EUROPEAN COMMISSION

Brussels, 17.7.2026

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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

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I.Justice System 1  

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 2026 2 . 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 interests 3 . 

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 deputies 4 . 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 Cassation 5 . Furthermore, the law introduces an automatic judicial review of prosecutorial decisions to suspend or terminate pre-trial proceedings for crimes committed by the Prosecutor General. The law 6  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 2025 8 .

Parliament adopted amendments to introduce automatic judicial review 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 commitments 9 . 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 crimes 10 . 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 possibility for judicial review, but limited it to a few authorities 11 . 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 reported 12 , 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 committed 13 . Currently, there are seven prosecutors working within this structure 14 . 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 decisions 15 . Moreover, stakeholders consider that there is a need for disaggregated data on proceedings that are open against magistrates to ensure transparency 16 . 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 judges 17 .

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 Reports 19 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 unaddressed 20 . The authorities have not re-initiated the process to reform the composition and the appointment procedure of the members of the SJC 21 despite the legal deadline set by Parliament of July 2025 22 . 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 check 23 . 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 SJC 24 . 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 time 25 . 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 2025 26 imposed a six-month limit to the interim mandate when fulfilling the function of Prosecutor General and Supreme Administrative or Cassation Court President 27 . 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 elapsed 28 . 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 President of the SAC for a term of six months 29 . 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 Court 30 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 mandate 31 . 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 SJC 32 .

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 recommendation 33 . 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 ISJC 34 , 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 amendments 35 , which have been adopted by Parliament 36 . 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 2025 37 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 mandate and the possible threat to judicial independence 38 . 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 secondments 39 . 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 secondment 40 . 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 promotion 41 . 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 jeopardised 42 , particularly when a secondment is terminated without the judge’s consent 43 . None of the previous draft amendments 44 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 secondments 45 . 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 reported 46 , 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 2025 47 . Moreover, no follow up was given by the parliamentary committee, which could not adopt a final report due to insufficient quorum. In parallel, a case before the European Court of Human Rights was filed by one of the magistrates subject to intimidation 48 . On 6 March 2026, the Minister of Interior assigned a security detail to Bulgaria’s European Prosecutor, following a report of alleged pressure on her 49 . 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 functions 50 . Furthermore, the Ministry also established a working group to analyse allegations concerning the influence of organised crime groups over the judiciary 51 .

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 Code 52 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 form 53 , for cases of technological impossibility or in the presence of specific legal requirements concerning the format of the acts 54 . 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 capital 55 . 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 justice system, such as lawyers, notaries and bailiffs. However, Bulgaria performs well regarding arrangements for producing machine-readable judicial decisions 56 .

Amendments to the legal aid rules increased the remuneration for lawyers. In July 2025, the Government amended the rules on remuneration for legal aid 57 . 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 citizens 58 . 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 mechanisms 59 . 

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 cases 60 , which means that courts generally deal efficiently with their caseload. While cases at third instance on average take up to 201 days to be resolved 61 , cases at first and second instance courts take respectively 184, and 148 days to be resolved 62 . 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 them 63 . The Government is currently working on the preparation of draft laws for the acceleration of criminal and civil proceedings 64 .

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 globally 65 . This perception has been relatively stable over the past five years 66 . 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 prioritised 68 . 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 2023 69 . 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 progress 70 .

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 71 . 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 independence 72 . In July 2025, fast-track amendments removed the requirement for a two-thirds majority in Parliament for the election of its collegial leadership 73 . This removed an important safeguard against political influence over the ACC, also highlighted by GRECO 74 . In January 2026, Parliament adopted legislation repealing the anti-corruption law and dissolving the ACC 75 . The ACC’s policy-making, preventive and investigative functions were transferred to other institutions 76 . The closure of the ACC by the previous parliamentary majority took place before the 2023 reform could be fully implemented 77 . The new Government, which took up office in May 2026, has stated its commitment to strengthening the anti-corruption framework 78 . 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 institutions 79 . 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 members 80 . The appointment procedures have been 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 cases 81 . In 2025, the Supreme Court of Cassation delivered five judgments in corruption cases involving a high-level official, one of which was final 82 . 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 2025 83 . 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 evidence 84 . They also consider that investigations and prosecutions in high-level corruption cases are initiated in an arbitrary and selective manner 85 . 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 investigations 86 . 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 General 87 . 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.

Several legislative amendments were adopted to implement 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 persons 88 . 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 corruption offences under the Criminal Procedure Code 89 . 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 detection 90 .

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 strengthened 91 . 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 2025 92 . 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 independence 93 .

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 recommendations 94 . 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 continue 95 . However, according to GRECO, the operational independence of the police from the Ministry remains insufficient 96 . 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 instructions 97 . A working group had previously prepared draft legislative amendments reinforcing the operational independence of the police from the Ministry, but it did not advance further 98 . As regards the judiciary, the ISJC exercises limited powers since a ruling of the Court of Justice 99 . 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 proceedings 100 . 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 predictability 101 .

