What changes on 1 January 2027
Everyone who works in Bulgaria and was born after 1959 has a second pension: five percent of the gross salary, part of the social contributions paid on it, goes to a universal pension fund, УПФ, run by one of ten private companies. The money is in your name, it is inherited, and it is paid out when you retire, on top of the state pension.
Until now each company ran one fund for everyone, the same for someone of twenty-five as for someone retiring next year, and so it was cautious for both. From 1 January 2027 each fund splits into three subfunds that differ in one thing: how much of the money may be in stocks.
How much each subfund may hold in stocks
- Dynamic: up to 90%
- Balanced: up to 55%
- Conservative: up to 25%
Your account moves as it is: its value does not change on the day, only how it is invested from then on. You choose by 30 November 2026, with the company that holds your money now. If you do not, the company places you by your age on 1 January 2027.
If you do not choose
| Your age on 1 January 2027 | Where your money goes |
|---|---|
| Under 45 | Dynamic, then balanced from 50 |
| 45 to 49 | Dynamic, for at least five years |
| 50 to three years before the pension age | Balanced |
| The last three years before the pension age | Conservative, with no choice |
In Bulgaria, as of 16 September 2026
A subfund you choose yourself stays until you change it, except in the last three years before the pension age, when the conservative one is compulsory; the move at 50 is for those who leave it to their age. After the first choice, or the placement, the next change is possible after 31 December 2027.
Why dynamic, if your pension is decades away
The money in your second pension is the money you are least likely to need soon: it stays locked until you retire. For someone of thirty that is thirty-five years away, and over thirty-five years the question is not how far a fund can fall this year. It is where it will be when you get there.
Stocks are what grows over that kind of time, and they are also what swings. In a single year a mix that is three quarters stocks can end anywhere from -9.2% to 24.8%; a conservative mix, from -4.5% to 14.9%. That is the part people see, and it is why the conservative subfund sounds safer. But good and bad years average out, and the range of the average narrows with every year you hold.
The average yearly return, over longer and longer
- 1 year: Dynamic mix: 75% stocks, -9.2% to 24.8%; Conservative mix: 20% stocks, -4.5% to 14.9%
- 5 years: Dynamic mix: 75% stocks, 0.2% to 15.4%; Conservative mix: 20% stocks, 0.9% to 9.5%
- 10 years: Dynamic mix: 75% stocks, 2.4% to 13.1%; Conservative mix: 20% stocks, 2.1% to 8.3%
- 20 years: Dynamic mix: 75% stocks, 4% to 11.6%; Conservative mix: 20% stocks, 3% to 7.4%
- 35 years: Dynamic mix: 75% stocks, 4.9% to 10.6%; Conservative mix: 20% stocks, 3.6% to 6.8%
Eight times out of ten the average lands inside the bar; the mark is the middle case. On the planner's own assumptions for stocks, bonds and cash: 75% stocks, 20% bonds and 5% cash against 20% stocks, 70% bonds and 10% cash. An illustration, before fees and inflation.
Over 35 years the picture turns around. A bad run of the dynamic mix averages 4.9% a year, more than a bad run of the conservative one at 3.6%, and the middle cases are 7.8% against 5.2%. A small difference in the yearly average is a large one in money.
100 € a month for 35 years
- Paid in: 42,000 €
- Conservative mix, a bad run: 93,000 €
- Conservative mix, the middle case: 119,000 €
- Dynamic mix, a bad run: 133,000 €
- Dynamic mix, the middle case: 212,000 €
Five percent of a gross salary of 2 000 €, the same every month. A bad run is the lower edge of the planner's band, one time in ten worse; the middle case its line. Rounded to the thousand, before fees and inflation.
Paid in, 42,000 €. In the conservative mix that becomes about 119,000 €, or 93,000 € on a bad run. In the dynamic mix, about 212,000 €, and even a bad run ends with 133,000 €, more than the conservative mix's middle case.
Two more things work for the young. Every month another five percent goes in, so a fall early in your working life means that month's money buys more, cheaply. And the law already takes care of the end: in the last three years before the pension age the conservative subfund is compulsory, so a crash on the eve of retirement is not the risk it would be if you stayed in stocks to the last day.
That is why I think the dynamic subfund is the right one for anyone with twenty years or more to go, and why it is the one I would choose.
