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
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Bulgaria, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN 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 {COM(2025) 900 final} - {SWD(2025) 901 final} - {SWD(2025) 903 final} - {SWD(2025) 904 final} - {SWD(2025) 905 final} - {SWD(2025) 906 final} - {SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 909 final} - {SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} - {SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} - {SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} - {SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 921 final} - {SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} - {SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 927 final} - {SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} - {SWD(2025) 931 final}  
 
 
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 
the 
whistleblowers legislation has entered into force. Measures to mitigate the high risks of 
corruption in public procurement are still insufficient. 

is  under  preparation  and 

further  amendments 

transparency 

to 

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. 

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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  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. 

the  Parliament-elected  members  of 

•  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  Anti-Corruption 
Commission. 

institutional  reforms  of 

the 

•  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. 

• 

2 

 
 
•  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.  

3 

 
 
 
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. 

4 

 
 
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. 

5 

 
 
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. 

6 

 
 
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. 

7 

 
 
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. 

8 

 
 
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 
the  Constitutional  Court42. 
judicial  mediation  was  declared  unconstitutional  by 
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 

40   The  majority 

of 

the 

Minsku Mazowieckim, Joined Cases C-748/19 to C-754/19, EU:C:2021:931, points 72-90. 
committee’s  members 

- 
attend 
Joint  CSO 
https://www.parliament.bg/bg/parliamentarycommittees/3350/steno/8051.  See 
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. 

the  meeting. 
also 

not 

did 

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. 

9 

 
 
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. 

10 

 
 
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. 

11 

 
 
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. 

12 

 
 
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 

13 

 
 
 
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. 

14 

 
 
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. 

15 

 
 
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.  

16 

 
 
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. 

17 

 
 
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. 

18 

 
 
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. 

19 

 
 
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 

20 

 
 
 
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 
to  another 
procedure  of  appointing  an 

interim  government 

is  subject 

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”. 

21 

 
 
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. 

22 

 
 
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). 

23 

 
 
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, 
law,  Deystvie,  Amnesty 
Bulgarian  Helsinki  Committee,  Bulgarian  Centre  for  not-for-profit 
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. 

24 

 
 
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 
in  State-Owned  Bulgartransgaz,  https://acf.bg/en/akf-razkri-skandalni-
Political  Parties 
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. 

Industrial  Association 

Bulgarian 
https://www.bia-bg.com/uploads/gallery/-
%20ANKETI/Anketa_2024/ANKETA_2024.pdf 

(2024),  2024  Through 

the  eyes  of 

the  business, 

25 

 
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 
https://www.parliament.bg/bg/parliamentarycommittees/3350/steno/8051  

(2024),  Committee  meeting  of  30  April  2024, 

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 
14.08.2024, 
https://www.bta.bg/en/news/bulgaria/725622-eppo-investigation-of-bulgartransgaz-related-to-
expansion-of-chiren-underground- 

Underground 

Storage, 

Says, 

CEO 

Gas 

Capital  (2025),  European  Prosecutor  Teodora  Georgieva:  public  procurement  us  a  well-
2025, 
established 
https://www.capital.bg/politika_i_ikonomika/pravo/2025/02/28/4748542_teodora_georgieva_obs
htestvenite_poruchki_sa/  

February 

draining 

scheme 

funds, 

for 

28 

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). 

26 

 
Constitutional Court Case No. 40 of 21 November 2024 

Constitutional Court Case No. 5 of 8 April 2025. 

Constitutional Court Decision No. 11 of 1 July 2024. 

Constitutional Court Decision No. 13 of 26 July 2024. 

Constitutional Court Decision No. 14 of 26 July 2024. 

Constitutional Court, Decision No. 1 of 13 March 2025 

Constitutional Court, Decision No. 5 of 24 September 2024. 

Council of Europe, Platform to promote the protection of journalism and safety of journalists – 
Bulgaria.  

Council  of  Europe:  Committee  of  Ministers  (2010),  Recommendation  CM/Rec(2010)12  of  the 
independence,  efficiency  and 
Committee  of  Ministers 
responsibilities. 

to  member  states  on 

judges: 

Council of Europe: Committee of Ministers (2024), Notes CM/Notes/1501/H46-10 of 11-13 June 
2024. 

Council  of  Europe:  Committee  of  Ministers  (2025),  Supervision  of  the  execution  of  judgments 
and decisions of the European Court of Human Rights, 18th Annual Report of the Committee of 
Ministers, https://rm.coe.int/gbr-2001-18e-rapport-annuel-2024/1680b4d77d. 

Council  of  Europe:  Venice  Commission  (2017),  Bulgaria  -  Opinion  on  the  judicial  system  act 
(CDL-AD(2017)018). 

Council of Europe: Venice Commission (2020),  Bulgaria - Urgent interim opinion on the draft 
new constitution (CDL-AD(2020)035). 

