EUROPEAN COMMISSION Luxembourg, 13.7.2022 SWD(2022) 502 final COMMISSION STAFF WORKING DOCUMENT 2022 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 2022 Rule of Law Report

















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Abstract Reforms in Bulgaria in the area of justice and anti-corruption were first followed by the Commission under the Cooperation and Verification Mechanism (CVM) and are currently monitored under the Rule of Law Mechanism. The Government has committed, in the context of the Bulgarian Recovery and Resilience Plan, to establish an effective mechanism for the accountability and criminal liability of the Prosecutor General and his/her deputies, as well as a judicial review of prosecutorial decisions not to open an investigation. This would address longstanding concerns referred in the previous editions of the Rule of Law Report and in the CVM. There are increasing concerns related to the functioning of the Supreme Judicial Council and the need to address its composition is all the more important. Concerns related to the Inspectorate to the Supreme Judicial Council remain. The absence of regular competition for the promotion of magistrates, combined with an extensive use of secondments, risks to affect the independence of magistrates. A legislative reform has abolished the specialised judicial authorities, while providing for the reappointment of the relevant magistrates to ordinary courts and prosecution offices, with safeguards to protect judicial independence and procedural rights. Challenges remain in the area of digitalisation of justice. Administrative justice continues to perform well in terms of efficiency. The Anti-Corruption Commission has continued to perform its activities, with envisaged reforms aiming at restructuring it to improve its capacity towards investigation of corruption cases. A solid track-record of final convictions in high-level cases of corruption is still lacking. The National Strategy for Prevention and Countering Corruption, as well as the general provisions for the integrity of the public administration continue to be implemented, including provisions for specific sectors and a mechanism for the declaration and verification of assets. Lobbying and protection of whistleblowers are still not properly regulated, although there are plans to address that. Sector-specific corruption risks such as management of budget funds and control activities, including procurement were identified during the COVID-19 pandemic. As regards media freedom and pluralism, the legal framework, based on a set of constitutional safeguards and legislative measures, guarantees freedom of expression and editorial independence. The lack of a clear regulatory framework to ensure transparency in the allocation of state advertising remains a concern, despite some measures having been taken to improve transparency. As regards media ownership transparency, reflections are ongoing about a more effective enforcement of media ownership obligations. Legal safeguards exist regarding the independence of public service media, but appear to be insufficient; a revision of the law is being considered in order to strengthen the independence of public service media and define in more detail the public service remit and the related financing. The professional environment of journalists has slightly improved since the last year but issues such as access to public information, working conditions and strategic lawsuits, remain. The establishment of a Post-monitoring Mechanism to accompany future CVM related reform is progressing well after a decision of the Supreme Administrative Court. New rules have been adopted by the Parliament to improve the law-making process. The emergency regime related to the COVID-19 pandemic has ended. A Council for Civil Society Development has been set up with the objective of assisting civil society, which will include drafting and implementation of policies covering Civil Society Organisations themselves.

Recommendations In addition to recalling the commitments made under the national Recovery and Resilience Plan relating to certain aspects of the justice system and the anti-corruption framework and the remaining commitments under the Cooperation and Verification Mechanism, it is recommended to Bulgaria to: ·Ensure timely ordinary competitions for promotion to avoid long-term secondment of judges to fill in vacant positions, taking into account European standards on secondment of judges. ·Advance with the 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. ·Take steps to adapt the composition of the Supreme Judicial Council, taking into account European standards on Councils for the Judiciary. ·Continue the implementation of measures to improve the integrity of the specific sectors of the public administration, including measures tailored to the police and the judiciary. ·Ensure that the institutional reforms of the Anti-Corruption Commission and the specialised judicial authorities lead to an improved effectiveness of investigations and a robust track-record of prosecution and final judgments in high-level corruption cases. ·Improve transparency in the allocation of state advertising, in particular with regard to state advertising contracted through intermediaries, such as media agencies.



The Cooperation and Verification Mechanism (CVM) was established at the accession to the European Union in 2007 as a transitional measure to facilitate Bulgaria’s continued efforts to reform its judiciary and step up the fight against corruption and organised crime . In line with the decision setting up the mechanism and as underlined by the Council, the CVM ends when all the benchmarks applying to Bulgaria are satisfactorily met . The Commission’s latest CVM report, adopted in October 2019, recorded that Bulgaria had made a number of further commitments and concluded that the progress made under the CVM was sufficient to meet Bulgaria’s commitments made at the time of its accession to the EU. As the Commission also underlined, Bulgaria will need to continue working consistently on translating the commitments specified in the report into concrete legislation and on continued implementation. Said implementation continues to be monitored in the context of the Rule of Law Mechanism, and more concretely, in the Commission’s annual Rule of Law Report. I.Justice System The judicial system of the Republic of Bulgaria includes a total number of 182 courts which are ordinary and specialised. As a general rule, the ordinary courts hear cases in three instances, with the system of these courts comprising 113 district courts, 28 regional courts and 5 courts of appeal. The specialised courts include military and administrative courts. The Supreme Court of Cassation is the court of last instance in cases heard by ordinary and military courts, while for administrative cases, the Supreme Administrative Court is the court of last instance. The judiciary also includes the Prosecutor’s Office. The Constitutional Court of Bulgaria reviews constitutionality of laws and gives interpretative decisions . The Prosecutor’s Office has a unified structure and is headed by the Prosecutor General . Bulgaria participates in the European Public Prosecutor’s Office. The Supreme Judicial Council (SJC) is the highest administrative authority in the Bulgarian judiciary. It is responsible for managing the judiciary and ensuring its independence. Judges, prosecutors and investigators are appointed, promoted, transferred and dismissed by their respective chamber (Judges’ or Prosecutors’) of the SJC . In addition to the SJC, activities of magistrates are supervised by the Inspectorate. The Supreme Bar Council is an independent and self-governing body established by law . Independence

