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Investment treaty awardUnpaid

ACF Renewable Energy v. Bulgaria

Changes to solar feed-in support

Headline amount
€61M≈$68.3M · Principal
Respondent
BulgariaState
Awarded
Jan 5, 2024
Status
UnpaidNothing collected

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.