Analysis of national legal and institutional frameworks that influence the possibility of introducing private sponsorships schemes in Bulgaria

Report English

Policy framework

  1. Briefly describe relevant aspects and objectives of pertinent public policy documents.

The only policy document on migration is the National Strategy on Migration of the Republic of Bulgaria 2021-2025 (“the Strategy”).[1] The section regarding international protection and asylum is notably short, generally written and has no differentiation of the various groups of asylum seekers, their needs and no specific set of goals.[2] It does not take into consideration negative practice in the Bulgarian asylum system. For instance, Amnesty International and the UNHCR have both in their commentaries to the Strategy pointed out the need to set a goal for the elimination of the vicious practice in Bulgaria of detention of unaccompanied minors. This has been rejected by the experts responsible for the drafting of the Strategy[3] since “there is already national legislation available.”[4]

The integration section of the Strategy is extremely brief as well. Integration is not brought out as a goal of the Strategy but is said that a “separate and purposeful” policy should be developed based on the implementation of an Ordinance,[5]which is practically rarely put in use,[6] as well as on annual National Plans for Action on Integration, which have not been issued for the past 2 years.[7]

  1. Has the legal arrival of refugees (resettlement, relocation and/or similar) been recognized as one of priorities or mentioned in policy documents? If yes, please describe and cite the relevant parts.

No. Legal arrival of migrants is considered a priority in the Strategy only in the context of migrants arriving in Bulgaria with the main goal of working or studying.[8] The only reference made to asylum seekers is implicit and in the context of mitigation of illegal migration through “political decisiveness on the development of legal pathways to Europe” and effective returning of illegal migrants. This reflects the general stance of the public and the political parties in Bulgaria towards asylum seekers, especially from countries outside of Europe.

  1. Is there any mechanism in place for the purpose of monitoring and evaluation of implementation of relevant policies? If yes, please describe.

The text of the Strategy itself envisages a mechanism for reporting, evaluating and correction of the Strategy.[9] On the suggestion of the National Council for Migration, Borders, Asylum and Integration (NCMBAI), the Government approves an annual Implementation plan for the Strategy. The NCMBAI is responsible for the control of its execution and in the first trimester of the year the NCMBAI files a report for the execution. The Report contains an evaluation of the execution and suggestions for corrections of the Strategy based on analysis of economic, social, and political changes in the country and the EU and of regional and global processes, all made by the NCMBAI itself.

Legal framework - general provisions

  1. Please list national legislation that regulates topics related to asylum system (such as competent authorities, status determination procedure, rights, and obligations of both applicants for and beneficiaries of international protection, integration etc.)
  • Law on Asylum and Refugees (LAR);[10]
  • Foreigners in the Republic of Bulgaria Act (FRBA)[11] and its Implementation Rules (FRBA Rules);[12]
  • Constitution of the Republic of Bulgaria (CRB);[13]
  • Ordinance for the Responsibility and Coordination of State Authorities Accomplishing Actions for the Implementation of the Dublin Regulation and the EURODAC Regulation;[14]
  • Ordinance on the Rules for Administrative Detention of Aliens and the Functioning of the Premises for Aliens’ Temporary Accommodation;[15]
  • Internal Rules of Procedure in Immigration Detention Centres;[16]
  • Integration Ordinance;[17]
  • Law on the Bulgarian Citizenship;[18]
  • Child Protection Act;[19]
  • Persons with Disabilities Act;[20]
  • Other laws, applicable to all foreigners, which regulate aspects of refugee integration (Health Act, Health Insurance Act, Recognition of Professional Qualifications Act, Labour Migration and Labour Mobility Act, etc.).

 

  1. Beside refugee status and subsidiary protection, are there any other national protection and/or humanitarian statuses provided by your national legislation? Please describe and provide the full citation of the relevant provisions.

There are three other forms of protection status in Bulgaria: humanitarian status on other grounds, asylum, and temporary protection.[21]

Humanitarian status on other grounds is a type of national protection, which is provided on humanitarian grounds outside of the scope of Art. 9, para. 1 of the LAR.[22] Persons who have been granted humanitarian status on the grounds pursuant to Art. 9, para. 8 undergo the same procedure as persons with humanitarian status on the grounds, listed in Art. 9, para. 1.

Asylum is a type of protection granted for political reasons based on the decision of the president.[23] It can hardly be considered a viable type of protection since the grounds for application are narrow and the granting of asylum itself has a very political meaning. For the past 10 years there have been 204 applications for asylum, only one of which has been approved in 2013 and subsequently withdrawn in 2015.[24]

Temporary protection is a type of protection granted by the government in cases of mass influx of people. [25] The government decision can be issued after the Council of the EU has decided that temporary protection should be available for a certain group of asylum seekers.[26] At present it is available exclusively for persons fleeing from the Russian invasion of Ukraine. The application process is very short, and the application and accommodation processes are executed by more organizations as opposed to international protection.[27]

  1. Provide information on what authority approves refugee status, subsidiary protection, other national protection and/or humanitarian status in the first instance procedure (for example Ministry of Interior)? Please also provide details on competent authority in the appeal phase.

The main body responsible for the status determination procedure (SDP) is the State Agency for Refugees (SAR), part of the Council of Ministers. The Chairperson is the body of executive power and, respectively, the authority which approves/rejects the applications for international protection.[28] The Agency itself is the administrative body which organizes and executes the different stages of the SDP.[29] Temporary protection is granted by the government, where not only SAR, but also employees of the Ministry of Interior (MoI) partake in the admission process of the asylum seekers for the state to handle the amount of people entering the country.[30] As for asylum, the president has delegated these responsibilities to the vice-president, who works with the help of the Commission for Granting Asylum.[31] 

Appeal is regulated for decisions on applications for international and temporary protection. Granting of asylum is not an instrument for the protection of right to refuge, but a political act and is completely dependent on the decision of the president (or respectively the vice-president), thus the decision cannot be appealed.[32] In the ordinary procedure for granting of international or temporary protection, the competent authorities for appeals are, at first instance, the administrative courts and, at second and last instance – the Supreme Administrative Court.[33] In the accelerated procedure and for following applications, appeals can be made only before one instance and the time limit for filing the appeal is twice as short – 7 days instead of 14.

  1. What set of rights are guaranteed under your national legislation to beneficiaries of international protection? Are there any differences in the level of rights granted to recognized refugees and foreigners granted subsidiary protection? Please explain and provide the full citation of the relevant provisions.