The level of perceived judicial independence in Bulgaria continues to be low among the general public and is now very low among companies. Overall, 31% of the general population and 28% of companies perceive the level of independence of courts and judges to be ‘fairly or very good’ in 2022 . According to data in the 2022 EU Justice Scoreboard, the perceived judicial independence among both the general public and companies has consistently decreased in the last years, although it remains higher than in 2016 (23% for the general public and 21% for companies). Both figures have decreased in comparison to 2021 (32% for the general public and 43% for companies). Provisions for an effective accountability and criminal liability mechanism for the Prosecutor General and his/her deputies are planned within the framework of the Recovery and Resilience Plan (RRP) related reforms. The lack of a possibility for an effective criminal investigation of the Prosecutor General and his/her deputies has been a long-standing issue, which was raised not only by the European Commission but also by the European Court of Human Rights and the Council of Europe . As pointed out in previous reports, the combination of the powers held by the Prosecutor General and his/her position in the Supreme Judicial Council result in a considerable influence within the Prosecutor’s Office as well as potentially within the Supreme Judicial Council (both in its Prosecutorial Chamber and its Plenary) and within the magistracy . On 14 October 2021, Bulgaria submitted its RRP to the Commission. The European Commission adopted a positive assessment of Bulgaria’s RRP on 7 April 2022. On 3 May 2022, the Council adopted the implementing decisions on the approval of the plan. As part of the rule of law-related reforms in the plan, the authorities committed to introduce an effective mechanism for the accountability and criminal liability of the Prosecutor General and his/her deputies. The mechanism would include guarantees for the independent character of the investigation, including by introducing measures that would allow the suspension of the Prosecutor General and his/her deputies in the event of criminal proceedings against them, as well as including the selection by the Supreme Judicial Council of a judge appointed to the position of prosecutor acting as an investigating magistrate. The envisaged reform would also include safeguards to ensure the career stability and independence of that judge in accordance with the decisions of the Committee of Ministers of the Council of Europe and the opinions of the Venice Commission. Furthermore, the Bulgarian Government committed to cooperate with the Human Rights Directorate of the Council of Europe and to consult the Venice Commission of the Council of Europe on the draft amendments prior to their submission to the National Assembly. In addition, in view of limiting the potential influence of the Prosecutor General within the Supreme Judicial Council, the Government has also committed to exclude the representatives of the prosecution and and investigation services from being nominated as members elected by the Parliament to the Council. Finally, as regards the increased accountability of the Prosecutor General, the Government has committed in the RRP to set up procedures for hearings of the Prosecutor General, as well as annual reporting obligations on corruption related matters. The Constitutional Court confirmed the right of the Minister of Justice to request to the Supreme Judicial Council the early termination of the mandate of the Prosecutor General. On 8 February 2022, the Constitutional Court declared constitutional the possibility for the Minister of Justice to ask for the early termination of the mandate of the Prosecutor General (and also of the Presidents of the Supreme Court of Cassation and the Supreme Administrative Court). On 22 July 2021, the interim Minister of Justice filed a request to the Supreme Judicial Council for the dismissal of the Prosecutor General. The Plenary of the Supreme Judicial Council voted the request of the Minister as inadmissable and considered that the Minister did not have the power to file such a request. Following this, the Minister of Justice challenged the decision of the Supreme Judicial Council before the Supreme Administrative Court and requested clarifications from the Constitutional Court on the powers of the Minister of Justice to request the early dismissal of the Prosecutor General. The Constitutional Court confirmed that the Minister of Justice has such power to request the early dismissal of the Prosecutor General. On 2 March 2022, the new Minister of Justice filed a new request for the dismissal of the Prosecutor General. The introduction of judicial review against decisions of prosecutors not to open an investigation is envisaged. In the adopted RRP, the Government has committed to introduce a mechanism for judicial review of any decisions of prosecutors not to open an investigation. As noted in the 2021 Rule of Law Report, this is a long-standing concern and the envisaged measures would address the recommendations from the Council of Europe. On 2 December 2021, the Committee of Ministers of the Council of Europe reiterated the recommendation but also welcomed that the authorities committed under the RRP to work together with the Council of Europe in order to develop the legislation for this mechanism. In addition, arrangements would be made to avoid an excessive additional workload for courts and prosecutors. The reform is expected to be adopted by mid-2023. Concerns over the functioning and composition of the Supreme Judicial Council have increased, also in the context of disciplinary proceedings. The situation mentioned in the 2020 and 2021 Rule of Law Reports, with the judges elected by their peers not forming a majority in the Supreme Judicial Council (SJC), remains unchanged . Since 1 July 2021, the concerns have increased as the SJC functions with only four peer-elected judges due to the resignation of two peer-elected members. The same voting practice of the Plenary of the Supreme Judicial Council presented in the previous report continues to underline the decisive role of the Prosecutor General in the SJC . The concerns regarding the composition and functioning of the SJC have been reiterated by the European Parliament’s ad-hoc delegation to Bulgaria, the Council of Europe , the UN Universal Periodic Review and various stakeholders . In addition, similar concerns over the functioning of the SJC have arisen in the context of disciplinary proceedings. On 19 October 2021, the European Court of Human Rigths issued a decision regarding disciplinary proceedings against a judge before the SJC. While the Court confirms that the disciplinary proceedings before the SJC comprised a number of procedural guarantees, it considered that the disciplinary proceedings conducted by the SJC and the sanctions imposed had amounted to an interference with the exercise of the magistrate’s right to freedom of expression which had not been “necessary in a democratic society” for pursuing legitimate aims set out in Article 10 of the Convention. In addition, in 2021, the Supreme Administrative Court annulled several decisions of the SJC imposing disciplinary sanctions on judges or prosecutors for insufficient reasoning or procedural irregularities. Addressing the issue of the SJC’s composition by aligning it to European standards, is all the more important in view of the forthcoming end of the current mandates of SJC members. Concerns remain regarding political influence and the functioning of the Inspectorate to the Supreme Judicial Council (ISJC). As mentioned in previous Rule of Law Reports, currently the Inspectorate oversees the activity of the judiciary, assesses the integrity and potential conflicts of interest of magistrates, and is responsible for proposing any opening of disciplinary proceedings regarding magistrates to the SJC. The ISJC consists of an Inspector General and ten inspectors, who are independent and elected by the National Assembly . The working group that was set up in December 2020 and tasked with addressing concerns regarding the risk of political influence on the Inspectorate has finalised its work, identifying two groups of proposals for legislative amendments. One, needing further work within the framework of the current working group. The other, would require a longer period for implementation, which is why, no amendement has been tabled in Parliament alleviating