COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report The rule of law situation in the European Union
Date: 2026-07-17
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  Brussels, 17.7.2026  SWD(2026) 902 final  COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report              The rule of law situation in the European Union {COM(2026) 900 final} - {SWD(2026) 901 final} - {SWD(2026) 903 final} - {SWD(2026) 904 final} - {SWD(2026) 905 final} - {SWD(2026) 906 final} - {SWD(2026) 907 final} - {SWD(2026) 908 final} - {SWD(2026) 909 final} - {SWD(2026) 910 final} - {SWD(2026) 911 final} - {SWD(2026) 912 final} - {SWD(2026) 913 final} - {SWD(2026) 914 final} - {SWD(2026) 915 final} - {SWD(2026) 916 final} - {SWD(2026) 917 final} - {SWD(2026) 918 final} - {SWD(2026) 919 final} - {SWD(2026) 920 final} - {SWD(2026) 921 final} - {SWD(2026) 922 final} - {SWD(2026) 923 final} - {SWD(2026) 924 final} - {SWD(2026) 925 final} - {SWD(2026) 926 final} - {SWD(2026) 927 final} - {SWD(2026) 928 final} - {SWD(2026) 929 final} - {SWD(2026) 930 final} - {SWD(2026) 931 final}  
 
 
ABSTRACT 

In Bulgaria, a new ad hoc prosecutor for the investigation of possible crimes committed by 
the  Prosecutor  General  was  appointed,  while  a  new  law  has  been  adopted  to  address 
procedural  issues  affecting  the  full  operationalisation  of  the  mechanism  for  the  effective 
accountability  and  criminal  liability  of  the  Prosecutor  General.  Parliament  adopted 
amendments  to  introduce  automatic  judicial  review  for  prosecutorial  decisions  in  case  of 
termination  and  suspension  of  investigations  for  corruption-related  crimes.  The  process  to 
reform  the  Supreme  Judicial  Council  has  not  been  re-initiated.  The  continued  exercise  of 
functions  following  the  expiry  of  mandates  at  high  magisterial  level  raised  concerns, 
including where this has an effect on some investigations. The reform of the Inspectorate to 
the  Supreme  Judicial  Council  has  been  adopted.  There  has  been  an  increasing  number  of 
long-term  secondments  of judges to  fill  in  vacant  positions. Digitalisation of administrative 
justice  improved  and  amendments  to  the  legal  aid  rules  increased  the  remuneration  for 
lawyers. The year-on-year data shows that courts perform efficiently when dealing with civil 
and commercial proceedings. 

The implementation of the National Strategy for the Prevention and Countering of Corruption 
2021-2027 and the related Roadmap has continued unevenly. A new anti-corruption law re-
established  the  Anti-Corruption  Commission  and  provided  for  stronger  guarantees  for  its 
independence through a new procedure for the appointment of its leadership. A robust track-
record of high-level corruption cases is yet to be established. Cooperation between national 
authorities competent for the fight against corruption has been further strengthened. Measures 
to strengthen integrity in the police and the judiciary continue, while the Inspectorate to the 
Supreme Judicial Council no longer exercises its full powers due to the expiry of its mandate. 
Efforts  are  underway  to  strengthen  the  integrity  of  persons  with  top  executive  functions. 
Doubts  remain  over  the  effectiveness  of  rules  on  asset  and  interest  disclosure  for  public 
officials, and the impact of the temporary transfer of related functions to the National Audit 
Office  remains  to  be  assessed.  The  newly  adopted  legislation  on  transparency  of  lobbying 
exempts  important  categories  of  interest  representatives  from  the  registration  requirements. 
The  implementation  of  the  whistleblowing  framework  requires  further  action.  Public 
procurement remains a vulnerable area along with increased corruption risks identified in the 
energy, road infrastructure and waste management sectors.  

Actions  taken  by  the  previous  chairperson  of  the  Council  for  Electronic  Media  are  viewed 
positively,  while  concerns  were  raised  about  internal  conflicts  on  decision-making.  After 
years  of  delay,  a  new  Director-General  has  been  appointed  to  the  Bulgarian  National 
Television  (BNT),  and  legislative  reforms  are  underway  to  improve  the  independence  of 
public  service  media.  Legislative  reforms  are  ongoing  to  address  remaining  shortcomings 
regarding the enforcement of media ownership disclosure obligations and on transparency of 
state  advertising.  Indications  regarding  political  and  economic  influence  over  the  media 
remain.  Several  legislative  initiatives  with  possible  adverse  impact  on  public  access  to 
information  have  been  undertaken.  There  has  been  a  decrease  in  physical  attacks  against 
journalists in the past year, but verbal attacks and online harassment have increased, and legal 
pressure on journalists persists. 

The  mandates  of  most  independent  and  regulatory  authorities  have  been  renewed  while  no 
steps have been taken to improve their independence. The Constitutional Court did not reach 
a  majority  to  decide  on  the  constitutionality  of  the  reform  limiting  the  powers  of  the 
President. Problems regarding the quality of the law-making process for legislative initiatives 
by  Parliament  persist.  The  Council  for  Civil  Society  Development  resumed  work  until  the 
Government fell. A draft law banning foreign funding for NGOs and an ad hoc parliamentary 
committee tasked with investigating certain foreign foundations lapsed following the election 
of a new Parliament. 

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RECOMMENDATIONS  

Overall, based on the recommendations in  the 2025 Rule of Law Report, considering other 
developments  that  took  place  in  the  period  of  reference  and  in  addition  to  recalling  the 
relevant commitments made under the Recovery and Resilience Plan and the country-specific 
recommendation  under  the  European  Semester  on  the  effectiveness  of  anti-corruption 
measures  including  the  independence  and  effective  functioning  of  the  Supreme  Judicial 
Council, and the independence and functioning of regulators, the Commission concludes the 
following:  

•  No progress has been made to adapt the legislative framework with a view to avoid long-
term  secondment  of  judges  to  fill  in  vacant  positions,  as  the  widespread  use  of 
secondments  continues  to  raise  concerns.  Therefore,  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. 

•  No  progress  has  been  made  to  re-initiate  the  process  to  reform  the  Supreme  Judicial 
Council.  As  the  composition  remains  the  same  and  no  draft  law  has  been  tabled,  it  is 
recommended  to  Bulgaria  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. 

•  No  progress  has  been  made  on  ensuring  a  robust  track  record  of  investigations, 
prosecutions  and  final  judgments  in  high-level  corruption  cases.  Therefore,  it  is 
recommended  to  Bulgaria  to  take  measures  to  ensure  a  robust  track  record  of 
investigations, prosecutions and final judgments in high-level corruption cases.  

•  Some further progress has been made on ensuring the effective performance of the Anti-
Corruption  Commission  through  the  adoption  of  a  new  law  which  re-establishes  it  and 
introduces a new procedure for the appointment of its leadership. It is thus recommended 
to  Bulgaria  to  ensure  the  full  operationalisation  of  the  Anti-Corruption  Commission  in 
order to enable the fulfilment of its preventive and investigative functions.  

•  Limited progress has been made on improving the integrity of top executive functions, as 
a draft code of conduct has been prepared. As the related legislative amendments remain 
pending, it is recommended to Bulgaria to  continue efforts to strengthen 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. 

•  No  progress  has  been  made  to  improve  the  quality  of  the  legislative  process,  as  the 
practical  implementation  of  the  parliamentary  rules  for  lawmaking  continues  to  raise 
some concerns. Therefore, it is recommended to Bulgaria to strengthen the quality of the 
legislative process by ensuring the use of public consultations and impact assessments for 
legislative initiatives by Parliament. 

2 

 
 
 
 
As regards the other 2025 recommendations, the Commission concludes that: 

•  Parliament  adopted  the  legislative  reform  aiming  at  improving  the  functioning  of  the 
Inspectorate to the Supreme Judicial Council and avoiding the risk of political influence. 
The  pre-existing  safeguard  of  a  two-thirds  majority,  and  the  newly  added  role  of  the 
judges, prosecutors and investigative magistrates in the appointment of the ISJC members 
addresses the concerns linked to the risk of political influence in the ISJC. Therefore, the 
recommendation is fully implemented.  

•  Some progress has been made on completing 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, as the legislative process has 
advanced. Given that the topics of this recommendation are covered by provisions of the 
European Media  Freedom  Act  (EMFA), while the Rule of Law Report  will continue to 
monitor  significant  developments  and  report  on  their  impact,  further  follow-up  will  be 
ensured  as  part  of  the  Commission’s  support  to  Member  States  and  enforcement  of  the 
EMFA. 

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, 24% of the general population and 22% of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20262.  The  perceived  judicial  independence  among  the  general  public  has  slightly 
decreased in comparison with 2025 (27%) and has significantly decreased in comparison with 
2022  (31%).  The  perceived  judicial  independence  among  companies  has  decreased  in 
comparison with 2025 (27%) as well as in comparison with 2022 (28%). The main reasons 
cited by both the general public and the 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.  

A  new  law  has  been  adopted  to  address  procedural  issues  affecting  the  full 
operationalisation  of  the  mechanism  for  the  effective  accountability  and  criminal 
liability of the Prosecutor General, while a new ad hoc prosecutor for the investigation 
of  the  Prosecutor  General  was  appointed.  The  2025  Rule  of  Law  report  pointed  to 
procedural  issues  affecting  the  full  effectiveness  of  the  mechanism,  which  aims  to  address 
long-standing concerns about the lack of an effective criminal investigation of the Prosecutor 
General  and  his/her  deputies4.  On  29  May  2026,  Parliament  adopted  amendments  to  the 
Criminal Procedure Code aimed at improving the functioning of the mechanism by providing 
for a simultaneous appointment of the supervising prosecutor to the ad hoc prosecutor. This 
would be a judge from the Criminal Chamber of the Supreme Court of Cassation, who would 
exercise control over the actions of the ad hoc prosecutor, thereby precluding any role for the 
Prosecutor General or their deputies in carrying out internal hierarchical control. The law also 
assigns  additional  powers  to  the  supervising  prosecutor,  such  as  requesting  special 
surveillance in cases involving top prosecutors, seeking to reopen proceedings under certain 
conditions,  and  introducing  procedural  changes  to  ensure  random  selection  of  supervising 
judges  from  an  approved  list  by  the  Supreme  Court  of  Cassation5.  Furthermore,  the  law 
introduces  an  automatic  judicial  review  of  prosecutorial  decisions  to  suspend  or  terminate 

1   An overview of the institutional framework for all four pillars can be found here here.  
2   Figures 48 and 50, 2026 EU Justice Scoreboard and Figures 51 and 53, 2024 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 49 and 51, 2026 EU Justice Scoreboard.  
4   One  identified  shortcoming  related  to  the  fact  that  some  decisions  of  the  ad  hoc  prosecutor  can  only 
proceed with the authorisation of the Prosecutor General and his/her deputies. Other procedural issues were 
linked  to  the  hierarchical  and  practical  independence  of  the  ad  hoc  prosecutor.  Council  of  Europe, 
Supervision of the execution of the European Court’s judgments, Committee of Ministers Decision of 2-4 
December 
2025, 
(CM/Notes/1545/H46-13).  See  also  Joint  CSO  contribution  (2026),  written  input,  pp.  5-6.  See  also  2025 
Rule of Law Report, Bulgaria, p. 5. Stakeholders had also pointed to the lack of transparency of the ad hoc 
prosecutor’s work as a source of concern. Country visit Bulgaria, Bulgarian Institute For Legal Initiatives, 
Anti-Corruption Fund Foundation, Institute For Market Economics, Center For The Study Of Democracy, 
Initiative  Justice  For  All,  Supreme  Court  of  Cassation.  Concerning  the  lack  of  transparency,  see  also  the 
Supreme Court of Cassation Annual Report for 2025, published on 28 May 2026. 

(CM/Del/Dec(2025)1545/H46-13) 

2-4  December 

and  Notes 

2025, 

of 

5   Bulgarian Government (2026), additional written input, pp. 5-6. 

4 

 
 
 
 
pre-trial  proceedings  for  crimes  committed  by  the  Prosecutor  General.  The  law6  has  been 
reassessed  as  satisfactorily  fulfilling  the  milestone  in  light  of  the  new  amendments  in  the 
context of the Bulgarian Recovery and Resilience Plan (RRP)7. Following the expiry of the 
two-year  mandate  of  the  first  ad  hoc  prosecutor  for  the  investigation  of  possible  crimes 
committed  by  the  Prosecutor  General  and  his/her  deputies,  a  new  ad  hoc  prosecutor  was 
appointed  by  the  Prosecutors’  chamber  of  the  Supreme  Judicial  Council  (SJC)  on  22 
December 20258. 

to 

judicial  review 

introduce  automatic 

Parliament  adopted  amendments 
for 
prosecutorial  decisions  in  case  of  termination  and  suspension  of  investigations  for 
corruption-related  crimes.  On  29  May  2026,  Parliament  adopted  amendments  to  the 
Criminal  Procedure  Code  to  introduce  automatic  judicial  review  when  terminating  and 
suspending pre-trial proceedings for corruption-related crimes. This aimed at addressing the 
issue highlighted in previous Rule of Law Reports 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  and  at  fulfilling  Bulgaria’s  RRP 
commitments9.  In  addition,  the  amendments  aim  at  establishing  a  system  of  external 
oversight, expanding the powers of the competent investigating and judicial authorities, and 
strengthening  the  mechanisms  for  investigating  the  Prosecutor  General.  Stakeholders  had 
previously noted that the lack of judicial review hampered Bulgaria’s anti-corruption efforts 
since  this  limitation  existed  only  for  victimless  crimes10.  The  requirement  of  the  RRP 
milestone  related  to  extending  judicial  review  of  prosecutorial  acts  for  the  termination  or 
suspension of investigations had previously been assessed as not satisfactorily fulfilled in the 
context  of  Bulgaria’s  third  payment  request,  resulting  in  a  partial  suspension  of  payments. 
This  happened  due  to  the  amendments  adopted  on  18  November  2025,  which  created  the 

6   The law was promulgated in the State Gazette, issue 51 of 5 June 2026 and entered into force on the day of 

its promulgation. 

7   See milestone 222 of Bulgaria’s RRP on the accountability and criminal liability of the Prosecutor General. 
On 1 October 2025, the authorities submitted a  payment request which includes milestone 222, and on  2 
December 2025, the Commission partially suspended the payment of the related amount, as inter alia, some 
aspects of the milestone regarding accountability and criminal liability of the Prosecutor General have not 
been fully met. See Commission Implementing Decision of 22 December 2025 on the partial suspension of 
the  disbursement  of  the  third  instalment  of  the  non-repayable  support  for  Bulgaria,  pp.  6-9.  With  the 
amendments adopted on 29 May 2026, Bulgaria considers that it has taken all necessary measures to ensure 
the satisfactory fulfilment of milestone 222 within the 6-month suspension period, which ended on 22 June 
2026. The payment request for the suspended amount has been submitted by Bulgaria on 22 June 2026 and 
on 13 July 2026, the milestone was preliminarily assessed as satisfactorily fulfilled. 

8   See  Protocol No 41 of 22 December 2025, Prosecutor’s chamber of the SJC. The new  ad hoc  prosecutor 
was  selected  from  a  list  of  11  judges  who  have  the  rank  of  Supreme  Court  judge,  using  the  system  for 
random  allocation  of  cases  of  the  Supreme  Court  of  Cassation.  According  to  the  Supreme  Court  of 
Cassation’s annual report for 2025, there have been 18 notifications for possible crimes sent to the Court, 
eight  of  them  were  sent  to  the  ad  hoc  prosecutor,  while  10  of  them  were  under  the  remit  of  Sofia  City 
Prosecutor’s Office.  