All persons who have been granted international protection have the right to remain on the territory of the state[34] and to be reunited with their families.[35] Persons with a refugee status have the same rights as Bulgarian citizens with a few exceptions.[36] They have the right to apply for Bulgarian citizenship after 3 years of residency.[37] Persons granted subsidiary protection have the same rights as persons with a permanent residence permit.[38] This means that, as opposed to persons with a refugee status, persons under subsidiary protection can apply for Bulgarian citizenship 5 years after receiving protection.[39]

  1. If there is an additional national (humanitarian/protection) status prescribed by national legislation, please provide information on set of rights guaranteed as well as main differences in relation to level of rights granted to beneficiaries of international protection.

Persons with humanitarian status on the grounds in Art. 9, para. 8 have the same rights as persons with humanitarian status under Art. 9, para. 1. Persons who have been granted asylum have the same rights as persons with a refugee status.[40]

Rights of persons under temporary protection are far more limited: right to employment and vocational training, to appropriate accommodation or accommodation funding if needed, to social assistance, to emergency medical help, to freely return to their country of origin. [41] They also have the right to written information about the rules and conditions of temporary protection, right to a foreigner registration card, right to kindergarten for children under the age of 6, right to apply for international protection.[42] Vulnerable persons have the right to medical care equal to that of Bulgarian nationals.[43] Currently, persons fleeing the war in Ukraine have the right to humanitarian help in the form of accommodation and meals at places for accommodation, registered in the National Tourist Register, at a value of 40 BGN per day for the span of 3 months. This program is available until the 30th of September,[44] some sources say that it will be prolonged until 31st of October.[45]

  1. What does the national legislation prescribe in relation to family reunification with beneficiaries of international protection and which family members can be reunited? What conditions (such as proof of financial needs, proof of adequate housing, etc.) need to be fulfilled by persons who reunite with beneficiaries of international protection? What status is granted to reunited family members? Please provide the name of the law/regulation and full citation of the relevant provisions. 

Family reunification for persons with international protection is regulated by the LAR. All persons granted international protection have the right to reunite with their family.[46] Family ties must precede the arrival of the person on the territory of Bulgaria.[47] However, the FRBA does not contain a condition as to when the family ties were established.[48]

LAR contains an exhaustive list of the persons who count as family members.[49] Polygamy is not acknowledged in Bulgaria and a person can be unified with only one spouse. Unaccompanied minors can be unified with their parents or, in case their parents have deceased, another family member. [50] Permission is given by the Chairperson of the SAR, who can also decline the application.[51]

Family members of persons granted international protection can receive the same type of protection that that person has been granted, if the family ties precede the arrival of the person in Bulgaria.[52] The person who wants to request family reunification must present documents proving the relation between them and their family members. If they are unable to do so, family ties can be determined based on a declaration signed by the person or other means.[53] If it is unknown where the family members of the person are, he/she can request that the SAR, together with the UNHCR, the Bulgarian Red Cross and other organizations undertake actions to locate them.[54]

Arrivals 

  1. What possibilities of legal arrival(s) of refugee population are regulated within the existing legislative framework (such as family reunification or other channels such as resettlement/relocation/other models of (ad hoc) legal (humanitarian) admissions)? Which channels were used so far and when? What is/was the annual quota as set by the relevant document/provision for each channel? What was the result i.e. how many beneficiaries came through each channel in comparison to set quotas?

Possibilities for arrival on the territory of Bulgaria for asylum seekers apart from entrance through the border crossing point, include family reunification, resettlement and relocation.

Family members of persons who have already received international or temporary protection, have the right to enter Bulgaria based on the approved application for family reunification of their loved one.[55] This channel can be used constantly and there is no quota for it. For 2021, 203 family reunification applications were filed, 187 of which were approved and 16 were rejected.[56]

Resettlement and relocation are not specifically envisaged in national legislation but is executed in Bulgaria as a part of EU legislation and migration policy.[57] The quota for the programs throughout the years are as follows:

  • Relocated persons – 450[58] + 852 and an additional 697 persons after a period of 12 months;[59] time period – 2016-2017
  • Resettled persons
    • 2016-2017 – 50[60]
    • 2018-2019 – 110[61], 85 of which were actually resettled;[62]
    • Since 31st of October 2019 no new quota has been approved of.

In 2021 the Council of ministers issued a decision for admission of 70 Afghan nationals and their families to Bulgaria which have previously worked in our embassy there or have had official relations with EU, NATO or their structures.[63]This was however a one time ad hoc decision and no practice.

  1. What is/was the legal basis for the resettlement/relocation procedure or other models of legal (humanitarian) admissions? Please provide the name of law/regulation and the full citation of the relevant provisions. 
  • Decision №174 of 28.03.2017 of the Council of Ministers[64]
  • Decision №467 of 21.08.2017 of the Council of Ministers[65]
  • Decision №750 of 30.11.2017 of the Council of Ministers[66]
  1. What is/was the procedure for selection of beneficiaries in the resettlement/relocation procedure or in other type of nationally implemented program of legal admissions (for example some ad hoc programmes)?

Relocation and resettlement have a precise framework. The relocated persons are all from Italy and Greece – as per Decision №174, on the one hand, 60% of the first 450 must be from Italy and 40% - from Greece, on the other hand, 201 and 651 persons shall be relocated from Italy and Greece respectively to Bulgaria. The selection is based on “national selection preferences”, although no definition is given to this term whatsoever. The State Agency for National Security (SANS) is responsible for a screening process based on the information, given by either Italy or Greece and additional information provided by their record. If SANS establishes that a certain person is a threat to national security, SAR shall decline their relocation.[67] As for the resettled persons, the framework active throughout the years is applicable to Syrian nationals currently residing in Turkey, as it was developed in accordance with the EU-Turkey resettlement agreement.[68]

  1. How was/is the procedure of coming to your country organized (steps in the procedure: pre-departure, departure, arrival, integration phase)? Who are/were the relevant actors in each stage and what are/were their responsibilities/competencies?

The relocation procedure as described in the Framework has 5 phases: preparation (informing Italy and Greece for the number of persons who can be relocated and providing a list of national preferences), selection (evaluating the profile of the persons in comparison with the national preferences by the SAR and national security check by the SANS), transfer (agreement between Italy and Greece and the SAR and State Department for Border Police (SDBP) on the date and time of the transfer of the approved persons; Italy and Greece are responsible for the transport of the persons to the Bulgarian border and SAR is responsible for the transfer of the persons to its accommodation centres), application for international protection (in accordance with the LAR), integration (special integration programs with the voluntary assistance of municipalities). The application for international protection is conducted.