these concerns. These concerns are aggravated by the fact that the Inspectorate is still working on the basis of an expired mandate. In February 2022, the Ministry of Justice asked representatives of the judiciary, professional legal organisations, as well as the academic legal community to submit proposals regarding the optimisation of the organisation and activities of the SJC and the ISJC in the context of the established European and international standards for the activities of these types of bodies. The Plenary of the Supreme Administrative Court made a request to the Constitutional Court concerning the interpretation of the constitutional provisions regarding the ISJC. That request was declared admissible on 17 May 2022 and is now pending. The absence of regular competitions for the promotion of magistrates, combined with an extensive use of secondments, continue to raise serious concerns. As underlined in the 2021 Rule of Law Report, while magistrates may be promoted only through a competition, in practice only one competition for the promotion of judges has been completed in the last four years. The absence of regular competitions has resulted in an extensive use of secondments. European standards highlight that promotions should be based on merit and secondments should happen with consent and on a temporary basis, and only in exceptional circumstances . A widespread use of secondments may negatively impact on seconded magistrates, if they are faced with the risk of a termination of their secondment against their will; this increases the power of the administrative heads if they are competent to decide on secondments and their termination, which may create situations of dependence. The lack of regular merit-based promotions combined with an extensive use of secondments therefore risks to affect judicial independence. Some practices have been developed within the judiciary to circumscribe the powers of the administrative heads in this respect, but only regular and timely competitions based on merit would effectively avert the abovementioned risk. Legislative amendments have been introduced to put an end to the special promotion regime for magistrates in the Inspectorate to the Supreme Judicial Council and the Supreme Judical Council. As to the automatic promotion of magistrates described in the 2020 Rule of Law Report , on 14 April 2022 the same law adopted for the closure of the specialised judicial authorities amending the Judicial System Act also removed the specific promotion mechanism for SJC and ISJC members by ending the possibility for these members to be reinstated at the end of their term of office in a higher position as judge, prosecutor or investigator than that held before the election . Furthermore, concerns related to the automatic promotion of judges within the envisaged judicial map reform did not materialise in a draft law. The Supreme Judicial Council adopted criteria for deciding on additional remuneration of magistrates, aiming at limiting the discretionary powers of court presidents. In order to address the Council of Europe’s concerns regarding the broad discretionary powers of the Court Presidents for allocating additional remuneration of magistrates, in November 2021 the SJC set out criteria for additional remunerations for judges and prosecutors (except for the specialised judicial authorities) linked to the degree of workload of courts, prosecutor’s offices, and district investigation departments. A new draft law was adopted to close the specialised judicial authorities and provides for a mechanism for the reappointment of magistrates. On 14 April 2022, the Parliament adopted a law for the closure of the specialised judicial authorities because of several concerns also mentioned in previous Rule of Law Reports and raised by various stakeholders. Regarding the reappointment of the magistrates who worked in the specialised judicial authorities, the respective chamber of the SJC would have the obligation to open positions at district and appellate level based on the workload of each court, prosecutor’s office, and investigative service. The decisions of the SJC on reappointment would be subject to judicial review before the Supreme Administrative Court. This reappointment procedure appears to present sufficient safeguards for the protection of judicial independence. However, on 4 May 2022, the Prosecutor General challenged the constitutionality of the reform before the Constitutional Court. The Court considered the challenge admissible on 17 May 2022. The procedures for reappointment of these magistrates are suspended pending the ruling of the Constitutional Court. Quality Improvements on legal aid, court fees and alternative dispute resolution are envisaged. As noted in the previous two Rule of Law Reports, accessibility of courts remains a concern. In the adopted RRP, the Government has committed to improve the system of legal aid by extending it to additional types of cases and by including additional grounds for requesting the aid. In addition, amendments would provide for exemptions from court fees for beneficiaries of legal aid. Furthermore, a second commitment relates to the introduction of a mandatory alternative dispute resolution for certain cases, such as divorce by petition, disputes concerning parental rights and obligations. While this is a welcome reform, when drafting the amendments account will have to be taken of the case law of the Court of Justice of the EU, which outlines the conditions under which a mandatory alternative dispute resolution is acceptable under EU law. The entry into force of these reforms is envisaged for the last quarter of 2022. Challenges remain for the Unified Information System for Courts. As of 1 June 2021, all courts in Bulgaria should have started working with the Unified Information System for Courts (UISC). However, as mentioned in the 2021 Rule of Law Report, judges and court staff continue to claim that the system does not improve their work, but actually creates more obstacles. This was exemplified on 28 July 2021, when the plenary of the Supreme Court of Cassation requested from its President to order the discontinuation of the use of the USIC because the system appeared to be complex, cumbersome, and time-consuming for both judges and court staff. On 10 August 2021, the President of the Supreme Court of Cassation ordered the system’s discontinuation on the grounds that it does not have the capacity to provide citizens and legal entities with due access to fast and equal justice. On 28 January 2022, the Sofia City Administrative Court decided that the order of the President of the Supreme Court of Cassation was null and void. However, the new President of the Supreme Court of Cassation confirmed that the concerns regarding the USIC persist, and has challenged the ruling of the Sofia City Administrative Court, which is currently pending before the Supreme Administrative Court. There is still room for improvement in the area of electronic communications. In particular, it is not possible for all court staff and judges to work remotely in a secure manner. Secure electronic communication is available, to some extent for communication between courts, while not being available for other legal professionals. Access to electronic tools remains limited. There are several projects under Bulgaria’s RRP that aim to improve the digitalisation of justice. Namely, the foreseen reforms include annual analyses of the implementation of the legislative arrangements regarding digitalisation of justice to allow, among others, for secure electronic communication. These arrangements include, among others, the rules on service of notices and summons to an electronic address, the possibility of payment of fees and other obligations to the court by electronic means, and drafting of judicial acts as electronic documents. However, their finalisation is foreseen by late 2023 and late 2024. Efficiency Administrative justice continues to perform efficiently. As last year, the disposition time for administrative courts is among the most efficient in the EU at first instance courts . However, stakeholders