COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Bulgaria Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union

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COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 902 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in Bulgaria
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Rule of Law Report
The rule of law situation in the European Union
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1
ABSTRACT
Bulgaria has engaged in reform efforts, in dialogue with the Commission, under the Rule
of Law cycle and the Recovery and Resilience Plan, and there have been several
legislative developments particularly in the past six months. The Constitutional Court of
Bulgaria ruled that parts of the comprehensive constitutional amendments, essential for
the organisation of the State, had been adopted by a body not competent to do so, and
declared most of the reform unconstitutional. As a result, previous concerns that the
reform had aimed to address have reemerged. The provisions dismissed include limits on
the Prosecutor General’s powers, although the mechanism for the effective accountability
and criminal liability of the Prosecutor General and deputies was declared constitutional.
The effectiveness of this mechanism is constrained by some procedural issues. As for the
Supreme Judicial Council, the Constitutional Court dismissed the overall reform but
considered that a restructuring would be possible. The long-term secondment of judges
and the functioning of the Inspectorate to the Supreme Judicial Council remain a
concern. A draft law to extend judicial review for prosecutorial decisions for cases of
termination and suspension of investigations for victimless crimes was tabled. The level
of perceived judicial independence in Bulgaria continues to be very low. The law on
mandatory meeting for judicial mediation has been adopted. New digital tools have been
introduced to improve access to justice. Initial data show that courts perform efficiently
when dealing with civil and commercial proceedings.
The implementation of the National Anti-corruption Strategy remains limited. Some
steps have been taken to implement the reform of the Commission for Counteracting
Corruption and Illegal Assets Forfeiture. Cooperation between national authorities
competent in the fight against corruption is overall good, but a robust track-record of
high-level corruption cases is yet to be established, as convictions remain limited in
numbers and data about prosecutions is inconclusive. Work continues to strengthen
integrity in the police and judiciary, but important gaps remain in the rules on the
integrity of persons with top executive functions. Rules on asset and interest disclosure
for public officials are implemented, although enforcement is lacking. Legislation on
lobbying transparency is under preparation and further amendments to the
whistleblowers legislation has entered into force. Measures to mitigate the high risks of
corruption in public procurement are still insufficient.
Concerns regarding the funding and politisation of the media regulator persist. The draft
law aimed at strengthening the independence of public service media was not yet
adopted, and the appointment of a new Director-General of the Bulgarian national
television continues to be delayed. Despite the existence of several registers, the
enforcement of media ownership disclosure obligations remains limited. Improvement
has been achieved regarding the transparency in the allocation of state advertising.
Indications of political and economic influence over the media remain. Access to public
information is improving, although still hindered by previously existing obstacles.
Journalists are facing increasing challenges in their activities.
The Constitutional Court was called upon to review the election results in several polling
stations. Some independent and regulatory authorities continue to operate with an expired
mandate and the renewal procedures have been relaunched. The constitutional
amendments limiting the powers of the President in the procedure of appointing an
interim government is subject to another constitutionality check. The practical
implementation of rules for law-making continues to face challenges, and concerns
remain regarding the quality of the legislative process. Attempts to reintroduce
legislation requiring the registration of organisations receiving foreign funding were
again dismissed by Parliament.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Bulgaria has
made:
• No further progress on taking steps to adapt the relevant legislative framework to
avoid long-term secondment of judges to fill in vacant positions, taking into account
European standards on secondment of judges.
• No further progress on advancing with the draft legislative amendments aiming at
improving the functioning of the Inspectorate to the Supreme Judicial Council and
avoiding the risk of political influence, in particular by involving judicial bodies in
the selection of its members.
• No progress, following the ruling that the procedure used was unconstitutional, in
taking forward the plans to adopt a mechanism for introducing safeguards in the
appointment procedure of the Parliament-elected members of the Supreme
Prosecutorial Council, ensuring their independence and taking into account European
standards, particularly in view of the Council’s role in the appointment and dismissal
of the Prosecutor General.
• No progress yet on ensuring an improved effectiveness of investigations and a robust
track record of prosecution and final judgments in high-level corruption cases and
some further progress on the institutional reforms of the Anti-Corruption
Commission.
• Limited progress on improving the integrity of top executive functions, taking into
account European standards, in particular by ensuring that clear integrity standards
for the Government as well as an appropriate sanctioning mechanism are in place.
• Some further progress on advancing with the work aimed at improving transparency
in the allocation of state advertising, in particular with regard to state advertising
contracted through intermediaries, such as media agencies.
On this basis, and considering other developments that took place in the period of
reference, in addition to recalling the relevant commitments made under the Recovery
and Resilience Plan and the relevant country-specific recommendations under the
European Semester, it is recommended to Bulgaria to:
• Take steps to adapt the relevant legislative framework to avoid long-term secondment
of judges to fill in vacant positions, taking into account European standards on
secondment of judges.
• Advance with the draft legislative amendments aiming at improving the functioning
of the Inspectorate to the Supreme Judicial Council and avoiding the risk of political
influence, in particular by involving judicial bodies in the selection of its members.
• Re-initiate the process to reform the Supreme Judicial Council, in particular its
composition, to ensure its independence and effectiveness, taking into account
European standards on Councils for the Judiciary.
• Ensure a robust track record of investigations, prosecutions and final judgments in
high-level corruption cases and take further steps to ensure the effective performance
of the Anti-Corruption Commission.
• Improve the integrity of top executive functions, taking into account European
standards, in particular by ensuring that clear integrity standards for the Government
as well as an appropriate sanctioning mechanism are in place.
3
• Complete the work aimed at improving transparency in the allocation of state
advertising, in particular with regard to state advertising contracted through
intermediaries, such as media agencies.
• Strengthen the quality of the legislative process by ensuring the use of public
consultations and impact assessments for legislative initiatives by Parliament.
4
I. JUSTICE SYSTEM1
Independence
The level of perceived judicial independence in Bulgaria continues to be very low
among both the general public and companies. Overall, 27% of the general population
and of companies perceive the level of independence of courts and judges to be ‘fairly or
very good’ in 20252
. The perceived judicial independence among the general public has
increased in comparison with 2024 (24%) and has decreased in comparison with 2021
(32%). The perceived judicial independence among companies has slightly increased in
comparison with 2024 (25%) and has significantly decreased in comparison with 2021
(43%). The main reasons cited by both the general public and companies for the
perceived lack of independence of courts and judges are the perception of interference or
pressure from the Government and politicians, as well as the interference or pressure
from economic or other specific interests3
.
The Constitutional Court of Bulgaria ruled that parts of the comprehensive
constitutional amendments, essential for the organisation of the State, had been
adopted a body not competent to do so, and declared most of the reform
unconstitutional. On 20 December 2023, Parliament had adopted comprehensive
amendments to the Constitution, aimed at improving judicial independence and
addressing long-standing concerns. The reform had changed the Supreme Judicial
Council’s composition, explicitly limited the powers of the Prosecutor General at
constitutional level4
, and it also limited certain powers of the President of the Republic
regarding the appointment of interim governments5
. In its judgment of 26 July 2024, the
Constitutional Court ruled that several provisions were essential for the organisation of
the state, and thus their adoption required a Grand National Assembly6
, while other
provisions were struck down due to their drafting quality, lack of clarity and purpose.
While some of the provisions were declared compatible in themselves with the
Constitution, the Court struck them down as part of the larger reform being declared
unconstitutional7
. Consequently, the draft new Judicial System Act was not further
pursued in Parliament despite some provisions not being affected by the constitutional
amendments. As regards the reform limiting the Prosecutor General’s powers, the
Constitutional Court ruled that Parliament lacked the competence to make these changes
which it deemed essential for the organisation of the state. As for the Prosecutor General,
the combination of the powers and position of the Prosecutor General, which allow for
1
An overview of the institutional framework for all four pillars can be found here.
2
Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard.
The level of perceived judicial independence is categorised as follows: very low (below 30% of
respondents perceive judicial independence as fairly good and very good); low (between 30-39%),
average (between 40-59%), high (between 60-75%), very high (above 75%).
3
Figures 51 and 53, 2025 EU Justice Scoreboard.
4
E.g. the provisions linked to the position of the Prosecutor General in the overall structure of the
Prosecutor’s Office, and those linked to the powers of the Prosecutor General giving methodological
guidance and oversight of legality.
5
Constitutional court, Decision No. 13 of 26 July 2024.
6
The Grand National Assembly is a special legislative body convened to adopt a new Constitution or
amend key constitutional provisions, such as those concerning fundamental rights, organisation of the
state or the territorial integrity of the state. It consists of 400 deputies and operates under stricter
procedures and broader representation compared to the ordinary National Assembly.
7
In this context, the draft new Judicial System Act meant to implement the constitutional amendments
was not further pursued in Parliament despite some of its provisions not being affected by the
constitutional amendments.
5
disproportionate influence over the Prosecutor’s Office and the magistracy as a whole,
continue to raise concerns8
.
The mechanism for the effective accountability and criminal liability of the
Prosecutor General and his or her deputies was declared compatible with the
Constitution. On 26 July 2024, the Constitutional Court published a second judgment
concerning the constitutionality of the mechanism for the effective accountability and
criminal liability of the Prosecutor General and his or her deputies9
. The Court
considered the mechanism in its entirety compatible with the Constitution, and further
explained that due to the position of the Prosecutor General and the powers he has,
additional limits to his powers could be imposed through judicial review, which is a step
forward in strengthening judicial oversight. However, in the first judgment of the same
day, on the constitutional amendments and anchoring the mechanism in the Constitution,
the Court considered that such provisions do not belong in the Constitution but in
ordinary legislation10
.
Procedural issues remain to be addressed to ensure the full effectiveness of the
mechanism for the investigation of the Prosecutor General and his or her deputies.
This mechanism addresses long-standing concerns from previous Rule of Law Reports
regarding the issue related to the previous lack of a possibility for an effective criminal
investigation of the Prosecutor General and his or her deputies, demonstrating Bulgaria’s
commitment to reform11
. It is also subject to an assessment as a milestone in the
Recovery and Resilience Plan12
. Procedural issues remain to be addressed to ensure the
full effectiveness of the mechanism, linked to the hierarchical and practical independence
of the ad hoc prosecutor. The judicial review of a decision not to open an investigation
seems to be limited by procedural gaps13
, and there are decisions that can only proceed
with the authorisation of the Prosecutor General and his or her deputies14
. The current ad
hoc prosecutor has suggested that the simultaneous appointments of the ad hoc and the
controlling ad hoc prosecutors15
would solve some of the issues and strengthen the
independence of this mechanism16
. The Government has agreed that this would increase
the effectiveness of the mechanism. Stakeholders, including the Council of Europe, have
8
See 2024 Rule of Law Report, Bulgaria, p. 4.