Efforts are under way to strengthen the integrity of persons with top executive functions 102 . 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 Administration 103 . 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 tools 104 . 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 GRECO 105 . 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’ work 106 . Furthermore, rules on integrity checks and on incompatibilities of persons hired as advisers to senior political officials remain to be introduced 107 . In light of the above, while some steps have been taken, only limited progress was made on this recommendation.

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 inconsistencies 108 . Following the submission of 410 reports of conflicts of interest, the ACC concluded that conflicts existed in 24 cases 109 . Following the closure of the ACC, this task was transferred to the NAO 110 . 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 2025 111 . 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 ACC 112 . 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 2026 113 . 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-compliance 114 . 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 will be imposed 115 . While the law is broadly aligned with relevant international and European standards, the extensive exemptions from the obligation to register raise concerns 116 . 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-up 117 .

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 campaigns 118 . 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 Code 119 . One political party failed to submit its annual accounts for a second time and NAO informed the prosecution service thereof 120 . 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 proceedings 121 .

The whistleblowing legislative framework is in place, while effective implementation requires further action 122 . In 2025, the Commission for Personal Data Protection (CPDP) received 115 whistleblower reports and referred fifteen reports to the Anti-Corruption Commission 123 . 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 requested 124 . 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 remain 125 . Civil society considers that the latest amendments to the law have not facilitated anonymous reporting, which could incentivise reporting and improve safety for whistleblowers 126 .

Public procurement remains an area at high risk of corruption and a number of investigations point to increased corruption risks in the energy sector, road 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 Association 127 . 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 years 128 . 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 cases 129 . 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 activity 130 . 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 billion 131 . 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 sector 132 . 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 Fund 133 . Finally, concerns about corruption have also arisen with regard to road infrastructure and waste management 134 . 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 enterprises 135 .

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 Bulgaria 136 . 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 2025 137 . 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 journalists 138 . 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 regulator 140 . In April 2026, the CEM elected a new chairperson, who was proposed by the previous chairperson and another member of the Council 141 . 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 legislation 142 .

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 2026 143 . The CEM has subsequently also approved the new composition of the BNT Management Board, replacing three members elected in 2019 144 . 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 undermine the independence of the public broadcaster 145 . 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-General 146 . 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 ownership 148 . 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 funding 149 . While the CEM confirms its monitoring of compliance by radio and audiovisual media service providers and subsequent sanctioning of violations 150 , stakeholders continue to raise concerns about inconsistencies in media companies’ compliance with ownership transparency obligations, particularly as regards beneficial owners 151 . In view of these concerns, the Media Pluralism Monitor has increased its risk level for transparency of media ownership to medium-high 152 . Concerns also continue to be raised about a lack of ownership disclosure by online media services who appear to be under political influence 153 .

There has been some further progress on the recommendation to improve transparency in the allocation of state advertising 154 . Under the draft law amending the RTA, media service providers are required to publish information on their public advertising revenues 155 . Furthermore, the Ministry also envisages amendments to the Public Procurement Act 156 , which would require contracting authorities to publish information on their annual public advertising expenditure and empower the CEM to compile, assess, and analyse this information 157 . The Ministry of Culture is also reviewing its internal administrative procedures in line with the existing regulatory framework with a view to improving transparency of state advertising, including state advertising contracted through intermediaries 158 . Stakeholders report that while the Ministry of Tourism continues to publish monthly reports of its advertising expenditure on very large online platforms and search engines 159 , other state actors have not implemented their obligations on the transparency of their state advertising expenditure 160 . Given the ongoing work on legislative reforms, there has been some progress on the recommendation.

Indications regarding political and economic influence over the media remain 161 . Stakeholders note that private business interests and ties to political actors continue to influence the editorial policies of many private media outlets 162 . 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 funding 163 . Furthermore, cases have been reported where media contracted by public authorities were explicitly forbidden from publishing content that would be damaging to their reputation 164 . 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 independence 165 . 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 concentrations 166 .

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 2025 167 . 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 information 168 . In October 2025, an amendment to criminalise the publishing of information about private life was proposed to the Criminal Code to deter violations of privacy 169 . The amendment was later withdrawn after strong opposition from experts, civil society organisations and media, who warned that it could be used to censor legitimate journalism 170 . 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 persisted 171 .

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 period 172 , the online environment has become increasingly hostile towards journalists, in particular women journalists 173 . 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 journalism 174 . However, the use of strategic lawsuits against public participation (SLAPPs) and other forms of legal pressure against journalists 175 persists – with journalists losing several SLAPPs in court in the past year 176 . 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 cases 177 . 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 2025 178 . 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 assault 179 . While the Criminal Code was amended in July 2025, to reduce the special minimum fines for the basic offences of insult and defamation 180 , stakeholders and flagged that civil defamation cases continue to be filed with increasingly high compensation claims 181 . Furthermore, stakeholders report worsening working conditions for parliamentary reporters and journalists working for online platforms, who have been denied access to the building of the National Assembly 182 .

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 renewed 183 . However, the authorities that require a qualified majority vote (two thirds of the members of Parliament) have not been renewed 184 , and vulnerabilities identified in previous editions of the Rule of Law Report remain 185 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 mandate 186 . In two challenges before the Constitutional Court related to recent appointments of the Deputy Head of the National Audit Office 187 and the Head of the Commission for Personal Data Protection 188 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 Parliament 189 .