report delays, which tend to occurr when the Supreme Administrative Court reviews decisions of the Supreme Judicial Council. As for litigious and non-litigious civil and commercial cases, the persistent lack of disaggregated data does not allow for a proper evaluation of the overall efficiency of the judicial system . As a result, specific inefficiency problems could remain unnoticed. II.Anti-Corruption Framework The Commission for Counteracting Corruption and Illegal Assets Forfeiture (the Anti-Corruption Commission) remains responsible for both preventive and sanctioning actions for high-profile corruption, the implementation of rules on asset declarations and conflict of interests, the confiscation of illegally acquired assets, as well as the monitoring of the implementation of institutional integrity action plans. Created in the context of the post-2018 reform, the Anti-Corruption Commission has progressed in its reorganisation. Special criminal offences (including high-level corruption) remain under the competence of the specialised judicial authorities until July 2022. Afterwards, the competence will be transferred to the regional and appellate judicial authorities around the country. The perception of public sector corruption among experts and business executives is that the level of corruption in the public sector remains high. In the 2021 Corruption Perceptions Index by Transparency International, Bulgaria scores 42/100 and ranks 27th in the European Union and 78th globally . This perception has been relatively stable over the past five years . The 2022 Special Eurobarometer on Corruption shows that 88% of respondents consider corruption widespread in their country (EU average 68%) and 30% of respondents feel personally affected by corruption in their daily lives (EU average 24%). As regards businesses, 87% of companies consider that corruption is widespread (EU average 63%) and 61% consider that corruption is a problem when doing business (EU average 34%). Furthermore, 15% of respondents find that there are enough successful prosecutions to deter people from corrupt practices (EU average 34%) , while 10% of companies believe that people and businesses caught for bribing a senior official are appropriately punished (EU average 29%) . The reorganisation of the Anti-Corruption Commission has progressed, and a new reform of the Commission is envisaged. A reform of the Commission is foreseen under Bulgaria’s RRP, and aims at modifying the investigative powers and further reorganising the structure of the Commission by splitting it in two separate bodies . The objectives of these changes are to streamline the operations of the Commission and achieve better results on both anti-corruption and asset recovery actions. The impact of the reform on the effectiveness of the investigative operations of the Commission remains to be assessed, as the relevant draft-law remains to be approved, and it was made public оn 9 June 2022. In the meantime, the reorganisation of the Commission is ongoing in line with the 2018 reform plan. In 2021, eight territorial offices were closed, bringing the territorial structure to 20 units in total . The Commission has also recruited 20% additional personnel (bringing the staff up to 500 officers in total) , acquired updated office equipment, signed cooperation agreements with foreign peer agencies, and adopted internal rules and guidelines for external stakeholders . Furthermore, the Commission received 255 reports on conflicts of interest; initiated 90 procedures that resulted in 22 decisions regarding senior public officials. Additionally, the anti-corruption directorate of the Anti-Corruption Commission received 877 alerts in 2021, performed 618 integrity checks (of which 97 on the demand of the prosecution offices), responded to 45 requests for support in corruption crimes, and forwarded 93 files to the Special Prosecutor’s office .

The National Strategy for Prevention and Countering Corruption continues to be implemented. In 2021, a working group was tasked by the Government to prepare an annual report on the implementation of the 2021-2027 anti-corruption strategy . To facilitate the implementation of the anti-corruption strategy, the Government proposed measures in its RRP . More precisely, the measures foreseen in the RRP aim at fighting corruption at all levels of public administration and of the justice systems. They intend to ensure that the members of the Civil Council of the National Council on Anti-Corruption Policies monitor the implementation of the National Strategy for Prevention and Counteraction against Corruption and its associated Roadmap. Despite the work of the specialised judicial authorities, a solid track-record of final convictions in high-level cases of corruption remains to be established. In 2021, the Prosecutor’s office and Specialised Prosecutor’s office presented data on their activity regarding corruption cases. The accuracy and reliability of these regular reports are envisaged to be improved through the reforms introduced in the RRP. As mentioned above, in April 2022, the Parliament adopted a law for the closure of the specialised judicial authorities . The law presents a mechanism for redistribution of the cases currently with the specialised judicial authorities. Given the early stage of the reform, it is too early to assess the effects in practice. In 2021, 33 cases related to corruption offences were initiated before the Supreme Court of Cassation , with 19 decisions issued (including eight appeal decisions quashed, and nine convictions with up-to seven-year imprisonment) . In March 2022, former top executive officials (notably the former Prime Minister, Finance Minister, Chief of the parliamentary budgetary Commission, as well as a media adviser) were detained under suspicions of corruption as part of a police operation. The introduction of a verification mechanism for enhancing the integrity of the civil servants is envisaged in the RRP. An effective system for checking and improving the integrity of civil servants occupying positions with high corruption risks is foreseen among the RRP measures. Moreover, general provisions for the integrity of the public administration continue to be implemented, including through practical projects. In 2021, 90 cases were registered in 2021 for new corruption offences committed in the public administration (16% less than 2020). The Ministry of Interior received 1 478 reports of misconduct within the public administration. In 2021, the Ministry of Interior launched two projects on public administration integrity. Training on public ethics and anti-corruption are delivered by the Academy of the Ministry of Interior . Measures aimed at improving the integrity of specific sectors of the public administration, including the police and the judiciary, continue to be deployed. Several authorities have continued to implement sector-based measures to improve the integrity of the public administration. As regards police measures, the rotation of public officers at risk of corruption (such as border or traffic control staff, and staff involved in residence and/or citizenship procedures) has been in place since 2015 in order to deter corruption and is being implemented on a permanent basis. The establishment of the facility to host the Centre for Active Monitoring in the System of the Ministry of Interior was completed at the end of 2021 to deter instances of corruption . In order to reduce the potential for corruption within the Ministry of Interior, the number of electronic administrative services was increased . During 2021, there were 126 reports of misconduct of border police received, which resulted in opening pre-trial proceedings against nine officers, plus five disciplinary proceedings (for serious disciplinary breaches) , and disciplinary sanctions were issued in 12 cases (including the dismissal of six officers) . During 2021, the National Revenue Agency (NRA) performed an assessment on conflicts of interests of its personnel; an online training on ethics was delivered to staff of both NRA and the National Customs Agency . As to the judiciary, the