When dynamic is not the answer
If your pension is less than about ten years away, a fall has little time to be made good, which is what the balanced subfund is for. And if you know a bad year would make you move out, do not start in dynamic: a move made after a fall turns a fall on paper into a real loss, and a calmer subfund you stay in beats a dynamic one you leave.
The ten dynamic subfunds, side by side
The law gives all ten the same outer limits. The differences are in what each company wrote into its investment policy, and this is what those policies say.
DallBogg's floor is implied: at least 15% in listed shares plus 10% in fund units. Saglasie and CCB-Sila say only that the dynamic subfund will never hold less in stocks than their balanced one.
Similar targets, very different floors
Four of the published policies aim at 75% in stocks and Allianz at 80%; the other four publish no target. What differs is how far the manager may cut stocks in a downturn. A high floor keeps the subfund close to its target when markets fall; a low one lets it turn defensive. Under its own policy, Toplina's dynamic subfund could legally be as cautious as a balanced one.
Only three put a number on the return goal
Allianz aims at €STR plus 2 percentage points a year over three years and at Bulgarian inflation plus 2 over ten, and is the only one with a volatility target. DSK-Rodina aims at 2.5 points a year above euro-area inflation over five years or more, and Doverie at 2 points above inflation averaged over five. The rest measure themselves against the regulator's benchmark, a model portfolio of their own or the average of the other funds. Saglasie and CCB-Sila use word for word the same goal.
Rules on geography range from strict to none
Allianz, Lev Ins and UBB set limits on the EU, the United States and emerging markets; DSK-Rodina requires at least 5% in Bulgarian securities; Toplina caps any one country at 25% and any one sector at 40%. Doverie, Saglasie, CCB-Sila and DallBogg set no limits beyond the law.
Different horizons and ways of managing
Lev Ins plans for about 30 years and Doverie for 25 to 30, UBB for 15 or more, Toplina for 10 or more, Saglasie and CCB-Sila for 5 to 10 and DSK-Rodina for over 5. Allianz and UBB may follow an index, CCB-Sila runs an index core with active picks around it, and Doverie and DSK-Rodina are fully active.
What I would look at, in this order
- The floor. Dynamic is chosen for its stocks, so look at how low the policy lets them go. A subfund that may drop to 15% is a dynamic subfund in name.
- A goal with a number. "Inflation plus 2 points over five years" is something you can check in five years; "a higher long-term return" is not.
- How it is managed. The fee is capped the same whether the company follows an index or picks shares, so the difference is not the cost but the bets: a subfund that follows the market holds the market, and the principles on this site are why I prefer that. A preference, not a rule.
- Not last year's return. See below why.
Allianz (ПОД „Алианц България“)
Stocks: 55%–90%, target 80%
- Limits: Bonds 10–54% (target 17%) · cash up to 15% (target 3%) · property up to 5%
- Return goal: €STR + 2 pp a year over 3 years; Bulgarian consumer prices + 2 pp a year over 10 years
- Measured against: Its own targets and the other dynamic subfunds; a volatility band of 8–16% (10-year standard deviation), the only one to set one
- Horizon: Not stated in years
- Geography: EU at least 20% · US at most 60% · emerging markets at most 40% of assets
- How it is managed: May replicate a stock or bond index, or make short-term tactical trades with a stop-loss.
Lev Ins („Лев Инс Пенсионно осигуряване“)
Stocks: 60%–90%, target 75%
- Limits: Bonds up to 40% (target 20%) · cash up to 25% (target 5%)
- Return goal: Long-term growth with a positive real, after-inflation, return
- Measured against: Its own model portfolio: 41% North American stocks, 30% European, 4% Bulgarian; 19% government bonds, 1% corporate, 5% cash
- Horizon: About 30 years
- Geography: EU at least 10% · North America at most 70% · emerging markets at most 50% of assets
- How it is managed: A six-month tactical strategy moves the mix within the bands.
UBB („ОББ Пенсионно осигуряване“)
Stocks: 55%–90%, target 75%
- Limits: Bonds up to 45% (target 20%) · cash and deposits up to 30% (target 5%)
- Return goal: Beat inflation over at least 15 years; beat the regulator's benchmark in the medium term
- Measured against: The regulator's benchmark; consumer prices
- Horizon: At least 15 years
- Geography: Within the stocks: EU at least 10% · US at most 80% · emerging markets at most 50%
- How it is managed: May replicate an index. Its list of sectors starts with semiconductors, software and tech hardware.