The resettlement procedure is analogical to the relocation one except for the preparation and selection, which are more detailed and include more actors. As per Decision №467, SAR informs the European Commission and the UNHCR of the number of persons who Bulgaria will accept. The UNHCR identifies the refugees in need of resettlement, makes a list with attached registration forms and prepares the documentation. The selection team, constituted by experts from SAR, SANS, the Ministry of Interior and interpreters, reviews the documentation provided by the UNHCR. In the selection phase the selection team is sent to Turkey, where it evaluates the truthfulness of the documentation, takes fingerprints, decides if the exclusion clauses are applicable. A record is made of each person. Afterwards, a list is made of the approved persons which is provided to the European Commission and the UNHCR. In the transfer phase the Ministry of Foreign Affairs issues travel documents to the accepted persons. SAR informs SDBP about the date, time, and entry point of the approved persons.

  1. What protection status is/was granted to beneficiaries upon arrival under each channel of legal admission (refugee status, subsidiary protection status, residence, other)? Please describe and provide the full citation of the relevant provisions. Also provide information which authority approves the status and at what point (for example before or after arrival)?

In cases of family reunification, the family members can receive the same status as their relative who has filed the application.[69] All other channels for arrival require applying for international protection via the general procedure.

  1. Other possible forms of legal arrival provided by national legislation (out of the scope of asylum legislation), which could be applicable to the refugee population (for example student’s sponsorships, family reunification for other foreigners, residence permits related to work, humanitarian residence related to position of victims or medical conditions, visa regime, possibilities related to legislation on foundations etc.). What legislative prerequisites do they have to fulfil? Please provide the name of law/regulation and full citation of the relevant provisions.

The FRBA envisages the opportunity for persons to receive a visa or permission to enter Bulgarian territory based on humanitarian grounds, whenever the state interests require so or whenever Bulgaria has an international obligation to do so.[70] This however is an exception and cannot be compared to the concept of a humanitarian visa.[71] Similarly, border control can issue at the legal entry points to Bulgaria 15-day visas, whenever the state interests require so, in case of extraordinary circumstances or on humanitarian grounds.[72] All other visas are available to refugees,[73] in case they have a valid travel document.[74] Visa and valid passport are required even if the refugee is a member of the family of a Bulgarian national,[75] unless they are a national of the EU or other countries with whom Bulgaria has concluded an agreement.[76] Family reunification is also an option under the FRBA.[77]

Integration

  1. Which authority/-iеs has/have (full or partial) responsibility for integration policies and on which level (level of the State, regional level, local authorities)?

The Government carries the main responsibility of approving the National Strategy on Migration. It is consulted by the NCMBAI. On regional and local level the mayor of each municipality has the authority to conclude an integration agreement with the SAR.[78]

  1. Who is responsible for coordination of integration policies?

The NCMBAI.[79]

  1. Which actors (state authorities, local authorities, international organizations, NGOs, others) participate in the implementation of integration policies, and what is their role? If there is any difference in integration/relevant actors in relation to beneficiaries of international protection and to those who came to country through legal admission channels (for example through resettlement, relocation), provide details/explanation.

The Strategy does not list which actors shall implement the integration section of the policy. Integration agreements are voluntary. Up until now only 17 such contracts have been made and only for relocated persons.[80] The main role in the integration process is implicitly delegated to NGOs and CSOs.

  1. Is the role of relevant actors regulated by legislation? If yes, provide the name of relevant regulation and full citation of the relevant provisions.

In the Integration Ordinance the role of the mayor and state institutions is regulated and the possible participation of NGOs in the integration process has also been mentioned, but only in the context of the integration agreements.[81]

  1. To what extent are these actors educated to work with persons granted international protection (in terms of the challenges these persons may face like potential vulnerabilities, trauma, etc.)?

There are no legal guarantees laid down that all actors are qualified to work with persons granted international protection, especially the volunteers, thus many of the fieldworkers have not been practically trained for such work.

  1. Are there any regular training programmes provided by relevant actors at the national and local level for institutions, but also for the local community in order to educate them about the rights, obligations, specific characteristics and needs of beneficiaries of international protection?

Some NGOs organize such trainings with or with the support of the state, but their scope is narrow and most state employees have not undergone such trainings for work with refugees, especially vulnerable ones.[82]

  1. Do the actors involved in the integration process (whether at local or national level) receive coordinated and continues support in carrying out their activities and / or responsibilities within their competence?

Rarely, most of the times the NGOs support each other. The main supporting mechanism envisaged in the Strategy for integration projects is financial support via the Fund “Migration, Asylum and Integration”.[83] Some NGO projects receive state support whenever they have won a state or municipality-initiated competition.

  1. To what extent (if any) immigrant-run and refugee-run associations and/or human rights CSOs partake in policy designing and implementing practices of early and later integration phases?

They are seen as a part of the general public as evident from the commentaries to the Strategy: the expert drafters rejected Amnesty International’s proposal for creating a possibility for NGOs and CSOs to participate in the drafting process since “the project was presented to the greater public for commentary, which is enough of a guarantee for the participation of all interested stakeholders.”[84]

Institutional framework

  1. Please list and describe structure and staffing of bodies/institutions on national and regional level responsible for asylum/migration/integration and briefly describe which bodies/institutions provide support to beneficiaries of international protection.

The institution responsible for assessing and deciding on the applications for international protection is the SAR.[85] It is governed by a Chairperson who is assisted by two Deputy Chairmen.[86] The institution responsible for assessing and deciding on the applications for asylum is the president of the Republic of Bulgaria (currently the vice-president)[87] with the help of the Commission on Asylum – an auxiliary body with advisory functions, which consists of a chairperson and members and is assisted by staff experts.[88] The government provides temporary protection introduced by a decision of the Council of the EU.[89]

The Migration Directorate of the MoI is the national specialized structure which regulates migration processes and conducts administrative control over the residence of foreigners in Bulgaria.[90] Separate regional Migration Departments with territorial competencies exist in the 28 regional MoI Directorates.

In respect of integration, the mayor of the municipality or an official authorized by him/her can sign an integration agreement.[91] Other institutions facilitating the integration of the beneficiaries of asylum and international protection are: the SAR; the Ministry of Education and Science; the Agency for Social Assistance and the National Employment Agency to the Minister of Labour and Social Policy; the Regional Health Inspectorates as administrative structures of the Ministry of Health; the Ministry of Youth and Sports; and the State Agency for Child Protection.

  1. Number of staff working at the determining authority/ies responsible for integration.

No specific data on the total number of staff responsible for integration is available.

  1. Annual budget and sources of finances.

Pursuant to Art. 18 of the Ordinance the sources of funding for integration measures are:

  • European funds
  • International and foreign financial instruments such as the Norwegian Financial Mechanism, etc.
  • International institutions and organizations.
  • national funding.
  1. During which phases of integration mentioned bodies/institutions provide support and assistance to beneficiaries of international protection?