Inspectorate to the Supreme Judicial Council publishes anonymised cases of violations of the Judiciary System Act. It has also established guidelines for the reporting of cases of misconduct . To prevent and counteract conflicts of interest in the judiciary, the Inspectorate is in the process of developing a programme consisting of an electronic public register of electronic declarations of circumstances related to the prevention and establishment of conflicts of interest and property declarations. Moreover, in the context of the implementation of the Bulgarian RRP, it will, among other things, revise the ethical guidelines for the conduct of magistrates and deliver anti-corruption trainings. The system of declaration of assets and conflict of interests for public officials continues to be regularly implemented. For 2021, there were 12 430 declarations of assets received by the Anti-corruption Commission (compared to 6 303 for 2020), and a total of 5 279 verifications of asset declarations, with 679 decisions (compared to 483 for 2020) establishing an administrative violation in cases of both failure to submit and wrongly submitted asset declarations. A tender for designing an online platform to file and verify declarations of asset and conflict of interests was launched in December 2021 . In December 2021, the Anti-corruption Commission adopted guidelines concerning the procedure to file declarations of property and interests . Since July 2021, officers of the National Customs Agency are required to sign declaration of assets, including bank accounts . Lobbying lacks a dedicated regulation. As noted in the 2020 and 2021 Rule of Law Reports, there are no specific obligations for the registration of lobbyists or reporting of contacts between public officials and lobbyists. Milestones have been included in the framework of the RRP to regulate lobbying activities. As a result, legislative measures need to be adopted by the end of 2023 to specifically regulate lobbying activities in the context of public decision-making. Provisions are in place for the audits on political party financing. The National Audit Office (NAO) is responsible for carrying out audits on the consistency of financial activities, revenue, expenditure and management of assets made available to political parties . On 8 January 2022, the NAO adopted a report covering the period from January to December 2020 and auditing the financial activities and real estate given to political parties . Moreover, political parties submit an annual report to the National Audit Office, which is responsible for maintaining the Unified Public Register during elections. The Register renders public information about the participants in the elections, such as donors; type, purpose and amount of donations made; the funds provided by the candidates and the members of the initiative committees; the declarations of origin of the donated and provided funds; the reports of the parties, initiative committees and coalitions on revenues, expenditures and payment commitments in connection with the election campaign . According to the law, the Committee for Combating Corruption, Conflict of Interest and Parliamentary Ethics shall provide explanations to the Members of the Parliament on the application of the ethical norms, and may establish a breach of ethics rules, issue decision and impose measures. A working group tasked to prepare a draft regulation on the protection of whistleblowers has been established. The Anti-Corruption Commission is responsible for receiving whistleblowing complaints in cases of corruption or conflict of interest. In September 2021, the Ministry of Justice established a working group tasked to prepare draft regulation on the protection of whistleblowers . The consultation process on the draft amendments for a regulation on the protection of whistleblowers ended on 23 May 2022. At the time of publication of this report, the proposals for changes in the draft amendments received during the public consultation were being processed. . Nevertheless, as part of Bulgaria’s engagements resulting from the adoption of the RRP, the introduction of legislative measures is planned for September 2022 to align with the requirements of the EU directive for the protection of whistleblowers. Bulgaria abolished its investor citizenship scheme. The European Commission has frequently raised its serious concerns about investor citizenship schemes and certain risks, including corruption, that are inherent in such schemes. Оn 24 March 2022, the Parliament repealed the provisions allowing for the naturalisation of investors based on an investor citizenship scheme . Specific corruption-risks such as management of budget funds and conducting control activities, including procurement were identified, in the COVID-19 pandemic. On 31 January 2022, the Ministry of Health performed a corruption-related risk assessment during the COVID-19 pandemic, which underlined specific corruption risks in the area of management of budget funds and in the conducting of control activities, including procurement. The analysis prompted the adoption of an annual health sector anti-corruption plan, including mitigating measures . In January 2021, the Anti-corruption Commission published a report on the sector-specific risk of corruption . In 2021, the Public Procurement Agency issued guidelines, including standardised model contracts, aimed at clarifying public procurement procedures . A report on the results of the public procurement monitoring the period 2018-2020, including corruption-risk, was adopted in 2021 . III.Media Pluralism and Media Freedom The Bulgarian legal framework is based on a set of constitutional safeguards and legislative measures, such as the Radio and Television Act. The Access to Public Information Act regulates access to public information and the re-use of public sector information. The Compulsory Deposit of Copies of Printed and Other Works Act contains requirements regarding media ownership transparency (“Law on Deposit of Copies”). The institutional framework consists of the media regulator, the Council for Electronic Media (CEM), and the National Council for Journalistic Ethics and its executive body – the Ethics Commission. While the legal framework concerning the media regulator remains unchanged, concerns have been flagged about the lack of sufficient safeguards to secure its complete independence in practice. While certain legal safeguards are in place, the CEM has raised concerns about the availability of adequate and stable financial resources for its activities (resources have nonetheless increased in 2021) which might have an effect on its work independently from state pressure. Moreover, several stakeholders have shared doubts about the lack of complete political independence in the activities carried out by the regulator and some commentators point to the fact that the very constitution of CEM inevitably exposes it to risks of political influence. The media self-regulatory body is the National Council for Journalistic Ethics (NCJE), whose decisions are not always implemented in practice by the relevant media. The decisions of the Ethics Commission (the executive body of the NCJE) are only binding on the signatories of the Bulgarian Media Code of Ethics and voluntary for other media players. Some stakeholders have expressed concerns that the decisions against media acting in breach of journalistic ethics have not always been implemented in practice and that no sanctions were imposed. Some issues remain as regards the effective transparency of media ownership and related enforcement of these obligations. 