Court case 2984/2026 – Court Ruling (Bulgaria, 2026)

The data subject requested that the controller (a Bulgarian non-banking financial institution specialized in providing online fast loans and installment loans) provide copies of all documents containing their personal data, including loan agreements, credit applications, and information about payments made under their contracts. The controller provided only an extract from its records and information about the processing of the data, without supplying copies of the requested documents. The Administrative Court of the city of Lovech annulled the controller's refusal and ordered the company to reconsider the request in accordance with the law. It held that the company had failed to fulfil the individual’s right of access to personal data under Article 15 of the GDPR. The controller appealed to the Bulgarian Supreme Administrative Court (BSAC), arguing that the lower court’s decision was inadmissible or legally incorrect. The company also requested that the proceedings be suspended pending a related case before the Court of Justice of the European Union (CJEU), Case C-676/2025. The BSAC rejected the request to suspend the proceedings, finding that the pending CJEU case concerned different circumstances, namely contractual relationships that had already ended. Since the contractual relationship in the present case had not been shown to have ended, the outcome of the CJEU case was not decisive. The Court also confirmed that the controller's response constituted an explicit refusal because it did not provide the requested document copies in the first place. The BSAC confirmed that Article 15(3) GDPR requires a data controller to provide a copy of the personal data being processed, including data contained in stored documents. Referring to the CJEU judgment of 4 May 2023 in Case C-487/2021, it explained that this right may require copies of entire documents, rather than extracts alone, where necessary for the individual to understand and verify the accuracy and lawfulness