Council  of  Europe:  Venice  Commission  (2023),  Bulgaria  -  Opinion  on  the  judicial  system  act 
(CDL-AD(2023)039). 

Council  of  Europe:  Venice  Commission  (2024),  Bulgaria  -  Joint  Opinion  of  the  Venice 
Commission and the Directorate General of Human Rights and Rule of Law (DGI) of the Council 
of  Europe  on  the  Code  of  Ethical  Conduct  for  Prosecutors  and  Investigators,  (CDL-
AD(2024)005). 

Council of Europe: Venice Commission (2024), Joint Opinion of the Venice Commission and the 
Directorate General of Human Rights and Rule of Law (DGI) of the Council of Europe on The 
Code of Ethical Conduct for Judges, (CDL-AD(2024)004).  

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  30  April  2025,  Inspektorat  kam  Visshia 
sadeben savet, Joined Cases C-313/23, C-316/23 and C-332/23, EU:C:2025:303. 

DeFakto  (2025),  The  panel  of  judges  postponed  its  meeting  due  to  lack  of  quorum,  but  also 
because 
2025, 
https://defakto.bg/2025/05/13/sadiyskata-kolegiya-otloji-zasedanieto-si-poradi-lipsa-na-kvorum-
no-za-dobro-poradi-reshenieto-na-ses-che-organi-s-iztekal-mandat-imat-ogranicheni-funktsii/  

its  mandate 

the  CJEU 

13  May 

decision., 

expired 

after 

27 

 
DeFakto  (2025a),  Following  a  decision  by  the  Supreme  Administrative  Court,  Emil  Koshlukov 
continues to  manage  BNT,  despite  his term  expiring 3  years ago,  13  Jun  2025,  https://defakto-
bg.translate.goog/2025/06/23/sled-reshenie-na-vas-emil-koshlukov-poluchi-osthe-vreme-da-
upravlyava-bnt-vapreki-iztekliya-mu-mandat-predi-3-g/?_x_tr_sl=bg&_x_tr_tl=en&_x_tr_hl=en-
US&_x_tr_pto=wapp 

Dnevnik (2024), "Shameful debate" and disputes over majorities: How MPs kept the head of the 
anti-corruption 
2024, 
https://www.dnevnik.bg/bulgaria/2024/09/19/4678072_dps_iska_ot_slavchev_da_kaje_dali_razp
uva_chadur_nad/ 

commission, 

September 

19 

Dnevnik  (2024),  Is  no  one  noticing  what  is  happening  in  Bulgaria?,  6  October  2024 
https://www.dnevnik.bg/analizi/2024/10/06/4684878_nikoi_li_ne_zabeliazva_kakvo_se_sluchva
_v_bulgariia/ 

Dnevnik  (2024),  It  is  scandalous  that  the  Anti-Corruption  Commission  wiretapped  and 
investigated 
2024, 
https://www.dnevnik.bg/analizi/2024/10/04/4684365_skandalno_e_che_antikorupcionnata_komi
siia_e/  

immunity, 

October 

person 

with 

4 

a 

Dnevnik (2025), Daniela Taleva to "Dnevnik": The law makes the ad hoc prosecutor dependent 
on 
investigates, 
https://www.dnevnik.bg/biznes/intervju/2025/03/04/4749963_daniela_taleva_pred_dnevnik_zako
nut_postavia_ad_hok/  

those 

he 

DW  (2024),  The  fight  against  corruption:  honest  people,  not  puppets,  4  March  2024, 
https://www.dw.com/bg/borba-sresu-korupciata-pocteni-hora-a-ne-marionetki/a-68431899 

EPPO (2025), Annual report 2024.  

EPPO  (2025),  EPPO  opens  administrative  enquiry  into  possible  wrongdoing  by  one  of  its 
European Prosecutors, 26 March 2025, https://www.eppo.europa.eu/en/media/news/eppo-opens-
administrative-enquiry-possible-wrongdoing-one-its-european-prosecutors  

European  Centre  for  Press  and  Media  Freedom  (2024),  Media  Freedom  Rapid  Response  – 
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 (2023), 2023 EU Justice Scoreboard.  

European  Commission  (2023),  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Bulgaria. 

European Commission (2023), Commission recommendation on promoting the engagement and 
effective  participation  of  citizens  and  civil  society  organisations  in  public  policy-making 
processes (C/2023/8627 final). 

European  Commission  (2024),  2024  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Bulgaria. 

28 

 
European  Commission  (2024),  2024  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Bulgaria. 

European  Commission  (2024),  Recommendation  for  COUNCIL  RECOMMENDATION  on  the 
economic,  social,  employment,  structural  and  budgetary  policies  of  Bulgaria,  SWD/2024/602 
final 

European Commission (2025), 2025 EU Justice Scoreboard.  

European  Commission,  (2024),  2024  Country  Report  –  Bulgaria  Accompanying  the  document 
Recommendation  for  COUNCIL  RECOMMENDATION  on  the  economic,  social,  employment, 
structural and budgetary policies of Bulgaria, COM(2024) 602 final - SWD(2024) 600 final. 