9   See milestone 222 of Bulgaria’s RRP on the effectiveness of criminal proceedings. 
10   2025 Rule of Law Report, Bulgaria, p. 6. 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. 

5 

 
 
 
 
possibility for judicial review, but limited it to a few authorities11. The amendments adopted 
on 29 May 2026 also reinstated the provision according to which the request for acceleration 
of an investigation is assessed by the courts, and not the Prosecutor’s Office. The milestone 
will be reassessed in light of the newly adopted law.  

Concerns  related  to  prosecutorial  autonomy,  judicial  independence  and  transparency 
remain regarding the structure for the investigation of magistrates within the Sofia City 
Prosecutor’s Office. As previously reported12, a small number of prosecutors are responsible 
for  investigating  cases  concerning  possible  offences  committed  by  magistrates.  These 
prosecutors are part of a centralised structure within the Sofia City Prosecutor’s Office, and 
selected  by  the  administrative  head  of  this  office,  who  is  a  direct  subordinate  to  the 
Prosecutor General. The office only deals with cases related to magistrates, regardless of the 
type  of  crime  committed13.  Currently,  there  are  seven  prosecutors  working  within  this 
structure14.  This  centralised  structure  continues  to  raise  concerns  regarding  prosecutorial 
autonomy  and  regarding  judicial  independence  as  exemplified  by  cases  open  against 
magistrates for the content of their decisions15. Moreover, stakeholders consider that there is 
a  need  for  disaggregated  data  on  proceedings  that  are  open  against  magistrates  to  ensure 
transparency16. On 23 December 2025, the Bulgarian Judges Association has appealed to the 
Administrative  Court  against  the  Supreme  Judicial  Council’s  refusal  to  provide  data  on 
investigations and preliminary inquiries against judges17.  

There  has  been  no  progress  on  the  recommendation  regarding  the  reform  of  the 
Supreme Judicial Council (SJC)18. The concerns raised in previous Rule of Law Reports19 
as regards the influence of the Prosecutor General in the SJC, and the fact that judges elected 
by their peers did not form a majority in the SJC remain unaddressed20. The authorities have 

11   Parliament  decided  to  limit  in  the  Criminal  Procedure  Code  the  authorities  that  could  challenge 
prosecutorial decisions to terminate and suspend investigations concerning high-level corruption offences to 
the  Anti-Corruption  Commission.  Parliament  also  adopted  a  law  repealing  the  Anti-Corruption  Law  and 
thus shutting down the Anti-Corruption Commission and transferring its competences to other institutions. 
SG  No  16  of  10  February  2026  promulgating  the  law  adopted  on  28  January  2026.  See  for  more 
information pillar II. 

12   2025 Rule of Law Report, Bulgaria, p. 6. 
13   2025 Rule of Law Report, Bulgaria, pp. 6-7. 
14   Bulgarian Government (2026), written input, p. 12. 
15   Country visit, Bulgaria, Bulgarian Judges Association. See also study published on 23 February 2026 by the 
Bulgarian  Helsinki  Committee,  “Wiretapped  justice”,  which  examines  investigations  against  magistrates 
and use of wiretapping against magistrates between 2015 and 2025.  See also from last year notification of 
the judge to the Supreme Judicial Council, 29 January 2025. See also Bulgarian Judges Association position 
(2025), 30 January 2025. Concerning this case, see C-2/26, Kaldov, Request for a preliminary ruling from 
the Sofiyski rayonen sad (Bulgaria) lodged on 5 January 2026 – Criminal proceedings against HV.  

16   Country visit Bulgaria, Bulgarian Judges Association.  
17   Country visit Bulgaria, Bulgarian Judges Association. See also  Access to Information Programme (2025), 

Press release of 23 December 2025.  

18   The 2025 Rule of Law Report recommended to Bulgaria to “[r]e-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.”  After  having  been  considered  fully 
implemented  in  2024,  this  recommendation  was  reintroduced  in  2025  due  to  the  reversal  of  the 
constitutional reform following the Constitutional Court decision of July 2024. 

19   2023 Rule of Law Report, Bulgaria, pp. 6-8. 
20   Venice Commission opinions (CDL-AD(2020)035), para. 44 and (CDL-AD(2023)039), para. 47. Under the 
current  system,  out  of  the  14  members  that  form  the  Judges’  Chamber  of  the  SJC,  a  maximum  of  6 
members can be peer-elected judges. Currently, there are only 4 peer-elected members. When it comes to 
the  SJC  Plenary,  these  4  peer-elected  members  are  a  minority  out  of  20.  In  the  context  of  the  European 

6 

 
 
 
 
not re-initiated the process to reform the composition and the appointment procedure of the 
members of the SJC21 despite the legal deadline set by Parliament of July 202522. Meanwhile, 
on 26 June 2026, Parliament adopted amendments that limit the possibility of persons having 
held the position of interim Prosecutor General or President of a Supreme Court for 6 months 
to  be  elected  as  members  to  the  SJC  for  at  least  one  year.  On  11  December  2025,  the 
Constitutional  Court  closed  the  case  challenging  the  constitutionality  of  the  provisions 
precluding a SJC with an expired mandate to appoint a new Prosecutor General. The closure 
was due to the withdrawal of the challenge before the Supreme Administrative Court, which 
had  initially  prompted  the  constitutionality  check23.  The  SJC  continues  to  operate  on  an 
expired mandate since 3 October 2022. On 13 November 2025, the Supreme Administrative 
Court ruled that the preliminary ruling of the Court of Justice of the EU (Court of Justice) in a 
case  regarding  the  Inspectorate  to  the  SJC  (ISJC)  was  not  applicable  to  the  SJC24.  In  its 
decision, the Court of Justice had ruled that the principle of judicial independence precludes a 
practice  in  which  members  of  a  judicial  body  elected  by  Parliament  for  a  specific  duration 
and  competent  to  review  the  integrity  of  magistrates  and  the  initiation  of  disciplinary 
proceedings  continue  to  perform  their  functions  beyond  the  legal  duration  of  their  terms  of 
office,  where  such  extension  of  the  expired  terms  of  office  does  not  have  an  express  legal 
basis  containing  clear  and  precise  rules  such  as  to  circumscribe  the  performance  of  those 
functions, and where it is not guaranteed that that extension is, in practice, limited in time25. 
As a result, there has been no progress on the recommendation made in the 2025 Rule of Law 
Report. 

The continued exercise of functions following the expiry of mandates at high magisterial 
level  raised  concerns,  including  where  this  has  an  effect  on  some  investigations.  The 
amendments  to  the  Judicial  System  Act  (JSA)  of  15  January  202526  imposed  a  six-month 
limit to the interim mandate when fulfilling the function of Prosecutor General and Supreme 
Administrative  or  Cassation  Court  President27.  This  provision  directly  affected  both  the 
interim  Prosecutor  General,  who  held  this  position  since  16  June  2023,  and  the  interim 
President  of  the  Supreme  Administrative  Court  (SAC),  who  held  this  position  since  22 
November 2024, as their terms of office elapsed28. Following this time limit, in July 2025 the 
interim  mandates  of  the  interim  Prosecutor  General  and  the  interim  President  of  the  SAC 
ended.  On  14  October  2025,  the  Judges’  chamber  of  the  SJC  appointed  a  new  interim 

Semester,  the  Commission  has  proposed  that  the  Council  recommend  that  Bulgaria  “strengthen[s]  the 
independence and effective functioning of the Supreme Judicial Council”. 

21   Bulgarian Judges Association (2025), written input,  p. 9. See  also Joint CSO contribution (2026), written 

input, pp. 7-9. 

22   On 15 January 2025, Parliament adopted amendments to the Judicial System Act precluding a SJC 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 positions, and announced 
that within 6 months Parliament has to start a procedure for electing new members to the SJC.  

23   Constitutional Court, Ruling No 9 of 11 December 2025. 
24   Supreme Administrative Court ruling No. 11370 of 13 November 2025. 
25   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. 

26   2025 Rule of Law Report, Bulgaria, p. 7. 
27   Art. 173, para. 15 of the JSA. See also 2025 Rule of Law Report, Bulgaria, p. 7. 
28   The  intention of  the  legislator  was  that  the  law  restricts  the  interim  mandates  of  current  interim  mandate 
holders  and  future  interim  mandate  holders.  Draft  law  for  Amendment  and  Supplement  of  the  Judicial 
System Act of 5 December 2024, No. 51 454 01 15, p. 7. 

7 

 
 
 
 
President  of  the  SAC  for  a  term  of  six  months29.  However,  the  interim  Prosecutor  General 
refused  to  step  down,  deeming  that  the  time  limit  did  not  apply  retroactively  to  his  2023 
appointment.  This  situation  has  had  an  impact  on  a  number  of  cases,  as  courts  of  different 
levels – including the Supreme Cassation Court30 had different interpretations on whether to 
consider  him  as  fulfilling  the  function  of  interim  Prosecutor  General  or  not.  Following  a 
request  for  a  constitutionality  check,  the  Constitutional  Court  decided  on  7  April  2026  that 
the provision limiting the interim mandates of the Prosecutor General  and the Presidents of 
Supreme Courts to six months is constitutional. The Court clarified that the Supreme Courts, 
in their respective fields of competence, have the power to interpret the provision and decide 
on the legality of the acts taken by the interim Prosecutor General following the end of their 
mandate31. On 22 April 2026, the interim Prosecutor General withdrew from the position, and 
a  new  one  was  appointed  for  a  period  of  six  months  by  the  Prosecutor’s  Chamber  of  the 
SJC32.  

Parliament adopted the reform aiming to improve the functioning of the Inspectorate to 
the  Supreme  Judicial  Council  (ISJC)  and  to  avoid  the  risk  of  political  influence  thus 
fully implementing the 2025 recommendation33. On 25 June 2026, Parliament adopted the 
amendments to the Judicial System Act (JSA) that allow the General Assemblies of judges, 
prosecutors  and  investigative  magistrates  to  propose  candidates  for  Inspector  General  and 
Inspectors  to  the  ISJC  through  the  Supreme  Courts  and  the  Supreme  Prosecutor’s  Office. 
These  amendments  aim  at  addressing  the  previously  reported  concerns  with  the  ISJC34, 
notably as regards its functioning and the risk of political influence, as Parliament is the only 
institution involved at all stages of the procedure for appointment of its members. Parliament 
would  nonetheless  retain  a  role  in  the  phase  of  proposal  of  candidates.  Stakeholders  have 
informed that they have not been involved in the preparation of draft amendments35, which 
have  been  adopted  by  Parliament36.  Meanwhile,  the  ISJC  continues  to  function  with  an 
expired mandate since 2020. Moreover, in several cases, the Supreme Administrative Court 
applied the ruling of the Court of Justice of April 202537 and declared acts of the ISJC as null 
and void as it considered the ISJC is no longer able to take such decisions due to its expired 

29   Judge’s chamber of the SJC, Protocol No. 23 of 15 July 2025 and No. 27 of 14 October 2025. The interim 

President whose mandate had lapsed took a leave until a decision was taken, BTA (2025). 

30   On  2  October  2025,  the  Supreme  Cassation  Court  published  a  press  release  in  which  it  clarified  that  the 
Criminal  Chamber  of  the  Court  no  longer  considers  the  interim  Prosecutor  General  as  fulfilling  this 
function since July 2025. See Supreme Cassation Court (2025). 

31   Constitutional  Court,  Decision  No.  7  on  Case  No.  2  of  2026.  On  12  January  2026,  the Bulgarian  Judges 
Association  requested  the  Supreme  Cassation  Court  for  an  interpretative  decision  to  unify  the  case  law 
regarding  the  above-described  situation.  Bulgarian  Judges  Association  (2026),  written  input  3.  The 
interpretative  decision  is  expected  to  be  rendered  in  the  coming  months  following  the  constitutionality 
check.  

32   Prosecutor’s chamber of the Supreme Judicial Council, Protocol No. 13 of 22 April 2026. 
33   The  2025  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.” No progress was previously assessed on this recommendation in 2025, some progress in 2024 
and no progress in 2023.  

34   See 2025 Rule of Law Report, Bulgaria, p. 8. 
35   Country visit Bulgaria, Bulgarian Institute For Legal Initiatives, Anti-Corruption Fund Foundation, Institute 
For Market Economics, Center For The Study Of Democracy, Initiative Justice For All, Bulgarian Judges 
Association. 

36   Country visit Bulgaria, Ministry of Justice. 
37   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. 

8 

 
 
 
 
mandate  and  the  possible  threat  to  judicial  independence38.  As  a  result,  the  pre-existing 
safeguard of a two-thirds majority, and the newly added role of the judges, prosecutors and 
investigative  magistrates  in  the  appointment  of  the  ISJC  members  addresses  the  concerns 
linked to the risk of political influence in the ISJC. Therefore, the Commission considers the 
recommendation made in the 2025 Rule of Law Report as fully implemented. 

There  has  been  an  increasing  number  of  long-term  secondments  of  judges  to  fill  in 
vacant positions, with no progress made to take steps to avoid such secondments39. The 
widespread use of secondments continues to raise concerns as it may have a negative effect 
on  seconded  magistrates  faced  with  the  risk  of  termination  of  their  secondment40. 
Stakeholders  report  that  the  number  of  secondments  has  increased  to  the  same  levels  as 
before the SJC decided to use the preliminary implementation of administrative decisions for 
appointment  to  speed  up  the  conclusion  of  competitions  for  appointment  and  promotion41. 
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 
jeopardised42,  particularly  when  a  secondment  is  terminated  without  the  judge’s  consent43. 
None  of  the  previous  draft  amendments44  to  improve  the  situation,  notably  by  precluding 
secondments to a vacant position for an undetermined period of time, have been tabled before 
Parliament. Stakeholders consider that the lack of timely competitions remains the key issue, 
which triggers the great  number of secondments45. Against this background,  there has been 
no progress on the recommendation made in the 2024 and 2025 Rule of Law Reports. 

The  ad  hoc  committees  created  to  investigate  cases  of  intimidation  of  magistrates  and 
possible infiltration of the judiciary have concluded their work without follow up, while 
the  interim  Government  resumed  work  on  the  matter.  As  previously  reported46,  a 
judiciary committee and a parliamentary committee were set up in 2024 to investigate cases 
of  intimidation  of  magistrates  and  possible  infiltration  of  the  judiciary.  The  judiciary 
committee established by the Judges’ chamber of the SJC has not yet published the report on 
this  issue  originally  foreseen  for  July  202547.  Moreover,  no  follow  up  was  given  by  the 
parliamentary committee, which could not adopt a final report due to insufficient quorum. In 

38   Lex.bg (2026). 
39   The 2025 Rule of Law Report recommended to Bulgaria to “[r]e-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.”  No  progress  was  previously  assessed  on  this 
recommendation in 2025, some progress in 2024 and significant progress in 2023. 