9
Constitutional court, Decision No. 14 of 26 July 2024.
10
Constitutional court, Decision No. 13 of 26 July 2024. The two decisions confirm the compatibility of
the mechanism with the Constitution but make it more susceptible to legislative changes requiring only
a simple majority.
11
See 2023 Rule of Law Report, Bulgaria, p. 4.
12
See milestone 222 of Bulgaria’s RRP on the accountability and criminal liability of the Prosecutor
General.
13
Cases filed by the Prosecutor’s Office are not susceptible to a judicial review; in case of a termination
of the pre-trial proceedings, the controlling ad hoc prosecutor is appointed to review the decision of
termination. However, the provision laying down the precise conditions under which this could happen
does not currently exist, and it is impossible to appoint the controlling ad hoc prosecutor (Art. 411d of
the CPC mentions the non-existing Art. 243a of the CPC).
14
In case the ad hoc prosecutor needs to request an extension of the deadline to conclude an inspection or
an investigation against the Prosecutor General, the latter is responsible for approving this extension.
15
This is a second judge who is appointed as an ad hoc deputy Prosecutor General whose purpose would
be to control the acts of the ad hoc prosecutor during the pre-trial proceedings.
16
The ad hoc prosecutor lacks a dedicated office and autonomous tools such as a budget for experts’
opinions and IT systems, and there are no dedicated operative officers. The SJC declined the ad hoc
prosecutor’s request to choose clerks they work with, or to hire new people who are not coming from
the prosecution. As regards the staff helping with investigations, there are no operative officers that can
be used during the investigation.
6
pointed out that the ad hoc prosecutor is operational but express some concerns about its
impact so far17
.
The Government has tabled a draft law to extend judicial review for prosecutorial
decisions for cases of termination and suspension of investigations for victimless
crimes. On 27 June 2025, in the context of the Recovery and Resilience Plan, the
Government tabled a draft law that would give to a number of state bodies the possibility
to challenge decisions suspending or terminating investigations to offences for victimless
crimes. This comes as a response to reports by stakeholders that frequent termination of
investigations during pre-trial proceedings often goes unchallenged in court due to the
absence of effective legal mechanisms to contest such prosecutorial decisions. They
consider that this hampers, in particular, the anti-corruption efforts of Bulgaria since this
limitation exists only for victimless crimes18
. The draft law is under public consultation
until 10 July 2025.
The Sofia City Prosecutor’s Office has been restructured but concerns remain
regarding the structure for the investigation of magistrates. As previously reported,
there are ten prosecutors in Bulgaria responsible for cases concerning offences that may
be committed by magistrates. These prosecutors are selected by the administrative head
of the Sofia City Prosecutor’s Office, who is a direct subordinate to the Prosecutor
General, and specialise solely on cases related to magistrates19
. This continues to raise
concerns regarding prosecutorial autonomy and possible concerns regarding judicial
independence as every prosecutor, investigator or judge could be subject to a criminal
investigation20
, as recently exemplified by an investigation opened against a first instance
court judge for the content of his decisions21
, and by the investigations against
prosecutors as noted by the Council of Europe22
. On 28 May 2025, the newly appointed
interim administrative head of the Sofia City Prosecutor’s Office has ordered a
restructuring of the office to create new structures and to centralise the work of the
17
Country visit Bulgaria, Bulgarian Institute For Legal Initiatives, Anti-Corruption Fund Foundation,
Institute For Market Economics, Center For The Study Of Democracy and Initiative Justice For All.
See also Joint CSO contribution (2025), written input, pp. 8-9. See also Council of Europe, Supervision
of the execution of the European Court’s judgments, Committee of Ministers Notes of 11-13 June 2024,
(CM/Notes/1501/H46-10).
18
Center for the Study of Democracy (2025), written input, p. 20. There are also other notable cases for
which the pre-trial proceedings have been terminated during the reporting period, see Lex.bg (2025), 4
April 2025. See also Council of Europe, Supervision of the execution of the European Court’s
judgments, Committee of Ministers Decision, CM/Del/Dec(2023)1475/H46-12 of September 2023,
para. 4; CM/Del/Dec(2023)1483/H46-10 of December 2023, para. 3. CM/Notes/1475/H46-12 of
September 2023, p. 1. H/Exec(2023)10 of September 2023, p. 1-3; CM/Notes/1501/H46-10 of 11-13
June 2024. See also Venice Commission opinion (CDL-AD(2023)039), para. 91. In relation to the
previously introduced judicial review for decisions not to open an investigation, under Art. 213b of the
CPC, the Government reported data for 2024: 144 736 files with refusals were resolved, 5 411
confirmed by the upper (district/appellate) prosecutor's office (i.e. potential subject of judicial control),
512 appealed before court).
19
See 2024 Rule of Law Report, Bulgaria, p. 7.
20
See Association of Prosecutors in Bulgaria position (2025), 30 January 2025.
21
See notification of the judge to the Supreme Judicial Council, 29 January 2025. See also Bulgarian
Judges Association position (2025), 30 January 2025.
22
Council of Europe, Supervision of the execution of the European Court’s judgments, Committee of
Ministers Notes of 11-13 June 2024, (CM/Notes/1501/H46-10), point B, 4, a) and b). See also Supreme
Judicial Council, Judges’ chamber meeting (2024), 15 October 2024 - hearing of magistrates in
connection with the alleged influence of organised crime groups in the justice system. There were 800
judges who were investigated by the prosecutor's office, who ultimately decided that they had not
committed a crime.
7
Office23
, though this did not change the dedicated structure for the investigation of
magistrates, which was maintained. It is noted that the Sofia City Prosecutor’s Office
consists of a total of eight units in view of the volume of cases and the specific workload
of the prosecutors and their specialisation. On an annual basis the Prosecutor’s Office
provides data to the Supreme Judicial Council on the number of criminal proceedings
against magistrates that is processed in a dedicated register.
The reform regarding the appointment of members to the Supreme Prosecutorial
Council was declared unconstitutional, therefore no progress was possible on the
recommendation24. The Constitutional Court’s judgment also quashed the reform
related to the division of the Supreme Judicial Council into two Councils – Supreme
Judicial Council for judges, and Supreme Prosecutorial Council for prosecutors.
Similarly to the findings of the 2024 Rule of Law Report25
, the Court praised the reform
for improving the judicial independence by giving judges elected by their peers a better
representation in the Supreme Judicial Council. However, the Court did not agree with
the high number of Parliament-elected members in the Supreme Prosecutorial Council,
considering that this gives the Parliament too much influence over the Supreme
Prosecutorial Council and the Prosecutor’s office26
. As a result, the rules regarding the
composition and appointment of members of the Prosecutorial Council reverted to those
that existed before the 2023 constitutional amendments with one single Supreme Judicial
Council. Consequently, the concerns raised in previous Rule of Law Reports27
as regards
the influence of the Prosecutor General in the Supreme Judicial Council, and the fact that
judges elected by their peers did not form a majority in the Supreme Judicial Council28
remain unaddressed29
. On 15 January 2025, the Parliament adopted amendments to the
Judicial System Act forbidding a Supreme Judicial Council with an expired mandate
(since October 2022) to elect a new Prosecutor General, and new Presidents of the
Supreme Courts, and closed all open or pending procedures for election of these
positions30
. While the authorities note that these amendments aim to safeguard
institutional integrity and prevent decisions being made by abody with an expired
mandate, this further restricts the functioning of the Supreme Judicial Council. The
interim Prosecutor General challenged the closure of the election before the Supreme
Administrative Court, which sent a request for a constitutionality check, that is still
pending31
. Some of the members of the Supreme Judicial Council, arguing that the
23
See Order of the Administrative head of the Sofia City Prosecutor’s Office of 28 May 2025.
24
The 2024 Rule of Law Report recommended to Bulgaria to “[t]ake forward the plans to adopt a
mechanism for introducing safeguards in the appointment procedure of the Parliament-elected members
of the Supreme Prosecutorial Council, ensuring their independence and taking into account European
standards, particularly in view of the Council’s role in the appointment and dismissal of the Prosecutor
General.”
25
See 2024 Rule of Law Report, Bulgaria, pp. 9-10.
26
Constitutional court, Decision No. 13 of 26 July 2024.
27
See 2023 Rule of Law Report, Bulgaria, pp. 6-8.
28
Venice Commission opinions (CDL-AD(2020)035), para. 44 and (CDL-AD(2023)039), para. 47; JSA,
Art. 16(3) and (4) – Since the Judicial Chamber (14 members) was presided by either one of the ex
officio members (the President of the Supreme Court of Cassation or the President of the Supreme
Administrative Court) a majority could be reached, both in the Plenary of the SJC and the Judicial
Chamber, without the votes of the judges elected by their peers.
29
Currently only 4 out of 20 members are peer-elected judges.
30
See Law amending the Judicial System Act, adopted on 15 January 2025. See also Joint CSO
contribution (2025), written input, p. 5.
31
See Constitutional Court Case No. 5 of 2025. The interim Prosecutor General was allowed to challenge
the procedure before the Supreme Administrative Court because he was a candidate (the only one) for a
new Prosecutor General.
8
findings of the Court of Justice on the Inspectorate to the Supreme Judicial Council
working on an expired mandate is also applicable to their institution, have considered
that additional constraints on the work of the Supreme Judicial Council, linked to the
expired mandate, may be necessary32
.
There has been no further progress as regards the functioning and risk of political
influence of the Inspectorate to the Supreme Judicial Council (ISJC)33. The draft
new Judicial System Act, which was published for public consultation in July 2024 was
no longer pursued following the Constitutional Court judgment declaring most of the
reform unconstitutional. New draft amendments to the Judicial System Act were
published for a public consultation on 19 December 202434
. These draft amendments also
tried to address the previously reported concerns with the ISJC, notably as regards its
functioning and the risk of political influence, as the Parliament is the only institution
involved at all stages of the appointment procedure. These draft amendments were not
pursued further by the new Government appointed in January 2025, and no further steps
have been taken to continue this workstrand. In the context of a preliminary ruling
request, the Court of Justice ruled that the principle of judicial independence precludes a
practice in which a judicial body, such as the ISJC, is working beyond the expiry of its
mandate without an express legal basis for this, and without this extension of mandate
being limited in time35
. As a result, there has been no further progress on the
recommendation made in the 2024 Rule of Law Report.