Assistance is envisaged to mainly be provided immediately post-arrival – in respect of housing, entry in the population register, issuance of Bulgarian personal documents, enrolling children in schools, registration with the Labour Office Directorate, etc. Other more durable forms of assistance and support include provision of material or financial assistance to meet the basic household needs of the foreigner and his/her family members, the provision of monthly assistance for children enrolled in a preparatory group for compulsory preschool preparation, as well as training in Bulgarian language,though practically they are hardly ever provided for.[92]

  1. Please describe cooperation and coordination between various bodies/institution at national and local level in relation to integration.

The cooperation between institutions arises mainly in connection with the implementation of the integration agreement. The SAR prepares an integration profile of the foreigner during the SDP, informs him/her about the integration agreement, carries out information campaigns presenting the municipalities to the potential beneficiaries, and provides information materials to the foreigners on their rights and obligations under the integration agreement.[93] The mayor of a municipality submits an application to the SAR for the number of foreigners with whom he/she can sign an integration agreement.[94] Then the SAR provides the mayors of the municipalities with information on the foreigners who have applied for an integration agreement, and assists in the transportation of the foreigners and their family members to the respective municipalities. When the integration agreement is signed, the municipality sends it to the SAR together with a prepared individual integration plan.[95]

Other state entities are also engaged in the process for different services: the Ministry of Education and Science, the Regional Departments of Education, the Regional Health Insurance Fund, the Territorial Division of the Employment Agency, the Labour Office Directorate, Ministry of Youth and Sports, State Agency for Child Protection provide support in their respective fields; the Deputy Prime Minister coordinates the process of implementation of the signed integration agreements; the MoI notifies the mayor in case of administrative offences and crimes committed by the beneficiaries; and the State Agency for National Security, which identifies risks to national security in the process of integration of beneficiaries[96].

  1. Please describe collaboration of the government with private and civil sector regarding integration practices.

On a local level, the Integration Ordinance provides for the opportunity for the civil society sector to assist in the execution of integrational agreements.[97] On a national level there is no separate civil society consultative body on issues related to the integration of migrants. Representatives of the UNHCR and the IOM are, however, invited to participate in meetings of the NCMBAI.[98]

  1. Please list the most relevant NGOs projects related to the integration, implemented from 2015 onwards. Please provide references/links.
  • “National Integration Evaluation Mechanism” (NIEM) by Multi Kulti Collective[99]
  • “Advocacy for Refugee Integration in Bulgaria” by the Bulgarian Council on Refugees and Migrants (BCRM) and the UNHCR[100]
  • “Community support to asylum seekers and refugees in Bulgaria” by the Council of Refugee Women in Bulgaria (CRWB) and the UNHCR[101]
  • “Comprehensive integration support for legally resident third country nationals” by the Caritas Sofia and CRWB[102]
  • “Support for women, refugees or asylum seekers and their children, at risk of homelessness” by CRWB[103]
  • “Social Mediation and Community Support to Refugees and Asylum Seekers in Bulgaria” by CRWB[104]
  • “Increasing the capacity for work on social integration of refugees” by BCRM and UNHCR[105]
  • “Improving of reception conditions and protection environment for asylum seekers and refugees in Bulgaria” by BCRM and UNHCR[106]
  • "Legal aid to financially disadvantaged refugees and immigrants during a pandemic by using and improving the Migrantlife.Bg platform" by FAR[107]
  • “Bulgaria as part of an accessible information network” by FAR;
  • “Building an accessible network for legal aid to displaced persons from Ukraine in Bulgaria and preventing and counteracting human trafficking” by FAR[108]
  • “Effective Legal Aid to Refugees and Migrants in Bulgaria under the Active Citizens Fund” by CLA “Voice in Bulgaria” and FAR[109]

Strengths and weakness of national legislation and institutional and policy framework

  1. Have you identified any need for creation of new inter-institutional or inter-sectional partnerships, with indication of who would be a coordinator of such a partnership in sponsorship programs?

There is a need for inclusion of NGOs in the decision-making process regarding integration as NGOs are currently carrying out the integration process. Representatives of the private sector should also be more engaged when it comes to employment issues.

Additionally, there is currently no working coordination mechanism between institutions for effective integration of asylum seekers and refugees. The only available mechanism in the area of asylum and migration is the Coordination mechanism for unaccompanied refugee children, which was just recently approved by the Minister of Labour and Social Policy.[110] In practice this mechanism is ineffective as the actors are not fully aware of their responsibilities. We are indeed in a need of a systematic mechanism, where responsibilities are clearly written down and all actors are duly informed of their responsibilities with the SAR as a coordinating entity, as it is the main institution dealing with questions of asylum.

  1. Have you identified any financial needs/constraints or practical preconditions that should be taken into account?

When it comes to developing something new, usually national funds do not suffice and most projects are financed by the EU or other available mechanisms. Another issue would be the general lack of interest in the topic of asylum and migration, which leaves many state staff not to be interested to inform themselves on the matter.

  1. Highlight any other strengths and weakness of relevant legislation, other challenges/obstacles and consider any elements that may facilitate or hinder the establishment and functioning of sponsorship schemes? What existing legislation is applicable? What laws, regulations, policies, and procedures would need to be changed or enacted to enable community sponsorship/private sponsorship in your country? Please provide information how any of this legal/institutional/policy framework is being implemented (or not implemented) in practice and, if possible, please provide examples of best practices, obstacles, challenges identified in different phases (for example in arrival or in different stages of integration practices) within the system.

Many legal vacuums would constitute hurdles for a sponsorship scheme. Holding valid identification documents is necessary to enter into a rental contract, yet identification documents cannot be issued if the person does not state a domicile, leading to the vicious practice of “buying” fictional addresses of residence. Address of residence is a problem when applying for social assistance as well.[111] Some types of the social assistance cannot be enjoyed by beneficiaries of international protection without additional special arrangements (e.g. interpretation, social mediation), which are not envisaged or secured to them by law or institutionally.[112] When accessing the labour market there are no reliefs in the procedure for legalization of diplomas and acknowledgement of professional qualifications. Foreigners have no access to the labor market for the first 3 months of their SDP.[113]

A good practice in the area of integration, established over the years, is the assistance of social mediators, who advise and consult in the first integration steps of asylum seekers.