40   2023 Rule of Law Report, Bulgaria, pp. 9-10.  
41   To  achieve  progress  on  the  recommendation,  in  2022,  the  SJC  concluded  several  competitions  for 
appointment  and  promotion  of  magistrates  by  applying  the  administrative  procedure  for  preliminary 
implementation  of  administrative  decisions  (i.e.  decisions  on  promotion).  This  allows  to  conclude  the 
competitions  without  waiting  for  the  final  decisions  on  any  potential  challenges  by  candidates.  See  2023 
Rule of Law Report, Bulgaria, pp. 9-10. IME (2025). According to the register maintained by the Supreme 
Judicial Council, as of 31 December 2025, there are 212 seconded judges, 131 of them being seconded for 
more than a year, with the longest secondment being 133 months. 

42   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. 

43   As  regards  EU  law  requirements,  see  CJEU,  Judgment  of  16  November  2021, Prokuratura  Rejonowa  w 

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

44   2024 Rule of Law Report, Bulgaria, p. 11. 
45   Country visit, Bulgaria, Bulgarian Judges Association, Institute for Market Economics. See also request for 

a preliminary ruling of 29 May 2025, Case C-364-25, Katachev. 

46   2024 Rule of Law Report, Bulgaria, p. 12. 
47   Country visit Bulgaria, Supreme Judicial Council. 

9 

 
 
 
 
parallel,  a  case  before  the  European  Court  of  Human  Rights  was  filed  by  one  of  the 
magistrates  subject  to  intimidation48.  On  6  March  2026,  the  Minister  of  Interior  assigned  a 
security detail  to  Bulgaria’s European Prosecutor, following a report of alleged pressure on 
her49. In March 2026, the interim Ministry of Justice established a working group tasked with 
developing  a  mechanism  for  the  institutional  protection  of  magistrates  in  cases  of  threats, 
pressure  or  other  forms  of  undue  interference  with  the  performance  of  their  functions50. 
Furthermore, the Ministry also established a working group to analyse allegations concerning 
the influence of organised crime groups over the judiciary51. 

Quality  

Digitalisation of administrative justice improved and a new system for online allocation 
of  payment  orders  was  set  up  in  the  civil  justice  procedure,  in  other  areas  challenges 
remain. On 24 July 2025, Parliament adopted amendments to the Administrative Procedure 
Code52  as  part  of  the  RRP  to  establish  a  framework  supporting  the  digitalisation  of  public 
administration  and  justice,  with  the  objective  of  improving  the  efficiency  of  administrative 
bodies and the judiciary. Key measures include electronic case files that can also be signed 
electronically, remote court hearings, and mandatory digital submissions for certain entities. 
With  the  introduction  of  the  possibility  to  initiate  proceedings  online,  the  reform  aims  to 
reduce  costs,  accelerate  proceedings,  and  improve  access  by  minimising  physical  presence. 
The law also provides limited exceptions to the possibility to carry out procedural actions in 
electronic form53, for cases of technological impossibility or in the presence of specific legal 
requirements  concerning  the  format  of  the  acts54.  In  July  2025,  the  new  system  allowing 
online allocation of payment orders cases was launched as part of the civil justice procedure. 
This allows for a better distribution of cases across the country regardless of the origin of the 
case, which alleviates  some of the workload from  the courts in  the capital55. Improvements 
were noted in the area of administrative justice as well as regarding the possibility to access 
closed  and  ongoing  cases,  execute  electronic  payments,  and  serve  electronically  papers  to 
citizens  and  lawyers  albeit  in  limited  areas.  Nonetheless,  there  are  still  gaps  in  the  overall 
digitalisation of the justice system. Procedural rules have not yet been updated to allow the 
use  of  digital  tools  in  all  proceedings.  There  are  challenges  regarding  the  level  of 
digitalisation  of  judicial  proceedings,  which  does  not  allow  for  online  filing  of  claims  and 
electronic service of documents in all civil and commercial proceedings. Gaps exist regarding 
digital technologies and secure communication, which currently do not allow staff and judges 
to work securely in a digital environment or to communicate safely with other actors in the 

48   Application  no.  25072/24  TSARIGRADSKA  and  Others  v  Bulgaria,  lodged  on  22  August  2024, 

communicated on 6 October 2025. 

49   See Press release from the Ministry of Justice of 6 March 2026. 
50   Bulgarian Government (2026), additional written input, pp. 7-8. 
51   Bulgarian Government (2026), additional written input, p. 23. 
52   See milestone 215 of Bulgaria’s RRP. 
53   Bulgarian Government (2026), p. 10. Key provisions entered into force on 1 July 2026.  
54   Bulgarian Judges Association (2026), written input, p. 13. See also Joint CSO contribution (2026), written 

input, p. 2. 

55   Country  visit  Bulgaria,  Bulgarian  Judges  Association,  Supreme  Judicial  Council,  Supreme  Bar  Council. 
The algorithm used to distribute the cases takes into account the average total workload, the actual number 
of judges and the workload under the Rules for Determining the Workload of Judges, including as a priority 
court  with  lower  workloads  and  temporarily  excluding  courts  with  above-average  workloads.  The 
introduction of a system for payment orders is covered by milestone 258 of Bulgaria’s RRP. 

10 

 
 
 
 
justice  system,  such  as  lawyers,  notaries  and  bailiffs.  However,  Bulgaria  performs  well 
regarding arrangements for producing machine-readable judicial decisions56.  

Amendments to the legal aid rules increased the remuneration for lawyers. In July 2025, 
the  Government  amended  the  rules  on  remuneration  for  legal  aid57.  These  amendments 
increase  minimum  and  maximum  remuneration  rates  for  legal  aid  services  across  civil, 
criminal,  administrative,  labour,  family,  and  asylum  proceedings,  with  many  fees  raised  by 
50-100% effective from 1 October 2025. Advance payments of up to 50% are now permitted 
for prolonged cases, alongside supplements for multiple clients, high complexity or extended 
durations, and per-phase billing at each court instance. Overall, the measures aim to enhance 
the  financial  incentives  and  operational  efficiency  for  lawyers  providing  state-funded  legal 
aid, potentially improving access to justice for vulnerable citizens58. In July 2025, a reform 
on the Law on International Commercial Arbitration was adopted, which imposes additional 
requirements  for  law  firms  that  would  like  to  offer  arbitration.  It  aims  at  strengthening  the 
regulation of arbitration and promoting alternative dispute resolution mechanisms59.  

Efficiency 

The year-on-year data shows that courts perform efficiently when dealing with civil and 
commercial proceedings. According to the 2026 EU Justice Scoreboard, it takes on average 
90 days to resolve a civil, commercial, administrative and other non-criminal cases60, which 
means that courts generally deal efficiently with their caseload. While cases at third instance 
on average take up to 201 days to be resolved61, cases at first and second instance courts take 
respectively 184, and 148 days to be resolved62. However, long-term reporting is needed to 
identify trends, as disaggregated data on civil and commercial proceedings has only become 
available  since  2023.  The  estimated  time  to  resolve  administrative  cases  at  first  instance 
increased  from  121  days  in  2023  to  129  days  in  2024.  However,  at  this  stage,  some 
businesses  still  consider  the  efficiency  of  the  justice  system  as  a  barrier  for  them63.  The 

56   2026 EU Justice Scoreboard, Figure 43-45. 
57   Bulgarian Government (2026), p. 10. See SG No 53 of 1 July 2025. 
58   Bulgarian Judges Association (2026), written input, p. 13. 
59   The reform introduces a mandatory register of permanent arbitration institutions. The registration is serving 
as a condition for conducting arbitration activities and prohibits the establishment of national ad hoc 
arbitration. 

60   Down from 186 days in 2023. According to the statistics of the SJC, over the past three years, over 80% of 
cases  concluded  in  district,  regional,  appellate,  military  and  administrative  courts  have  been  concluded 
within  three  months.  In  first  instance  civil,  commercial,  corporate  and  administrative  cases,  the  average 
share of cases concluded within three months is over 80%, while only about 7% are concluded within three 
to  six  months.  The  results  are  similar  in  first  instance  criminal  cases,  where  approximately  83%  are 
concluded within three months; about 70% of appellate  civil cases and cassation administrative  cases are 
concluded within three months. 
61   Down from 249 days for 2023. 
62   2026 EU Justice Scoreboard, Figures 5 and 6.  For second instance the length of proceedings increased by 

10 days compared ot the 2023 data.  

63   Survey  conducted  by  the  Bulgarian  Industrial  Association  in  December  2025,  among  847  micro,  small, 
medium and big companies in Bulgaria. It shows that 44% of the respondents consider that the efficiency of 
the judiciary is a barrier for businesses.  

11 

 
 
 
 
Government  is  currently  working  on  the  preparation  of  draft  laws  for  the  acceleration  of 
criminal and civil proceedings64.  

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 2025 Corruption Perceptions Index by 
Transparency International, Bulgaria scores 40/100 and ranks 26th in the European Union and 
84th globally65. This perception has been relatively stable over the past five years66. The 2026 
Special  Eurobarometer  on  Corruption  shows  that  86%  of  respondents  consider  corruption 
widespread  in  their  country  (EU  average  71%)  and  37%  of  respondents  feel  personally 
affected by corruption in their daily lives (EU average 30%). As regards businesses, 87% of 
companies consider that corruption is widespread (EU average 65%) and 48% consider that 
corruption  is  a  problem  when  doing  business  (EU  average  37%).  Furthermore,  21%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 
practices  (EU  average  38%),  while  12%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 31%)67.  

The  implementation  of  the  National  Strategy  for  the  Prevention  and  Countering  of 
Corruption  2021-2027  and  the  related  Roadmap  has  continued  unevenly.  Action  has 
been taken on several anti-corruption measures set out in the Strategy, while most measures 
are behind schedule. Measures falling under the Bulgarian RRP and those required under the 
OECD  accession  process  have  been  prioritised68.  There  is  currently  no  monitoring 
mechanism  in  place  to  track  implementation.  So  far,  only  one  annual  report  has  been 
prepared, but not yet adopted, covering the year 2022. Proposals for a mid-term review of the 
Strategy  have  not  been  followed  up.  The  National  Council  for  Anti-Corruption  Policies 
(NCACP) has not convened since October 202369. In addition, a recent report by the National 
Audit  Office  (NAO)  notes  the  absence  of  a  clearly  designated  authority  responsible  for 
ensuring  continuous  implementation,  as  well  as  the  lack  of  a  monitoring  and  reporting 
mechanism and clear, measurable indicators to assess progress70.  

64   Bulgarian Government (2026), additional written input, p. 17. There is a draft law amending the Criminal 
Procedure Code published for public consultations, and a draft law amending the Civil Procedure Code that 
is being finalised for adoption by the Government.  

65   The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-60), 

66  

relatively high (between 59-50), high (below 50). 
In 2021 the score was 42, while in 2025 the score is 40. 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. 

67   Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025). 
68   This includes inter alia the legislative amendments on the protection of whistleblowers, integrity measures 

in state-owned enterprises and the central administration, and the adoption of a law on lobbying. 

69   Country visit Bulgaria, Secretariat of the National Council for Anti-Corruption Policies. The NCACP is an 
interagency body with advisory, coordination and supervision functions and continuing the operation of the 
NCACP  is  envisaged  under  the  Strategy.  The  Roadmap  tasks  the  NCACP  with  monitoring  the 
implementation of anti-corruption policies and with updating the Strategy. In December 2025, the Minister 
of Justice was appointed as its Chair instead of the Prime Minister. See also Decree No 271 of 3.12.2025. 
70   National Audit Office (2025). The report also cites overlaps between the mission of the NCACP and that of 
the  Rule  of  Law  National  Coordination  Mechanism,  underlining  the  need  to  clearly  delineate  their  tasks. 
Improving the transparency of the work of the NCACP has also been recommended by the OECD. OECD 
(2022), p. 7. 

12 

 
 
 
 
A  new  anti-corruption  law  re-established  the  Anti-Corruption  Commission  and 
provided for stronger guarantees for its independence through a new procedure for the 
appointment of its leadership71. The 2023 anti-corruption law initially established an Anti-
Corruption  Commission  (ACC),  vested  with  exclusive  powers  to  investigate  high-level 
corruption. One of the key elements  of the reform  was the introduction  of a framework for 
the  appointment  of  its  three-member  leadership  through  a  transparent  process  aimed  at 
ensuring  its  political  independence72.  In  July  2025,  fast-track  amendments  removed  the 
requirement  for  a  two-thirds  majority  in  Parliament  for  the  election  of  its  collegial 
leadership73. This removed an important safeguard against political influence over the ACC, 
also highlighted by GRECO74. In January 2026, Parliament adopted legislation repealing the 
anti-corruption  law  and  dissolving  the  ACC75.  The  ACC’s  policy-making,  preventive  and 
investigative functions were transferred to other institutions76. The closure of the ACC by the 
previous  parliamentary  majority  took  place  before  the  2023  reform  could  be  fully 
implemented77.  The  new  Government,  which  took  up  office  in  May  2026,  has  stated  its 
commitment to strengthening the anti-corruption framework78. On 29 May 2026, Parliament 
adopted  a  new  anti-corruption  law  re-establishing  the  ACC  with  stronger  guarantees  for  its 
political  independence.  The  new  ACC  would  be  composed  of  five  members  appointed 
respectively  by  five  different  bodies,  three  of  which  are  independent  from  the  political 
institutions79.  The  law  reinstates  the  ACC’s  preventive  and  investigative  functions.  It  also 
provides  that  the  ACC  will  fully  resume  its  functions  within  three  months  following  the 
appointment  of  at  least  three  of  its  members80.  The  appointment  procedures  have  been 

71   The 2025 Rule of Law Report recommended to Bulgaria to “[e]nsure […] the effective performance of the 
Anti-Corruption  Commission.”  Some  progress  was  previously  assessed  on  this  recommendation  in  2025, 
significant progress in 2024 and no progress in 2023. 

72  See  2025  Rule  of  Law  Report,  Bulgaria,  p.  11.  Two  specific  milestones  concerning  the  Anti-Corruption 
Commission are envisaged under the Bulgarian RRP, namely the milestones 218 and 220. The assessment 
of the Anti-Corruption Commission framework and operationalisation in the Rule of Law report does not 
prejudge the assessment of the fulfilment of the milestones under the Bulgarian Recovery and Resilience 
Plan.  

73   Draft Law 51-554-01-123 of 2 July 2025. The two-thirds majority was ruled unconstitutional in 2024 by the 
Constitutional  Court  in  Decision  No  13 of 26  July 2024  in  case  No  1/2024.  Parliament moved  swiftly  to 
apply the new  procedure, whereby Parliament and CSOs had seven days to propose  candidates that were 
then  assessed  by  an  independent  nomination  committee  in  view  of  presenting  a  non-binding  ranking  of 
candidates to Parliament. The nomination committee adopted its assessment report on 27 August 2025 but 
the procedure did not advance further. Report 51-553-120-12 of 27.08.2025.  

74   GRECO (2025). 
75   See Bulgarian Institute for Legal Initiatives (2026). 
76   See SG No 16 of 10 February 2026 promulgating the law adopted on 28 January 2026. In its written input, 
the  Bulgarian  Government  considered  that  the  investigative  activities  of  the  ACC  could  not  be  properly 
assessed  due  to  the  short  time  period  since  the  entry  into  force  of  the  2023  law.  Bulgarian  Government 
(2026), written input, pp.13-15. Country visit Bulgaria, Anti-corruption Commission. 

77   The closure was neither preceded by public consultation, nor supported by an in-depth analysis or impact 
assessment.  Draft  bills  introduced  by  members  of  Parliament  do  not  need  to  be  accompanied  by  impact 
assessment. 