There has been no further progress to avoid long-term secondment of judges to fill
vacant positions36. Even though the issue of long-term secondment was not covered in
the Constitutional Court judgment of July 2024, and draft provisions to remove the
possibility of seconding a judge to a vacant position for undetermined period of time had
been prepared, concrete legislative plans have not been taken forward in this area. The
widespread use of secondments may have a negative effect on seconded magistrates if
they are faced with the risk of termination of their secondment37
. European standards in
this area highlight that secondments of judges with or without consent require the
necessary guarantees to prevent the risk of judicial independence being jeopardised38
,
32
DeFakto (2025). According to the President of the Supreme Court of Cassation and another member of
the Judges’ chamber of the SJC, the CJEU, Judgment of 30 April 2025, Inspektorat kam Visshia
sadeben savet, Joined Cases C-313/23, C-316/23 and C-332/23, EU:C:2025:303 also has an effect over
the SJC as it fulfils similar functions as the Inspectorate. This is also considered as one of the reasons
for the lack of quorum in the Judges’ chamber of the SJC.
33
The 2024 Rule of Law Report recommended to Bulgaria to “[a]dvance with the draft legislative
amendments aiming at improving the functioning of the Inspectorate to the Supreme Judicial Council
and avoiding the risk of political influence, in particular by involving judicial bodies in the selection of
its members.”
34
Country visit, Bulgaria, Ministry of Justice. See also Joint CSO contribution (2025), written input, pp.
3-4, which explains that this draft law’s development did not include any civil society organisations and
no professional organisations.
35
CJEU, Judgment of 30 April 2025, Inspektorat kam Visshia sadeben savet, Joined Cases C-313/23,
C-316/23 and C-332/23, EU:C:2025:303, points 81-97.
36
The 2024 Rule of Law Report recommended to Bulgaria to “[t]ake steps to adapt the relevant
legislative framework to avoid long-term secondment of judges to fill in vacant positions, taking into
account European standards on secondment of judges.”
37
See 2023 Rule of Law Report, Bulgaria, pp. 9-10. According to the register maintained by the Supreme
Judicial Council, as of November 2024, there are 196 seconded judges, 57 of them being seconded for
more than a year, with the longest secondment being 81 months.
38
Secondments are being done on a temporary basis and in exceptional circumstances. See also for the
specific case of Bulgaria - Venice Commission opinion (CDL-AD(2017)018), paras. 86 and 87.
9
particularly when a secondment is terminated without the judge’s consent39
. Against this
background, there has been no further progress on the recommendation made in the 2024
Rule of Law Report.
The ad hoc committees created to investigate cases of intimidation of magistrates
and possible infiltration of the judiciary have concluded their work. The
parliamentary committee could not adopt a final report due to lack of quorum and the
committee was not reinstated after the last elections in October 202440
. The judiciary
committee established by the Judges’ chamber of the SJC has finished the inquiry and is
working on a report on this issue, set to be published by July 2025. At the same time the
Prosecutor’s Office terminated the pre-trial proceedings against a suspect allegedly
linked to these organised crime groups41
.
Quality
The law on mandatory meeting for judicial mediation has been adopted and
includes proceedings relevant for businesses. On 1 July 2024, the law on mandatory
judicial mediation was declared unconstitutional by the Constitutional Court42
.
According to the Court, the mandatory aspect of the mediation violates the right to access
a court and to effective judicial protection as guaranteed by the Constitution43
. The
Ministry of Justice has prepared a new draft law, which would align the legislation on
judicial mediation with the requirements set by the Constitutional Court. It also intends to
address the reform of the mediation framework in Bulgaria’s Recovery and Resilience
Plan44
. The aim is for a certain number of civil and commercial proceedings to be
preceeded by a mandatory information session on mediation, instead of mandatory
mediation. Legislation tabled in Parliament in May 2025 sets out the cases where it
would be possible for courts to oblige the parties to hold mediation sessions45
. On 27
June 2025, the draft law was adopted at second reading by Parliament, and it will be
published in the State Gazette and will subsequently enter into force.
New digital tools to improve access to justice have been introduced, while electronic
communication tools are still lacking. The authorities have introduced new digital tools
to improve access to justice46
. In some civil and commercial cases, it is now possible to
initiate proceedings online and it is possbile to file an application for legal aid online in
civil, commercial, and administrative cases. Availability of electronic communication
tools is still limited to the prosecution, and as for the courts, electronic communication is
only possible between courts but not with other actors in the justice system (e.g. notaries,
39
As regards EU law requirements, see CJEU, Judgment of 16 November 2021, Prokuratura Rejonowa w
Minsku Mazowieckim, Joined Cases C-748/19 to C-754/19, EU:C:2021:931, points 72-90.
40
The majority of the committee’s members did not attend the meeting. -
https://www.parliament.bg/bg/parliamentarycommittees/3350/steno/8051. See also Joint CSO
contribution (2025), written input, pp. 6-7. See Publication by the Anti-corruption Fund Foundation of
4 June 2021. See 2024 Rule of Law Report, Bulgaria, p. 12. See also Civil Liberties Union for Europe
(2025), written input, pp. 140-146.
41
See Press release of the Prosecutor’s Office of 4 April 2025.
42
See Constitutional Decision No. 11 of 1 July 2024.
43
Art. 57 and 117 of the Constitution.
44
See reform C10.R3, milestone 227 of Bulgaria’s RRP.
45
Country visit, Bulgaria, Ministry of Justice. See also Joint CSO contribution (2025), written input, pp.
9-10.
46
It is noted that amendments adopted on 31 July 2024, postponed the entry into force of the electronic
order for payment procedure, which is scheduled to apply from 1 July 2025.
10
lawyers or bailiffs)47
. Some businesses consider that the insufficient number of electronic
services is a barrier for them48
. On 10 June 2025, the Government tabled a draft law
related to the digitalisation of administrative justice. The draft aims at streamlining
proceedings and ensuring that actions, such as remote open court hearings and the
electronic submission of requests, are effectively implemented49
.
Efficiency
The courts perform efficiently when dealing with civil and commercial proceedings.
Following the positive development announced in the 2024 Rule of Law Report, for the
first time Bulgaria was able to report disaggregated data on the disposition time of civil
and commercial litigious proceedings for 2023. According to the 2025 EU Justice
Scoreboard, it takes on average 186 days to resolve a civil or commercial case, which
means that courts generally deal efficiently with their caseload. This new data also allows
to observe the performance of the courts in all three instances. It appears that while cases
at third instance on average take up to 249 days to be resolved, cases at first and second
instance courts take respectively 186 and 138 days to be resolved50
. Nevertheless, more
long-term reporting is needed to establish whether Bulgaria’s efforts regarding the
efficiency of its courts could have a positive impact on both citizens and businesses.
However, at this stage, some businesses consider the efficiency of the justice system as a
barrier for them51
.
II. ANTI-CORRUPTION FRAMEWORK
The perception among citizens, experts and business executives is that the level of
corruption in the public sector remains high. In the 2024 Corruption Perceptions
Index by Transparency International, Bulgaria scores 43/100 and ranks 26th
in the
European Union and 76th globally52
. This perception has been relatively stable over the
past five years53
. The 2024 Special Eurobarometer on Corruption shows that 80% of
respondents consider corruption widespread in their country (EU average 69%) and 32%
of respondents feel personally affected by corruption in their daily lives (EU average
30%). As regards businesses, 89% of companies consider that corruption is widespread
(EU average 63%) and 55% consider that corruption is a problem when doing business
(EU average 35%). Furthermore, 18% of respondents find that there are enough
successful prosecutions to deter people from corrupt practices (EU average 36%), while
47
2025 EU Justice Scoreboard, Figure 43-45.
48
Survey conducted by the Bulgarian Industrial Association in December 2024, among 738 micro, small,
medium and big companies in Bulgaria. It shows that 31% of the respondents consider that the
insufficient number of electronic services is a barrier for businesses.
49
This reform is part of Milestone 215 of the Recovery and Resilience Plan.
50
2025 EU Justice Scoreboard, Figures 5 and 6. It should be noted that work is ongoing to prepare
amendments to the Criminal Code, Criminal Procedure Code, and Judicial System Act (JSA), in order
to increase the efficiency of proceedings regarding traffic accident cases.
51
Survey conducted by the Bulgarian Industrial Association in December 2024, among 738 micro, small,
medium and big companies in Bulgaria. It shows that 35% of the respondents consider that the
efficiency of the judiciary is a barrier for businesses.
52
The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-
60), relatively high (between 59-50), high (below 50).
53
In 2020 the score was 44, while in 2024 the score was 45. The score significantly increases/decreases
when it changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively
stable (changes from 1-3 points) in the last five years.
11
8% of companies believe that people and businesses caught for bribing a senior official
are appropriately punished (EU average 33%)54
.
The implementation of the National Strategy for the Prevention and Countering of
Corruption 2021-2027 remains limited. The ongoing implementation of the National
Strategy for the Prevention and Countering of Corruption 2021-2027 and related
Roadmap has not continued in a structured and systematic manner as regards all of its
priorities55
. Annual reports on the implementation of the Strategy have not been prepared
for 2023 and 2024 while the Government has committed to improving monitoring and
reporting to ensure greater transparency56
. The proposals for a mid-term revision of the
Strategy, which were prepared by an interministerial working group and discussed at the
meeting of the National Council on Anti-Corruption Policies in October 2023, were not
further pursued by the Council of Ministers57
. The National Council on Anti-Corruption
Policies has not been convened since October 2023. Furthermore, civil society continues
to criticise the absence of a sufficiently thorough and evidence-based needs analysis for
the implementation and the revision of the current strategy58
. The implementation of
measures set out in sectoral anti-corruption plans has continued.
Some further progress has been made to implement the reform dividing the
Commission for Counteracting Corruption and Illegal Assets Forfeiture59. As
reported in 2024, the Commission for Counteracting Corruption and Illegal Assets
Forfeiture had been divided into two separate bodies (the Anti-Corruption Commission
and the Commission for Illegal Assets Forfeiture)60
. The three-member leadership of the
new Anti-Corruption Commission (‘ACC’), intended to be in place by January 2024, still
needs to be appointed61
. This remains an important step for the effective implementation
of the law. Draft rules of procedure for an independent Nomination Committee have been
submitted to Parliament62
. The Government and the ACC have noted that the ACC is
fully functional63
. Specialised administrative and operational capacity, including
54
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
55
Country visit, Bulgaria, National Council on Anti-corruption Policies and Transparency International.
56
In its RRP (milestone 226), the Government has committed to providing yearly implementation reports
on the 2021-2027 anti-corruption strategy. The assessment related to the topic of Milestone 226 in the
Rule of Law report does not prejudge the assessment of the fulfilment of the measures in the framework
of the Bulgarian Recovery and Resilience Plan.
57
Country visit Bulgaria, Secretariat of the National Council for Anti-Corruption Policies.
58
Country visit Bulgaria, Bulgarian Institute for Legal Initiatives, Center for the Study of Democracy and
Transparency International.