 

QUALITATIVE EMPIRICAL RESEARCH REPORT

  1. Introduction

As the topic of asylum and migration is considered very controversial, borderline taboo, it is often sensationalized by the media and exploited by politicians to further their agendas. Recently this situation has been amplified due to the lack of clarity on the accommodation of Ukrainian refugees and the therefore stemming issues,[114] the upcoming elections[115]and a recent incident where a bus with illegal migrants in it crashed in a police car attempting to cease the vehicle, killing both of the police officers inside.[116]

Currently the state is struggling with the amount of migrants as 53% of the capacity of the SAR is filled[117] and as another peak in migration from the Turkish border arises.[118]

  1. Methodology
    1. Period of research and research sites

The research was conducted using the focus group (FG) methodology. The FGs were organized in the span of approx. 3 months (end of June to beginning of September 2022). Representatives of 4 of the target groups (CSOs, Private sector, Refugees and Mixed) were gathered in person in coworking facilities. 2 of the target groups (Political parties and Religious communities) had to be interviewed individually both in person and online.[119]

  1.  
    1. Selection and recruitment of participants

Participants were contacted through official communication and personal professional networks. Representatives of various political parties from the whole political spectrum were contacted based on their participation in the Parliament and political life in Bulgaria. Representatives of various religious communities were contacted based on their influence on a national and local scale. CSO representatives were contacted based on their expertise in the area. Private sector representatives were contacted based on previous engagement of the companies or individuals in similar formats, as well as the individual’s motivation to participate. Refugee participants were contacted based on their personal stories and experiences, but also their willingness to participate in such formats. Participants in the mixed group were contacted based on the previous focus groups.

  1.  
    1. Main research challenges

The opinions of the representatives of political parties and religious communities were gathered through individual interviews as none of the invited persons responded on time to the invitation or at all. Consideration must be taken of the fact that the last Bulgarian government had fallen at the end of June,[120] thus the timeframe for conducting the focus groups lined up with pro-term election preparation. As contacting them through official communication did not bear any results, resort had to be made to personal professional contacts.

Additionally, finding participants for the private sector group was also challenging as the timeframe for conducting the focus groups lined up with the peak vacation time of the year. Thus many of the invitations were left with no initial response or met a decline as the company representatives did not entirely understand the topic of the discussion. The challenge was resolved with multiple contacting of many companies until a group was formed.

Also, some of the questions in the protocol had to be adjusted to the experience of the focus group as many of the participants did not have a legal background or background in asylum and migration.

  1.  
    1. Participant demographics

Altogether 32 persons participated in the focus groups. Separately for each group the participants are as follows: Religious communities (RCFG) – 5 (all men); CSO (CSOFG) – 7 (5 women, 2 men); Private sector (PSFG) – 5 (3 women, 2 men), Refugees (RFG) – 6 (1woman, 5 men); Political parties (PPFG) – 4 (all men); Mixed (MFG) – 5 (2 women, 3 men). Participants from the PPFG are activists from smaller parties and movements with experience either in Parliament or political life in Bulgaria as a whole. Participants from the RCFG appertain to different beliefs (orthodox Christianity, Catholicism, Protestantism, Ecumenism, Judaism, Islam) and have a different position in the religious organization they belong to (spiritual leaders, pastors, administrative staff, heads of NGO part or a religious organization). Participants from the CSOFG are expert researchers, lawyers and activists engaged in the area of asylum and migration. Participants from the PSFG have various backgrounds – law, human resources, investment, academic work, production of orthopaedic materials. Participants from the RFG all have or are currently undergoing the standard SDP in Bulgaria. Participants from the MFG include lawyers, representatives of NGOs and refugees.

  1. Findings
    1. “Perception of refugees and needs for protection in the national context“ (including subtopics such as levels of information, sensibility, public opinion, media portrayals, etc)

The general opinion on the matter is that the perceptions of refugees and migrants in Bulgaria is mainly negative and predicted by the interests of media and politicians. No integrational mechanism is currently available for asylum seekers, which is further hindered by many prohibitions and legal vacuums as stated by the RFG. All agree that the attitude towards refugees somewhat depends on their state of origin – Ukrainian refugees enjoy a bit more favourable attitude than other refugees.

CSOFG signalled that there is a general lack of coordination between institutions and interest in the Bulgarian society on the topic of asylum and migration. Diversion is also drawn between big cities and small localities as the former have a more liberal approach to such topics, as pointed out by the RCFG. This could be due to lack of information available in smaller localities, as the PPFG and the MFG emphasized on the need for providing more information in smaller towns, though MFG notes that the expected proactive spread of information by the SAR is non-existent.

  1.  
    1. „Awareness levels and attitudes towards sponsorship and other complementary pathways“ (including perceived advantages of complementary schemes, selection criteria for candidates, roles and responsibilities of sponsors, duration of sponsorship, other practicalities, etc)

Most of the participants except for those in the CSOFG were not familiar with the concept of private sponsorship schemes (PSS) and even with other complementary pathways. The consensus is that such a scheme could be very beneficial for the state as legal migration would be encouraged, the economic and demographic crisis can be minimised, and some order can be put in the chaos that is the current integration in Bulgaria. However, designing, developing, implementing and coordinating such a scheme is unrealistic. A particular risk which a PSS poses is that of labour exploitation (CSOFG).

Most of the FGs (CSOFG, MFG, PSFG) agree that the sponsor should set out their criteria for the persons they would sponsor so that conditions of the sponsorship can be as clear as possible. PPFG suggested that priority be given to those most capable of integrating, in agreement with RCFG, and that the characteristics of the local receiving community be considered in the identification stage. Additionally, the beneficiaries must fulfil the criteria to receive a refugee status (CSOFG, PSFG). PSFG suggested that the identification is done in two stages – initial one to see whether the person fulfils the criteria and has the needed documentation and a follow up one which is far more detailed. Some suggested criteria for the sponsor themselves include: to be registered in a database, undergo sponsor training and an interview on their motivation to participate, to have no convictions, to prove financial stability, to be legally residing, to be settled in Bulgaria (CSOFG).

All agreed that the state should be responsible for the admission and issuing of the documents of the beneficiaries, though whether the state should have more responsibilities than that is a disputable question. It should also be engaged in the identification phase, where the UNHCR could be of help (PSFG and CSOFG). The sponsor is seen to act mainly in the steps after arrival (PSFG). Some of the listed possible responsibilities of the sponsor include covering travel costs (CSOFG and RFG); assist with finding or providing accommodation when possible (PSFG and RFG); preparation of documents and support during the RDP, finding a job, language and education (RFG); steps towards integration as a whole (PSFG).

When it comes to legal regulation, both legal guarantees and special tripartite agreement between each sponsor and each beneficiary, and the state should be concluded with clear grounds for ceasing should be available (CSOFG, PSFG). Breach of the agreement by the sponsor should lead to administrative responsibility (CSOFG). Additionally, the RCFG note that a separate mechanism for dispute resolution between the religious communities would be needed. The PSS should continue up until the beneficiary is able to self-sustain (RFG, PSFG). How much the legal maximum should be however is a point of contention.