78   Press release of the Council of Ministers.  
79   SG No 51 of 5 June 2026 promulgating the law adopted on 29 May 2026. The five appointing institutions 
are the Parliament, the President, the Supreme Administrative Court, the Supreme Court of Cassation, and 
the Supreme Bar Council. Under the previous legislation, the leadership of the ACC was comprised of three 
members, to be appointed by Parliament following an assessment of candidates by a nomination committee. 
See 2025 Rule of Law Report, Bulgaria, p.11. 

80   Alinea 3, paragraphs 3 and 4 of the final and transitional provisions provide that the appointment or election 
of the leadership of the ACC by the responsible institutions needs to take place within a month of entry into 
force of the law.  

13 

 
 
 
 
launched  by  all  five  bodies.  Following  the  adoption  of  a  new  anti-corruption  law,  which 
provides  for  stronger  guarantees  for  political  independence  of  the  ACC  than  the  previous 
legal framework, there has been some progress as regards the part of the recommendation on 
the functioning of the ACC.  

There  has  been  no  progress  in  establishing  a  robust  track-record  of  investigations, 
prosecutions and final judgements in high-level corruption cases81. In 2025, the Supreme 
Court  of  Cassation  delivered  five  judgments  in  corruption  cases  involving  a  high-level 
official, one of which was final82. According to the latest annual activity report on combating 
corruption of the prosecution service, there were 54 new pre-trial proceedings, 13 indictments 
and  one  judgement  concerning  high-level  officials  in  202583.  Recent  improvements  to  the 
criminal  law  framework  aim  to  address  previous  challenges  related  to  criminal  procedures, 
such  as  problems  related  to  the  overly  formalistic  procedures  to  extend  the  deadlines  for 
criminal  investigations.  However,  stakeholders  continue  to  express  concerns  that  the 
prosecution is largely ineffective, as charges are not brought or inadequately pursued, even in 
cases  supported  by  well-substantiated  reports  or  publicly  available  evidence84.  They  also 
consider that investigations and prosecutions in high-level corruption cases are initiated in an 
arbitrary and selective manner85. Prosecutors identify frequent changes to the regulatory and 
institutional  framework,  often  without  prior  impact  assessment,  as  a  key  challenge  to  their 
performance. In this regard, the closure and subsequent re-establishment of the ACC give rise 
to concerns as regards the continuity of ongoing investigations86. Furthermore, the expiry of 
the  mandate  of  the  previous  interim  Prosecutor  General  affected  criminal  proceedings,  as 
courts did not re-open cases in which they considered that he had not legitimately exercised 
the function of interim Prosecutor General87. As further concrete steps are needed to establish 
a  robust  track  record  of  investigations,  prosecution,  and  final  judgments  in  high-level 
corruption  cases,  there  has  been  no  progress  yet  on  the  implementation  of  this  part  of  the 
recommendation. 

to 

implement 

legislative  amendments  were  adopted 

Several 
international 
recommendations  on  foreign  bribery.  The  Criminal  Code,  the  Criminal  Procedure  Code 
and  the  Administrative  Violations  and  Penalties  Act  were  all  amended  between  July  and 
November 2025 to address gaps in the definition of the offence of bribery and to strengthen 
the procedural rules governing  the liability of legal  persons88. The criminal  liability regime 
and  the  level  of  criminal  sanctions  for  bribery  of  foreign  officials  were  aligned  with  those 
applicable to bribery involving local officials. In order to address deficiencies regarding the 
framework  for  the  liability  of  legal  persons  and  ensure  they  may  be  held  accountable,  the 
amendments  also  introduce  the  possibility  to  associate  legal  persons  to  proceedings  for 

81   The  2025  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  […]”.  No  progress  was 
previously assessed on this recommendation in 2025, 2024 and 2023. 

82   Bulgarian  Government  (2026),  additional  input.  Supreme  Court  of  Cassation  (2026).  The  case  was 

terminated due to the deteriorated state of health the defendant.  

83   Prosecution service (2026), pp. 25, 33 and 44. 
84   Anti-corruption Fund (2025). 
85   CSO joint contribution, p. 12. Country visit, Bulgarian Institute For Legal Initiatives, Anti-Corruption Fund 
Foundation, Institute  For  Market  Economics,  Center  For  The  Study  Of  Democracy,  Initiative  Justice  For 
All. Bulgarian Government (2026), additional written input, p. 24. 

86   Country visit Bulgaria, Association of Prosecutors.  
87   Bulgarian Judges Association (2026), written input 2. 
88   OECD (2023); OECD (2021). SG No61, No65 and No97 of 2025. 

14 

 
 
 
 
corruption offences under the Criminal Procedure Code89. This remains to be complemented 
by  measures  addressing  a  number  of  outstanding  issues,  such  as  internal  controls  and 
compliance  programmes  by  the  private  sector,  measures  to  prevent,  detect  and  sanction 
foreign bribery in public procurement, and the low level of enforcement and detection90. 

Cooperation  between  national  authorities  competent  for  the  fight  against  corruption 
has been further strengthened. Operational cooperation between national law enforcement 
authorities, including the Ministry of Interior, and the prosecution service, is reportedly good. 
Cooperation  between  the  prosecution  and  the  State  Agency  for  National  Security  and  the 
State  Financial  Inspection  Agency  has  been  strengthened91.  The  EPPO  also  reports  that 
cooperation with the Bulgarian authorities is overall effective and timely. The EPPO reported 
17 corruption cases among its open cases in Bulgaria in 202592. In February 2026, the EPPO 
College  found  the  Bulgarian  European  Prosecutor  guilty  of  serious  misconduct  following 
disciplinary  proceedings  for  possible  involvement  in  activities  that  may  have  compromised 
her independence93.  

Measures  to  strengthen  integrity  in  the  police  and  the  judiciary  continue,  while  the 
Inspectorate to the Supreme Judicial Council no longer exercises its full powers. On 20 
May 2026, the Ministry of Interior adopted a Programme for the Prevention and Countering 
of  Corruption  (2026–2028),  setting  out  the  medium-term  priorities  and  measures  for 
strengthening  integrity  and  preventing  corruption  within  the  Ministry,  in  line  with  GRECO 
recommendations94.  In  June  2025,  a  new  Integrity  Testing  Instruction  was  adopted  and 
strategic  corruption  risk  assessments  were  carried  out  for  high-risk  areas.  Regular  trainings 
on  integrity  and  anti-corruption  standards  continue95.  However,  according  to  GRECO,  the 
operational  independence  of  the  police  from  the  Ministry  remains  insufficient96.  In  this 
respect,  the  national  authorities  maintain  that  operational  independence  is  ensured,  as 
investigative authorities are required to act independently, objectively and solely on the basis 
of the law, under the supervision and direction of a prosecutor issuing binding instructions97. 
A  working  group  had  previously  prepared  draft  legislative  amendments  reinforcing  the 
operational independence of the police from the Ministry, but it did not advance further98. As 
regards  the  judiciary,  the  ISJC  exercises  limited  powers  since  a  ruling  of  the  Court  of 

89   Bulgarian Government (2026), written input, pp.25-26. This concerns Article 83a of the Act.  
90   See 2025 Rule of Law Report, Bulgaria, p. 13, OECD (2023). 
91   Bulgarian Government (2026), written input, p. 15.  
92   EPPO (2026), p. 15. 
93   EPPO (2026) News item.  
94   Bulgarian Government (2026), additional written input. 
95   Bulgarian  Government  (2026),  written  input,  p.  17.  Ethical  rules  and  standards  are  part  of  the  training 
provided  by  the  Ministry  of  Interior  Academy  and  the  specialised  police  training  centres.  Corruption 
prevention measures continue to be implemented in the area of border and traffic control, including video 
surveillance, announced and unannounced inspections and rotation of staff. 

96   GRECO (2022), p. 39 and GRECO (2025) p. 18-19. GRECO noted that while the police is clearly a body of 
the  executive,  it  is  nevertheless  important  to  make  an  organisational  distinction  between  the  ministry  in 
charge  of  the  police  and  the  functions  of  the  Police,  including  articulating  clearly  the  principle  of 
operational independence of the Police in individual cases would be of paramount importance.  

97   Under Article 3 of the Law on the Ministry of Interior, the activity of the ministry is to be carried out in 
respect of a number of principles, including the principle of political neutrality, objectivity and impartiality. 
98   GRECO  (2025).  Work  on  the  implementation  of  the  outstanding  recommendations  is  ongoing  in  several 

working groups. Country visit Ministry of Interior. 

15 

 
 
 
 
Justice99.  In  particular,  it  no  longer  exercises  powers  related  to  proposals  for  disciplinary 
sanctions  or  integrity  checks.  The  Inspectorate  has  published  an  analysis  of  good  and  bad 
practices  in  ethics  compliance,  containing  proposals  to  strengthen  the  integrity  of  the 
judiciary and effectively countering corruption. In 2025, the ISJC opened six inspections for 
checks related to conflicts of interest, actions that undermine the prestige of the judiciary and 
violations of the principle of independence, none of which led to disciplinary proceedings100. 
In  May  2026,  the  Ministry  of  Justice  adopted  a  framework  governing  the  exercise  of  the 
Minister’s power to propose candidates for key senior positions in the judiciary, which aims 
to ensure transparency and predictability101.  

Efforts  are  under  way  to  strengthen  the  integrity  of  persons  with  top  executive 
functions102. An interdepartmental working group has prepared a draft Code of Conduct for 
persons  with  top  executive  functions  and  related  draft  amendments  to  the  Law  on 
Administration103.  The draft  Code contains principles  of integrity, rules of  professional  and 
anti-corruption  conduct,  rules  for  receiving  gifts  and  privileges  and  relations  with  interest 
representatives. The draft  legislative amendments propose  a supervisory  mechanism for the 
implementation of the Code, the appointment of an integrity adviser and provide for sanctions 
and enforcement tools104. The draft law and Code of Conduct have not yet been approved by 
the  Government  or  submitted  to  public  consultation.  As  a  result,  integrity  standards  within 
the Government remain fragmented. Steps remain to be taken to ensure sufficient functional 
independence of internal inspectorates, as recommended by GRECO105. In this regard, draft 
amendments  to  the Civil Servants  Act  seek to  strengthen the independence of inspectorates 
by  prohibiting  the  delegation  by  the  Minister  of  their  administrative  powers  over  the 
employees  of  the  inspectorates  to  other  senior  public  officials  who  could  interfere  with  the 
inspectorates’  work106.  Furthermore,  rules  on  integrity  checks  and  on  incompatibilities  of 
persons hired as advisers to senior political officials remain to be introduced107. In light of the 
above,  while  some  steps  have  been  taken,  only  limited  progress  was  made  on  this 
recommendation. 

99   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. 

100   Bulgarian Government (2026), written input, p. 16-17. Of these six cases, four were terminated for lack of 
sufficient  evidence  of  an  infringement,  one  was  deemed  inadmissible  and  one  was  concluded  with  a 
decision  to  send  the  materials  on  it  to  the  superior  administrative  head  and  to  the  Minister  of  Justice  for 
further assessment.  

101  Bulgarian Government (2026), additional written input, pp. 8-9. The standard defines the professional and 
leadership qualities expected of candidates, an assessment methodology based on objective and measurable 
indicators, and a competitive procedure ensuring comparability and publicity. 

102   The  2025  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”.  No  progress  was 
previously assessed on this recommendation in 2024, and limited progress in 2025. 

103   The  working  group  established  by  order  of  the  Prime  Minster  included  representatives  of  the  Chief 
Inspectorate, heads of inspectorates under the Administration Act, and representatives of two NGOs that are 
members of the Civil Council to the National Council on Anti-Corruption Policies.  

104   Country visit, Chief Inspectorate to the Council of Ministers. 
105   GRECO (2025), p. 12. In this respect, the Chief Inspectorate reports that it  – along with other ministerial 
inspectorates  –  does  not  have  the  appropriate  functional  independence  to  effectively  exercise  its  control 
powers,  as  it  is  under  direct  administrative  subordination  to  the  Prime  Minister  or  relevant  Minister. 
Country visit, Chief Inspectorate to the Council of Ministers. 

106  The  draft  Article  6(3)  of  the  Civil  Servants  Act  has  been  submitted  to  public  consultation  until  12  July 

2026.   

107   GRECO (2025). See also 2025 Rule of Law Report, Bulgaria, p. 17. 

16 

 
 
 
 
Doubts remain over the effectiveness of rules on asset and interest disclosure for public 
officials, and the impact of the temporary transfer of related functions to the National 
Audit  Office  (NAO)  remains  to  be  assessed.  Before  its  closure,  the  Anti-Corruption 
Commission (ACC) continued fulfilling its tasks as regards verification of assets and interest 
declarations.  In 2025, the ACC referred two  cases to  the National  Revenue Agency  and 30 
cases  to  the  Commission  for  Illegal  Assets  Forfeiture  CIAF  for  detected  inconsistencies108. 
Following  the  submission  of  410  reports  of  conflicts  of  interest,  the  ACC  concluded  that 
conflicts existed in 24 cases109. Following the closure of the ACC, this task was transferred to 
the  NAO110.  In  April  2026,  NAO  informed  that  in  the  first  quarter  of  2026,  reports  of 
conflicts  of  interest  increased  over  two-fold  compared  to  the  same  period  in  2025111.  The 
newly  adopted  anti-corruption  law  re-establishing  the  ACC  also  reinstates  its  asset  and 
interest declaration verification powers. In addition, the law provides for the establishment of 
a publicly accessible system for electronic submission and analysis of the declarations, to be 
maintained by the ACC112. No steps have been taken to appoint the five-member leadership 
of  the  Commission  for  Illegal  Asset  Forfeiture,  which  also  has  important  functions  in  the 
verification of assets and interest, once significant discrepancies are detected.  

The  newly  adopted  legislation  on  transparency  of  lobbying  exempts  important 
categories  of  interest  representatives  from  the  registration  requirements.  The  law  on 
transparency  of  lobbying  activities  was  adopted  in  March  2026,  following  a  public 
consultation in January 2026113. It covers any communication with members of the legislative 
and  executive  branches,  as  well  as  of  local  government,  aimed  at  influencing  decision-
making.  The  law  requires  the  public  institutions  concerned  to  publish  information  about 
exchanges with interest  representatives in the context of decision-making and to maintain a 
public calendar of meetings with interest representatives linked to the transparency register. It 
also  provides  for  the  adoption  of  a  code  of  ethics  for  interest  representatives  and  sets  up  a 
transparency register to be managed by the NAO, which would also be empowered to impose 
sanctions  in  case  of  non-compliance114.  The  procedure  for  entering  and  modifying 
information  in  the  register  will  be  established  by  an  ordinance  of  the  Minister  of  Justice. 
During  the  first  year  of  the  transparency  register’s  operation,  no  fines  or  penalty  payments 

108   In 2025, a total of 17 489 declarations were submitted to the ACC. Bulgarian Government (2026), written 

input, p. 34.  

109   Bulgarian Government (2026), written input, Annex 8, pp. 1-2.  
110   This departed from common institutional practice. In general, supreme audit institutions across EU Member 
States do not themselves have formal anti-corruption policy or enforcement powers but may contribute to 
anti-corruption indirectly through audit, reporting and integrity-related functions. International Organisation 
of Supreme Audit Institutions (2019). 