59
The 2024 Rule of Law Report recommended to Bulgaria to ‘[e]nsure a robust track record of
investigations […] in high-level corruption cases and the effective performance of the Anti-Corruption
Commission.’
60
See 2024 Rule of Law Report, Bulgaria, p. 16.
61
The institutional reform divided the previous Commission into two separate bodies and transferred the
exclusive competence to investigate corruption crimes of high-level officials to the ACC as of 1 March
2024. See 2024 Rule of Law Report, Bulgaria, p. 16. Two specific milestones on the reform of the
Anti-Corruption Commission are envisaged under the Bulgarian RRP, namely the milestones 218 and
220, the assessments of which in the Rule of Law report does not prejudge the assessment of the
fulfilment of the measures under the Bulgarian Recovery and Resilience Plan.
62
The law gives both Parliament and civil society organisations the right to nominate candidates, which
have to fulfil certain criteria. According to a draft law submitted to the Parliament on 2 July 2025,
candidates then have to be appointed by the Parliament by simple majority - more than half of the votes
of members present, in line with Decision 13/2024 of the Constitutional Court.
63
Its regular activities, including the system for prevention of conflicts of interest and for asset
declaration, reportedly continue as before. Bulgarian Government (2025), written input, p. 23. Country
visit Bulgaria, Anti-corruption Commission.
12
experienced investigators, has been built up to support the investigative functions of the
ACC and it disposes of its own budget64
. In 2024, a total of 820 signals and 245 pre-trial
proceedings have been received and initiated by the investigative inspectors at the
specialised Anti-Corruption Directorate65
. However, stakeholders have underlined the
importance of the new procedure for appointment of the ACC leadership for its
credibility. A recent ruling of the Sofia Administrative Court annulled a decision of the
ACC on the ground that the decision was taken by a body which was not established in
compliance with the Law on Countering Corruption, due to Parliament’s failure to
appoint its new leadership within the three-month deadline set by that law66
. An appeal
against the ruling before the Supreme Administrative Court is pending67
. Given the fact
that the ACC is functioning and steps towards the adoption of rules of procedure of the
Nomination Committee were taken, there is some further progress as regards the
functioning of the ACC in the recommendation in the 2024 Rule of Law Report.
There has been no progress yet in establishing a robust track-record of high-level
corruption cases, as convictions remain limited in numbers and data about
prosecutions is inconclusive68
. In 2024, the Supreme Court of Cassation delivered
judgments in four corruption cases against high-level officials69
. One of these cases
resulted in a suspended sentence, two were terminated due to expiry of the statute of
limitations, and one was referred back to the court of appeal70
. In May 2024, the
Prosecutor General submitted to Parliament its second annual activity report on
combating corruption where it reports in relation to corruption. According to the report
there were 70 new pre-trial proceedings, 10 indictments and 4 sentences in 2024
concerning high-level officials71
. Stakeholders continue to question the prosecution’s
record on high-level corruption, with charges not brought or inadequately brought
forward even in cases of well-substantiated allegations or publicly available evidence72
.
64
Bulgarian Government (2025), written input, pp. 25-26. Information regarding the staff, resources, or
the exercise of the new investigative functions of the Commission is however not available. In 2024,
the ACC had to take on an estimated 170 cases with c. 15 investigative inspectors, which raised
questions over the Commission’s preparedness to carry out its investigative tasks. See also 2024 Rule
of Law Report, Bulgaria, p. 17.
65
Anti-Corruption Commission (2025), pp. 19-20. Between 01.01.2025 to 10.06.2025 the Specialised
Directorate "Counteracting Corruption" received 297 reports. It received and initiated 53 pre-trial
proceedings.
66
Sofia Administrative Court, Decision No 26743 in Case 6637 of 11.12.2024. This case has been
suspended awaiting the ruling which the Court of Justice of the European Union is to give on a
preliminary reference submitted by the Supreme Administrative Court in case 7373/2024 (C-611/24,
pending). Many other decisions of the Commission, adopted after the expiry of the three-month period
for the election of a new leadership of the ACC, have been confirmed by administrative courts.
67
Supreme Administrative Court, Case 1216/2025.
68
The 2024 Rule of Law Report recommended to Bulgaria to ‘[e]nsure a robust track-record of
investigations, prosecutions and final judgments in high-level corruption cases […]’. See 2024 Rule of
Law Report, Bulgaria, p. 2.’
69
In 2023, the Supreme Court of Cassation tracked six cases related to high-level corruption on which it
rendered a decision. See 2024 Rule of law Report, Bulgaria, p. 18.
70
Bulgarian Government (2025), written contribution, Annex provided by the SCC.
71
Prosecutor’s Office (2025), pp. 26, 33, 41 and 46. Reporting is based on the Unified Catalogue of
Corruption Crimes which covers a more extensive list of crimes than those that fall in the material
scope of the Law on Countering Corruption.
72
Country visit Bulgaria, Bulgarian Institute For Legal Initiatives, Anti-Corruption Fund Foundation,
Institute For Market Economics, Center For The Study Of Democracy and Initiative Justice For All.
See also 2024 Rule of Law Report, Bulgaria, p. 18. Stakeholders also raised concerns that over the past
year investigations and prosecutions were initiated selectively against representatives of specific
political parties. See Joint CSO contribution (2025), written input, pp. 10-11.
13
Similar concerns have been expressed by GRECO73
. Prosecutors continue to attribute the
lack of results to the outdated and overly formalistic Code of Criminal Procedure, as well
as the inconsistent efforts of corruption investigators, while no specific actions that could
be taken by the Prosecutor’s Office to build a robust track-record were identified74
.
Efforts to ensure accurate reporting, including disaggregated data, on high-level
corruption are underway75
. The detection, investigation and prosecution of foreign
bribery cases is seen as ineffective and continues to be criticised by the OECD76
.
Legislative amendments aiming to improve the legal framework on foreign bribery were
adopted by Parliament in June 202577
. On this basis, it is not possible to conclude that
there are sufficient concrete results in establishing a robust track record of investigations,
prosecution and final judgments in high-level corruption cases, and as such there has
been no progress yet on the implementation of this part of the recommendation.
Cooperation between national authorities competent on the fight against corruption
is overall good. The Ministry of Interior, the Anti-Corruption Commission and
prosecutors report that there is effective cooperation on anti-corruption investigations78
.
In 2024, the National Audit Office (NAO) submitted seven audit reports to the
prosecution service on suspicions of criminal activity. In the past year, the prosecution
service has terminated inspections related to 6 NAO reports, whereas investigations
continue on 11 other reports79
. Comprehensive information has not been provided by the
Prosecutor’s Office as regards the reasons for terminating inspections80
. The European
Public Prosecutor’s Office (EPPO) reported 19 corruption cases among its open cases in
Bulgaria in 202481
. In March 2025, the EPPO opened an administrative inquiry into
possible wrongdoing by the European Prosecutor from Bulgaria, who was also
temporarily suspended82
.
Further measures have been taken to strengthen integrity in the police and the
judiciary. In 2024, the Ministry of Interior ensured enhanced supervision of officials in
charge of road traffic, registration of vehicles, provision of security services and border
control to prevent corruption within these bodies. Implementation of the 2024 Anti-
Corruption Plan of the Ministry of Interior has continued, including measures aiming to
address corruption risks in public procurement, rotation of staff in high-risk sectors,
video surveillance and training83
. Other positive developments include the adoption of
73
GRECO (2023).
74
Country visit Bulgaria, Association of Public Prosecutors and Prosecutor General.
75
In particular, the Unified Catalogue of Corruption Offences, which serves as the basis for reporting,
combines data about corruption offences with other offences which fall outside the material scope of
the Anti-corruption Law. Regular annual reporting on high-level corruption cases is envisaged under
milestone 222 of Bulgaria’s RRP to improve accuracy and reliability of data. Council Implementing
Decision on the approval of the assessment of the recovery and resilience plan for Bulgaria,
SWD(2022) 106 final.
76
OECD (2023), p. 4.
77
Draft law 51-502-01-20 of 3 June 2025.
78
Country visit Bulgaria, Anti-corruption Commission, Ministry of Interior and Association of
prosecutors.
79
Country visit Bulgaria, National Audit Office.
80
Country visit Bulgaria, National Audit Office. Concerns about the lack of effective prosecutorial
follow-up to identified allegations of criminal behaviour remain valid, see 2024 Rule of Law Report,
Bulgaria, p. 24.
81
EPPO (2025), p. 19.
82
EPPO (2025), Press statement.
83
2024 Annual activity report of the Ministry of Interior. Bulgarian Government (2025), written input,
Annex ‘Specific measures in sectors at high risk of corruption’. In 2024, 88 reports were received
against employees of the Directorate-General Border Police, resulting in the initiation of 19 pre-trial
14
rules on donations and a revised code of ethics for the police. However, as reported by
GRECO, the operational independence of the police from the Ministry of Interior
remains insufficient, a dedicated anti-corruption strategy for the police is still lacking and
promotion and recruitment procedures need to be improved84
. As regards the judiciary, in
December 2024, the codes of ethics for judges and prosecutors were further aligned with
Venice Commission recommendations85
. Nevertheless, complementary rules clearly
defining disciplinary offences, as well as rules of conduct for prosecutors and
investigators faced with instructions that they believe to be wrong or illegal, are
lacking86
. In 2024, the Inspectorate to the Supreme Judicial Council (ISJC) continued to
provide training courses to magistrates, covering issues related to conflicts of interest and
the application of the codes of ethics87
. The ISJC initiated 18 inspections for integrity and
conflicts of interest, resulting in one disciplinary proceeding88
. Work is ongoing on the
finalisation of a code of ethics for state-owned enterprises89
.
There has been limited progress to strengthen the integrity of persons with top
executive functions90
. There are still no rules on integrity checks and on
incompatibilities of persons hired as advisers to senior political officials, and there is no
comprehensive code of conduct and enforcement mechanism for persons in top executive
functions91
. Integrity provisions for top executive functions remain fragmented, with
various institutions having differing provisions92
. Clear rules on the declaration of gifts to
persons in top executive functions are also lacking93
. The interministerial working group,
set up at the start of 2024, did not advance further with the preparation of a code of
conduct for top functions, as envisaged in the Anti-Corruption Strategy94
. The Chief
Inspectorate and various ministerial inspectorates do not have the appropriate functional
independence to effectively fulfil their role in prevention and detection of corruption95
.
The new Government Programme for the period 2025-2029 includes measures to
improve integrity among persons holding public office in the central executive branch
and to guarantee the functional independence of the inspectorates. In March, a new
interministerial working group was set up to prepare, by 30 September 2025, draft
amendments to the Law on Administration and a Code of Conduct for persons holding
public positions in the central executive branch. The legislative amendments will set out
an obligation for the Council of Ministers to adopt a Code of Conduct for persons
proceedings by various Prosecutor’s Offices in the country. A follow-up anti-corruption plan was
adopted in January 2025.
