On 02.05.2025, a Decision [1] was published on the website of the Council of Ministers – pris.government.bg – whereby, pursuant to Article 2, paragraph 2 of the Asylum and Refugees Act, a new Program for Humanitarian Support and Integration of Displaced Persons from Ukraine was adopted (hereinafter referred to as “the Decision” and “the Program,” respectively).

The Program is effective as of May 1, 2025. Under the new Program, displaced persons from Ukraine who have been granted temporary protection after February 24, 2022, and who do not fall into a risk group, may benefit from this Program once for a period of up to 60 calendar days. The Program specifies the criteria according to which a person falls into a risk group and, on this basis, can benefit from accommodation for the entire duration of temporary protection until March 4, 2026. 

According to item 4.3.2 of the Program for Humanitarian Support and Integration of Displaced Persons from Ukraine with Temporary Protection in the Republic of Bulgaria, "...persons may stay in the accommodation facility only if they pay for their stay at the prices announced by the relevant accommodation facility". This means that persons from Ukraine who do not fall into a risk group must either leave their accommodation after the initial 60-day period has expired or, if they remain, pay for their stay. 

After the Program came into force, a large proportion of Ukrainian refugees did not fall into the so-called "risk groups." You can read more about the criteria according to which a person can use free accommodation for the entire duration of their temporary protection and the problems that these criteria have created in practice here. 

As a result of the Program adopted by the Council of Ministers, hundreds of family members from Ukraine currently have different statuses – it is common for some members of a family to be accommodated free of charge under the Program for the entire duration of their temporary protection because they fall into the so-called "risk group," while other family members are denied this. The latter, if they want to continue living together and keep their family ties intact, are forced to pay for their stay. 

However, apart from the laconic provision that "...persons may stay in the accommodation facility only if they pay for their stay at the prices announced by the relevant accommodation facility," nothing else is specified in the Program. There is no clarity as to the cost of the stay, who determines it and how, whether it is the same for all accommodation facilities and for all persons from Ukraine. There are no rules for paying for this stay – in what order, on what basis, etc. There are no guarantees under the Program that if a person pays for their own stay, they will be accommodated together with their family (and not in another room, for example), etc.

In response to a request under the Access to Public Information Act made by Foundation for Access to Rights, the Ministry of Tourism replied that the cost of the stay is determined independently by each individual accommodation facility. The lack of transparency, through summarized and publicly available information on the cost of accommodation in different places, jeopardizes the rights and interests of Ukrainian refugees, who are unable to assess and compare the price they are required to pay with prices in other places. 

Furthermore, most of the persons who are forced to pay for their own accommodation have family members who are accommodated under the Program free of charge. The latter cannot move freely from one place of accommodation to another without good reason. This means that if they want to keep their families together, persons who are not accommodated under the Program will have to pay for their own stay in the accommodation where the other family members are allocated, regardless of the cost of the stay. The fact that some of the accommodation facilities are hotels and others are state-owned facilities also creates inequality between the persons accommodated.

In addition, the Program lacks clear rules on how to pay for the stay and the necessary documents that the owners and/or managers of the accommodation facilities are required to issue to refugees from Ukraine who are paying for their own stay. The Program does not stipulate a reciprocal obligation on the part of the owner and/or manager of the accommodation to accommodate a person together with their family members (i.e., in the same room/apartment, etc.) in exchange for the possibility of paying for their own stay,  as such cases have been reported to  Foundation for Access to Rights. 

The Program also does not provide for a mechanism to control this activity of self-payment stays – which institution is responsible for violations of the rights of accommodated persons, in what order and under what circumstances it can be notified. It is unclear whether there are different rules and procedures for Ukrainian refugees or whether they are treated like any tourist who has decided to use the services of a particular hotel or accommodation facility. In the latter case, however, it is difficult to explain why the text of point 4.3.2 of the Program would be included at all – the right of individuals in Bulgaria to use hotels and pay for their stay there exists even without being specified in the Program. However, insofar as it explicitly provides for the possibility for displaced persons from Ukraine to stay in accommodation in return for payment, it is necessary to regulate this possibility in detail in the Program.

In conclusion, the Foundation for Access to Rights deems it essential to update the text of the Program by providing a detailed description of the procedure for independent payment of accommodation, as outlined in point 4.3.2. This clarification would help ensure stronger protection of the rights of persons displaced from Ukraine. Furthermore, it is recommended to enhance transparency and public accessibility of the independent payment procedure by publishing a comprehensive list of accommodation facilities and their respective prices. The list should clearly specify what is included in the price (e.g., accommodation, additional fees, utilities, etc.), outline the payment methods, and indicate which documents must be issued to the accommodated person as proof of payment.

[1]  https://pris.government.bg/document/6d69bf743388f6a39ebd340a91111fb6