The “fuels, petroleum and electricity” sector (CPV 09) ranks fourth by value among Bulgarian public tenders — €2.15 billion across 5,480 contracts for the period May 2023 – June 2026. The average value is €380,678, the median €56,763. But the numbers that truly set this sector apart are not about value. They are about how contracts get awarded.
If other sectors are competitions, fuels are often a direct award. Here we face a market whose logic differs fundamentally from everything else — because the commodity is standardised, regulated and sometimes exchange-traded.
39% without a notice: the anatomy of the direct award
Here is the most striking statistic in the entire analysis: nearly 39% of fuels and energy tenders are awarded via “Negotiation without prior notice” — the highest share of direct awards across all sectors. This is a procedure in which the contracting authority does not announce a public tender but negotiates directly with a supplier.
The reasons are structural. Electricity and natural gas are often bought at regulated or exchange prices, where a public competition makes no sense — the price is set by the market, not by the bid. Emergency fuel deliveries, supplies from a sole possible source, extensions of existing contracts — all of this falls under the direct-award regime.
For the supplier, this turns the strategy upside down. In a sector where 39% of the money is awarded without a tender, the key is not to win a procedure, but to be among the qualified suppliers the contracting authority can approach directly. Registration, pre-qualification and licences (for trading petroleum products, for supplying electricity) become more important than the craft of writing bids.
Median: one bidder
The remaining 61% of tenders go through a procedure — mostly the “Open procedure” (about 24%) and the “Public competition”. But even there, competition is scarce: an average of 2.7 bids, yet a median of just 1. The typical energy tender has only one participant.
This is a direct consequence of market concentration. Wholesale fuel suppliers, licensed electricity traders and natural gas distributors are few. When the commodity is standardised and margins are thin, few have the interest and the capacity to participate.
Low competition also explains the price dynamics: a median deviation of 0.0% — the final price is exactly the estimated one. There is no haggling, because often there is no one to haggle with. The average deviation (−13.9%) reflects individual competitive procedures, but the median reveals the truth: fuels are awarded at the estimated price.
A pure price game
If there is one sector where the “lowest price” criterion is absolute, it is energy: 97.5% of tenders are awarded on price — practically all of them. The logic is iron-clad: a litre of diesel to a defined standard is a litre of diesel, a megawatt-hour of electricity is a megawatt-hour. The commodity is interchangeable, quality is defined by standards (EN 590 for diesel, sulphur content, calorific value), and the only differentiating variable left is price.
This keeps the documentation relatively light — a technical specification of 3.4 pages on average, an 11.8-page notice, 43.8 documents per tender. The specification is rarely complex; it simply defines the standard and the quantity. But the lightness is deceptive, because the traps lie elsewhere.
Where bids are lost
Non-compliance with technical parameters. Even with a standardised commodity, the specific requirements (sulphur content, calorific value, fuel grade) must be covered in detail and proven with certified analyses. The blanket claim “meets the standard” is not enough.
Gaps in proving experience. Contracting authorities insist on references for deliveries by volume. Their absence disqualifies.
Inaccurate price offers. With 97.5% of awards decided on price, a small mistake — forgotten VAT, excise duty, a transport fee — sinks the bid. Fuel pricing is multi-component and must be transparent.
Problems with guarantees and securities. Failing to submit, or incorrectly drawing up, bank guarantees for participation and performance is a frequent cause of exclusion (an average of 1.63 disqualifications per tender).
Missing the environmental criteria. Sustainability, green procurement and carbon-footprint criteria are entering energy tenders more and more often — a segment that will grow with the energy transition.
Who buys and who wins
Buyers in the energy sector are diverse, but with a clear state imprint. The leading contracting authorities are the State Agency “State Reserve” (€153 million) — which maintains the strategic fuel stocks — the Ministry of Finance (€129 million) and the large state-owned enterprises such as “Maritsa-Iztok Mines” (€99 million). To these add hundreds of municipalities, hospitals and schools buying heating fuel and electricity for their buildings. It is a market in which every public institution is a buyer, but the large volumes are concentrated in state structures.