84
GRECO (2025).
85
Bulgarian Government (2025), written input, p. 14. Making corruption prevention systems for the
judiciary more robust, including through the Inspectorate to the Supreme Judicial Council (ISJC) and
adopting the codes of conduct is a commitment under the RRP (see milestone 219). The assessment
related to the topic of Milestone 219 in the Rule of Law report does not prejudge the assessment of the
fulfilment of the measures in the framework of the Bulgarian Recovery and Resilience Plan.
86
Venice Commission (2024).
87
Bulgarian Government (2025), written input, p. 34.
88
Bulgarian Government (2025), written input, p. 30.
89
See Milestone 224 of the Bulgarian RRP. The assessment related to the topic of Milestone 224 in the
Rule of Law report does not prejudge the assessment of the fulfilment of the measures in the framework
of the Bulgarian Recovery and Resilience Plan.
90
The 2024 Rule of Law report recommended to Bulgaria to ‘[i]mprove the integrity of top executive
functions, taking into account European standards, in particular by ensuring that clear integrity
standards for the Government as well as an appropriate sanctioning mechanism are in place.
91
See also GRECO (2025).
92
2024 Rule of Law Report, Bulgaria, p. 22.
93
GRECO (2025), recommendation xi.
94
Bulgarian Government (2025), written input p. 24.
95
GRECO (2025), recommendation x.
15
holding public office in the central executive branch96
. As some initial steps have been
taken to improve the integrity framework for persons in top executive functions, there
has been limited progress on the recommendation made in the 2024 Rule of Law Report.
The rules on asset and interest disclosure for public officials are implemented but
doubts remain on the extent and effectiveness of verifications and sanctions. The
Anti-Corruption Commission has continued implementing the rules on the disclosure of
assets and interests97
. The draft regulation on the declaration of assets of certain public
officials which was previously reported on was not further pursued98
. The ACC reports
that it has sufficient resources to accomplish its verification tasks and that it conducts in-
depth reviews, including complete income and asset analyses comparing the declared
circumstances with data available in the public and other state registers99
. The Anti-
corruption Fund points out structural issues related to verifications, which they find to be
formalistic, superficial and non-dissuasive, as well as lacking an in-depth assessment of
whether the income justifies declared assets100
. The annual reports of the Anti-Corruption
Commission provide publicly available information on fines imposed in relation to
delays in the submission of asset declarations. The ACC referred five cases to the
National Revenue Agency and six cases to the Commission for Illegal Assets Forfeiture
(‘CIAF’) for detected inconsistencies101
. Concerns over the lack of results of the asset
and interest declaration system, which was not reformed, remain valid102
.
Legislation on lobbying transparency is under preparation. In light of the
Government’s commitment to adopt legislative measures to regulate lobbying, in
November 2024, the Ministry of Justice set up a working group to prepare a legislative
proposal103
. While the draft law is not publicly available, civil society organisations
96
The Code of conduct would include guidelines on conflicts of interest contacts with third parties, gifts
and other benefits, additional activities, contracts with state bodies, post-employment restrictions. The
draft amendments would also establish a supervisory mechanism for the implementation of the code,
providing for precise sanctions for violations and instruments for their enforcement.
97
In 2024, the ACC inspected 8 597 annual declarations of assets and interests (irregularities remain in 12
cases), as well as 1 735 initial and final declarations filed in 2023 (irregularities remain in 126
cases).Verifications of 14 656 annual declarations submitted in 2024 and of 12 118 initial and final
declarations submitted between 06.10.2023 to 31.12.2023 have been initiated. The verifications resulted
in 2 524 administrative proceedings and 495 decrees establishing an administrative violation. The
administrative violations concern cases of both failure to submit and wrongly submitted asset
declarations. Bulgarian Government (2025), p. 34. Anti-corruption Commission (2025), pp 11-12
98
2024 Rule of law Report, Bulgaria, p. 23.
99
Country visit Bulgaria, Anti-corruption Commission. In 2024, 13 competitions have been finalised and
16 persons appointed in the Directorate in charge of investigations.
100
Country visit Bulgaria, Anti-corruption Fund. GRECO has expressed similar concerns. GRECO (2023),
recommendation ix.
101
652 cases were also referred to CIAF due to late submission of the declaration.
102
2024 Rule of Law Report, Bulgaria, p. 23.
103
Bulgarian Government (2025), written input, p. 33. Under the RRP a concept note shall be prepared on
the regulation of lobbying, and legislative measures shall be adopted to regulate lobbying activities in
the context of public decision-making. The assessment related to the topic of Milestone 223 in the Rule
of Law report does not prejudge the assessment of the fulfilment of the measures in the framework of
the Bulgarian Recovery and Resilience Plan.
16
continue to participate actively in this work104
. NAO is envisaged as the body that would
possibly manage a future transparency register105
.
Audits on political party and campaign financing continue. NAO remains responsible
for carrying out audits of the annual accounts of political parties, which are also required
to share a list of donors106
. In 2024, NAO carried out six audits related to political party
and campaign financing, one of which is still ongoing. Given that several snap elections
were carried out in the past years, NAO’s resources remain under strain. Information on
donors, donations made, and other information related to the campaign is submitted and
analysed via the Unified Electoral Code Register. In 2024, NAO adopted 59
administrative acts and fines amounting to EUR 25 000 due to administrative violations
of the electoral code107
. In the context of the October electoral campaign, the Ministry of
Interior received 984 reports of irregularities, mainly corruption-related, leading to 128
pre-trial proceedings. This is an increase of 58.2% compared to the parliamentary
elections in June 2024108
.
Further amendments to the legislation for the protection of whistleblowers have
been adopted by Parliament The amendments, largely aimed at aligning the current
legislative framework for the protection of whistleblowers with the EU Whistleblowers
Directive were adopted by Parliament on 30 April 2025 and have entered into force109
.
Amongst others, the amendments seek to address the narrow personal scope of protection
and the temporal limitation precluding investigations for breaches committed more than
two years before the reporting. This commitment is also included in Bulgaria’s RRP110
.
The Commission for Data Protection remains the competent authority to oversee
whistleblower protection. It regularly updates publicly available information on its
website, along with detailed answers to frequently asked questions (see statistics). The
Anti-Corruption Commission is then the main body which receives and investigates
reports of corruption involving senior public officials111
. Civil society organisations
continue to play a role in promoting the protection of whistleblowers and fostering a
culture of safe and effective whistleblowing112
. Some civil society organisations are,
104
Joint CSO contribution (2025), written input, p. 14. Contribution from the Bulgarian Institute for Legal
Initiatives for the 2024 Rule of Law Report, p. 25.
105
2024 Rule of Law Report, Bulgaria, p. 23. GRECO has also recommended to introduce rules governing
the interactions between top executive functions and lobbyists, see GRECO (2023), recommendation
xiii.
106
This work with the support of the Unified Public Register of political parties registered in view of
participating in elections, whereas the Unified Electoral code Register allows electronic submission of
documents by political parties.
107
Country visit Bulgaria, National Audit Office. Audits are performed on political parties that have
declared revenue and expenditure above a certain threshold (approximately EUR 500).
108
Report of the Ministry of Interior (2024).
109
Draft amending act 51-402-01-29.
110
Milestone 217 of Bulgaria’s RRP requires that Bulgaria ‘[introduces] the requirements of Directive
(EU) 2019/1937, notably: the creation of confidential internal and external channels for reporting
irregularities and corruption; the establishment of verification mechanisms of the submitted reports;
providing protection and support measures to whistleblowers; ensuring provision of feedback and
publicity on the results of the performed investigation based on reports’. The assessment related to the
topic of Milestone 217 in the Rule of Law report does not prejudge the assessment of the fulfilment of
the measures in the framework of the Bulgarian Recovery and Resilience Plan. Discussions on the
fulfilment of this milestone are ongoing.
111
In 2024 the ACC decided on 568 crime reports, of which 126 were referred to the prosecution due to
suspicion of corruption crimes.
112
Including through membership of the Southeast Europe Coalition on Whistleblower Protection. See
p.16.
17
however, still critical of the fact that the Commission for Data Protection is the
competent authority to oversee whistleblower protection and point out that the
whistleblowing system in place since 2023 has only resulted in few reports113
.
Measures to mitigate the high risks of corruption in public procurement are still
insufficient. Corruption has been flagged as one of the main barriers for businesses in a
survey conducted by the Bulgarian Industry Association among 738 companies114
.
Businesses’ attitudes towards corruption in the EU show that 35% of companies in
Bulgaria (EU average 25%) think that corruption has prevented them from winning a
public tender or a public procurement contract in practice in the last three years115
.
Moreover, only 30% of companies perceive the level of independence of the public
procurement review body (Commission on Protection of Competition) as very or fairly
good116
. The Single Market and Competitiveness Scoreboard on access to public
procurement in Bulgaria reports 37% of single bids for 2023 (EU average 29%). As such,
public procurement continues to be considered as an area at high risk of corruption, in
addition to the management of public property, management of EU funds and the
conclusion of concession contracts117
. In 2024, NAO detected 153 irregularities in the
application of the public procurement legislation and issued 67 administrative sanctions,
49 of which concern mayors and their deputies118
. The most frequent irregularities that
have been reported concern setting terms that unreasonably restrict certain participants;
non-compliance with the provisions of the Public Procurement Act when determining the
award criteria; non-application of the legal procedure for awarding public procurement;
subdivision of public procurement, which leads to awarding under a more simplified
procedure; selection of negotiated procedures with a limited number of participants or
with only one participant in non-compliance with the requirements of the Public
Procurement Act 119
. Public procurement policy has not included dedicated measures to
combat corruption120
. The Government has committed to develop targeted measures to
strengthen public procurement by focusing on competitive and transparent practices 121
.
III. MEDIA PLURALISM AND MEDIA FREEDOM
Concerns regarding the funding and politisation of the media regulator persist. The
appointment procedure for members of the Council of Electronic Media (CEM) relies on
shared competences for Parliament and the President of Bulgaria122
. Following the
expiration of the last chairperson's mandate in September 2024, and an absence of a
113
Country visit Bulgaria, CSOs. 2024 Rule of Law Report, Bulgaria, p. 25. By law the Commission for
Data Protection is required to analyse the practice of implementing the law regularly and at least every
three years.
114
Survey conducted by the Bulgarian Industrial Association in December 2024, among 738 micro, small,
medium and big companies in Bulgaria. It shows that 47% of the respondents consider corruption as a
major barrier for businesses.
115
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 10
percentage points above the EU average.
116
Figure 59, 2025 EU Justice Scoreboard.