111   NAO  (2026).  In  the  first  quarter  of  2026,  246  signals  of  conflicts  of  interest  were  submitted  to  NAO 
compared  to  100  for  the  same  period  in  2025.  A  conflict  was  effectively  established  in  4  cases  as  of  11 
April 2026. Signals concern primarily elected officials at the local level, as well as (increasingly so) at the 
central level.  

112   Article 63(7) and (12) of the law.  
113   See SG No 30 of 27 March 2026 promulgating the law on transparency of interest representation. The draft 
was  elaborated  in  a  working  group  set  up  by  the  Ministry  of  Justice,  with  the  participation  of  relevant 
stakeholders and in consultation with the OECD and the European Commission. Under the RRP legislative 
measures shall be adopted to regulate lobbying activities in the context of public decision-making.  

114  The  Government  explains  this  choice  with  the  independence  and  public  trust  in  the  NAO,  as  well  as  its 
successful performance of similar functions  under other special laws, pursuant to which, for instance, the 
Unified Public Register of Parties, Coalitions, and Initiative Committees is established within NAO.  

17 

 
 
 
 
 
will be imposed115. While the law is broadly aligned with relevant international and European 
standards,  the  extensive  exemptions  from  the  obligation  to  register  raise  concerns116. 
Stakeholders  highlight  that  overall  the  law  imposes  the  highest  administrative  burden  on 
smaller  non-governmental  organisations  and  had  expressed  a  preference  for  a  different 
institutional set-up117. 

Audits on political  party and campaign financing continue. In 2025, the National  Audit 
Office (NAO) adopted two audit reports concerning the financial activities of political parties 
and  three  audit  reports  on  the  financing  of  election  campaigns118.  The  most  frequent 
violations include failure to submit information or late submission, the names of candidates 
and the amount of funds provided by them, or declarations of origin of donated or provided 
funds above the applicable threshold. No irregularities gave rise to suspicion of a crime. Ten 
penalty notices were issued for violations of the Electoral Code119. One political party failed 
to  submit its annual  accounts for a second time and NAO informed the prosecution service 
thereof120.  In  the  context  of  the  parliamentary  elections  held  in  April  2026,  the  Ministry of 
Interior  received  2  974  reports  of  irregularities,  including  corruption-related  ones.  This  has 
led to the initiation by the Ministry of a total of 614 pre-trial proceedings121.  

The  whistleblowing  legislative  framework  is  in  place,  while  effective  implementation 
requires  further  action122.  In  2025,  the  Commission  for  Personal  Data  Protection  (CPDP) 
received  115  whistleblower  reports  and  referred  fifteen  reports  to  the  Anti-Corruption 
Commission123. According to the Ombudsman’s latest audit of the CPDP, the latter does not 
provide automatic identity  protection as a rule but  only  when specifically requested124. The 
audit  also  reveals  human  resource  shortages,  absence  of  detailed  procedures  on  corrective 
measures, limited effective support for whistleblowers, and delays in the recording of signals 
and  their  referral  to  the  competent  authorities.  These  issues  highlighted  in  the  audit  risk 
undermining  the  effective  protection  of  whistleblowers  in  practice.  Moreover,  civil  society 
organisations (CSOs)  note that obstacles to  reporting remain125. Civil society considers that 

115  Bulgarian Government (2026), additional written input.  
116   In particular, the law exempts all professional organisations, acting in the interests of their members, from 
the registration requirement, as well as participants in working groups or consultative bodies, set up by state 
bodies. 

117   Country visit Bulgaria, Bulgarian Institute For Legal Initiatives, Anti-Corruption Fund Foundation, Institute 
For Market Economics, Center For The Study Of Democracy, Initiative Justice For All. CSOs maintain that 
the transparency register should be managed by the Registry Agency rather than the National Audit Office, 
due to risks of politicisation, and the proportionality of the penalties. BILI et al (2026). 

118   National Audit Office, Audit reports No 0600100224, No 0600100325, No 0600100824, No 0600101624 

and No 0600200924. 

119   Bulgarian Government (2026), written input, p.19. 
120   National Audit Office (2026). 
121   Press service of the Ministry of Interior (2026) and Bulgarian Government (2026), additional written input, 
p.29.  Of  all  these,  72  cases  submitted  to  the  prosecution  service  involved  candidates  for  Members  of 
Parliament. Seized amounts for suspected vote-buying surpassed EUR 1 million. See also BTA (2026).  

122   See milestone 217 of Bulgaria’s RRP on the legal framework related to whistleblowing. 
123   The  CPDP  is  the  Central  Authority  for  External  Reporting  under  the  Whistleblower  Protection  Act  and 
pursuant to that Act, the Ombudsman institution has a duty to inspect the CPDP and ensure that it complies 
with its statutory obligations under that Act. CPDP (2026), pp. 139-140.  

124   The protection of a whistleblowers’ identity is a key element of the protection of whistleblowers and it may 
only  be  disclosed  exceptionally,  only  when  necessary  and  proportionate.  Ombudsman  Institution  (2025), 
Press item. 

125   Country  visit,  Bulgarian  Institute  For  Legal  Initiatives,  Anti-Corruption  Fund  Foundation,  Institute  For 
Market Economics, Center For The Study Of Democracy, Initiative Justice  For All.  Obstacles mentioned 

18 

 
 
 
 
the  latest  amendments  to  the  law  have  not  facilitated  anonymous  reporting,  which  could 
incentivise reporting and improve safety for whistleblowers126.  

Public  procurement  remains  an  area  at  high  risk  of  corruption  and  a  number  of 
in  the  energy  sector,  road 
investigations  point  to  increased  corruption  risks 
infrastructure and waste management. Corruption continues to be perceived as one of the 
main barriers for businesses in a survey conducted by the Bulgarian Industry Association127. 
Businesses’ attitudes towards corruption in the EU show that 53% of companies in Bulgaria 
(EU average 30%) think that corruption has prevented them from winning a public tender or 
a  public  procurement  contract  in  practice  in  the  last  three  years128.  Moreover,  only  21%  of 
companies  perceive  the  level  of  independence  of  the  public  procurement  review  body 
(Commission  on  Protection  of  Competition)  as  ‘very  or  fairly  good’  when  it  is  reviewing 
public procurement cases129. The Single Market  and Competitiveness  Scoreboard on access 
to  public  procurement  in  Bulgaria  reports  41%  of  single  bids  for  2025  (EU  average  27%). 
Public procurement remains one of the most vulnerable areas of activity130. In April 2026, to 
increase  transparency  of  public  procurement,  the  Ministry  of  Finance  launched  a  database 
covering  nearly  7  000  active  tenders  for  a  total  amount  of  over  EUR  30  billion131.  Other 
vulnerable  areas  concern  control  activities  and  the  provision  of  administrative  services, 
management  of  public  property,  concessions,  issuing  of  permits,  licensing  and  registration 
regimes,  as  well  as  sports.  Recent  investigations  conducted  by  the  EPPO  and  reports  by 
CSOs,  and  investigative  journalists  raise  specific  concerns  about  corruption  risks  in  the 
energy  sector132.  In  the  healthcare  sector,  risks  of  misuse  of  funding  arise  in  relation  to 
legislation  that  allows  private  hospitals  to  bypass  procurement  rules  when  purchasing 
medicines  paid  under  the  National  Health  Insurance  Fund133.  Finally,  concerns  about 
corruption  have  also  arisen  with  regard  to  road  infrastructure  and  waste  management134. 
Measures  aiming  to  mitigate  corruption  risks  include  the  preparation  of  legislative 
amendments regarding integrity checks for civil servants in positions of high corruption risk 
in  the  central  administration  and  measures  to  strengthen  integrity  in  state-owned 

include low levels of awareness about the protection regime, limited confidence in reporting mechanisms, a 
reluctance to report due to fear of retaliation, inadequate penalties for violations and an overall culture of 
silence. See 2025 Rule of Law Report, Bulgaria, p. 16. 

126   Joint contribution by CSOs, p.16. This is as such not required by Directive (EU) 2019/1937, which leaves it 

to Member States to decide whether to oblige entities to follow up on anonymous reports. 

127   Survey  conducted  by  the  Bulgarian  Industrial  Association  in  December  2025,  among  847  micro,  small, 
medium  and  big  companies  in  Bulgaria.  It  shows  that  50%  of  the  respondents  consider  corruption  as  a 
major barrier for businesses. 

128   Flash  Eurobarometer  557  on  Businesses’  attitudes  towards  corruption  in  the  EU  (2025).  This  is  23 

percentage points above the EU average. 

129   Figure 59, 2026 Justice Scoreboard. 
130   ACC (2025), National Audit Office, written contribution and country visit, Chief Inspectorate. CSOs also 

pointed to the 15-year concession of the national lottery as an example. 

131   Ministry  of  Finance  (2026).  This  followed  the  initiation  of  investigations  into  several  very  high-priced 
procurement  contracts  related  to  road  infrastructure  and  healthcare,  due  to  suspected  irregularities.  BTA 
(2026), Euractiv (2026). 

132   BTA (2024). Anti-Corruption Fund (2025). Follow the Money (2026). 
133   Bulgarian legislation currently excludes certain privately owned medical establishments from the scope of 
EU procurement rules, even when they receive more than 50% of their financing from public funds. This 
exception  exists  since  2016  and  has  created  risks  for  misuse  of  public  funds.  In  December  2025,  the 
Commission  decided  to  refer  Bulgaria  to  the  CJEU  for  breach  of  EU  procurement  rules.  A  legislative 
amendment is pending adoption in Parliament. See (INFR(2018)2268). 
134   See also bTV (2025). Free Europe 52025-Waste management contracts. 

19 

 
 
 
 
enterprises135. 

III.  MEDIA PLURALISM AND MEDIA FREEDOM  

Actions  taken  by  the  previous  chairperson  of  the  Council  for  Electronic  Media  are 
viewed  positively,  while  concerns  were  raised  about  internal  conflicts  on  decision-
making.  The  appointment  procedure  for  members  of  the  Council  for  Electronic  Media 
(CEM)  is  a  shared  competence  between  Parliament  and  President  of  Bulgaria136.  The 
prevailing view among current members of the CEM is that the regulator has functioned well 
since the election of its previous chairperson for a one-year term in April 2025137. This view 
is  shared  by  the  National  Council  for  Journalistic  Ethics,  which  highlights  the  concrete 
actions taken by the chairperson to advocate for the quality of legislation and the interests of 
the  media  and  journalists138.  However,  concerns  have  been  raised  by  the  2026  Media 
Pluralism  Monitor  and  other  stakeholders  regarding  internal  conflicts  on  decision-making, 
which  have  contributed  to  the  delay  in  the  election  of  a  new  Director-General  for  the 
Bulgarian National Television (BNT)139. This has prompted concerns also from stakeholders 
regarding possible damage to the CEM’s reputation and attempts to discredit the regulator140. 
In  April  2026,  the  CEM  elected  a  new  chairperson,  who  was  proposed  by  the  previous 
chairperson and another member of the Council141. While the CEM notes that it continues to 
face systematic budgetary challenges, it received additional Government funding in 2025 to 
cover initial resource needs for implementing new EU legislation142. 

A  new  Director-General  has  been  appointed  to  the  Bulgarian  National  Television 
(BNT),  and  legislative  reforms  are  underway  to  improve  the  independence  of  public 
service  media.  After  a  series  of  unsuccessful  selection  procedures  and  legal  appeals  in  the 
past three years, the CEM elected a new Director-General of the BNT in February 2026143. 
The  CEM  has  subsequently  also  approved  the  new  composition  of  the  BNT  Management 
Board,  replacing  three  members  elected  in  2019144.  Notwithstanding  these  developments, 
stakeholders  raised  concerns  about  the  lack  of  legislative  safeguards,  notably  those 
preventing the Director-General's term from being extended indefinitely, and how this could 

135   See milestone 226a of the Bulgarian RRP. The assessment related to the topic of milestone 226a 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.  The  draft  amendments  to  the  Civil  Servant  Act  provide  for  the 
identification  of  positions  exposed  to  high  corruption  risk  in  the  central  executive  branch  and  integrity 
testing.  Tools  to  counter  corruption  in  state‑owned  enterprises  include  the  obligation  to  implement 
corruption  risk  management  systems  covering  the  selection  of  senior  officials,  conflict  of  interest 
prevention  measures,  a  methodology  for  assessing  and  controlling  corruption  risks,  ethics  and  integrity 
training, the appointment of an integrity officer and the adoption of a Code of conduct. 

136   2025 Rule of Law Report, Bulgaria, p. 17; Country visit Bulgaria, CEM. 
137   Country visit Bulgaria, CEM. 
138   NSW (2026), written input. 
139   2026  Media  Pluralism  Monitor  report  on  Bulgaria,  p.  19;  Country  visit  Bulgaria,  CEM,  AEJ-Bulgaria, 

NSW, MFD, AIP. 

140   Country  visit  Bulgaria,  AEJ-Bulgaria,  NSW,  MFD,  AIP;  AIP,  ACF,  AEJ-Bulgaria,  BCNL,  BDF,  BHC, 

BILI, CSD, Deystvie, IME (2026), written input, pp. 22-23. 

141   CEM website (2026c). 
142   CEM (2026), additional written input. 
143   CEM  (2026), additional written input; CEM  website (2026b); 2025 Rule of Law  Report, Bulgaria, p. 18. 
The previous Director-General requested the suspension of the appointment, but his request was dismissed 
by the  Sofia Administrative Court.  Ruling of the Sofia Administrative Court in Case No. 211/2026 of 24 
February 2026. 

144   CEM (2026), additional written input [in the context of the country visit]; CEM website (2026a). 

20 

 
 
 
 
undermine the independence of the public broadcaster145. In addition, the CEM reported that 
pressure  from  the previous Director-General  restricted its  ability to  fulfil its  function in  the 
selection  process  of  the  new  Director-General146.  While  no  laws  have  yet  been  adopted  to 
improve the independence of public service media, provisions are expected in the upcoming 
draft law amending the Radio and Television Act (RTA)147.  

Legislative  reforms  are  underway  to  address  some  of  the  remaining  shortcomings 
regarding  the  enforcement  of  media  ownership  disclosure  obligations.  The  CEM 
continues  to  work  with  the  Ministry  of  Culture  to  strengthen  the  legislative  framework  on 
transparency of media ownership, particularly as regards beneficial ownership and state and 
public  ownership148.  Moreover,  in  addition  to  the  CEM’s  public  register  covering  media 
ownership of radio and audiovisual media service providers, the Ministry of Culture currently 
keeps  a  public  register  based  on  declarations  made  by  any  media  outlet  of  its  beneficial 
ownership and public funding149. While the CEM confirms its monitoring of compliance by 
radio  and  audiovisual  media  service  providers  and  subsequent  sanctioning  of  violations150, 
stakeholders  continue  to  raise  concerns  about  inconsistencies  in  media  companies’ 
compliance  with  ownership  transparency  obligations,  particularly  as  regards  beneficial 
owners151. In view of these concerns, the Media Pluralism Monitor has increased its risk level 
for transparency of media ownership to medium-high152. Concerns also continue to be raised 
about  a  lack  of  ownership  disclosure  by  online  media  services  who  appear  to  be  under 
political influence153. 

