NISO: who must register, what is filed, and by when
If your company’s operations generate industrial or hazardous waste, you are an obliged party under NISO, regardless of the size of the company, the sector, or whether anyone has ever inspected you. Record keeping has been entirely electronic since 2021, and since 2023 the deadline for the annual report is 31 March, with no corrections possible afterwards.
Many sources online still give 10 March. That is the old wording of the ordinance.
This guide brings together what you need: who is obliged, what exactly is filed, by when, what the penalties are, and where companies most often go wrong.
What is NISO?
NISO is the National Waste Information System, the electronic platform through which all record keeping for waste activities in Bulgaria is carried out. It is maintained by the Executive Environment Agency (ExEA) and is available at nwms.eea.government.bg.
Until 2021 records were kept on paper: record books certified at RIOSV, and annual reports filed in person or by post. Since 1 January 2021 all record keeping has been electronic in NISO: classification working sheets, record books, monthly entries and annual reports.
The legal basis is Ordinance No. 1 of 4 June 2014 on the procedure and forms for providing information on waste activities, substantially amended by SG No. 82 of 2021 and SG No. 33 of 2023.
Who must register with NISO?
The obligation covers everyone whose operations generate industrial or hazardous waste, as well as anyone carrying out waste activities: collection, transport, treatment, trade and brokerage.
In practice this means:
- Manufacturers: from food and chemicals to engineering and printing
- Retail chains, distributors and warehouses: written-off batches, defective goods, expired stock
- Medical and health establishments: hospitals, clinics, laboratories, dental and medical practices
- Pharmacies, wholesalers and manufacturers of medicinal products
- Garages, car washes and petrol stations: waste oils, filters, contaminated packaging
- Construction firms, for waste outside the scope of the construction regime
- Municipalities and utility operators
A common misconception: a small volume does not remove the obligation. A dental practice producing two kilograms of hazardous waste a month is an obliged party on exactly the same footing as a factory. The difference is in the volume of work, not in whether the duty exists.
Municipal waste from an office or retail site, collected by the municipal system against the household waste charge, is not reported by you. But if you separate paper, plastics or metals and hand them to a company, that is an activity subject to reporting.
What is filed in NISO?
Ordinance No. 1/2014 sets out three reporting documents: record books under Art. 44(1) of the WMA, annual reports under Art. 44(6) of the WMA, and the identification document under Art. 29(5) of the WMA. To these is added the working sheet, without which none of the above can begin.
1. Classification working sheet
Before you can report anything, the waste needs a code. The working sheet under Annex No. 5 to Ordinance No. 2/2014 is filed through NISO and approved by RIOSV. There is more on the ordinances that govern this on our Licenses & Documents page.
The working sheet is drawn up for a waste code, not for a batch or a journey. If you write off stock only once, the obligation is the same. Without an approved working sheet you cannot open a record book and you cannot lawfully hand over the waste. This is the most common cause of delay for companies writing off for the first time.
2. Record books
Record books are kept electronically in NISO with a qualified electronic signature. A separate book is kept for each waste code and each site.
The entry is made when the waste arises and when it is handed over, not at the end of the month and not at the end of the year. A discrepancy between the record book entry and the quantity on the identification document is the first thing an inspection sees.
3. Annual report
The annual report summarises the whole year: which codes arose, in what quantities, and to whom they were handed over. It is filed on the form set out in the annexes to Ordinance No. 1/2014.
What are the deadlines?
Annual report: by 31 March of the year following the reporting year.
This changed in 2023. The earlier wording required filing by 10 March with corrections allowed until 31 March. The current Art. 23 of Ordinance No. 1/2014, as amended by SG No. 33 of 2023 and in force from 10 April 2023, sets a single deadline, 31 March, and expressly provides that the data cannot be altered once it has passed.
The practical difference matters. You used to have three weeks to find and fix a mistake. Now a mistake filed on 31 March stays in the system permanently.
Record books: continuously, whenever waste arises and is handed over.
There is no monthly deadline, but entries are not made retrospectively. A record book filled in all at once in December is formally kept and practically unconvincing under inspection.
Working sheets: before the first handover.
Approval by RIOSV takes time. If you are planning to clear a warehouse by a particular date, start with the working sheet, not with the transport. How we work sets out the sequence step by step.
How do you get access to NISO?
Registration and work in the system require a qualified electronic signature (QES) within the meaning of the Electronic Document and Electronic Certification Services Act.
There are two ways to work:
- With your own QES. The manager or an authorised employee registers as an obliged party and keeps the records themselves.
- Through an authorised person. You appoint an external consultant, or the company that carries your waste, to keep the records on your behalf.
One warning from experience: if the QES was issued to an employee who then leaves, access to the profile is lost and recovering it takes time. Check whose signature it is well before 30 March.
What are the penalties?
For failing to keep records and to provide information on waste activities, the WMA provides for a financial penalty under Art. 135. For legal entities and sole traders the amount is between BGN 2,000 and BGN 6,000. The exact figure depends on the nature of the breach and on whether it is a repeat offence.
The most common mistakes
From our experience with clients who come to us after an inspection rather than before one:
- A record book with no approved working sheet. You are trying to report a code RIOSV has not yet approved. The system will not allow it, and the clock is running.
- A discrepancy between the record book and the identification document. You estimated the weight by eye at loading, and the facility issued a weighbridge note with a different figure. Record the weighbridge figure, not the estimate.
- Handing over to a company with no document under Art. 35. Art. 8(1) of the WMA requires a written contract with a holder of a permit, an integrated permit or a registration document for the relevant activity, site and code. Ask for the document and check that your code is on it. Not every carrier is entitled to every code.
- Missing the 31 March deadline. After it, no corrections are possible. If you have missed it, file as soon as you can and consult RIOSV. A late filing is a better position than a missing one.
- “We had no waste, so there is nothing to file.” Registration and the obligation remain even with zero activity. Check with the relevant RIOSV what is required in your case rather than staying silent.
- The wrong code. Classification follows origin, not the type of product. The same solvent takes a different code depending on which process it comes from. Using municipal codes from group 20 for industrial waste is a classic error, and an immediately visible one.
Frequently asked questions
Does a small company have to register with NISO?
Yes, if its operations generate industrial or hazardous waste. Volume is irrelevant: a dental practice and a manufacturing plant are obliged parties on exactly the same footing.
What is the deadline for the annual waste report?
31 March of the year following the reporting year. After that date the data cannot be corrected. Sources giving 10 March are quoting a version repealed in 2023.
Is an electronic signature needed for NISO?
Yes. Working in the system requires a qualified electronic signature. The alternative is to authorise someone who holds one.
What is a classification working sheet?
A document under Annex No. 5 to Ordinance No. 2/2014 that establishes the waste code. It is filed through NISO and approved by RIOSV. It is drawn up for a code, not a batch, and it is the precondition for everything else.
What is the fine for failing to keep records in NISO?
A financial penalty under Art. 135 of the WMA of between BGN 2,000 and BGN 6,000 for legal entities and sole traders, the amount depending on the breach.
Do we have to report municipal waste from the office?
No, if it is collected by the municipal system against the household waste charge. Paper, plastics, glass and metals collected separately and handed to a company under contract are subject to reporting.
A question about your own record keeping?
Send us a list of the codes you generate and we will tell you what is missing from your profile, before RIOSV finds it.