117
Country visit Bulgaria, NAO. NAO (2025).
118
NAO (2025). The total amount of fines amounts to over EUR 150 000.
119
See also Anti-Corruption Fund (2025e).
120
The 2014-2020 National Strategy for the development of the public procurement sector does not
include any anti-corruption measures and has not been followed up by a post-2020 strategy. The 2024
annual report of the Public Procurement Agency does not refer to the implementation of anti-corruption
measures.
121
Bulgarian Government (2025), written input.
122
Bulgarian Government (2025a), p. 40.
18
voting majority for electing a new chairperson, CEM was led by temporary acting heads
on a rotational basis123
. On 22 April 2025, a new chair was elected for a one-year term.
The 2025 Media Pluralism Monitor and other stakeholders noted risks of political
pressure or influence124
. The regulator indicated that its operations continue to be
hindered due to significant and systematic budgetary challenges, even in light of the
upcoming implementation of the European Media Freedom Act125
.
The draft law to strengthen independence of public service media was not adopted
and the Council for Electronic Media has not yet appointed a new Director-General
of the Bulgarian national television. There has been no progress in adopting the
envisaged revision of the law intended to define in more detail the public service remit
and the related financing which was planned to be presented in Parliament in 2024,
though a dedicated working group within the Ministry of Culture continues to pursue this
issue126
. While CEM elected a new Director-General of the Bulgarian national radio
(BNR) for a second three-year term in 2024, the election of a new Director-General of
the Bulgarian national television (BNT) was further delayed due to legal disputes on the
results of the 2022 competition, for which a final decision was issued by the Supreme
Administrative Court in June 2025127
. In line with the judgement ordering the re-launch
of the appointment procedure, the Government has committed to a permanent
appointment in compliance with national law128
. The current Director-General remains in
the position ad interim. Stakeholders continue to note that this situation contributes to
uncertainty and possibly undermines the independence of the broadcaster129
.
There are still shortcomings regarding the enforcement of media ownership
disclosure obligations despite the existence of several registers. In addition to the
CEM public register covering media ownership structures of radio and television
operators, the Ministry of Culture hosts a public register based on declarations made by
any media outlet of its beneficial ownership and the funding received from public funds,
political parties, etc130
. There are concerns that this regulatory framework is not
sufficiently enforced since, despite the lack of disclosure of ultimate owners by some
media companies, no fines as foreseen by the law have been imposed in 2024 despite
violations being reported by stakeholders131
. Another issue is the lack of disclosure of
ownership of websites that are not considered media outlets and therefore fall outside the
current scope of media law, reportedly spreading disinformation and propaganda
operating almost anonymously notwithstanding their increasing audience132
.
123
Country visit Bulgaria, CEM.
124
Certain members of the regulator indicated that they faced pressure as regards their activities by certain
politicians and political parties. 2025 MPM Report, p. 17-18; International Press Institute (2025),
written input, p. 12; Joint CSO contribution (2025), written input, pp. 17-18. See also 2024 Rule of Law
Report, Bulgaria, p. 26.
125
Country visit Bulgaria, CEM; CEM (2025), written input, p. 2.
126
2024 Rule of Law Report, Bulgaria, p. 29.
127
DeFakto (2025a).
128
Bulgarian Government (2025a), p. 46.
129
2024 Rule of Law Report, Bulgaria, p. 29. Country visit Bulgaria, Association of European Journalists
– Bulgaria, For the truth project, National Council for Journalistic Ethics.
130
Both registries are accessible online.
131
Country visit Bulgaria, Association of European Journalists – Bulgaria; National Council for
Journalistic Ethics; For the truth Project; Access to Information Programme, Media Democracy
Foundation.
132
Country visit Bulgaria, Media Democracy Foundation; 2025 MPM Report, p. 5, 10, 13, 26; RSF
(2025), written input, p. 12-13.
19
There has been some further progress on the recommendation regarding
transparency in the allocation of state advertising133
. The amendments to the Public
Procurement Act adopted in October 2023134
have improved transparency when
awarding state advertising to radio and television broadcasters and on-demand media
services135
. Still, those amendments do not apply to contracts below a certain threshold136
or contracts through intermediaries (media agencies). In addition, there is no compulsory
legal requirement for media advertising contracts to be concluded through public
procurement, and allocation of state advertising is not being annually monitored and
reported by a centralised authority137
. Moreover, concerns remain regarding the use of
state advertising as a means to buy influence, notably with regard to online media
receiving funding from political parties to cover election campaigns138
. Furthermore, as a
positive development in the specific remit of online platforms, the Ministry of Tourism
has been publishing on its website monthly reports for their spending on advertising on
these platforms139
. Some further progress has been made at improving transparency in the
allocation of state advertising.
Indications of political and economic influence over the media remain. The 2025
Media Pluralism Monitor notes that there has been no improvement in this context,
highlighting the existence of several party-affiliated audiovisual media in the country140
.
This view is shared by stakeholders who point to political influence in editorial policies,
notably in cases where privately owned media have ownership interests in other
regulated sectors, including due to the fact that some of the biggest companies are
internationally owned141
. A survey conducted at the end of 2024 also shows an increase
in political pressure, including on media advertising and particularly at local and regional
levels142
. The lack of regulation of online media and the purchase of local and regional
media by municipal administrations underpin the criticism of how public funds are used
to fund private media and further undermine the media market plurality, leading to
“media deserts”, particularly at the local level143
. There are still no specific provisions
governing cross-ownership of media companies or addressing media concentrations and
their impact on media pluralism or editorial independence144
.
Access to public information is improving, despite some continuing difficulties.
Improved budget and good practices in terms of financial transparency on public
institutions’ websites, updated internal rules on access to information and improved
133
The 2024 Rule of Law Report recommended Bulgaria to ‘[a]dvance with the work aimed at improving
transparency in the allocation of state advertising, in particular with regard to state advertising
contracted through intermediaries, such as media agencies’.
134
The amended law was published in the official journal No. 20 of 18 October 2023.
135
Country visit Bulgaria, Association of European Journalists – Bulgaria; National Council for
Journalistic Ethics; For the truth Project; Access to Information Programme; Media Democracy
Foundation.
136
BGN 10 000 [EUR 5 112]
137
2025 MPM Report, p. 29.
138
RSF (2025), written input, p. 12-13.
139
2025 MPM Report, p. 29. The obligation stems from Art. 6a(3) from the Tourism Act, as amended in
June 2023, and entered into force in 2024.
140
2025 MPM Report, p. 26
141
Country visit Bulgaria, the Media Democracy Foundation and ‘For the truth project’; RSF (2025-
online).
142
Association of European Journalists – Bulgaria (2024).
143
Country visit Bulgaria, journalists’ associations. The term “media desert” refers to a geographic area or
community that lacks access to local news and information.
144
2024 Rule of Law Report, Bulgaria, p. 28; International Press Institute (2025), written input, p. 13-14.
20
management of internal information systems have been reported by civil society145
.
However, administrative refusals by state institutions and selective engagement are still
reported by stakeholders, in spite of the Access to Public Information Act, with several
ongoing court cases filed due to such refusals146
.
Journalists are facing increasing challenges in their activities. Several reports147
indicate an increasing number of cases of threats to media professionals in 2024
compared to 2023, including by public and political actors, with most incidents having
taken place in public places during electoral periods. Since the 2024 Rule of Law Report,
two new alerts regarding physical attacks to the safety and integrity of journalists and to
their and harassment and intimidation were registered on the Council of Europe Platform
to promote the protection of journalism and safety of journalists148
. There were also six
alerts reported by the Media Freedom Rapid Response mechanism relating to physical
assaults and intimidation and harassment149
. As reported by stakeholders, the number of
lawsuits against journalists continues to increase, though most of the reported cases have
been decided against the plaintiffs150
. Due to the parliamentary elections in October 2024
and the establishment of a new Government in January 2025, the legal reform prepared
by the working group tasked with drafting legislative measures to introduce protections
against SLAPPs was delayed151
. Beyond lawsuits, stakeholders highlight an overall
worsening of verbal attacks against journalists in political discourse, targeting both
individual journalists and media service providers and including persistent online
harassment of journalists, as well as the rise in hate speech against women journalists and
fact-checkers152
. In December 2024, a political party submitted a draft law in Parliament
which would have the effect of restricting the possibility for journalists of receiving
funding from foreign sources153
. The draft law was dismissed by Parliament on 5
February 2025. Following legislative reforms to the Criminal Code concerning insult and
defamation in 2023, a legislative proposal for lower penalties for defamation has been
submitted by the Council of Ministers to the National Assembly for adoption154
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
The Constitutional Court reviewed the election results in several polling stations.
After the October 2024 parliamentary elections, a group of members of Parliament seized
the Constitutional Court to review the election results in several polling stations,
following concerns that voter fraud has occurred, and to recount the votes in case
irregularities were found155
. In its judgment of 14 March 2025, the Constitutional Court
145
Access to Information Program (2024).
146
Country visit Bulgaria, Media Democracy Foundation; 2025 MPM Report, p. 15.
147
RSF (2025), written input, p. 13-14; 2025 MPM Report, p. 16.
148
Council of Europe Platform to promote the protection of journalism and safety of journalism (2024-
2025). Bulgaria has replied to one of those two alerts, notably the one relating to attacks on physical
safety and integrity of journalists.
149
European Centre for Press and Media Freedom, Media Freedom Rapid Response – Bulgaria (2024).
150
Several examples provided by Media Democracy Foundation. RSF (2025), written input, p. 14.
Association of European Journalists – Bulgaria (2024), p. 41-44.
151
2024 Rule of Law Report, Bulgaria, p. 29-30; RSF (2025), written input, p. 14.
152
2025 MPM Report, p. 16-17.
153
Country visit Bulgaria, journalists’ associations.
154
Decision No. 347 of the Council of Ministers on 2 June 2025.
155
Constitutional Court, Decision No. 1 of 13 March 2025. See also Joint CSO contribution (2025),
written input, pp. 24-26. In March 2025, the President of the Constitutional Court complained that the
opening of an enquiry by the Prosecutor’s Office and a request for the Court to provide documents
21
found that the election of 16 members of Parliament was illegal156
. This led to a
recalculation of the seats and the parties represented in Parliament.
Some independent and regulatory authorities continue to operate with an expired
mandate and the Government has now relaunched the renewal procedures. Since
the new Government was appointed on 16 January 2025157
, it has launched the
procedures for the renewal of mandates of several independent and regulatory authorities,
including the positions of Ombudsperson and Deputy Ombudsperson that have been
vacant since January 2024158
. The appointment of four authorities was completed159
.