  1.  
    1. “Monitoring and evaluation of sponsorships and other complementary models” (including stakeholders cooperation agreements, coordination mechanisms, indicators of success, etc)

Aside some disputes in the RFG, the general agreement is that the state should be in the centre of coordinating the PSS, represented preferably by the SAR. CSOFG suggested that NGOs should monitor such a scheme, while the PSFG noted that NGOs should help where needed as coordinated by the SAR. For coordination of integration in the post-arrival phase the RCFG suggested that the Ministry of Labour and Social Policy is responsible. PSFG suggest that control checkpoints are put into place for every stage to know how the beneficiary is doing. All this information should be put in a coherent database, including information on sponsors.

Evaluation of the PSS should be done based on a complex evaluating system in the opinion of the PPFG, which allows to take into consideration the feedback of the community and flexible corrections accordingly. They believe however that „success“ can be measured hardly 2-3 years after the start of the programme. Indicators of success as per the MFG include number of beneficiaries; number of sponsors; duration of the PSS as a whole; community feedback.

When it comes to the development of related policies, participants in the process should be the SAR, the government, and the Prime minister (PPFG), MoI, Ministry of Education, Ministry of Labour and Social Policy, MFA, NGOs, universities, employers (CSOFG), UNHCR, syndicates, forum of the business leaders, council of the rectors of universities (MFG).

  1.  
    1. “Interest in participating in/supporting sponsorship and other complementary programs” (including potential roles, preferred parts of process/services, support needed and from whom, perceived role of other stakeholders/partners, etc)

CSOFG and RCFG are interested to participate in such a scheme with the expertise and role they currently have. PSFG and RFG also showed interest to participate in such a scheme or recommend others to join. PPFG does not believe that the public and authorities would be convinced at this point that implementing a PSS would be successful.

CSOFG, RFG, PSFG and MFG agree that support in the form of tax deductions for the sponsors would be a big motivating factor for participation in the PSS. Other noted opportunities for motivation: a coordination mechanism allowing easier communications with institutions (CSOFG and RFG), deduction from living costs such as water and electricity (PSFG). More emphasis should be put on the positives of PSS for the country and a guarantee could be put in place that the beneficiaries would be obliged to stay a certain period of time in Bulgaria to work and obliged to learn Bulgarian. Motivation for the state would be the possibility for better control over the migration stream (CSOFG).

To avoid scepticism and uncertainty, PPFG and RCFG approve of the idea to launch a small-scale pilot project to test the attitudes and readiness of the general public for such a scheme.

  1. Discussion

Naturally, some points of contention between the different social groups became evident. The first one would be the question of the criteria for selecting beneficiaries. Though most other groups agree that the sponsors should state their preferences, RFG sees this as a selective search for the best leftover workforce in other countries and states that prioritizing persons is not humane. In this regard the PSFG suggest that a separate branch of the PSS is established for vulnerable persons unable to work or study, which branch is to be more dependent on state funding. RCFG shared that supporting persons from the same religion would be a priority for them.

Another topic of controversy is the responsibilities of the state. Some participants in the RFG believe that the state should have minimal responsibilities in the PSS. MFG also agrees that the state should be less involved, although it's participants stand by the state being responsible for access to territory. PPFG in agreement with the opinion of the RCFG also argue that the state should have a lead role in the identification as it is a guardian of national security, whilst participants in the RFG felt that the UNHCR or a similar organisation should have a greater role in the identification stage. PPFG and PSFG agreed that the state could participate in the integration part through funding, providing for medical care, education, language learning, etc. As regard the responsibilities of the sponsor, covering travel costs proves to be a controversial point for PSFG as this is a high investment for a company to make for a person compared to the cost which it pays for finding a Bulgarian to do the same job.

The suggested length for the PSS also varies form FG to FG: CSOFG stood by at least 6 months, RFG participants proposed anywhere between 4-12 months with flexible options for amendment and periodical screening and assessment.

Whether new legal framework is needed is also a controversial point: some participants in the CSOFG and in the PPFG believe that an entirely new framework is required for the PSS to come into place, as many of the current legislation creates hurdles for the asylum seekers, especially in regards to effective integration; other participants from the same groups and the MFG think that it would be easier and more effective to try and use the existing legal opportunities to implement the scheme, especially as early lobbying for legal amendments could be ineffective.

  1. Conclusion and Recommendations

In conclusion, the FGs agree on many aspects of a PSS, and first of all – that a PSS or any other alternative pathway would be beneficial for the state in terms of introducing new workforce on the Bulgarian labour market. The efficiency of this project however is prejudiced by the current narratives against asylum seekers and migrants as a whole. More information should be spread in smaller localities and more positive narratives in the media showing the stories of refugees in Bulgaria would be vital to starting a recourse in the public opinion on the matter. Many other legal hinderances would also have to be amended prior to a PSS coming into place: the prohibition on working for the first 3 months of applying for asylum; opening a bank account; finding an address to receive documents on, etc. Very clear distribution of responsibilities has to be written down and all conditions for participation have to be clear to all parties involved prior to the execution of the project. The advantages of PSS should be highlighted in the debate with decision-makers and the public, out of which saving human lives and legal access to the territory by refugees are the first to mention.

 

The Project COMP4SEE was funded by the European Union’s Asylum, Migration and Integration Fund. The content of this document represents the views of the author only and is his/her sole responsibility. The European Commission does not accept any responsibility for use that may be made of the information it contains.

 

[1] Council of Ministers. National Strategy on Migration 2021-2025. 24.03.2021, available at: https://www.mvr.bg/docs/librariesprovider57/default-document-library/национална-стратегия-по-миграция-на-република-българия-2021---2025-г.pdf?sfvrsn=887ab4a7_0, last visited on 25.09.2022.

[2] The Strategy, section VI, pps. 30-32.

[3] Council of Ministers. Information on reflection of the notes, suggestions, and findings on the Project for a Decision of the Council of Ministers for adoption of a National Strategy on Migration 2021-2025 (Commentaries to the Strategy), pps. 3, 5 and 14; available at: https://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=5827, last visited on 25.09.2022.

[4] FRBA, Art. 44, para. 9.

[5] Ordinance for the Conditions and Procedure for Conclusion, Execution and Suspension of the Agreement for Integration of Foreigners with Granted Political Asylum or International Protection (“Integration Ordinance”); available at: https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=116399, last visited on 25.09.2022.

[6] Rositsa Atanasova. Expert commentary of “CLA – Voice in Bulgaria” on the National Strategy on Migration of the Republic of Bulgaria 2021-2025, available at: https://migrantrights.eu/2021/05/12/експертен-коментар-от-цпп-глас-в-бълг/, last visited on 25.09.2022.

[7] The Strategy, section IV, p. 20.