European Court of Human Rights, judgment of 18 January 2005, Kehayov v. Bulgaria, 41035/98 

European Court of Human Rights, judgment of 20 October 2005, UMO and others v. Bulgaria, 
59491/00 

European Implementation Network (EIN) (2025), written input for the 2025 Rule of Law Report. 

Free Europe (2025),  A state-owned company operates as a "draining scheme". The Ministry of 
Interior  obstructs  investigations  of  the  European  Prosecutor's  Office,  28  February  2025, 
https://www.svobodnaevropa.bg/a/teodora-georgieva-prokuror-razsledvaniya-
shemi/33331508.html  

GRECO  (2020),  Fourth  evaluation  round  ‘Corruption  prevention  in  respect  of  members  of 
parliament, judges and prosecutor’ - Second Compliance Report. 

GRECO  (2023),  Fifth  evaluation  round  -  Evaluation  Report  on  Bulgaria  on  preventing 
corruption  and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law 
enforcement agencies. 

GRECO  (2025),  Fifth  evaluation  round  ‘Preventing  corruption  and  promoting  integrity  in 
central  governments  (top  executive  functions)  and  law  enforcement  agencies’  -  Compliance 
report.International  Press  Institute  (2024),  Media  Capture  Monitoring  Report,  Country  chapter 
on Bulgaria. 

Joint  contribution  from  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  (2025), 
Contribution for the 2025 Rule of Law Report. 

Lex.bg  (2025),  The  Prosecutor's  Office  has  discontinued  the  main  case  in  the  "Eight  Dwarfs" 
case,  4  April  2025,  https://news.lex.bg/Прокуратурата-прекрати-основното-дело-по-казуса-
Осемте-джуджета/  

Mediapool (2025), GERB, BSP, ITN and Peevski rejected a commission on the sabotage of the 
European  Prosecutor's  Office  in  Bulgaria,  6  March  2025,  https://www.mediapool.bg/gerb-bsp-
itn-i-peevski-othvarliha-komisiya-za-sabotazha-na-evroprokuraturata-v-bulgaria-
news368871.html 

Ministry of Interior (2024), Report on actions to ensure free and fair elections for the National 
Assembly on 27 October 2024, https://www.gov.bg/files/common/doklad%20MVR.pdf  

29 

 
OECD (2023), Implementing the OECD Anti-Bribery Convention in Bulgaria Phase 4 Follow-Up 
Report:  Bulgaria,  Implementing  the  OECD  Anti-Bribery  Convention,  OECD  Publishing, 
Paris, https://doi.org/10.1787/3785c992-en. 

Prosecutor’s  Office  (2025),  Report  on  the  activity  of  the  prosecution  on  countering  corruption 
crimes in 2024, https://parliament.bg/pub/plenary_documents/51-527-00-14_.pdf.  

Reporters without Boarders (2025), written contribution to the 2025 Rule of Law Report. 

Sega (2025), The Bulgarian European Prosecutor told startling cases of sabotage, 1 March 2025, 
https://www.segabg.com/hot/category-bulgaria/bulgarskiyat-evroprokuror-razkaza-stryaskashti-
sluchai-na-sabotazh  

Sega  (2025),  European  Chief  Prosecutor  Laura  Kövesi  investigates  Bulgaria’s  Ministry  of 
June  2025,  https://www.segabg.com/hot/category-bulgaria/koveshi-vleze-
Agriculture,  19 
bulgarskoto-zemedelsko-ministerstvo.  

Sofia Administrative Court, Decision No 26743 in Case 6637 of 11.12.2024.  

Supreme Administrative Court, Case 1216/2025.  

Supreme Judicial Council (2025), Documents related to the activities of the group around Martin 
Bozanov, https://vss.justice.bg/page/view/110231  

Supreme  Judicial  Council,  Judges’  Chamber  (2025),  A  notification  of  a  judge  to  the  Supreme 
Judicial  Council  on  an  investigation  against  them  based  on  the  content  of  their  decision,  29 
January 2025, https://news.lex.bg/wp-content/uploads/2025/01/тук-7.pdf  

30 

 
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 
• 
• 
• 
•  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 

Inspectorate to the Supreme Judicial Council 
Internal Security Directorate – Ministry of Interior 
Institute for Market Economics 

*  The  Commission  also  met  the  following  organisations  in  a  number  of  horizontal 
meetings:  

•  Amnesty International  
•  Araminta  
•  Civil Liberties Union for Europe  
•  Civil Society Europe  

31 

 
 
•  European Civic Forum  
•  European Partnership for Democracy  
•  European Youth Forum,  
• 
• 
•  JEF Europe  
•  Philea – Philanthropy Europe Association.  
•  Transparency International 

International Commission of Jurists  
International Federation for Human Rights (FIDH)  

32