However, there is still a significant number of authorities working on an expired
mandate160
. Concerns have been raised as to the increased potential risk that the lack of
secure tenure accentuates the potential political influence over decisions of some of these
authorities161
. Moreover, the Constitutional Court judgment of 26 July 2024 declared
incompatible with the Constitution the provision declaring that Parliament respects the
principles of openness, transparency, publicity, and justification in the selection of the
members of the bodies that are wholly or partially elected by it, in order to guarantee
their independence162
. In 2024, the Commission noted that the political crisis in the
country showed vulnerabilities with the way independent and regulatory authorities are
appointed163
.
The constitutional amendments limiting the powers of the President in the
procedure of appointing an interim government is subject to another
amounted to unjustified pressure on the Court. Stakeholders voiced concern on the grounds of respect
for the separation of powers.
156
Constitutional Court, Decision No. 1 of 13 March 2025.
157
In October 2024, Bulgaria held its seventh parliamentary election since April 2021, following which a
government was formed by three main parties represented in Parliament, supported by two others
without seats in it.
158
Ombudsperson; Commission for Personal Data Protection; National Competition Authority; National
Social Security Institute.
159
Financial Supervision Committee; National Social Security; Bulgarian Fiscal Council; Energy and
Water Regulatory Commission.
160
As of 15 April 2025, these are: Supreme Judicial Council and the Inspectorate to it; Commission for
Public Oversight of Statutory Auditors; Committee for disclosing the documents of the State Security
and intelligence services of the Army; Commission for Protection against Discrimination; Public
Enterprises and Control Agency; National Council of the Bulgarians living abroad. There are also
authorities for which the mandate was prematurely terminated or have been reformed: Anti-corruption
Commission, and Commission for Illegal Assets Forfeiture; National Bureau for Control over Special
Intelligence Means. In the context of a preliminary ruling request, the Court of Justice ruled that the
principle of judicial independence precludes a practice in which a judicial body, such as the ISJC, is
working beyond the expiry of its mandate without an express legal basis for this, and without this
extension of mandate being limited in time. CJEU, Judgment of 30 April 2025, Inspektorat kam Visshia
sadeben savet, Joined Cases C-313/23, C-316/23 and C-332/23, EU:C:2025:303, points 81-97.
161
For some authorities, there could be potential risk of institutions being more likely to take decisions in
line with the predicted position of the authorities responsible for renewing their mandates given the
threat of sudden termination of the already expired mandate. See 2024 Rule of Law Report, Bulgaria,
pp. 31-32. In addition to the example of last report on the National Audit Office, the dismissal of the
National Social Security by the Parliament was also declared unconstitutional. See Constitutional
Court, Decision No. 5 of 24 September 2024.
162
The Court considered that the wording of the provision created a double regime for the election of
bodies whose appointment procedure is outlined in the Constitution (such as the Supreme Judicial
Council and the Inspectorate to it).
163
See 2024 European Semester, Bulgaria (Country report), p. 15 and 18; (Country Specific
Recommendations) number 2 on page 10. See also Bulgarian Institute for Legal Initiatives (2025),
“How (In)dependent Institutions Work - Structural and functional analysis of public bodies elected by
the National Assembly”.
22
constitutionality check. The constitutionality of the 2023 reform, which restricted the
choice of the President of the Republic when appointing an interim government was
among the provisions on which the Constitutional Court judgment of 26 July 2024 could
not reach a conclusion164
. Following the October 2024 parliamentary elections and the
new appointment of a judge to the Constitutional Court, a group of members of
Parliament requested a new constitutionality check of this reform165
. There has not yet
been a decision.
Problems over the practical implementation of rules for law-making continue, and
concerns regarding the quality of the legislative process persist. As previously
reported166
, improved rules for law-making in Parliament have been adopted and
continue to be in place167
. However, the practical implementation of these rules continues
to raise some concerns168
. Since the majority of legislative amendments have been
proposed directly by members of Parliament169
, these do not go through the same
mandatory procedure as for government initiatives, including as regards impact
assessment and public consultations170
. In that context, stakeholders continued to express
criticism that the impact assessment and public consultations carried out by the members
of Parliament are often done pro forma171
. As regards the public consultations, according
to a study prepared by Parliament, in 94% of the draft laws there is no information about
public consultations or discussions organised to determine the problems and reasons
necessitating the adoption of the draft law. In 94.2% of the draft laws, the arguments and
different points of view of the stakeholders were not included, and in 65% there was no
analysis on the compatibility of the draft laws with EU law172
. Stakeholders also reported
that the practice of introducing legislative changes through amendments to other,
unrelated, acts between the first and the second reading has been used again, although
sporadically173
. Frequent changes to the legislation have been flagged as one of the key
barriers for businesses174
.
Less than half of the companies surveyed in Bulgaria express high levels of
confidence in the effectiveness of investment protection. 41% of companies are very
164
Constitutional Court Decision No. 13 of 26 July 2024.
165
Constitutional Court Case No. 40 of 2024.
166
Milestone 241 under the RRP.
167
See 2024 Rule of Law Report, Bulgaria, p. 33.
168
Country visit, Bulgaria, Bulgarian Centre for Not-for-Profit Law, Deystvie, Amnesty International –
Bulgaria, Bulgarian Helsinki Committee. See also Joint CSO contribution (2025), written input, pp. 22-
23.
169
About 78% of the drafts were tabled by members of Parliament. See National Assembly. Study of the
law-making activity of the National Assembly (November 2024 – February 2025), p. 7.
170
The Rules of Procedure of Parliament state that draft laws tabled both by members of Parliament and
by the government shall be subject to preliminary impact assessments. However, the preliminary
impact assessments of the government need to comply with higher standards, as set out by the Law on
the Normative Acts and the relevant secondary legislation.
171
Country visit, Bulgaria, Bulgarian Centre for Not-for-Profit Law, Deystvie, Amnesty International –
Bulgaria, Bulgarian Helsinki Committee.
172
See National Assembly. Study of the law-making activity of the National Assembly (November 2024 –
February 2025), pp 36-40.
173
This practice allows to circumvent the requirement for public consultations and public discussions. This
is especially true for the changes made in the final and transitional provisions. Country visit, Bulgaria,
Bulgarian Centre for Not-for-profit Law, Open Society Institute, Bulgarian Helsinki Committee,
Deystvie, Bulgarian Institute For Legal Initiatives And Institute For Market Economics.
174
Survey conducted by the Bulgarian Industrial Association in December 2024, among 738 micro, small,
medium and big companies in Bulgaria. It shows that 47% of the respondents consider the frequent
changes to the legislation as a major barrier for businesses.
23
or fairly confident that investments are protected by law and courts175
. The main reasons
among companies for their lack of confidence are the difficulty to challenge
administrative decisions in court (34%) and the concerns about the quality of the law-
making process and the quality (30%), efficiency or independence of justice (34%)176
.
Moreover, only 34% perceive the level of independence of the national competition
authority (Commission on Protection of Competition) as very or fairly good177
. A
number of judicial mechanisms are in place at the level of the Supreme Administrative
Court to ensure the implementation of administrative court judgments, which include
fines for responsible officials for non-compliance. However, these mechanisms do not
include the possibility to quash administrative decisions for continued non-compliance
with court’s instructions, to issue binding orders to the administration to perform or
refrain from administrative acts, or to award direct or consequential damages or
compensation178
.
On 1 January 2025, Bulgaria had 89 leading judgments of the European Court of
Human Rights pending implementation, the same number as the previous year179.
At that time, Bulgaria’s rate of leading judgments from the past 10 years that had been
implemented was at 46% (compared to 47% in 2024; 54% remained pending), and the
average time that the judgments had been pending implementation was 7 years and 3
months (compared to 6 years and 9 months in 2024)180
. The oldest leading judgment,
pending implementation for 20 years, concerns the poor conditions of detention in
remand facilities and prisons, and the lack of an effective remedy to complain about such
conditions. Nonetheless, it is noted that in 2024, the Committee of Ministers
acknowledged the significant progress achieved by the State in this judgment181
. As
regards the respect of payment deadlines, on 31 December 2024 there were 9 cases in
total awaiting confirmation of payments (compared to 13 in 2023)182
. On 16 June 2025,
the number of leading judgments pending implementation had increased to 92183
.
The members of the Council for Civil Society Development are being renewed. After
the new Government took office on 16 January 2025, the Council for Civil Society
Development was able to resume its work. However, since the mandate of its members
175
Figure 54, 2025 EU Justice Scoreboard.
176
Figure 55, 2025 EU Justice Scoreboard. 30% of the surveyed investors perceive the frequent changes in
legislation or concerns about quality of law-making process as a reason for the lack of confidence in
investment protection.
177
Figure 60, 2025 EU Justice Scoreboard.
178
Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in
place at the level of the highest administrative jurisdictions; the same or other mechanisms may be in
place at lower instance administrative courts.
179
For an explanation of the supervision process, see the website of the Council of Europe.
180
All figures calculated by the European Implementation Network (EIN) and based on the number of
cases that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written
input, p. 2.
181
Judgment of the ECtHR, 41035/98, Kehayov v. Bulgaria, pending implementation since 2005. The
Committee noted that the authorities have adopted in recent years numerous measures, which have
enabled the almost complete eradication of overcrowding, even though the overall capacity of the
prisons and prison hostels has decreased, and have allowed significant improvement in the material
conditions of detention. The Committee decided to continue the supervision of the remaining questions
regarding overcrowding, outdoors activities for persons detained in Investigation Detention Facilities
and further improvement of material conditions of detention in the context of the Kehayov case under
the standard supervision procedure. See also a case on the freedom of assembly and association,
judgment of the ECtHR, 59491/00, UMO and others v. Bulgaria pending implementation since 2006.
182
Council of Europe (2025), p. 156.
183
Data according to the online database of the Council of Europe (HUDOC).
24
expired, on 28 March 2025, the Government started a procedure for the selection of new
members184
. The draft decision on the renewal of the Council is currently being assessed
at interdepartmental level, following which the decision can be adopted by the
Government. Once the decision adopted, the Council will start its activities. The
Council’s main tasks are to conduct an annual review of the needs and challenges faced
by civil society organisations; to monitor the implementation of the civil society strategy;
and to develop a national funding mechanism for civil society. However, to date, no such
reviews have been published or conducted by the Council; no civil society strategy is
currently in place, as the last one expired in 2015; and the work on developing the
national funding mechanism was not finalised185
. In response to this, civil society
organisations have called for action, including advocating for amendments to the
Council’s rules of procedure to ensure its continuity and effective functioning. Currently,
there is cooperation and dialogue between the Secretariat of the Civil Society
Development Council and the civic sector. Amendments to the Rules of Procedure for
the Organisation and Activities of the Council are being prepared, in order to adapt them
to the Law on Non-Profit Legal Entities, ensuring its continuity and effective
functioning.