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 decision 190 , leaving the provisions in place but susceptible to a new challenge in the future 191 .

There has been no progress on strengthening the quality of the legislative process for initiatives by members of Parliament 192 . As previously reported, the practical implementation of the parliamentary rules for lawmaking continues to raise some concerns 193 . Since the majority of legislative amendments have been proposed directly by members of Parliament 194 , these do not go through the same mandatory procedure as government initiatives, including as regards impact assessment and public consultations 195 . 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 law 196 . The EU Agency for Fundamental Rights also noted a lack of consultation strategies for legislative initiatives 197 . Stakeholders also reported that the practice of introducing legislative changes through amendments to other, unrelated, acts between the first and the second reading persists 198 , as well as the use of accelerated procedures on sensitive issues 199 . Frequent changes to legislation have been flagged as one of the key barriers for businesses 200 . 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 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 appeals 204 .

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 year 205 . 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 conditions 207 . 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 93 209 . Stakeholders have also raised concerns about the non-implementation of Court of Justice judgments 210 .

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 instability 211 . 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 projects 212 .

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. Civic space in Bulgaria continues to be rated narrowed by Civicus 213 . After previous unsuccessful attempts to introduce legislation requiring the registration of organisations receiving foreign funding or labelling organisations as foreign funded 214 , 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 foundations 215 . Stakeholders raised concerns about the possible impact on freedom of association and the overall chilling effect and stigmatisation of foreign funding for civil society 216 . 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 Ombudsman 217 to challenge the constitutionality of this law 218 , 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 health 219 .

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 be found at https://commission.europa.eu/publications/2026-rule-law-report-targeted-stakeholder-consultation_en . 

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 near Blagoevgrad and Why the Perpetrators Were Never Charged, https://acf.bg/en/kazusat-hemusgeyt-chast-2-kak-54-mln-le/ .

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 Reveals Possible Abuse at Road Infrastructure Agency Worth Hundreds of Millions, 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 .

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 about the scheme, https://btvnovinite.bg/predavania/tazi-sutrin/kade-sa-55-miliona-leva-za-magistrala-hemus.html?campaignsrc=clipboard .

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 million euro under the Recovery and Resilience Plan, https://kinsights.capital.bg/politics_and_society/2025/11/14/4852061_the_week_future_of_lukoils_local_assets_remains/ .

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.

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/H46-1 0.

Council of Europe: Committee of Ministers (2023), Supervision of the execution of the European Court’s judgements, CM/Del/Dec(2023)1483/H46-1 0.

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 Orion holding and the role of Hristo Kovachki, https://www.dnevnik.bg/politika/2025/06/04/4790681_koaliciia_kovachki_upravliavashtite_i_peevski_spriaha/ .

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 .

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 anti-corruption body, https://www.ftm.eu/articles/gas-project-bulgaria-chaos-to-eppo?share=Na1EjqQBj8o%2FSrMLi7UMc6F44GJy5alS%2FkTGp45xLMzsa7rnJ8vvkyiTDyhFrzA%3D . 

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 .

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 GERB, https://www.svobodnaevropa.bg/a/zakrivane-antikoruptsionna-komisiya-gerb-dps-pp-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 Audit Office (2025), Audit report №0300201223, https://www.bulnao.government.bg/bg/documents/15559/OD_KORUPZIA_12.2025.pdf .

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 .

OECD (2025), Reforming Bulgaria’s Anti‑corruption Authorities, https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/01/reforming-bulgaria-s-anti-corruption-authorities_79108af5/11ef33c9-en.pdf .

Ombudsman Institution, Whistleblowers Are Not Protected from Retaliation, https://www.ombudsman.bg/en/n/ombudsman-institution-whistleblowers-are-not-protected-from-retaliation-2292 .

Ombudsman Institution, Whistleblowers Are Not Protected from Retaliation, https://www.ombudsman.bg/en/n/ombudsman-institution-whistleblowers-are-not-protected-from-retaliation-2292 .

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 of the Nomination Committee 51-553-120-12 of 27.08.2025. https://www.parliament.bg/pub/cW/20250828103831_Doklad_27082025.pdf .

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 Court,  https://www.vks.bg/analizi-i-dokladi/vks-doklad-prilagane-na-zakona-2025-prilojenie2.pdf .

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).

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

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

·Internal Security Directorate – Ministry of Interior

·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

* 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

·ILGA-Europe

·International Federation for Human Rights

·Philea - Philanthropy Europe Association

·Transparency International EU

(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/Del/Dec(2025)1545/H46-13) and Notes 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.

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

(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.

(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 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.

(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.

(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.

(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.

(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. 

(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), relatively high (between 59-50), high (below 50).

(66)      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.

(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.

(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.

(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.

(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.

(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.

(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 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.

(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).

(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.

(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.

(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.

(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 State Security and intelligence services of the Army; Commission for Protection against 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.”

(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 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. 

(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.

(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.