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, as well as the funding received from public funds, political parties, etc. Although the legal framework is in place, some media do not declare their ownership structure (in particular online media) while others declare owners who are not the ones that effectively control the media outlet. A revision of the 2018 Law on the Deposit of Copies is being considered by the current government to improve the effective availability of media ownership information. While the lack of a clear regulatory framework regarding transparency in the allocation of state advertising remains unchanged, some measures have been taken to improve transparency in practice. Notably, this takes the form of a list of contracts awarded for the purpose of state advertising, including recipient and amount received, which can be consulted on a publicly-available website. Stakeholders underlined however remaining issues in particular when it comes to a lack of transparency when media outlets receive state advertising through intermediaries (media agencies). The 2022 Media Pluralism Monitor also considered that state regulation of resources and support to the media sector, including state advertising resources, scored at high risk (97%) and that the lack of regulatory standards regarding the distribution of state advertising remains problematic. Media in Bulgaria are subject to a set of rules regarding their operation on the market, but there are no specific media pluralism laws restricting media ownership and therefore potential media concentration. Media can rely on the principle of editorial independence from economic and political actors which is set out in the Radio and Television Law and features in the Code of ethics of Bulgarian media. Apart from general competition rules which are underpinned by economic considerations, no specific rules exist when it comes to activities that may have an impact on media concentration. As to the entry and operation of media service providers, the law provides for different regimes when it comes to linear services (licensing/registration requirement) and non-linear services (notification requirement). Certain legal safeguards exist regarding the independence of public service media but they appear to be insufficient. The media regulator CEM appoints the Director Generals of the Bulgarian national radio (BNR) and television (BNT) following a public competition and after hearings of the relevant candidates. Director Generals submit reports on their activities to CEM at regular intervals (currently every six months). The management boards of the BNR and the BNT consist of five members each, and are endorsed by the media regulator upon proposal by the Directors General. The appointment procedure for management and board functions, taken together with the funding of public service media, does not seem to guarantee independence from the government or other political influence. A revision of the law is in preparation in order to strengthen the independence of public service media and define in more detail the public service remit and the related financing. The professional environment for journalists appears to have improved slightly since the last report. Stakeholders consider that the press has been able to express itself more freely in comparison to past years. Nevertheless, issues remain, in particular when it comes to access to public information, working conditions and pressure on journalists at local level as well as the increase of strategic lawsuits against public participation, so-called SLAPPs cases. Three new alerts regarding attacks and harassment of journalists were registered in 2022 on the Council of Europe Platform to promote the protection of journalism and safety of journalists. This includes physical threats against an investigative journalist and defamation lawsuits, including heavy fines in one defamation case. Finally, no measures supporting directly the media sector and its journalists have been put in place in the context of the COVID-19 pandemic. IV.Other Institutional Issues related to Checks and Balances

Bulgaria is a representative democratic republic with a directly elected President, a unicameral National Assembly and a Constitutional Court in charge of constitutional review of laws and interpretative decisions. The National Assembly has a final decision-making power when adopting laws . Bulgaria has two national human rights institutions. First, the Ombudsperson is an independent constitutional body, elected by the National Assembly and tasked with the promotion and protection of human rights and fundamental freedoms which has an A-status accreditation from GANHRI. Second, the Commission for the Protection against Discrimination is a body that implements policies in the spheres of gender equality and non-discrimination which has a B-status accreditation from GANHRI. The establishment of a Post-monitoring Mechanism is progressing. As indicated in previous reports, the Government committed to set up a Coordination and Cooperation Council (‘post-monitoring council’) with the aim of assessing Bulgaria’s progress in judicial reform, fight against corruption and organised crime in an independent, transparent, and objective manner. This body, which would become operational once the CVM is formally lifted, includes a Civic Council which provides for the representation of civil society in the mechanism. A positive development follows from the recent ruling of the Supreme Administrative Court as regards the procedure to select members of the Civil Council in the framework of the post-monitoring mechanism. The Court’s decision concerned the successful appeal made by an NGO to take part in the Civil Council previously rejected by the former Minister of Justice. It is positive that the role of civil society is acknowledged as an important and vital element of any national policy development and implementation. On 23 June 2022, the Government published for public consultation draft amendments to the decision for the establishment of the Post-monitoring Mechanism. The new amendments aim at extending the competences of the Mechanism to cover the topics included in the Commission’s annual Rule of Law Reports. Moreover, the draft envisages that the Mechanism would start functioning immediately after its adoption by the Council of Ministers independently from the CVM. New procedural rules have been adopted to improve the law-making process. In 2021, Bulgaria held three parliamentary elections. All three of the Parliaments made amendments to their Rules of Procedure, which led to an improvement of the rules for the law-making process. As a result, all draft legislation proposed by Members of Parliament should now be accompanied by a reasoning and an impact assessment. Moreover, a summary of stakeholders’ opinions is to be presented with the draft laws. In addition, the possibility of introducing important legislative changes through amendments to other legal acts between the first and the second reading is now limited to amendments related to the matter of the initially submitted act and subject to the approval by a two-thirds majority of the committee responsible. Currently, there is no data yet to confirm whether the practices followed by the previous Parliaments continue to be used or whether the new rules are fully respected. The quality of law-making is an important factor for investor confidence and a reason for concern about effectiveness of investment protection for 24% of companies in Bulgaria . Stakeholder feedback suggests that quick adoption of laws before prior assessment results in costs and legal uncertainty for business. The emergency situation regime related to the COVID-19 pandemic ended. As described in the 2021 Rule of Law Report, the emergency regime (‘emergency epidemic situation’) adopted on 12 May 2020, and declared on 13 May 2020 was last renewed until 31 March 2022. Further easing of measures was introduced through an order of the Minister of Health on 17 March 2022, including the abolishment of the requirement for a ‘green certificate’ for all activities and events in the country. On 1 January 2022, Bulgaria had 92 leading judgments of the European Court of Human Rights pending implementation . At that time, Bulgaria’s rate of leading judgments from the past 10 years that remained pending was at 55% and the average time that the judgments had been pending implementation was 6 years and 4 months . One of the oldest leading judgments pending implementation for 22 years concerns the excessive use of force by law enforcement agents . On 1 July 2022, the number of leading judgments