Attempts to reintroduce legislation requiring the registration of organisations
receiving foreign funding were again dismissed by Parliament. Civic space in
Bulgaria continues to be rated as narrowed186
. Another draft law for the registration of
‘foreign agents’ was resubmitted to Parliament by members of Parliament on 11
November 2024. The previous drafts that were tabled in recent past legislatures have
either been dismissed or have lapsed due to the end of the Parliament’s mandate187
.
Shortly after the new Government took office, on 5 February 2025, the new draft law was
discussed in Parliament, where it was dismissed following a vote. Stakeholders expressed
concerns that some of the aspects of the controversial draft foreign agents act could be
tabled again or introduced through another legal act188
. Some stakeholders report that a
law adopted in 2024 prohibiting acts related to ‘propaganda for non-traditional sexual
orientation’ in schools and in their vicinity189
has had the effect of schools and teachers
not engaging with CSOs working in the field of LGBTIQ rights, including on topics such
as health190
.
184
Country visit, Bulgaria, Bulgarian Center for not-for-profit law. Since their first meeting in March 2022
and until February 2025, the Council met 19 times.
185
See also Joint CSO contribution (2025), written input, pp. 26-27
186
See rating given by CIVICUS, Bulgaria. Ratings are on a five-category scale defined as: open,
narrowed, obstructed, repressed and closed.
187
Since 2020, there have been five draft laws for the registration of foreign agents that have been tabled
in Parliament. Three of them have lapsed due to the dissolution of the Parliament and subsequent snap
elections, and two in 2023 and 2025 have been dismissed by the Parliament.
188
Country visit, Bulgaria, Bulgarian Institute for Legal Initiatives, Institute for Market Economics,
Bulgarian Helsinki Committee, Bulgarian Centre for not-for-profit law, Deystvie, Amnesty
International – Bulgaria. See also Joint CSO contribution (2025), written input, pp. 23-24. It should be
noted that the National Assembly Rules of Procedure provide that a draft law rejected at first reading
can be submitted for debate and voting only following fundamental revision and no earlier than three
months after the initial procedure.
189
See Law for the amendment and supplement of the law on pre-school and school education, adopted on
7 August 2024.
190
Country visit, Bulgaria, Bulgarian Institute for Legal Initiatives, Institute for Market Economics,
Bulgarian Helsinki Committee, Bulgarian Centre for not-for-profit law, Deystvie, Amnesty
International – Bulgaria. See also Joint CSO contribution (2025), written input, pp. 24-26. Civil Society
Europe (2025), written input, p. 10. See also Civil Liberties Union for Europe (2025), written input, pp.
168-170.
25
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2025 Rule of Law
report can be found at https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en
24chasa (2025), Was the mother of European prosecutor Teodora Georgieva murdered?, 24
February 2025, link
Access to Information Program (2024), The State of Access to Information in Bulgaria
(СЪСТОЯНИЕТО НА ДОСТЪПА ДО ИНФОРМАЦИЯ В БЪЛГАРИЯ), aip-2024.pdf.
Anti-Corruption Commission (2025), 2024 Annual Activity Report.
Anti-Corruption Fund (2021), Quick Checklist: The Story of Veselin Denkov and Specialised
Justice, https://acf.bg/bg/spisak-za-barz-kontrol-istoriyata-na-ve/
Anti-Corruption Fund (2025a), ACF Reports to EPPO and CINEA the Latest Questionable
Public Procurement for Chiren Underground Gas Storage, https://acf.bg/en/akf-signalizira-
evropeyskata-prokur/
Anti-Corruption Fund (2025b), ACF Reveals Scandalous Appointments of Persons Linked to
Political Parties in State-Owned Bulgartransgaz, https://acf.bg/en/akf-razkri-skandalni-
naznacheniya-na-po/
Anti-Corruption Fund (2025c), Another Questionable Tender Procedure for Chiren Underground
Gas Storage, https://acf.bg/en/bulgartransgaz-s-nova-samnitelna/
Anti-Corruption Fund (2025d), First Hearing of the Defamation Lawsuit Against Nikolay
Nedelkov, the Metropolitan Inspectorate Director Who Reported Sofia’s 240 Unregulated
Dumpsites, https://acf.bg/en/dnes-e-parvoto-zasedanie-po-delo-za-kle/
Anti-Corruption Fund (2025e), New ACF Investigation Exposes Suspected Large-Scale
Corruption Scheme within the Road Infrastructure Agency, https://acf.bg/en/razsledvane-na-akf-
razkriva-koruptsio/
Anti-Corruption Fund (2025f), Mr. Grass Head’s Holding Company: ACF Reveals Best-Kept
Secret of Bulgaria’s Energy Sector, https://acf.bg/en/holdingat-na-chichko-trevichko-razsl/.
Association of European Journalists – Bulgaria (2024), Bi-annual Survey on Press Freedom in
Bulgaria, Survey-on-Press-Freedom-2024.pdf.
Association of Prosecutors in Bulgaria (2025), Opinion of the Board of the Association of
Prosecutors in Bulgaria on the Charges Against a Prosecutor from the Sofia City Prosecutor's
Office, 30 January 2025, https://prokurori.bg/index.php/news/show/stanovishte-na-us-na-
asotsiatsiyata-na-pRokuRoRite-v-balgaRiya-po-povod-obvineniya-sReshtu.html
Bulgarian Government (2024), Input from Bulgaria for the 2025 Rule of Law Report.
Bulgarian Government (2024a), Input from Bulgaria for the 2025 Rule of Law Report, second
batch.
Bulgarian Industrial Association (2024), 2024 Through the eyes of the business,
https://www.bia-bg.com/uploads/gallery/-
%20ANKETI/Anketa_2024/ANKETA_2024.pdf
26
Bulgarian Institute for Legal Initiatives (2025), “How (In)dependent Institutions Work -
Structural and functional analysis of public bodies elected by the National Assembly”,
https://bili-bg.org/cdir/bili-
bg.org/files/2025_Как_работят_(не)зависимите_институции_WEB.pdf
Bulgarian Institute for Legal Initiatives (2025), “Where does the justice system go from here?”,
https://bili-bg.org/cdir/bili-bg.org/files/Оттук_накъде_със_съдебната_власт.pdf
Bulgarian Judges Association (2025), Appeal to the Judge’s Chamber of the Supreme Judicial
Council, 30 January 2025, https://judgesbg.org/2025/01/30/относно-сигнала-на-съдия-
мирослав-пет/
Bulgarian Judges Association and Foundation “Friedrich Naumann Foundation - for Freedom”
(2024), Seminar “Possibilities For External Control/Counterweight In The Implementation Of
The Prosecutorial Function – Historical Experience In Bulgaria And Decisions In Other
European Legal Systems”, https://judgesbg.org/2025/02/03/публична-дискусия-възможности-
за-вън/
Bulgarian National Assembly (2024), Committee meeting of 30 April 2024,
https://www.parliament.bg/bg/parliamentarycommittees/3350/steno/8051
Bulgarian National Assembly (2025), Study of the law-making activity of the National Assembly
(November 2024 – February 2025), https://www.parliament.bg/bg/ncpi
Bulgarian News Agency (2024), EPPO Investigation of Bulgartransgaz Related to Expansion of
Chiren Underground Gas Storage, CEO Says, 14.08.2024,
https://www.bta.bg/en/news/bulgaria/725622-eppo-investigation-of-bulgartransgaz-related-to-
expansion-of-chiren-underground-
Capital (2025), European Prosecutor Teodora Georgieva: public procurement us a well-
established scheme for draining funds, 28 February 2025,
https://www.capital.bg/politika_i_ikonomika/pravo/2025/02/28/4748542_teodora_georgieva_obs
htestvenite_poruchki_sa/
Centre for Regulatory Impact Assessment (2024), Eight years regulatory reform in Bulgaria,
https://ria.bg/?p=935
Center for the Study of Democracy (2025), Contribution for the 2025 Rule of Law Report.
Centre for Media Pluralism and Media Freedom (2025), Media pluralism monitor 2025.
CEPEJ (2023), Study on the functioning of the judicial systems in the EU Member States.
Civicus, Monitor tracking civic space – Bulgaria https://monitor.civicus.org/country/bulgaria/
Civil Liberties Europe (2025), Liberties Rule of Law Report 2025 Bulgaria
Civil Society Europe (2025), Joint Civil Society Contribution on Civic Space to the 2025 Annual
Rule of Law Report.
Civil Society Organisations (2025), written joint contribution to the 2025 of Law Report (Access
to Public Information Programme, Anticorruption Fund Foundation, Association of European
Journalists, Bulgaria Bulgarian Center for Not-for-profit Law, Bulgarian Donors Forum,
Bulgarian Helsinki Committee, Bulgarian Institute for Legal Initiatives, Center for the Study of
Democracy Deystvie organization, GLAS Foundation, Institute for Public Environment
Development, Institute for Market Economics).
27
Constitutional Court Case No. 40 of 21 November 2024
Constitutional Court Case No. 5 of 8 April 2025.
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30
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Annex II: Country visit to Bulgaria
The Commission services held virtual meetings in March 2025 with:
• Access to Information Programme
• Amnesty International - Bulgaria
• Anti-Corruption Council
• Anti-corruption Fund Foundation
• Association of Bulgarian Radio and TV Operators
• Association of European Journalists – Bulgaria
• Association of Prosecutors in Bulgaria
• Audio-Visual regulator – Council for Electronic Media
• Bulgarian center for not-for-profit law
• Bulgarian Helsinki Committee
• Bulgarian Industrial Association
• Bulgarian Institute for Legal Initiatives
• Bulgarian Judges Association
• Centre for the Study of Democracy
• Commission for countering corruption
• Commission for forfeiture of illegally acquired assets
• Constitutional court
• Deystvie
• For the truth project
• Inspectorate to the Supreme Judicial Council
• Internal Security Directorate – Ministry of Interior
• Institute for Market Economics
• Justice for All Initiative
• Ministry of Culture
• Ministry of Interior
• Ministry of Justice
• National Audit Office
• National Council for Journalistic Ethics
• Office of the Prosecutor General
• Open Society Institute
• Public service media – Bulgarian National Radio
• Supreme Administrative Court
• Supreme Bar Council
• Supreme Court of Cassation
• Supreme Judicial Council
• Transparency International - Bulgaria
* The Commission also met the following organisations in a number of horizontal
meetings:
• Amnesty International
• Araminta
• Civil Liberties Union for Europe
• Civil Society Europe
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• European Civic Forum
• European Partnership for Democracy
• European Youth Forum,
• International Commission of Jurists
• International Federation for Human Rights (FIDH)
• JEF Europe
• Philea – Philanthropy Europe Association.
• Transparency International