There has been some further progress on the recommendation to improve transparency 
in  the  allocation  of  state  advertising154.  Under  the  draft  law  amending  the  RTA,  media 
service providers are required to publish information on their public advertising revenues155. 
Furthermore,  the  Ministry  also  envisages  amendments  to  the  Public  Procurement  Act156, 
which  would  require  contracting  authorities  to  publish  information  on  their  annual  public 
advertising  expenditure  and  empower  the  CEM  to  compile,  assess,  and  analyse  this 
information157.  The  Ministry  of  Culture  is  also  reviewing  its  internal  administrative 
procedures  in  line  with  the  existing  regulatory  framework  with  a  view  to  improving 

145   Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP; Amnesty International – Bulgaria (2026), written 

input, p. 23. 

146   Country visit Bulgaria, CEM. 
147   The draft law amending the RTA is expected to be finalised by the end of May 2026, after which it will be 
coordinated with the relevant ministers and published for publish consultation. The expected provisions will 
address  editorial  and  functional  independence,  appointment  and  dismissal  procedures,  and  the  financial 
framework of public service media. Country visit Bulgaria, Ministry of Culture; Ministry of Culture (2026), 
written input. 

148   Country visit Bulgaria, CEM. 
149   Country visit Bulgaria, CEM. 
150   Country visit Bulgaria, CEM. 
151   AIP, ACF, AEJ-Bulgaria, BCNL, BDF, BHC, BILI, CSD, Deystvie, IME (2026), written input, p. 24. 
152 2026 Media Pluralism Monitor report on Bulgaria, p. 23. 
153   Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP. 
154   The  2025  Rule  of  Law  Report  recommended  Bulgaria  to  “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”.  Some  progress  was  previously  assessed  on  this 
recommendation in 2025, 2024, and 2023. 

155   Bulgarian Government (2026), written input, p. 34; Ministry of Culture (2026), written input, p. 2. 
156   No confirmed timeline is available at this point. Ministry of Culture (2026), additional written input. 
157   Ministry of Culture (2026), written input, p. 2. 

21 

 
 
 
 
including  state  advertising  contracted 

through 
transparency  of  state  advertising, 
intermediaries158. Stakeholders report that while the Ministry of Tourism continues to publish 
monthly  reports  of  its  advertising  expenditure  on  very  large  online  platforms  and  search 
engines159, other state  actors have not  implemented their  obligations on the transparency of 
their  state  advertising  expenditure160.  Given  the  ongoing  work  on  legislative  reforms,  there 
has been some progress on the recommendation. 

Indications  regarding  political  and  economic  influence  over  the  media  remain161. 
Stakeholders  note  that  private  business  interests  and  ties  to  political  actors  continue  to 
influence  the  editorial  policies  of  many  private  media  outlets162.  Concerns  have  also  been 
raised  about  how  political  influence  over  ownership  structures  and  distribution  of  state 
advertising  could  lead  to  self-censorship  and  limit  independent  reporting.  These  risks  are 
noted to  be particularly  high  for smaller  outlets,  at  local  and regional  levels,  which rely  on 
public  contracts  as  their  main  source  of  funding163.  Furthermore,  cases  have  been  reported 
where  media  contracted  by  public  authorities  were  explicitly  forbidden  from  publishing 
content  that  would  be  damaging  to  their  reputation164.  The  abovementioned  draft  law 
amending  the  RTA  is  expected  to  further  empower  the  regulator  to  assess  the  impact  of 
market concentrations on media pluralism and independence165. In addition, the amendment 
to  the  Competition  Protection  Act  (CPA),  effective  from  7  November  2025,  requires  the 
opinion  of  the  CEM  to  be  considered  in  decisions  to  approve  or  reject  media  market 
concentrations166. 

Some legislative initiatives with possible adverse impact on public access to information 
have  been  undertaken.  Stakeholders  have  raised  concerns  regarding  various  legislative 
initiatives with  possible negative effects  on access  to  official  information.  First,  a draft law 
amending the Access to Public Information Act (APIA), submitted for public consultation in 
July  2025167.  It  was  criticised  by  stakeholders  for  including  provisions  that  could  lead  to  a 
restricted application of the national law. Such provisions included the repeal of an obligation 
for  mandatory  online  publication  of  information  by  public  bodies  and  new  definitions  that 
could  limit  the  scope  of  available  information168.  In  October  2025,  an  amendment  to 
criminalise  the  publishing  of  information  about  private  life  was  proposed  to  the  Criminal 
Code  to  deter  violations  of  privacy169.  The  amendment  was  later  withdrawn  after  strong 
opposition from experts, civil society organisations and media, who warned that it could be 

158   Ministry of Culture (2026), written input, p. 2. 
159   2025 Rule of Law Report, Bulgaria, p. 19; Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP. 
160   Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP. 
161   2025 Rule of Law Report, Bulgaria, p. 19. 
162   The decision of a leading private television broadcaster to dismiss a journalist and tv-host following critical 
political  interviews  in  late  2025  has  been  widely  raised  as  an  example.  Country  visit  Bulgaria,  AEJ-
Bulgaria,  NSW,  MFD,  AIP;  Council  of  Europe’s  Safety  of  Journalists  Platform  and  the  Media  Freedom 
Rapid Response (2025), p. 10. 

163   Council of Europe’s Safety of Journalists Platform and the Media Freedom Rapid Response (2025), p. 10; 

2026 Media Pluralism Monitor report on Bulgaria, p. 34. 
164   Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP. 
165   Ministry of Culture (2026), written input, pp. 3-4. 
166   Ministry of Culture (2026), written input, p. 2. 
167   Draft Law Amending and Supplementing the Law on Access to Public Information. 
168   AIP, ACF, AEJ-Bulgaria, BCNL, BDF, BHC, BILI, CSD, Deystvie, IME (2026), written input, pp. 25-26. 
169   Draft Law Amending and Supplementing the Criminal Code. 

22 

 
 
 
 
used to  censor legitimate journalism170. The Media Pluralism Monitor noted that  a growing 
number  of  public  institutions  have  expanded  explanatory  guidance  on  their  websites 
regarding procedures for requesting public information, but that on some occasions, refusals 
of access have persisted171. 

There has been a decrease in physical attacks  against journalists in the past year, but 
verbal attacks and online harassment have increased, and legal pressure persists. While 
reports  of  physical  attacks  on  journalists  have  decreased  over  the  reporting  period172,  the 
online environment has become increasingly hostile towards journalists, in particular women 
journalists173.  To  address  these  concerns,  relevant  authorities,  including  the  Ministry  of 
Culture, have taken a series of measures including developing guidelines for handling online 
harassment and raising awareness on media freedom, respectful public discourse, and gender 
equality in journalism174. However, the use of strategic lawsuits against public participation 
(SLAPPs) and other forms  of legal  pressure against journalists175  persists  – with  journalists 
losing several SLAPPs in court in the past year176. The Ministry of Culture intends to build 
capacity  and  raise  awareness  among  legal  practitioners  in  relation  to  SLAPP  cases,  in 
addition to the update of the legal framework, which was published for public consultation on 
16 April 2026 and is planned to cover both domestic and cross-border cases177. The Council 
of  Europe  Safety  of  Journalists  Platform  recorded  four  new  alerts,  one  for  an  attack  on 
physical safety and integrity, one for harassment and intimidation of journalists, and two for 
other acts  having  chilling effects  on media freedom  since July  2025178. In the same period, 
the  Media  Freedom  Rapid  Response  Mechanism  has  reported  nine  alerts,  four  of  which 
concerned  legal  pressure  against  journalists,  three  interferences,  one  verbal  attack,  and  one 
physical assault179. While the Criminal Code was amended in July 2025, to reduce the special 
minimum  fines  for the basic offences of insult  and defamation180, stakeholders  and  flagged 
that  civil  defamation  cases  continue  to  be  filed  with  increasingly  high  compensation 
claims181. Furthermore, stakeholders report worsening working conditions for parliamentary 

170   AIP, ACF, AEJ-Bulgaria, BCNL, BDF, BHC, BILI, CSD, Deystvie, IME (2026), written input, p. 27; Civil 

Liberties Union for Europe (2026), written input, p. 17. 

171   On  such  occasions,  access  has  often  been  refused  on  the  grounds  that  the  requested  information  is  ‘not 
public’, despite the lack of such a limitation in the law. 2026 Media Pluralism Monitor report on Bulgaria, 
p. 16. 

172   Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP. 
173   AIP, ACF, AEJ-Bulgaria, BCNL, BDF, BHC, BILI, CSD, Deystvie, IME (2026), written input, p. 25; 2026 

Media Pluralism Monitor report on Bulgaria, p. 17; 2025 Rule of Law Report, Bulgaria, p. 20. 

174   Ministry of Culture (2026), written input, p. 6. 
175   For example, investigative journalism outlet Bird announced in December 2025 that it had 20 court cases 
pending against it, amounting to over EUR 250,000.  AIP, ACF, AEJ-Bulgaria, BCNL, BDF,  BHC, BILI, 
CSD, Deystvie, IME (2026), written input, p. 29. 

176   AIP, ACF, AEJ-Bulgaria, BCNL, BDF, BHC, BILI, CSD, Deystvie, IME (2026), written input, pp. 28-29. 

Annual Report on the Activities of the Supreme Court of Cassation (2025).  

177   Ministry of Culture (2026), written input, p. 7. The draft law in question amends the Civil Procedure Code 
and  provides  for  early  dismissal  of  manifestly  unfounded  claims,  measures  against  abuse  of  procedural 
rights, specific rules on evidence and security for defendants’ costs. 

178   One  of  the  alerts  was  resolved,  and  the  state  has  replied  to  two  others.  Council  of  Europe,  Platform  to 

promote the protection of journalism and safety of journalists (2026). 

179   Three  of  these  alerts  overlap  with  the  alerts  published  on  the  Council  of  Europe  Safety  of  Journalists 
Platform.  European  Centre  for  Press  and  Media  Freedom,  Media  Freedom  Rapid  Response  –  Bulgaria 
(2025). 

180   Bulgarian Government (2026), written input; Law Amending and Supplementing the Criminal Code. 
181   Country visit Bulgaria, AEJ-Bulgaria, NSW, MFD, AIP; Amnesty International – Bulgaria, written input, p. 

25. 

23 

 
 
 
 
reporters  and  journalists  working  for  online  platforms,  who  have  been  denied  access  to  the 
building of the National Assembly182. 

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

The mandates of most independent and regulatory authorities have been renewed while 
no steps yet have been taken to improve their independence. Since July 2025, most of the 
independent  and  regulatory  authorities  that  required  a  simple  majority  in  Parliament  to 
appoint  their  new  leadership  have  been  renewed183.  However,  the  authorities  that  require  a 
qualified majority vote (two thirds of the members of Parliament) have not been renewed184, 
and vulnerabilities identified in previous editions of the Rule of Law Report remain185 in the 
absence  of  actions  taken  to  strengthen  the  political  independence  of  the  independent  and 
regulatory authorities to improve their resilience and avoid situations in which most of them 
function  with  an  expired  mandate186.  In  two  challenges  before  the  Constitutional  Court 
related  to  recent  appointments  of  the  Deputy  Head  of  the  National  Audit  Office187and  the 
Head  of  the  Commission  for  Personal  Data  Protection188  due  to  the  alleged  lack  of 
qualifications  to  fulfil  their  roles,  the  Court  maintained  that  both  are  lawfully  appointed 
despite the arguments by the members of Parliament189.  

The Constitutional Court did not reach a majority to decide on the constitutionality of 
the  constitutional  reform  limiting  the  powers  of  the  President  in  the  procedure  of 
appointing  an  interim  government.  On  24  July  2025,  the  Constitutional  Court  published 
the ruling on the constitutionality check of the provisions adopted in the 2023 constitutional 
reform,  which  restricted  the  choice  of  the  President  of  the  Republic  when  appointing  an 
interim  government.  The  Court  could  not  reach  the  necessary  majority  to  reach  a  final 
decision190, leaving the provisions in place but susceptible to a new challenge in the future191.  

182   Civil Liberties Union for Europe (2026), written input, p. 17. 
183   Commission  for  Public  Oversight  of  Statutory  Auditors;  Committee  for  disclosing  the  documents  of  the 
for  Protection  against 
State  Security  and 
Discrimination; Ombudsperson; Commission 
for  Personal  Data  Protection; National  Competition 
Authority; National  Social  Security  Institute.  The  Public  Enterprises  and  Control  Agency  and  National 
Council  of  the  Bulgarians  living  abroad  have  not  been  renewed  yet.  In  the  context  of  the  European 
Semester,  the  Commission  has  proposed  that  the  Council  recommend  that  Bulgaria  “strengthen[s]  the 
independence and functioning of regulators.” 

the  Army; Commission 

services  of 

intelligence 

184   Supreme Judicial Council and Inspectorate to the Supreme Judicial Council. The qualified majority consists 

of two thirds of members of Parliament. 
185   See 2025 Rule of Law Report, Bulgaria, p. 21. 
186   Strengthening  the  independence  of  these  authorities  is  a  Country  Specific  Recommendation  to  Bulgaria 
under  the  European  Semester.  See  Council  Recommendation  on  the  economic,  social,  employment, 
structural and budgetary policies of Bulgaria, COM(2025) 202 final, p. 11. Country visit, Bulgaria, Ministry 
of  Justice,  Bulgarian  Judges  Association,  Bulgarian  Institute  For  Legal  Initiatives,  Anti-Corruption  Fund 
Foundation, Institute  For  Market  Economics,  Center  For  The  Study  Of  Democracy,  Initiative  Justice  For 
All. 

187   Constitutional Court, Case No. 10 of 2025. The Court rejected part of the constitutionality request, stating 
that verifying whether the NAO Head could resume their position after serving as interim Prime Minister 
falls under the Anti-Corruption Commission’s remit.  

188   Constitutional Court, Case No. 9 of 2025. 
189   Constitutional Court, Decisions No. 4 and 5 of 2026. 
190   Constitutional  Court  Case  No.  38  and  40  of  2024  –  Decision  No.  9  of  25  July  2025.  The  Constitutional 

Court has 12 justices and there is no tie-breaking mechanism in case of equal votes on decisions. 

191   It  is  noted  that  this  reform  has  been  challenged  already  four  times  before  the  Constitutional  Court.  See 
Constitutional Court Cases No. 3, 4, 38 and 40 of 2024. It should be noted that ENNHRI calls for protection 

24 

 
 
 
 
There  has  been  no  progress  on  strengthening  the  quality  of  the  legislative  process  for 
initiatives  by  members  of  Parliament192.  As  previously  reported, 
the  practical 
implementation of the parliamentary rules for lawmaking continues to raise some concerns193. 
Since  the  majority  of  legislative  amendments  have  been  proposed  directly  by  members  of 
Parliament194,  these  do  not  go  through  the  same  mandatory  procedure  as  government 
initiatives, including as regards impact assessment and public consultations195. According to a 
study prepared by Parliament, in 93% 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% of the draft laws, the arguments and different points of 
view  of  the  stakeholders  were  not  included,  and  in  70%  there  was  no  analysis  on  the 
compatibility of the draft laws with EU law196. The EU Agency for Fundamental Rights also 
noted a lack of consultation strategies for legislative initiatives197. Stakeholders also reported 
that the practice of introducing legislative changes through amendments  to other, unrelated, 
acts  between  the  first  and  the  second  reading  persists198,  as  well  as  the  use  of  accelerated 
procedures on sensitive issues199. Frequent changes to legislation have been flagged as one of 
the  key  barriers  for  businesses200.  Based  on  the  above,  there  has  been  no  progress  on  the 
related recommendation. 

