigation in January 2026 into whether the award complies with EU state aid rules.
Enforcement
D.D.C. (No. 24-cv-1715) denied Bulgaria’s motion to dismiss or stay and granted ACF’s motion to enforce the award on September 22, 2025. The court rejected Bulgaria’s argument that EU law voided its consent to arbitrate.
Recovered to date
None reported. ACF’s petition, as recited by the court, states that Bulgaria has paid no part of the award.
Notes
Whether Bulgaria appealed the D.D.C. judgment was not verified.