[8] The Strategy, section IV, p. 14.

[9] Ibid., section IV, pps. 51-52.

[10] Available in English at: https://www.refworld.org/pdfid/47f1faca2.pdf (please note that this translation includes only the amendments up until 2015; all cited provisions include the latest amendments up until 2021, provisions which have not been amended as of 2015 will not be cited); last visited on 25.09.2022.

[11] Available in English at: http://www.bulgarian-citizenship.com/wp-content/uploads/2017/12/FOREIGN… (please note that this translation includes only the amendments up until 2016; all cited provisions include the latest amendments up until 2021, provisions which have not been amended as of 2016 will not be cited); last visited on 25.09.2022.

[12] Available in Bulgarian at: https://www.lex.bg/laws/ldoc/2135738597, last visited on 25.09.2022.

[13] Available in English at: https://www.parliament.bg/en/const, last visited on 25.09.2022.

[14] Available in Bulgarian at: https://lex.bg/laws/ldoc/2135576190, last visited on 25.09.2022.

[15] Available in Bulgarian at: https://lex.bg/bg/laws/ldoc/2135684112, last visited on 25.09.2022.

[16] Available in Bulgarian at: https://www.mvr.bg/docs/librariesprovider57/default-document-library/%D0%BF%D0%B2%D1%80-%D1%81%D0%B4%D0%B2%D0%BD%D1%87_28072017-%D1%86%D0%BA%D0%BD%D1%87-31-07-174436e7736f1e4afc8b5d2e64abcc511b.doc?sfvrsn=770cba5f_0, last visited on 25.09.2022.

[17] See ftn 6.

[18] Available in Bulgarian at: https://www.lex.bg/laws/ldoc/2134446592, last visited on 25.09.2022.

[19] Available in English at: https://www.mlsp.government.bg/eng/child-protection, last visited on 25.09.2022.

[20] Available in Bulgarian at: https://www.lex.bg/bg/laws/ldoc/2137189213, last visited on 25.09.2022.

[21] LAR, Art. 1, para. 2.

[22] Ibid., Art. 9, para. 8.

[23] CRB, Art. 27, para. 2; also, LAR, Art. 2, para. 1.

[24] Commission for granting of asylum. Report for 2012-2016. Available at: https://m.president.bg/bg/cat111/Godishni-dokladi-ubejishte, last visited on 25.09.2022.

[25] LAR, Art. 1a, para. 3.

[26] Ibid., Art. 2, para. 2.

[27] Council of Ministers. National Strategy for Action in Cases of Temporary Protection in the Republic of Bulgaria. 7.07.2011; Available at: https://www.strategy.bg/StrategicDocuments/View.aspx?lang=bg-BG&Id=706, last visited on 25.09.2022.

[28] LAR, Art. 48, para. 1 (1); please note that the referenced Art. 17, para.4 was previously Art. 17, para. 3.

[29] Ibid., Art. 47, para. 2 (1) and (2).

[30] See ftn 27, Section 3, para. 2.

[31] LAR Art. 2, para. 1.

[32] Asylum.BG. Asylum from the President. Available at: https://asylum.bg/bg/bg5-1, last visited on 25.09.2022.

[33] LAR, Art. 84, paras. 2 and 3: „(2) The decisions under Art. 51, para. 2, Art. 70, para. 1, Art. 76b, para. 1, subparas. 1 and 2 and Art. 77, para. 1 may be appealed before the administrative court with jurisdiction over the current address indicated on the alien’s registration card within 7 days from the service thereof. (3) (New, 2020) The decisions under Art. 34, para. 3, Art. 39a, para. 2, Art. 75, para. 1, subparas. 2 and 4 and Art. 82, para. 2 may be appealed before the administrative court with jurisdiction over the current address indicates on the alien’s registration acrd within 14 days from the service thereof.”

[34] Ibid., Art. 32, para. 1: „(New, 2020) An alien who has been granted international protection shall be entitled to remain on the territory of the Republic of Bulgaria for the time being of the validity of the Bulgarian identification documents issued to them.”

[35] Ibid.., Art. 34, para. 1: „An alien who has been granted international protection shall be entitled to ask for family reunification on the territory of the Republic of Bulgaria, in case that the family ties precede the person’s arrival on the territory of the state.“

[36] Ibid.., Art. 32, para. 2 (previously para. 1).

[37] LBC, Art. 13a, para. 1: „A person who has been granted refugee status or asylum no less than 3 years as of the date of naturalization, can acquire Bulgarian citizenship, if they meet the conditions of Art. 12, paragraph 1 (1), (3), (4) and (5).”

[38] LAR, Art. 32, para. 3 (previously para. 2).

[39] LBC, Art. 13a, para. 2: “A person who has been granted subsidiary protection no less than 5 years as of the date of naturalization, can acquire Bulgarian citizenship, if they meet the conditions of Art. 12, paragraph 1 (1), (3), (4) and (5).”

[40] LAR, Art. 31, para. 2.

[41] Ibid., Art. 39, para. 1.

[42] FAR. Temporary protection. 11.03.2022, available at: https://farbg.eu/bg/latest/vremenna-zakrilavremennaya-zaschitatimchasoviy-zakhist, last visited on 25.09.2022.

[43] LAR, Art. 39, para. 3.

[44] Ministry of Tourism. The period of action of the program for humanitarian support for refugees from Ukraine will be prolonged by a month. 28.07.2022, available at: https://www.tourism.government.bg/bg/kategorii/v-mediite/s-edin-mesec-se-udulzhava-periodut-na-deystvie-na-programata-za-humanitarno, last visited on 25.09.2022.

[45] Dirbg. The program for accommodating Ukrainian refugees in hotel will continue until 31st of October. 14.09.2022, available at: https://business.dir.bg/ikonomika/udalzhavat-do-31-oktomvri-programata-za-nastanyavaneto-na-ukrainski-bezhantsi-v-hoteli, last visited on 25.09.2022.

[46] LAR, Art. 34, paras. 1-3.

[47] “(1) An alien who has been granted international protection shall be entitled to ask for family reunification on the territory of the Republic of Bulgaria, on the condition that the family ties precede the arrival of the alien on the territory of the state.”

[48] FRBA, Art. 24, para. 1(13); also, FRBA Rules, Art. 12, para. 1.

[49] Additional Provisions of the LAR, para. 1 (3).

[50] LAR, Art. 34, para 4.

[51] Ibid., Art. 12, para. 1, subparas. 1-3 “3. there are serious grounds to assume that he/she commits,  incites, aids, partakes in trainings or preparations towards acts contrary to the goals and principles of the United Nations Organisation;”

[52] Ibid, Art. 8, paras. 9 and 10; also, Art. 9, paras. 6 and 7.

