From a 15,000 euro fine for a drone violation?

A public discussion is currently underway on a draft for changes to the Civil Aviation Act, which could affect every drone operator in Bulgaria.

One of the most significant changes provides for the minimum fine for certain violations to be increased from 1,500 euros at 15,000 euros, and the maximum to reach 50,000 euros. The proposal concerns the violations related to the operation of unmanned aerial systems under Art. 143, para. 1, item 20.

В Drones.BG We support any measure that increases air safety. However, we believe that sanctions must be fair, proportionate and take into account the gravity of the specific violation.

It is not right to apply the same minimum penalty to both serious violations that have created a real risk to safety and to cases such as administrative oversight or unintentionally exceeding the maximum height without any consequences.

Therefore, we are preparing an official statement in which we will propose:

• The minimum penalty should remain 1,500 euros.
• If necessary, only the maximum penalty for serious and dangerous violations should be increased.
• To preserve the possibility of individual judgment according to the specific case
• For a first or minor violation without causing damage, a warning may be applied instead of a fine

Why do we think this is important?

• The law covers violations with very different degrees of public danger and the sanctions must be able to differentiate between them.
• The amount of the punishment must take into account the specific circumstances - whether there was intent, whether a real danger was created, and what the consequences are.
• The higher maximum fine is a sufficient tool to sanction serious violations, without affecting amateurs and bona fide operators.
• Maintaining the current minimum allows for fairer treatment of first and formal violations where there is no risk or harm caused.
• The possibility of applying the "minor case" institute under Article 28 of the ZANN should remain, when the specific situation allows it.
• The sanctions were updated relatively recently and, in our opinion, the effect of these changes should first be assessed before moving to a new increase.

We call on all drone operators, remote control pilots, companies, training centers and organizations to join the public discussion.

The more reasoned submissions are submitted, the greater the chance that future rules will be both safe, fair and practically applicable.

You can read the full draft of the law here:

https://www.mtc.government.bg/bg/category/170/proekt-na-reshenie-na-ministerskiya-svet-za-odobryavane-na-proekt-na-zakon-za-izmenenie-i-doplnenie-na-zakona-za-grazhdanskoto-vzdukhoplavane

You can submit your opinion by August 8, 2026:

• By email: mmanuilova@caa.bg
• To the Ministry of Transport and Communications: mail@mtc.government.bg
• Through the Public Consultation Portal, after registration.
• Through the Secure Electronic Service System
• On paper: Ministry of Transport and Communications, Sofia, 9 Diakon Ignatius Street.

Sample opinion

Subject: Draft Law on Amendments and Supplements to the Civil Aviation Act – Sanctions under Art. 143, Para. 1 Civil Aviation Act

We support the objectives of the draft law to enhance civil aviation safety and to more effectively sanction violations that pose a real danger to airspace. However, we believe that the proposed simultaneous increase in the lower and upper limits of sanctions under Art. 143, para. 1 of the Civil Aviation Act does not take into account the different severity of the violations covered by this provision.

Art. 143, para. 1 of the Traffic Safety Act applies both to serious and intentional violations that create a real risk to safety, and to formal, unintentional or first violations that do not have harmful consequences. The equally high minimum sanction limits the possibility of the punishment being tailored to the specific act, the degree of the risk created, the behavior and the economic capacity of the offender.

This is particularly relevant for drone operators, including individuals, model aircraft enthusiasts, athletes, educational organisations and micro-enterprises. The proposed minimum amount of EUR 15,000 may be clearly disproportionate in the case of an administrative omission or infringement with a low level of public danger and without creating a risk to aviation.

The principle of proportionality requires that the sanction be proportionate to the gravity of the specific case. This follows from both Art. 27 of the ZANN and Art. 84, § 2 of Regulation (EU) 2018/1139, which requires taking into account the degree of threat to safety, the nature of the activity and the economic capacity of the relevant natural or legal person.

At the same time, the explanatory memorandum to the bill does not contain sufficient factual and statistical justification for why it is necessary to increase the lower limit. The reference to economic growth and the long period without updating the sanctions may justify increasing the maximum amount, but does not prove that the sanction for the mildest violations should be increased tenfold.

We propose that the lower limit of fines and property sanctions under Art. 143, para. 1 of the Law on the Protection of Personal Data should remain at its current level, and that the envisaged increase be applied only to the upper limit.

For the composition relating to unmanned aerial vehicles, we propose instead of the range:
15,000 – 50,000 euros
to provide a range:
1,500 – 50,000 euros.

This approach will allow for the strict sanctioning of serious, repeated and intentional violations through a significantly higher maximum amount, while preserving the possibility of fair and proportionate determination of punishment in milder cases.

We ask that the proposal be considered and the opinion be reflected in the report on the submitted proposals under Art. 26, para. 5 of the Law on Normative Acts, with an indication of the reasons in the event of its possible non-acceptance.

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