Less than half of companies surveyed in Bulgaria express confidence in the effectiveness 
of investment protection. 47% of companies are very or fairly confident that investments are 
protected by law and courts, which has increased in comparison to 2025 (41%)201. The main 
reasons  among  companies  for  their  lack  of  confidence  is  unpredictable,  non-transparent 
administrative  conduct,  and  difficulty  in  challenging  administrative  decisions  in  court 
(30%)202. As regards authorities relevant for economic operators, 26% of companies perceive 

of  the  independence  of  the  Bulgarian  National  Human  Rights  Institution  (NHRI)  and  its  leadership  by 
removing the Ombudsperson from the institutions in the list of possible interim Prime Ministers.  

192   The 2025 Rule of Law Report recommended Bulgaria to “[s]trengthen the quality of the legislative process 
by  ensuring  the  use  of  public  consultations  and  impact  assessments  for  legislative  initiatives  by 
Parliament.” 

193   Country  visit,  Bulgaria,  Bulgarian  Centre  for  Not-for-Profit  Law,  Deystvie,  Amnesty  International  – 
Bulgaria, Bulgarian Helsinki Committee. See also Joint CSO contribution (2026), written input, pp. 29-30. 
See also 2025 Rule of Law Report, Bulgaria, p. 22. 

194   About 75% of the drafts were tabled by members of Parliament. See National Assembly. Study of the law-

making activity of the National Assembly (November 2024 – January 2026), p. 8.  

195   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.  

196   See  National  Assembly.  Study  of  the  law-making  activity  of  the  National  Assembly  (November  2024  – 

January 2026), pp. 33-48. 

197   EU Agency for Fundamental Rights (FRA) (2026), written input, pp. 8 – 11. 
198   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. 

199   Civil Liberties Union for Europe (2026), p. 20.  
200   Survey  conducted  by  the  Bulgarian  Industrial  Association  in  December  2025,  among  847  micro,  small, 

medium and big companies in Bulgaria.  
201   Figure 52, 2026 EU Justice Scoreboard.  
202   Figure  53,  2026  EU  Justice  Scoreboard.  28%  and  24%  of  the  surveyed  investors  respectively  perceive 
concerns  about  quality,  efficiency  or  independence  of  justice  and  frequent  changes  in  legislation  or 
concerns about the quality of the law-making process as a reason for the lack of confidence in investment 
protection.  

25 

 
 
 
 
the level of independence of the national competition authority (Commission on Protection of 
Competition)  as  very  or  fairly  good,  which  has  significantly  decreased  in  comparison  with 
2025  (34%)  203.  The  Supreme  Administrative  Court  has  jurisdiction  in  several  business-
related  cases,  including  in  cases  related  to  public  procurement,  public  concessions,  public 
contracts and economic regulation. A number of judicial mechanisms to improve efficiency 
in business-related judicial proceedings are available in these cases, including the possibility 
to  apply  interim  measures,  joint  examination  of  similar  cases  and  the  consolidation  of 
multiple appeals204. 

On  1  January  2026,  Bulgaria  had  93  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation,  an  increase  of  4  compared  to  the  previous 
year205.  At  that  time,  Bulgaria’s  rate  of  leading  judgments  from  the  past  10  years  that  had 
been implemented was at 44% (compared to 46% in 2025; 56% remained pending), and the 
average time that the judgments had been pending implementation was 7 years and 4 months 
(compared  to  7  years  and  3  months  in  2025)206.  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  conditions207.  As 
regards the respect of payment deadlines, on 31 December 2025 there were 11 cases in total 
awaiting confirmation of payments (compared to 9 in 2024)208. On 17 June 2026, the number 
of leading judgments pending implementation had remained at 93209. Stakeholders have also 
raised concerns about the non-implementation of Court of Justice judgments210.  

The  Council  for  Civil  Society  Development  remained  operational  during  the  interim 
Government.  The  Council  was  created  in  2022  and  has  functioned  sporadically  due  to  the 
political instability211. Following the election of 14 CSOs as new members of the Council in 
April 2025, its first meeting took place in September 2025. Between this date and December 
2025,  when  the  Government  fell,  the  Council  was  meeting  regularly  and  developing  a  new 
Strategy for the Support of Civil Society Development. The Council met several times during 
the  interim  Government.  Under  the  new  Government,  the  first  meeting  with  the  new 
responsible  Deputy  Prime  Minister  is  yet  to  take  place.  It  should  be  noted  that  since  its 
creation, the Council was unable to fulfil one of its main tasks of designing and launching a 
mechanism to provide financial support for CSOs’ public benefit projects212.  

A draft law banning foreign funding for NGOs and an ad hoc parliamentary committee 
tasked with investigating certain foreign foundations lapsed following the election of a 

203   Figure 60, 2026 EU Justice Scoreboard.  
204   Figures 66 and 67, 2026 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. 

205   For an explanation of the supervision process, see the website of the Council of Europe.  
206   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 2026. EIN (2026), written input, p. 2. 

207   Judgment of the ECtHR, 41035/98, Kehayov v. Bulgaria, pending implementation since 2005.  
208   Council of Europe (2026), p. 162.  
209   Data according to the online database of the Council of Europe (HUDOC). 
210   Joint CSO contribution (2026), written input, pp. 32-33.  
211   2025 Rule of Law Report, Bulgaria, pp. 23-24. 
212   Joint  CSO  contribution  (2026),  written  input,  pp.  35-36.  Although  1  million  BGN  was  allocated  in  the 
national  budget  for  CSO  public  benefit  projects  through  the  Council,  inconsistencies  in  the  regulatory 
framework — identified by the administration of the Council of Ministers  — made the implementation of 
this fund impossible. 

26 

 
 
 
 
new Parliament. Civic space in Bulgaria continues to be rated narrowed by Civicus213. After 
previous  unsuccessful  attempts  to  introduce  legislation  requiring  the  registration  of 
organisations receiving foreign  funding or labelling  organisations as foreign funded214, new 
draft amendments were tabled in October 2025 to introduce a legal ban on NGOs receiving 
foreign  funding. Furthermore, on 5 November 2025, the previous Parliament created a new 
ad hoc committee to  investigate the activities and funding of certain  foreign  foundations in 
the  country.  The  stated  objective  of  the  ad  hoc  committee  was  to  prepare  a  list  of  all 
individuals, legal entities and non-governmental organisations that have received funding or 
have  participated  in  activities  sponsored  by  an  organisation  funded  by  certain  foreign 
foundations215.  Stakeholders  raised  concerns  about  the  possible  impact  on  freedom  of 
association  and  the  overall  chilling  effect  and  stigmatisation  of  foreign  funding  for  civil 
society216.  These  developments  have  however  been  discontinued,  as  following  the 
parliamentary  elections  of  19  April  2026,  all  pending  draft  laws  have  lapsed,  and  all 
committees  have  been  closed.  On  26  June  2026,  a  draft  law  on  the  registration  of  foreign 
agents  was  tabled  in  Parliament  by  a  political  group.  Regarding  the  law  adopted  in  2024 
prohibiting acts related to ‘propaganda for non-traditional sexual orientation’ in schools and 
in their vicinity, stakeholders have reported that they filed a request to the newly appointed 
Ombudsman217  to  challenge  the  constitutionality  of  this  law218,  which  has  had  the  effect  of 
schools  and  teachers  not  engaging  with  CSOs  working  in  the  field  of  LGBTIQ+  rights, 
including on topics such as health219.  

213   Bulgaria’s  score  is  65/100.  Ratings  by  Civicus  are  on  a  five-category  scale  defined  as:  open,  narrowed, 
obstructed, repressed and closed. In this context, cases of harassment of CSOs have been noted, including 
by Government officials. See also Monitoring Action for Civic Space, Country Report, 2025, Bulgaria, pp. 
10-11 and FRA (2026), pp. 42-43 on the statements by the authorities against CSOs.  

214   2025 Rule of Law Report, Bulgaria, p. 24. 
215   Parliament.bg  (2025).  The  members  of  the  ad  hoc  committee  have  met  once  before  the  elections  on  19 

April 2026. 

216   See  Joint  CSO  contribution  (2026),  written  input,  p.  32.  See  also  Monitoring  Action  for  Civic  Space, 
Country Report, 2025, Bulgaria, pp. 10-11. FRA (2026), pp. 41-42. The mandate of the ad hoc committee 
and public messaging around it reinforce the existing narrative that CSOs act on behalf of external interests. 
These  narratives  disproportionately  target  organisations  working  on  human  rights,  migrants’  rights, 
LGBTIQ+ rights and women’s rights.  

217   There  are  two  National  Human  Rights  Institutions  in  the  country  –  the  Ombudsperson,  which  has  an  A-
status  accreditation  from  Global  Alliance  of  National  Human  Rights  Institutions  (GANHRI),  and  the 
Commission of the Protection against discrimination, which has a B-status accreditation from GANHRI. As 
regards  the  Commission  of  the  Protection  against  discrimination,  it  continues  to  work  with  an  expired 
mandate.  On  24  March  2026,  Parliament  adopted  an  amendment  to  give  functional  immunity  to  the 
Members of the Commission for Protection Against Discrimination when exercising their duties. As regards 
the  Ombudsman,  the  GANHRI  Sub-Committee  on  Accreditation  Report of  October  2025  considered  that 
the  provision  in  the  Constitution  providing  that  the  Ombudsman  or  Deputy  Ombudsman  can  become 
caretaker Prime Minister may impact on the real or perceived independence of the NHRI. 

218   See Law for the amendment and supplement of the law on pre-school and school education, adopted on 7 

August 2024. 

219   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  (2026),  written  input,  p.  32.  See  also  Civil  Liberties  Union  for  Europe 
(2026), written input, pp. 20-23. 

27 

 
 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2026 Rule of Law Report 
can 
https://commission.europa.eu/publications/2026-rule-law-report-targeted-
found 
stakeholder-consultation_en.  

be 

at 

Access to Information Programme (2025),  Press release of 23 December 2025 on the appeal of the 
Union of Judges in Bulgaria against a refusal of a public information request by the Supreme Judicial 
Council,  Съюзът  на  съдиите  в  България  с  помощта  на  ПДИ  обжалва  изричния  отказ  на 
Висшия съдебен съвет — Новини | Програма Достъп до Информация. 

Access to Public Information Programme (AIP), Anticorruption Fund Foundation (ACF), Association 
of  European  Journalists,  Bulgaria  (AEJ-Bulgaria),  Bulgarian  Center  for  Not-for-profit  (BCNL), 
Bulgarian Donors Forum (BDF), Bulgarian Helsinki Committee (BHC), Bulgarian Institute for Legal 
Initiatives  (BILI),  Center  for  the  Study  of  Democracy  (CSD),  Deystvie  organization  (Deystvie), 
Institute for Market Economics (IME), Input from civil society organisations for the 2026 Rule of Law 
Report. 

Amnesty International  – Bulgaria (2026),  Input from Amnesty International  - Bulgaria for the 2026 
Rule of Law Report. 

Anti-Corruption  Commission,  2025  Analysis  of  the  anti-corruption  plans  of  spending  authorities, 
https://cacbg.bg/web/files/documents/8/files/1.doklad%20anticorr%20plans%202025.pdf. 

Anti-Corruption Fund (2025a), How BGN 54M for the Construction of Hemus Highway Ended up in a 
Warehouse 
the  Perpetrators  Were  Never  Charged, 
https://acf.bg/en/kazusat-hemusgeyt-chast-2-kak-54-mln-le/.  

near  Blagoevgrad 

and  Why 

Anti-Corruption  Fund  (2025b),  Prosecutor  Claims  Investigation  of  Embezzlement  of  Public  Funds 
Compromised;  Supreme  Court  of  Cassation  and  Public  Prosecution  Turn  a  Blind  Eye, 
https://acf.bg/en/kazusat-hemusgeyt-chast-1-nablyudava/.  

Anti-Corruption Fund (2025c), 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/. 

Anti-Corruption Fund (2025d), ACF’s 2024 Annual Monitoring Report: Anti-Corruption Institutions 
are Strongly Influenced by the Political Environment, https://acf.bg/en/9638-2/. 

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), ACF Reveals Scandalous Appointments of Persons Linked to Political 
Parties in State-Owned Bulgartransgaz, https://acf.bg/en/akf-razkri-skandalni-naznacheniya-na-po/. 

Anti-Corruption  Fund  (2026a),  Financial  Transactions  Shed  New  Light  on  State-Sponsored  Road 
Assistance Scheme, https://acf.bg/en/patyat-na-parite-finansovi-tranzaktsii/.  

Anti-Corruption Fund (2026b), Tracking the State-Sponsored Roadside Assistance: ACF Investigation 
Infrastructure  Agency  Worth  Hundreds  of  Millions, 
Reveals  Possible  Abuse  at  Road 
https://acf.bg/en/po-sledite-na-bezplatnata-patna-pomosht/. 

AP News (2025), Bulgaria moves to prevent shutdown of its only oil refinery ahead of US sanctions, 
https://apnews.com/article/bulgaria-lukoil-refinery-shutdown-russia-sanctions-
11eff472c05a533eb64749cd598c8187. 

BILI (2026), Opinion on the Draft law amending and supplementing the Law on the National Audit 
Office, https://bili-bg.org/cdir/bili-bg.org/files/BILI_STATEMENT_ENG_CPC-logo_.pdf. 

28 

 
 
 
 
BTA  (2025),  The  nomination  committee  came  out  with  its  assessment  of  the  candidates  for  the 
leadership  of 
the  Anti-Corruption  Commission,  https://www.bta.bg/bg/news/bulgaria/956245-
nominatsionnata-komisiya-izleze-s-otsenki-za-kandidatite-za-chlenove-na-komisiya. 

BTV (2025), Where is the 55 million leva for the Hemus highway? Prosecutor Ivaylo Zanev told bTV 
https://btvnovinite.bg/predavania/tazi-sutrin/kade-sa-55-miliona-leva-za-
about 
magistrala-hemus.html?campaignsrc=clipboard. 

scheme, 

the 

Bulgarian Government (2026), Additional input from Bulgaria for the 2026 Rule of Law Report.  

Bulgarian Government (2026), Input from Bulgaria for the 2026 Rule of Law Report. 

Bulgarian Helsinki Committee (2026), “Wiretapped justice”. 

Bulgarian  Industrial  Association  (2025),  2025  through  the  eyes  of  business,  https://www.bia-
bg.com/uploads/gallery/-%20ANKETI/Anketa_2025/ANKETA_2025.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-съдиямирослав-
пет/. 

Bulgarian Judges Association (2025), Input from the Bulgarian Judges Association for the 2026 Rule 
of Law Report.  

Bulgarian National Assembly (2025), Temporary Committee to establish facts around the activities of 
George Soros and Alexnader Soror and their foundations on the territory of the Republic of Bulgaria, 
https://www.parliament.bg/bg/parliamentarycommittees/3758. 

Bulgarian  National  Assembly  (2026),  Study  of  the  law-making  activity  of  the  National  Assembly 
(November 2024 – January 2026), https://www.parliament.bg/bg/ncpi. 

Capital (2025), The Week: Future of Lukoil’s local assets remains uncertain; Bulgaria receives over 
400 
Plan, 
https://kinsights.capital.bg/politics_and_society/2025/11/14/4852061_the_week_future_of_lukoils_lo
cal_assets_remains/.  

