Blog · New construction
Buying off-plan: what the bank finances, and when.
Off-plan, the price is lower, the choice is wider and the home is new. But you are paying for something that does not exist yet. The bank knows this, which is why it only steps in at a certain stage. Here are the stages, when the loan money arrives and where the risk lies for you.
Published: 3 November 2026 · Spatial Development Act, Ordinance No. 3 of 2003, Bulgarian National Bank requirements for housing loans, FinCity practiceLoan before the rough construction is complete
Unless another property is offered as collateral
The most of the price to pay up to rough construction
The rest at Act 15 and Act 16
Cap on the loan against the home’s value
Bulgarian National Bank requirement since 1 October 2024
A category III building
Put into use with a use permit from the national construction authority
The stages
From the hole in the ground to the keys: what each “act” means.
Buying off-plan in Bulgaria, you will hear about “Act 14”, “Act 15” and “Act 16”. These are documents the law requires during construction. Each one changes something — what you can buy, what the bank will accept and how well protected you are.
| Stage | Document in place | What you buy | Does the bank step in |
|---|---|---|---|
| From building permit to rough construction | building permit | a preliminary contract or a right to build | no, unless another property is offered as collateral |
| Rough construction | Act 14 and the protocol under Art. 181(3) of the Spatial Development Act | the home itself, by notarial deed | yes, first tranche |
| Building completed | Act 15 | you are already the owner | second tranche |
| Put into use | Act 16 and the use permit | you are already the owner | final tranche |
Rough construction, under the law, is a building with its external walls and roof in place. In everyday speech the stage is called “Act 14”, but strictly speaking Act 14 is the act accepting the structure. The document that allows individual homes to be sold is the protocol of completed rough construction under Art. 181(3) of the Spatial Development Act. It is drawn up by the construction supervisor in the presence of a municipal official. That is the document the notary and the bank ask for.
Act 15 is the act confirming that the building is fit for acceptance. Act 16 is the protocol of the state acceptance commission confirming that the building is fit for use. For most apartment blocks, the national construction authority then issues a use permit. That is because, under the law, a building over 15 m is category III, and such buildings are put into use by that authority. Lower buildings (categories IV and V) receive a certificate of commissioning from the municipality, issued within 7 days.
The loan
When does the bank’s money arrive?
A bank lends against a mortgage. A mortgage can only be placed on something that exists and has an owner. So until the building is completed in rough construction, the bank in practice pays nothing — unless you offer it another property as collateral.
Hence the practical rule: by the rough-construction stage you should not have paid more than 70% of the price. The usual scheme is 70-20-10 — 70% up to rough construction, 20% at Act 15 and 10% at Act 16. If the split in the preliminary contract is heavier at the start, it will be hard to persuade a bank to take part.
Let’s do the sums for a €150,000 home with a 20% down payment:
| Stage | Payment | Who pays |
|---|---|---|
| On signing the preliminary contract | €30,000 (20%) | you, from your own funds |
| Rough construction, notarial deed | €75,000 (50%) | the bank, first tranche |
| Act 15 | €30,000 (20%) | the bank, second tranche |
| Act 16 | €15,000 (10%) | the bank, final tranche |
| Total | €150,000 | loan €120,000, i.e. 80% |
Illustration. The actual split is agreed with the seller and with the bank. The loan cannot exceed 85% of the home’s value — a central bank cap that also applies to off-plan purchases. Taxes, notary fees and loan fees are paid separately.
A loan for 100% of the price at the rough-construction stage is extremely rare, and we do not recommend it. Then you and the bank carry the entire completion risk, and the developer none of it.
The risk
What do you risk at each stage?
Before rough construction you only have a promise. A preliminary contract gives you the right to claim the home, but does not make you its owner. If the developer goes bankrupt or sells the home to someone else, you are a creditor like everyone else. The law allows another option: buying, by notarial deed, the right to build the future home. That is a property right, but it does not guarantee that the building will be finished either.
After rough construction you own an unfinished home. That is far safer — you have a notarial deed and the home is yours. The risk now is a different one: when and how the building will be finished. So the contract should set deadlines for Act 15 and Act 16, with a penalty if they are missed.
Encumbrances on the property. Developers often finance a project with a loan, and their bank holds a mortgage over the land or the building. Before the notarial deed it has to be released for your home — otherwise you are buying a property with someone else’s mortgage on it. A search in the property register shows what encumbrances there are.
Before you sign anything, check the developer too: what they have built so far, whether they finished their projects and whether work is actually going on at the site. It sounds basic, but that is exactly where most problems start.
What is being discussed
Will it become safer?
In 2025 the Bulgarian Prosecutors’ Association proposed a package of changes against off-plan sales fraud: advance payments would go through a special account and be released in stages — at Acts 14, 15 and 16 — and sales before a building is put into use would be allowed only with a bank guarantee or insurance covering the advances. As far as we know, at the end of October 2026 none of this has been passed into law. Until then, your protection lies in the payment split and a well-written contract.
- Spatial Development Act — Art. 23 (building height), Art. 137 (categories of construction), Art. 177 (putting into use), Art. 181 (transfer of building rights and of units in rough construction), § 5 of the additional provisions (definition of rough construction) (in Bulgarian)
- Ordinance No. 3 of 2003 on acts and protocols during construction — model acts 14, 15 and 16 (in Bulgarian)
- Legal analysis — certifying rough construction under Art. 181 of the Spatial Development Act (in Bulgarian)
- Bulgarian National Bank — requirements for housing loans from 1 October 2024
- FinCity — mortgage for buying a home off-plan (in Bulgarian)
- Bulgarian Prosecutors’ Association — proposals against off-plan property fraud and banker.bg (in Bulgarian)
This article is for information only and is not legal or financial advice. The 70-20-10 scheme comes from FinCity’s practice; the actual terms are agreed with the seller and the bank.
Buying off-plan?
A FinCity credit consultant will review the payment schedule in your preliminary contract, check whether a bank will accept it and find the best offer. Free and with no commitment.
Check your budgetYour data is protected under the GDPR: it is used only for the budget assessment, consent is voluntary and you have the right to ask for it to be erased.