On the supplier side, the licensed traders of electricity and petroleum products dominate: “Electrohold Trade” (€189 million), “Bent Oil” (€182 million) and “Synergon Energy” (€163 million). What they have in common is that all are pre-qualified, licensed players with access to the exchange or to petroleum logistics. This confirms the sector’s core thesis: here you do not enter with a good bid, but with a licence and a position on the wholesale market.
The annual dynamics are more volatile than in other sectors, reflecting the price shocks on energy markets in recent years — after the 2024 peak (€106 million), volumes are normalising. This is a sector sensitive to global prices, which makes flexible pricing and risk hedging essential for the supplier.
62% with one bidder — but for a different reason
As in the other low-competition sectors, 62.3% of energy tenders have one or zero bidders. But here the reason is specific and structural: the commodity is standardised, margins are thin, and access to the wholesale market is limited to licensed traders. It is not that competitors are discouraged by the documentation — simply, few can deliver at all. For the supplier with the necessary licences, this is perhaps the most predictable market: if you are qualified and meet the standards, competition is often symbolic and the price is the estimated one.
Playbook for the energy supplier
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Invest in pre-qualification and licences. In a market with 39% direct awards, being on the list of qualified suppliers is worth more than a perfect bid.
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Prove the standards with certified analyses. Do not declare compliance — prove it with laboratory data for every parameter.
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Make your pricing transparent and complete. Every component — commodity price, excise duty, VAT, logistics — correct and verifiable.
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Draw up your guarantees flawlessly. Bank guarantees for participation and performance are a frequent source of exclusion; treat them as a priority.
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Prepare for the green criteria. Sustainability is entering energy tenders; suppliers with a lower carbon footprint will have an advantage.
The process and the regulatory highlights
The energy sector has a dual process. In competitive procedures (“Open procedure”, “Public competition”) the supplier prepares a standard bid in the CAIS EOP platform — ESPD, technical compliance with the standards, price offer, guarantees. But in nearly 39% of tenders the process is fundamentally different: “Negotiation without prior notice” skips the public tender and leads to direct negotiations with a qualified supplier. Here success is decided before the procedure — through licensing, pre-qualification and a position on the wholesale market.
In regulatory terms, energy supplies sit at the intersection of several regimes: the licensing regime (for trading electricity, petroleum products, natural gas), the quality standards (EN 590, sulphur content, calorific value), and the general rules of the Public Procurement Act. Participation and performance guarantees are especially important — their incorrect preparation is among the leading causes of exclusion. Article 72 (abnormally low price) is triggered less often, because a standardised commodity leaves little room for undercutting.
The trends here are perhaps the most transformative of all sectors. The energy transition is reordering the market: criteria for green procurement, renewable energy, reduced carbon footprint and energy efficiency are entering public tenders fast. The liberalisation of the electricity market is opening up competition among traders, and decarbonisation pressure will shift volumes from fossil fuels towards green energy, pellets and alternative sources. The supplier that positions itself on the right side of this transition — with green certificates, renewable sources and low-carbon logistics — will find a growing market where traditional fuels are shrinking.
Conclusion
Fuels and energy are the most idiosyncratic of the five leading sectors. Here the commodity is standardised, price is king (97.5%), and a large part of the market — 39% — never goes through a tender at all. Competition is so scarce that the median is one bidder, and final prices coincide with the estimates. For the supplier this means that success is built not on writing bids, but on qualification — licences, standards, references, guarantees, pre-qualification. Whoever is on the right list and backs the standards with evidence operates in a market with few competitors and predictable prices. And as green criteria and the energy transition take hold, this already special sector will become even more strategic.
Whether a specific energy tender is worth the effort — and whether your file covers every requirement — is exactly what our risk assessment and requirements ↔ documents check verify.
Data: official OCDS dataset of the CAIS EOP platform, 5,480 contracts for CPV 09, May 2023 – June 2026. Statistics: own analysis. Values in euro.