Doverie (ПОК „Доверие“)
Stocks: 45%–90%, target 75%
- Limits: Bonds target 20% (10% government, 5% infrastructure, 5% corporate) · cash 1–30% (target 5%) · the stock floor may be missed in the first 12 months
- Return goal: 2% a year above inflation, averaged over 5 years; beat its main competitors in the short term
- Measured against: The real return; competitors' returns as published by the regulator
- Horizon: 25–30 years
- Geography: No limits beyond the law, and no sector or style limits
- How it is managed: Fully active. The stock target is 37% individual shares, 28% investment funds, 5% infrastructure, 3% exchange-traded funds, 1% property funds and 1% alternative funds.
DSK-Rodina (ПОК „ДСК-Родина“)
Stocks: 35%–90%, target 75%
- Limits: Bonds 10–65% (target 23%) · cash and deposits up to 10% (target 2%)
- Return goal: At least 2.5% a year above euro-area inflation over 5 years or more; beat the regulator's benchmark over 3 years
- Measured against: Euro-area inflation; the regulator's benchmark, with a board review if it falls 4 pp behind over 12 quarters
- Horizon: Over 5 years
- Geography: At least 5% in Bulgarian securities
- How it is managed: Active: growth, value and momentum styles, with no style limits.
DallBogg (ПОД „ДаллБогг: Живот и Здраве“)
Stocks: ≈25%–90%, No target
- Limits: Listed shares 15–70% plus fund units 10–50%, so a stock floor of about 25% · government bonds 10–70% · cash 0.5–40%
- Return goal: At least the average return of comparable funds over 3 years; above consumer prices over 5 years or more
- Measured against: The average of comparable funds over 24, 36 and 60 months; consumer prices
- Horizon: Not stated
- Geography: No limits beyond the law
- How it is managed: Publishes only ranges for each kind of instrument, with no overall target. May use alternative investment funds.
Toplina (ПОД „Топлина“)
Stocks: 15%–90%, No target
- Limits: Bonds 10–70% · deposits up to 25% · property up to 5%
- Return goal: Steady growth and a higher long-term return, with no figure
- Measured against: The simple average of all dynamic subfunds
- Horizon: At least 10 years
- Geography: At most 25% in any one country other than Bulgaria, and 40% in any one sector
- How it is managed: Bond duration capped at 12. The strategy is reviewed every 6 months.
CCB-Sila (ПОАД „ЦКБ-Сила“)
Stocks: up to 90%, No target
- Limits: No figures: the mix is set in an internal strategy reviewed every 6 months · stocks up to 90%, never below its balanced subfund · cash up to 10%
- Return goal: Beat inflation and its own balanced subfund over 3 years; substantially beat inflation and long-term rates over 5 years or more
- Measured against: The regulator's benchmark
- Horizon: 5–10 years
- Geography: No limits beyond the law
- How it is managed: A passive index core with active picks around it; growth, value and momentum styles.
Saglasie (ПОК „Съгласие“)
Stocks: up to 90%, No target
- Limits: No figures: the target weights are set by the board · stocks up to 90%, never below its balanced subfund
- Return goal: Beat inflation and its own balanced subfund over 3 years; maximise value and substantially beat inflation over 5 years or more
- Measured against: The regulator's benchmark; consumer prices over 12, 24 and 120 months
- Horizon: 5–10 years
- Geography: No limits beyond the law
- How it is managed: Calls itself "active-passive": growth, dividend, fundamental, technical and top-down methods. Scores ESG risk.
Budeshte (ПОД „Бъдеще“)
No 2027 subfund policy on its site when this page was checked; only the 2026 policy of its single fund is posted. Check budeshte.bg before deciding.
Past returns: what they say, and what they do not
The dynamic subfunds have no history yet. These figures are each company's current single fund, run under the old one-size rules, so they say something about the manager and nothing about the new subfund.
| Company | 5 years | 2 years | Volatility |
|---|---|---|---|
| CCB-Sila | 3.59% | 5.26% | 5.81% |
| UBB | 3.39% | 6.04% | 7.64% |
| Toplina | 3.37% | 6.7% | 11.88% |
| Lev Ins | 2.96% | 5.03% | 6.37% |
| Allianz | 2.84% | 5.76% | 7.46% |
| Doverie | 2.57% | 6.96% | 6.67% |
| Budeshte | 2.35% | 6.4% | 8.7% |
| DSK-Rodina | 1.75% | 5.91% | 7.49% |
| Saglasie | 1.66% | 4.57% | 5.12% |
| DallBogg | too new | 3.54% | 7.01% |
The average yearly return of each company's current single fund over five and over two years, and its volatility over two, from the regulator's data updated 24 August 2026. Sorted by five years.