pending implementation has increased to 97 . A Council for Civil Society Development has been appointed. On 16 February 2022, the Government appointed the members of the Council for Civil Society Development. The Council was established through legislative amendments, which entered into force on 1 January 2018 , while the rules governing the operation of the Council were adopted in 2019 . The election of the Council’s first members took place on 14 May 2020 . However, in May 2021, these first members published an open letter to the then interim Prime Minister claiming that they had not been able to perform any activity over the previous year and urged him to take the necessary measures that would allow the consultative body to begin operating. The main purpose of the Council is to participate in the drafting and implementation of policies in support of civil society development. In addition, the Council is also responsible for the advancement of the national civil society strategy, for making available the information on funding for civil society organisations, and for the definition of priority areas for development. At present however, the civil space is still considered narrowed. Annex I: List of sources in alphabetical order* * The list of contributions received in the context of the consultation for the 2022 Rule of Law report can be found at https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-consultation_en . Association of Judges (2022), Contribution from the European Association of Judges for the 2022 Rule of Law Report. Austrian Federal Economic Chamber (2022), Contribution from the Austrian Federal Economic Chamber for the 2022 Rule of Law Report. Bulgarian Council of Ministers (2019), Council of Ministers, Rules on the organisation and activity of the Council for Civil Society Development, 10 September 2019. Bulgarian Council of Ministers (2021), Decision of the Council of Ministers of 24 November 2021. Bulgarian Council of Ministers (2021), Decree of the Council of Ministers n.235 of 19.03.2021 https://strategy.bg/StrategicDocuments/View.aspx?lang=bg-BG&Id=1353 . Bulgarian Government (2022), Input from Bulgaria for the 2022 Rule of Law Report. Bulgarian Institute for Legal Initiatives Foundation (2022), Contribution from the Bulgarian Institute for Legal Initiatives Foundation for the 2022 Rule of Law Report. Bulgarian Institute for Legal Initiatives Foundation (2022), Written contribution from the Bulgarian Institute for Legal Initiatives Foundation in the context of the country visit. Bulgarian National Assembly (2021), Report of the Temporary Committee of the 46th National Assembly for investigating the facts and events around the protest of 2020. Bulgarian National Assembly (2021), Rules of Organisation and Procedure of the National Assembly. Bulgarian Ministry of Health (2022), Anti-corruption Plan of the Ministry of Heath for 2022. Bulgarian Ministry of Justice (2022), Written contribution from the Ministry of Justice in the context of the country visit.

Bulgarian Public Procurement Agency (2021), Methodological guidelines https://www2.aop.bg/metodologiya/metodicheski-ukazaniya/ . Centre for Media Pluralism and Media Freedom (2022), Media pluralism monitor 2022 – Report on Bulgaria. CEPEJ (2021), 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/ . Commission for Counteracting Corruption and Illegal Assets Forfeiture (2022), Activity Report for the Commission for Anti-Corruption and Illegal Assets Forfeiture of 2021. Commission for Counteracting Corruption and Illegal Assets Forfeiture (2022), Press release of 14 February 2022. Constitutional Court Decision No. 1 of 2022 on Case No. 17 of 8 February 2021. Constitutional Court Case No. 9 of 4 May 2022 Constitutional Court Case No. 7 of 29 April 2022. Council of Europe: Committee of Ministers (2010), Recommendation CM/Rec(2010)12 of the Committee of Ministers to member states on judges: independence, efficiency and responsibilities. Council of Europe: Committee of Ministers (2019), Decision CM/Notes/1362/H46-6. Council of Europe: Committee of Ministers (2019), Interim Resolution, CM/ResDH(2019)367. Council of Europe: Committee of Ministers (2020), Decision CM/Del/Dec(2020)1377bis/H46-9 of 1-3 September 2020. Council of Europe: Committee of Ministers (2020), Notes CM/Notes/1377bis/H46-9 of 3 September 2020. Council of Europe: Committee of Ministers (2021), Decision CM/Del/Dec(2021)1419/H46-8 of 2 December 2021. Council of Europe: Committee of Ministers (2021), Notes CM/Notes/1419/H46-8 of 30 November- 2 December 2021. Council of Europe: Committee of Ministers (2021), Decision CM/Del/Dec(2021)1398/H46-6 of 11 March 2021. Council of Europe: Committee of Ministers (2021), Notes CM/Notes/1398/H46-6 of 9-11 March 2021. Council of Europe: Venice Commission (2010), Report on the Independence of the Judicial System Part I: The Independence of Judges (CDL-AD(2010)004). Council of Europe: Venice Commission (2017), Bulgaria - Opinion on the judicial system act (CDL-AD(2017)018).

Council of Europe: Venice Commission (2019), Bulgaria - Opinion on draft amendments to the Criminal Procedure Code and the Judicial System Act, concerning criminal investigations against top magistrates (CDL-AD(2019)031). Council of Europe: Venice Commission (2020), Bulgaria - Urgent interim opinion on the draft new constitution opinion (CDL-AD(2020)035). Council of Ministers (2022), Draft Law on the Protection of Persons Reporting or Disclosure of Violations, https://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=6784 Council of Ministers (2022), draft amendments of Decree No. 240 of the Council of Ministers of 2019, https://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=6920 Council of the European Union (2006), Council conclusions of 17 October 2006, PRESS RELEASE, 2755th Council Meeting, General Affairs and External Relations General Affairs 13339/06 (Presse 264), https://data.consilium.europa.eu/doc/document/ST-13339-2006-INIT/en/pdf . Council of the European Union (2017), Council Conclusions on the Cooperation and Verification Mechanism, 12 December 2017, 15587/17 COVEME 9, https://data.consilium.europa.eu/doc/document/ST-15587-2017-INIT/en/pdf . Court of Justice of the European Union, judgment of 16 November 2021, Prokuratura Rejonowa w Minsku Mazowieckim, Joined Cases C-748/19 to C-754/19, EU:C:2021:931. Court of Justice of the European Union, judgment of 17 June 2017, Menini & Rampanelli v Banco Popolare – Società Cooperativa, C-75/16, ECLI:EU:C:2017:457. Court of Justice of the European Union, judgment of 18 March 2010, Alassini and Others, Case 317/08 to C-320/08, ECLI:EU:C:2010:146. Directorate-General for Communication (2019), Flash Eurobarometer 482: businesses' attitudes towards corruption in the EU. Directorate-General for Communication (2020), Special Eurobarometer 502: corruption. Directorate-General for Communication (2022), Flash Eurobarometer 507: businesses’ attitudes towards corruption in the EU. Directorate-General for Communication (2022), Special Eurobarometer 523: corruption. European Civic Forum (2022), Contribution from the European Civic Forum for the 2022 Rule of Law Report. European Commission (2006), Commission Decision of 13 December 2006 establishing a mechanism for cooperation and verification of progress in Romania to address specific benchmarks in the areas of judicial reform and the fight against corruption (C(2006) 6569), OJ L 354, 14.12.2006, European Commission (2019), Report from the Commission to the European Parliament and the Council on Progress in Bulgaria under the Cooperation and Verification Mechanism, COM(2019)498. European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation in Bulgaria. European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation in Bulgaria. European Commission (2022), ANNEX to the Proposal for a Council Implementing Decision on the approval of the assessment of the recovery and resilience plan for Bulgaria, of 7 April 2022, COM(2022) 172 final. European Commission (2022), Council Implementing Decision on the approval of the assessment of the recovery and resilience plan for Bulgaria, of 7 April 2022, COM(2022) 172 final.