Resilience 

Recovery 

million 

under 

euro 

and 

the 

Centre for Media Pluralism and Media Freedom (2026), Media pluralism monitor 2026. 

Civicus, Monitor tracking civic space – Bulgaria https://monitor.civicus.org/country/bulgaria. 

Civil Liberties Union for Europe (2026), Input from the Civil Liberties Union for Europe for the 2026 
Rule of Law Report. 

Commission for Personal Data Protection (2026), 2025 Annual report.  

Constitutional Court Decision No. 5 of 22 June 2023. 

Constitutional Court Decision No. 9 of 11 December 2025. 

Constitutional Court in Decision No 13 of 26 July 2024. 

Constitutional Court, Case No. 10 of 16 September 2025. 

Constitutional Court, Case No. 3 of 23 January 2024. 

Constitutional Court, Case No. 4 of 24 January 2024. 

Constitutional Court, Case No. 40 of 21 November 2024. 

Constitutional Court, Case No. 9 of 17 March 2026. 

Constitutional Court, Casе No. 38 of 15 November 2024. 

Constitutional Court, Decision No. 4 of 2026. 

Constitutional Court, Decision No. 5 of 2026. 

29 

 
 
 
Constitutional Court, Decision No. 7 of 12 January 2026. 

Constitutional Court, Decision No. 9 of 25 July 2025. 

Council for Electronic Media (CEM) (2026), Input from Bulgaria for the 2026 Rule of Law Report. 

Council For Electronic Media (CEM) website (2026a), CEM approved members of the Management 
Board of BNT, https://www.cem.bg/displaynewsbg/1108. 

Council  For  Electronic  Media  (CEM)  website  (2026b),  CEM  elected  Director  General  of  BNT, 
https://www.cem.bg/displaynewsbg/1106. 

Council  For  Electronic  Media (CEM)  website (2026c),  Dr.  Gabriela  Naplatanova  has  been elected 
Chairperson of the Council for Electronic Media, https://www.cem.bg/displaynewsbg/1123. 

Council  of  Europe  (2026x),  Supervision  of  the  execution  of  judgments  decisions  of  the  European 
Court  of  Human  Rights  –  19th  Annual  Report  of  the  Committee  of  Ministers  –  2025, 
https://rm.coe.int/2025-annual-report/48802b1633.  

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

Council  of  Europe:  Committee  of  Ministers  (2023),  Supervision  of  the  execution  of  the  European 
Court’s judgements, CM/Del/Dec(2023)1501/H46-10. 

Council  of  Europe:  Committee  of  Ministers  (2023),  Supervision  of  the  execution  of  the  European 
Court’s judgements, CM/Del/Dec(2023)1483/H46-10. 

Council  of  Europe:  Committee  of  Ministers  (2023),  Supervision  of  the  execution  of  the  European 
Court’s judgements, CM/Del/Dec(2023)1475/H46-12. 

Council  of  Europe:  Committee  of  Ministers  (2025),  Supervision  of  the  execution  of  the  European 
Court’s judgements, CM/Del/Dec(2025)1545/H46-13. 

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 draft amendments to the 
Constitution (CDL-AD(2023)039). 

Council  of  Europe’s  Safety  of  Journalists  Platform  and  Media  Freedom  Rapid  Response  (MFRR) 
(2025), Bulgaria: fragile media freedom progress at risk of backsliding without urgent reform. 

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. 

Dnevnik (2025), Coalition "Kovachki": The government and Peevski suspended a commission for the 
Kovachki, 
Orion 
https://www.dnevnik.bg/politika/2025/06/04/4790681_koaliciia_kovachki_upravliavashtite_i_peevski
_spriaha/. 

holding 

Hristo 

role 

and 

the 

of 

Dnevnik (2025),  Dian Ivanov withdrew his testimony against the mayor of Varna, which was given 
under 
pressure, 
https://www.dnevnik.bg/bulgaria/2025/07/16/4808440_dian_ivanov_ottegli_pokazaniiata_si_sreshtu_
kmeta_na/. 

Draft law 51-554-01-139 of 30 July 2025, https://www.parliament.bg/bg/bills/ID/166571.  

30 

 
 
 
Draft law 51-554-01-170 of 29 September 2025, https://www.parliament.bg/bg/bills/ID/166638.  

Draft law 51-654-01-2 of 14 January 2026, https://www.parliament.bg/bg/bills/ID/166794. 

Draft Law Amending and Supplementing the Criminal Code, 51-554-01-178 of 7 October 2025. 

Draft  Law  Amending  and  Supplementing  the  Law  on  Access  to  Public  Information,  submitted  for 
public consultation with the number 11319-K on 18 July 2025. 

DW  (2026),  With  or  without  an  anti-corruption  commission,  corrupton  is  here  to  stay, 
https://www.dw.com/bg/blgaria-i-da-ima-i-da-nama-kpk-korupciata-si-e-tuk/a-75559033. 

EPPO (2026a), Annual report 2025. 

EPPO  (2026b),  College  of  the  EPPO  decision  concerning  the  disciplinary  procedure  against  the 
Bulgarian  European  Prosecutor,  https://www.eppo.europa.eu/en/media/news/college-eppo-decision-
concerning-disciplinary-procedure-against-bulgarian-european. 

European  Centre  for  Press  and  Media  Freedom,  Media  Freedom  Rapid  Response  Mechanism  – 
Bulgaria (2025), Press Freedom Violations Monitoring. 

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  (2025),  2025  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Bulgaria. 

European  Commission  (2025),  Commission  implementing  decision  on  the  authorisation  of  the 
disbursement of the third instalment of the non-repayable support for Bulgaria of 22 December 2025, 
COM(2025) 9228 final. 

European Commission (2025), Country report Bulgaria, SWD(2025), 202 final.  

European Commission (2026), 2026 EU Justice Scoreboard. 

European Commission (2026), COM(2026) 202 final, CSR 3. 

European  Court  of  Human  Rights  (2024),  Application  No.  25072/24  –  Tsarigradska  and  Others  v. 
Bulgaria, communicated on 6 October 2025. 

European Implementation Network (2026), Input from the European Implementation Network for the 
2026 Rule of Law Report. 

European Network of National Human Rights Institutions (2026), ENNHRI calls for protection of the 
independence  of  the  Bulgarian  NHRI  and  its  leadership,  https://ennhri.org/news-and-blog/ennhri-
calls-for-protection-of-the-independence-of-the-bulgarian-nhri-and-its-leadership/. 

European  Union  Agency  for  Fundamental  Rights  (FRA)  (2026),  Input  for  the  2026  Rule  of  Law 
Report. 

Follow the Money (2026), Gas, lies, and videotape: How a gas project in Bulgaria brought chaos to 
EU’s 
https://www.ftm.eu/articles/gas-project-bulgaria-chaos-to-
eppo?share=Na1EjqQBj8o%2FSrMLi7UMc6F44GJy5alS%2FkTGp45xLMzsa7rnJ8vvkyiTDyhFrzA
%3D.  

anti-corruption 

body, 

Free  Europe  (2025),  Key  witness  against  Blagomir  Kotsev  withdrew  his  testimony  and  accused  the 
inspectors  of  exerting  pressure,  https://www.svobodnaevropa.bg/a/blagomir-kocev-varna-svidetel-
ottegleni-pokazania-kpk/33475814.html.  

31 

 
 
 
Free  Europe (2025),  No  need  to  work  on  ‘Magnitsky’.  What the  candidates for the  Anti‑Corruption 
Commission  said  during  their  hearing,  https://www.svobodnaevropa.bg/a/izlishno-da-se-raboti-po-
magnitski-kak-kandidatite-za-antikoruptsionnata-komisiya-predstaviha-ideite-si/33510423.html. 

Free  Europe,  "Conceptually  wrong."  MPs  set  in  motion  the  closure  of  the  CPC  under  a  project  of 
https://www.svobodnaevropa.bg/a/zakrivane-antikoruptsionna-komisiya-gerb-dps-pp-
GERB, 
db/33650599.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. 

Institute for Market Economics (IME) (2025), The judiciary in numbers, https://ime.bg/dashboard/. 

Institute for Market Economics (IME), Input from civil society organisations for the 2026 Rule of Law 
Report. 

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 Economic (2026), Input for the 2026 Rule of Law Report.  

Judicial System Act (2025). 

Lex.bg  (2026),  The  Supreme  Administrative  Court  confirmed:  the  ISJC  is  not  competent  to  request 
penalties for magistrates, news.lex.bg. 

Media Pluralism Monitor (2026), Bulgaria country report. 

Ministry of Culture (2026), Input from Bulgaria for the 2026 Rule of Law Report. 

Ministry of Justice (2026),  Press release of 6 March on assignment of security detail to Bulgaria’s 
European  Prosecutor,  https://www.justice.government.bg/home/index/dc944d20-e3fb-4861-9fea-
79fbe91f2adc. 

Monitoring Action for Civic Space (2025), Country Report Bulgaria, https://bcnl.org/en/macs-report-
monitoring-action-for-civil-space-in-bulgaria-2025. 

National 
https://www.bulnao.government.bg/bg/documents/15559/OD_KORUPZIA_12.2025.pdf.  

(2025), 

Office 

report 

Audit 

Audit 

№0300201223, 

National  Council  for  Journalistic  Ethics  (NSW)  (2026),  Input  from  the  National  Council  for 
Journalistic Ethics for the 2026 Rule of Law Report. 

National  Strategy  for  Preventing  and  Combatting  Corruption  in  the  Republic  of  Bulgaria  (2021  – 
2027), https://www.strategy.bg/bg/strategy-documents/1370. 

News.bg  (2025),  The  main  pre-trial  proceedings  in  the  ‘Eight  Dwarfs’  case  have  been  cancelled, 
https://news.bg/crime/prekratiha-osnovno-dosadebno-proizvodstvo-po-kazusa-osemte-
dzhudzheta.html.  

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. 

32 

 
 
 
(2025), 

OECD 
https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/01/reforming-bulgaria-s-anti-
corruption-authorities_79108af5/11ef33c9-en.pdf. 

Anti‑corruption 

Bulgaria’s 

Reforming 

Authorities, 

Institution,  Whistleblowers 

Ombudsman 
https://www.ombudsman.bg/en/n/ombudsman-institution-whistleblowers-are-not-protected-from-
retaliation-2292.  

Protected 

from 

Not 

Are 

Retaliation, 

Institution,  Whistleblowers 

Ombudsman 
https://www.ombudsman.bg/en/n/ombudsman-institution-whistleblowers-are-not-protected-from-
retaliation-2292.  

Protected 

from 

Not 

Are 

Retaliation, 

Prosecution service (2026), Report on the activity of the prosecution on countering corruption crimes 
in 2025, https://www.parliament.bg/pub/plenary_documents/51-627-00-1_.pdf. 

Regulation  (EU)  2016/679  of  the  European  Parliament  and  of the  Council  of  27  April  2016  on  the 
protection of natural persons with regard to the processing of personal data and on the free movement 
of  such  data,  and  repealing  Directive  95/46/EC  (General  Data  Protection  Regulation),  Regulation  - 
2016/679 - EN - gdpr - EUR-Lex. 

Report 
51-553-120-12 
https://www.parliament.bg/pub/cW/20250828103831_Doklad_27082025.pdf. 

Nomination 

Committee 

the 

of 

of 

27.08.2025. 

Roadmap for Implementation of the National Strategy for Prevention and Counteraction of Corruption 
in the Republic of Bulgaria (2021 – 2027), https://www.strategy.bg/bg/strategy-documents/1370.  

Sofia Administrative Court, Decision No. 211/2026 of 24 February 2026. 

Sofia  District  Court,  Request  for  a  preliminary  ruling  concerning  case  C-2/26  Kaldov  of  5  January 
2026. 

Sofia District Court, Request for a preliminary ruling concerning case C-364/25 Katachev of 29 May 
2025. 

Supreme Administrative Court, Decision No. 11370 of 13 November 2025. 

Supreme  Cassation  Court  (2025),  Press  release  of  2  October  2025  on  the  ability  of  the  interim 
Prosecutor  General  to  fulfil  this  function  since  July  2025,  https://www.vks.bg/novini/otkaz-za-
obrazuvane-i.f.gl.prokuror-02.10.html. 

Supreme Cassation Court (2026), Annex 2 to the 2025 Annual Report on the Activities of the Supreme 
Cassation 
https://www.vks.bg/analizi-i-dokladi/vks-doklad-prilagane-na-zakona-2025-
prilojenie2.pdf.  

Court, 

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.pd. 

Supreme Judicial Council, Judges’ Chamber (2025), Protocol No. 23 of 15 July 2025 to appoint new 
interim President of the SAC, https://vss.justice.bg/root/f/upload/46/krpr23-15_07_2025-sk.pdf. 

Supreme  Judicial  Council,  Judges’  Chamber  (2025),  Protocol  No.  27  of  14  October  2025, 
https://vss.justice.bg/root/f/upload/47/krpr27-14_10_2025-sk.pdf. 

Supreme  Judicial  Council,  Prosecutors’  Chamber  (2025),  Protocol  No.  41  of  22  December  2025  to 
select a new ad hoc prosecutor to investigate possible crimes committed by the Prosecutor General, 
https://vss.justice.bg/root/f/upload/47/krpr41-22_12_2025-pk.pdf. 

Supreme Judicial Council, Prosecutors’ Chamber (2026), Protocol No. 13 of 22 April 2026 to accept 
the  resignation  of  the  acting  Prosecutor  General,  https://vss.justice.bg/root/f/upload/48/krpr13-
22_04_2026-pk.pdf. 

Transparency International (2026), 2025 Corruption Perceptions Index (CPI).  

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Supreme Judicial Council (2025), Register for seconded magistrates for 2025. 

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Annex II: Country visit to Bulgaria 

The Commission services held virtual and in-person meetings in January 2026 with: 

•  Access to Information Programme  
•  Amnesty International – Bulgaria 
•  Anti-Corruption Council – Secretary of NCACP 
•  Anti-corruption Fund Foundation 
•  Association of Media Companies (ABBRO) (virtual) 
•  Association of Prosecutors in Bulgaria 
•  Bulgarian centre for not-for-profit law 
•  Bulgarian Helsinki Committee 
•  Bulgarian Industrial Association 
•  Bulgarian Institute for Legal Initiatives 
•  Bulgarian Judges Association 
•  CEM – Members of the Council for Electronic Media 
•  Chief Inspectorate of the Council of Ministers 
•  Commission for countering corruption 
•  Commission for forfeiture of illegally acquired assets 
•  Deystvie 
• 
•  Justice for All Initiative 
•  Media Democracy Foundation 
•  Ministry of Culture 
•  Ministry of Interior 
•  Ministry of Justice  
•  National Council for Journalistic Ethics 
•  Open Society Institute 
•  Prosecutor General’s Office 
•  Supreme Bar Council 
•  Supreme Court of Cassation 
•  Supreme Judicial Council 
•  The Association of European Journalists – Bulgaria 
•  The Centre for the Study of Democracy 
•  The Institute for Market Economics 
•  Transparency International – Bulgaria 

Internal Security Directorate – Ministry of Interior 

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

•  Civil Liberties Union for Europe 
•  Civil Society Europe 
•  End FGM EU 
•  European Civic Forum 
•  European Partnership for Democracy 
•  Human Rights Watch 

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• 
ILGA-Europe 
• 
International Federation for Human Rights 
•  Philea - Philanthropy Europe Association 
•  Transparency International EU 

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