27 Jan “DallBogg” and financial supervision without dispute over the numbers, but over the grounds
The Financial Supervision Commission and the insurer DallBogg have entered into a dispute over the company’s solvency. It erupted after a publication, and in the positions sent to the media, the FSC and DallBogg exchange serious accusations.
The regulator is biased, if not worse, the company writes.
The problems are a direct and exclusive consequence of inaction, omissions, or inconsistencies in the actions of the insurance company’s management bodies, the FSC responds. Here are the full texts of the two statements.
DallBogg shows a record capital adequacy of 188.54% for 2025 – preliminary data requested by the FSC on a monthly basis. The insurer is solid and stable. The regulator is biased, if not worse. Our shortcomings and inconsistencies are no worse than those of other insurers, but none of them in Europe are treated more discriminatorily. Whether the depositary blocked by the FSC issued the American shareholder’s shares on time or after the next general meeting, or did not issue them at all, is irrelevant to his shareholder rights, especially since his participation was accepted and expressly confirmed by the regulator itself on December 11, 2025.
No problems with the regulator are “intensifying,” as one manipulative media outlet claims. There are also no illegal transactions between related parties. The law does not prohibit such transactions, and they are expressly permissible and lawful when carried out within regulatory limits, in compliance with the principles of transparency and reasonable investor (according to the Capital Markets Act, Article 124) and in accordance with the company’s investment policy approved by the regulator (FSC) itself.
DallBogg’s position
The solvency capital requirement (SCR) for 2025 of DallBogg, the largest and best-capitalized Bulgarian insurer, is expected to reach a record 188.54% with a minimum threshold of 100%. There are no violations. There are no illegal transactions. Any characterizations of “empty,” “prohibited,” or “illegal” operations are insinuations devoid of legal and factual basis, aimed solely at undermining the company’s authority and instilling uncertainty in the public. How can notarized transactions be “empty” when real estate and money are transferred entirely in accordance with the rules and the law, with the achieved goal of strengthening the insurer and providing better service to the insured persons and beneficiaries under the insurance policies? All instructions and measures of the regulator have been strictly implemented.
The European authority EIOPA is fully informed of the results of the restructuring and exemplary market behaviour in all European markets, in accordance with the nine strict criteria set by EIOPA. EIOPA is also aware of the fulfillment of the capital adequacy criteria and is now fully informed of the artificial obstacles that the FSC is creating for the insurer to register its increased capital—not “fictitious” capital, but fully and actually paid in, exactly as required by law and the FSC.
In fact, the real problem lies not in the company’s activities, but in the actions of the Financial Supervision Commission. Through legal proceedings brought without legal interest and without legal grounds, according to a ruling by the Sofia City Court, the FSC effectively blocked the registration of the insurer’s capital increase of BGN 80 million. This proceeding, figuratively called the “slap case,” was used as a formal pretext for subsequent administrative orders, equally unlawful, by the investment supervisor. The mere filing of a statement of claim was used as a basis for a coercive measure against the Central Depository to stop the issuance of shares to a new investor and block the registration of the record capital increase, which was also instructed by the regulator in terms of amount.
Regardless of this series of formally fabricated but essentially unfounded and unlawful actions, the company’s activities are entirely lawful and carried out under the supervision of the regulator. Today, the company has both assets and cash – what could be better than that for the proper performance of the regulator’s duties and for the insured persons and beneficiaries of the insurance?
The FSC’s response
Regarding the publications of the insurance company “ZAD DallBogg: Life and Health” AD, the Commission emphasizes that the deadline for submitting the annual supervisory reports of insurers for 2025 expires at the end of the first week of April 2026. Therefore, the process of supervisory review of the financial condition of local insurers as at 31 December 2025 has not yet been completed. Until the supervisory review process is completed, any statements, assessments, or qualifications based on information not reported to the Commission are unverified opinions that have no supervisory significance and cannot give rise to any legal consequences.
With regard to allegations of difficulties or problems related to entries, registrations or the recording of circumstances in the relevant registers, the Commission states that such problems do not arise from acts of the Commission, but are a direct and exclusive consequence of omissions, incompleteness or inconsistencies in the actions of the management bodies of the insurance company, which are responsible for the timely, complete and lawful performance of their legal obligations to the competent institutions maintaining the relevant registers.
In this particular case, the company’s representatives submitted the shares from the company’s capital increase, approved by the general meeting held on 09.09.2025, for registration with Central Depository AD only on 27.10.2025. As a result of at least two general meetings of shareholders held on 23.09.2025 and 20.10.2025, the shareholders voted with shares that had not been issued and did not exist in the legal world. At the meeting held on 28.12.2025, there are also shareholders who vote with shares that do not exist in the legal world. This calls into question the legality of the decisions taken and, as they concern the capital, the financial indicators of the company.
The Commission recalls that the responsibility for initiating, completing, and properly administering the registration procedures lies entirely with the management bodies of the insurance company, with the Commission supervising the effective functioning of the insurer’s management system. The accumulating evidence of ineffectiveness in the insurer’s management system raises serious concerns about a number of non-compliances with regulatory requirements in the field of insurance, which cannot be compensated for by public suggestions or attempts to transfer institutional responsibility.
The Commission exercises its powers on the basis of established facts, duly collected evidence, and regulatory procedures. Any suggestions of established violations based on unverified or unconfirmed information are unfounded and misleading. Such suggestions do not contribute in any way to improving the effectiveness of the insurer’s management system or its financial condition.