European Commission (2022), EU Justice Scoreboard. European Commission (2022), Recommendation on immediate steps in the context of the Russian invasion of Ukraine in relation to investor citizenship schemes and investor residence schemes (C(2022) 2028 final). European Court of Human Rights, judgment of 18 May 2000, Velikova v. Bulgaria, 41488/98. European Court of Human Rights, judgment of 5 November 2009, Kolevi v. Bulgaria, 1108/02. European Court of Human Rights, judgment of 3 March 2015, S.Z. v. Bulgaria, 29263/12. European Court of Human Rights, judgment of 11 January 2022, Ekimdzhiev v. Bulgaria, 70078/12. European Court of Human Rights, judgment of 19 October 2021, Todorova v. Bulgaria, 40072/13. European Implementation Network (2022), Contribution from the European Implementation Network for the 2022 Rule of Law Report. European Parliament and Council of the European Union (2019), Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law. European Parliament, Committee on Civil Liberties, Justice and Home Affairs, Mission Report following the ad-hoc delegation to Slovakia and Bulgaria – 21-24 September 2021, adopted 17 November 2021 https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/LIBE/DV/2021/11-29/MissionreportSK_BG_1240476_EN.pdf . Franet, Center for the Study of Democracy (2022), Country research - Legal environment and space of civil society organisations in supporting fundamental rights – Bulgaria, Vienna, EU Agency for Fundamental Rights, https://fra.europa.eu/en/publication/2022/civic-space-2022-update#country-related . GRECO (2015), Fourth Evaluation Round – Evaluation report on Bulgaria on corruption prevention in respect of members of parliament, judges and prosecutors https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000016806c983f . Inspectorate to the Supreme Judicial Council (2022), Written contribution from the Inspectorate to the Supreme Judicial Council in the context of the country visit. International Press Institute (2022), Contributions from International Press Institute for the 2022 Rule of Law Report Judicial Chamber of the Supreme Judicial Council (2021), Decision under Protocol No. 42 of 23 November 2021 Ministry of Health (2022), Order No. RD-01-138/17.03.2022 National Audit Office (2022), Audit Report No. 0600100321 of 8 January 2022. Plenary of the Supreme Judicial Council (2021), Decision under Protocol No.13 of 25 November 2021 Plenary of the Supreme Judicial Council (2021), Protocol No.12 of 2021 Plenary of the Supreme Judicial Council (2021), Protocol No.14 of 2021

Plenary of the Supreme Judicial Council (2022), Agenda No.8 of 2022 Prosecutorial Chamber of the Supreme Judicial Council (2021), Decisions under Protocol No.40 of 23 November 2021. Reporters Sans Frontières (2022), Contribution from the Reporters Sans Frontières for the 2022 Rule of Law Report. Reporters without Borders (2022) – Bulgaria https://rsf.org/en/bulgaria . Reuters (2022), Press release https://www.reuters.com/world/europe/bulgarias-former-pm-detained-interior-ministry-says-2022-03-17/ . Sofia City Administrative Court (2021), Decision No. 500 of 28 January 2021 Statement of the Bulgarian Judges Association of 23 June 2021 https://judgesbg.org/144-2/ . Statement of 27 July 2021, signed by 69 judges from the Supreme Court of Cassation, named “Why is the USIC dangerous” http://vks.bg/novini/stanovishte-vks-eiss-27-07.html . Supreme Administrative Court (2020), Decision No. 12800 on Administrative case No. 7245/2020 Supreme Cassation Court (2021), Order No. 893 by the President of the Supreme Court of Cassation of 10 August 2021 Supreme Cassation Court (2022), Written contribution from the Supreme Court of Cassation in the context of the country visit. Supreme Judicial Council (2022), website of the Supreme Judicial Council for the register of seconded judges, http://www.vss.justice.bg/root/f/upload/34/REG_KOM_11_04_2022_S.pdf. Transparency International (2022), Corruption Perceptions Index 2021. UN OHCHR Regional Office for Europe (2022), Contribution from the UN OHCHR Regional Office for Europe for the 2022 Rule of Law Report. Annex II: Country visit to Bulgaria The Commission services held virtual meetings in March 2022 with: ·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 Institute for Legal Initiatives ·Bulgarian Judges Association ·Centre for the Study of Democracy ·Commission for countering corruption and for forfeiture of illegally acquired assets ·For the truth project ·Group of academics ·Initiative Justice for Everyone ·Inspectorate to the Supreme Judicial Council ·Ministry of Culture ·Ministry of Interior ·Ministry of Justice ·National Council for Journalistic Ethics ·Office of the Prosecutor General ·Open Society Institute ·Public service media – Bulgarian National Radio ·Specialised Criminal Court

·Specialised Prosecutor's Office ·Supreme Administrative Court ·Supreme Bar Council ·Supreme Court of Cassation ·Supreme Judicial Council ·Union of Publishers in Bulgaria * The Commission also met the following organisations in a number of horizontal meetings: ·Amnesty International ·Article 19 ·Civil Liberties Union for Europe ·Civil Society Europe ·European Centre for Press and Media Freedom ·European Civic Forum ·European Federation of Journalists ·European Partnership for Democracy ·European Youth Forum ·Free Press Unlimited ·Human Rights Watch ·ILGA Europe ·International Federation for Human Rights (FIDH)