Two things stand out. Over five years the best of these funds averaged 3.6% a year, less than prices in Bulgaria rose over the same years: that is what a fund built to be cautious for everyone at once delivers. And the order changes with the period: CCB-Sila's fund is first over five years, Doverie's over two. Choosing by last year's return is choosing by luck.
What is the same at every company
Set by the Social Security Code and the Financial Supervision Commission, so none of it helps you choose between companies.
Fees are capped by law and fall every year, while the fee on investment income rises, so more of what a company earns depends on how your money does. The actual fees are in each fund's rules, and the 2027 rules were not posted when this page was checked, so expect the caps. Today practically every fund charges the maximum: 3.75% of each contribution and 0.75% of the assets a year.
| Year | Of each contribution | Of assets, a year | Of investment income |
|---|---|---|---|
| 2027 | 3.59% | 0.65% | 1.5% |
| 2028 | 3.42% | 0.6% | 2% |
| 2029 | 3.26% | 0.55% | 2.5% |
| 2030 | 3.09% | 0.5% | 3% |
| 2031 | 2.93% | 0.45% | 3.5% |
| 2032 | 2.76% | 0.4% | 4% |
| 2033 | 2.6% | 0.35% | 4.5% |
| 2034 | 2.43% | 0.3% | 5% |
| 2035 | 2.27% | 0.25% | 5.5% |
| 2036 on | 2.1% | 0.2% | 6% |
- Stocks up to 90% of the assets. At most 40% in assets not in euro unless hedged, at most 5% in any one issuer, and at most 5% each in property and in regulated alternative funds.
- One benchmark for every dynamic subfund. The regulator's draft benchmark holds 75% in stocks: 35% in the S&P Global 1200, hedged to the euro, 30% in the S&P Euro and 10% in the BG40, the rest in euro bonds and cash. Results are compared over five years, phased in from 2028 to 2031, and a subfund that falls too far behind stops receiving the new members who are placed automatically.
How to choose, step by step
Before 30 November 2026. It takes one form.
Find out where your second pension is
The tax office's portal shows it: log in to НАП with your ПИК or an electronic signature and use the service that shows which pension fund your contributions go to. The company also sends you a statement of your account once a year.
Why: The application goes to the company that holds your money now, so that is where everything starts.
Choose the subfund
Dynamic, balanced or conservative. If your pension is decades away, the section above is why I would choose dynamic. In the last three years before the pension age there is no choice to make: the conservative subfund is compulsory.
Why: Doing nothing is a choice too. Under 50 it places you in the dynamic subfund, but then moves you to the balanced one at 50, whether or not that suits you then. A choice of your own stays until you change it.
Decide whether to stay with your company
Compare its dynamic subfund with the others above. To stay, you need nothing more. To move, you apply to the company you want to move to, not to the one you are leaving; a change of company is possible once a year, and the money follows on set dates. Ask the new company which subfund the move places you in, and put your choice in writing.
Why: Every company has the same limits and the same fee caps, so the only differences worth moving for are the ones in the policy: the floor, the goal and how it is managed.
Hand in the application by 30 November 2026
The form is the regulator's own, Приложение № 19 to Наредба № 3, and every company has it. Hand it in at an office of your company or through its insurance intermediary, or send it as an electronic document signed with a qualified electronic signature, КЕП: by email, or through the company's client portal where it has one. A consultation comes with it.
Why: The regulator says it in as many words: the consultation does not bind you. Listen, then write down what you decided.
Look again once a year, not when the news is loud
The subfunds start on 1 January 2027, and the next change is possible after 31 December 2027. From 2028 each dynamic subfund starts being measured against the common benchmark, which will be a fairer comparison than any one year's return.
One warning
Nobody needs your ПИК or your electronic signature to help you choose. Keep them to yourself, sign only a form you have read, and be wary of anyone who calls to say you must move company before a deadline: the only deadline is 30 November 2026, and it is for the choice of subfund.