[53] Ibid Art. 34, para. 5.

[54] Ibid., Art. 34, para. 9.

[55] LAR, Art. 12, para. 1, subparas. 1-3; also, FRBA Rules, Art. 12, para. 8.

[56] AIDA. Country Report: Bulgaria. 2021, p. 96; available at: https://asylumineurope.org/wp-content/uploads/2022/02/AIDA-BG_2021update.pdf, last visited on 25.09.2022.

[57] See next question, paras. 1-4.

[58] Ibid, para. 2.                              

[59] Ibid, para. 3.

[60] Council for Justice and Home Affairs. Outcome of the 3405th meeting. 20 July 2015, pps. 4 and 7

[61] Council of Ministers. Decisions of the Meeting on the 28.11.2018; available at: https://www.gov.bg/bg/prestsentar/zasedaniya-na-ms/dneven-red-na-zasedanieto-na-ministerskiya-savet-na-28-11-2017-g, last visited on 25.09.2022.

[62] UNHCR, The Bulgarian Council on Refugees and Migrants. Refugees: today and tomorrow. 12.2020, p. 42; available at: https://ec.europa.eu/migrant-integration/sites/default/files/2021-01/5AB_prinable.pdf, last visited on 25.09.2022.

[63] MFA. MFA successfully evacuated from Kabul the native staff member of the Bulgarian embassy. 25.09.2021, available at: https://www.mfa.bg/bg/news/31211, last visited on 25.09.2022.

[64] Decision №174 of 28.03.2017 of the Council of Ministers for approval of the amended Framework for Execution of the Republic of Bulgaria’s Obligations as regard Council Decision (EU) 2015/1523 of 14.09.2015 and Council Decision (EU) 2015/1601 of 22.09.2015, approved by Decision №858 of 2015 of the Council of Ministers; framework available at: https://mvr.bg/docs/librariesprovider72/документи-от-съветът/2c334c7a-nmpdf.pdf, last visited on 25.09.2022.

[65] Decision №467 of 21.08.2017 of the Council of Ministers for approval of the amended Framework of the National Mechanism for Execution of the Republic of Bulgaria’s Obligations as regard Resettlement, approved by Decision №263 of 2016; Available at: https://www.mvr.bg/docs/librariesprovider79/документи/rms467.pdf?sfvrsn=87ebeec5_2, last visited on 25.09.2022.

[66] Decision №750 of 30.11.2017 of the Council of Ministers for approval of the amended Framework of the National Mechanism for Execution of the Republic of Bulgaria’s Obligations as regard Resettlement, approved by Decision №263 of 2016; part of the 2018 National Action Plan of the NCMBAI, available at: https://www.strategy.bg/FileHandler.ashx?fileId=17043, last visited on 25.09.2022.

[67] Decision №174, p. 4, para. 4.2.

[68] Decision №467, p. 2.

[69] LAR, Art. 8, paras. 9 and 10; respectively, Art. 9, paras. 6 and 7; Art. 22.

[70] FRBA, Art. 10, para. 2.

[71] European Parliament. Humanitarian visas: "A right to be heard without risking your life". 8.11.2018; available at: https://www.europarl.europa.eu/news/en/headlines/world/20181031STO18177/humanitarian-visas-a-right-to-be-heard-without-risking-your-life, last visited on 25.09.2022.

[72] LAR, Art. 9e.

[73] FRBA, Art. 9a.

[74] Ibid, Art. 8, para. 1.

[75] Ibid, Art. 8a, para. 1.

[76] Ibid, Art. 8, para. 2.

[77] Additional Provisions of the FRBA, para. 1(1a).

[78] Integration Ordinance, Chapter III.

[79] Ordinance №226 of 10.09.2019 for the Establishment of a National Council for Migration, Boarders, Asylum and Integration and approval of a Regulation Book on the Organization and Activities of the NCMBAI, Section III, Art. 5, paras. 1 and 4; available at: https://saveti.government.bg/web/cc_1603/1, last visited on 25.09.2022.

[80] AIDA. Country Report: Bulgaria. 2021, p. 88.

[81] Integration Ordinance, Art. 28.

[82] AIDA. Country Report: Bulgaria. 2021, p. 45.

[83] The Strategy, section IV, p. 21.

[84] Commentaries to the Strategy, p. 8.

[85] LAR, Art. 2, para. 2.

[86] Ibid, Art. 50, para. 1.

[87] See answer to Question 6.

[88] Rules for Work of the Commission on Asylum to the President of the Republic of Bulgaria, Art. 7; available at: https://m.president.bg/bg/cat23/Komisia-po-predostaviane-na-ubejishte, last visited on 25.09.2022.

[89] LAR, Art. 2, para. 3.

[90] Migration Directorate. Official website. available at: https://www.mvr.bg/migration, last visited on 25.09.2022.

[91] Integration Ordinance, Art. 3.

[92] AIDA. Country Report: Bulgaria. 2021, pps. 87-88.

[93] Integration ordinance, Art. 20.

[94] Ibid, Art. 13.

[95] Ibid, Art. 14.

[96] Ibid, Chapter 4.

[97] Ibid, Chapter 5.

[98] European Commission, Governance of migrant integration in Bulgaria. Available at: https://ec.europa.eu/migrant-integration/country-governance/governance-migrant-integration-bulgaria_en, last visited on 25.09.2022.

[99] NIEM. About NIEM. http://www.forintegration.eu/pl/about-the-project, last visited on 25.09.2022.

[100] BCRM. Project description. https://bcrm-bg.org/en/projects/#undefined last visited on 25.09.2022.

[101] CRWB. Project description. 14.07.2021, available at; https://crw-bg.org/en/public-support-for-asylum-seekers-and-refugees-in-bulgaria/, last visited on 25.09.2022.

[102] CRWB. Project description. 30.09.2021, available at: https://crw-bg.org/en/comprehensive-integration-support-for-legally-resident-third-country-nationals/, last visited on 25.09.2022.

[103] CRWB. Project description. 31.05.2020, available at: https://crw-bg.org/en/support-for-women-refugees-or-asylum-seekers-and-their-children-at-risk-of-homelessness/, last visited on 25.09.2022.

[104] CRWB. Project description 31.12.2019, available at: https://crw-bg.org/en/social-mediation-and-community-support-to-refugees-and-asylum-seekers-in-bulgaria-2019/, last visited on 25.09.2022.

[105] BCRM. Project description, available at: https://bcrm-bg.org/en/projects/2019/#undefined, last visited on 25.09.2022.

[106] BCRM. Project description, available at: https://bcrm-bg.org/en/projects/2017/#undefined, last visited on 25.09.2022.

[107] Foundation for Access to Rights – FAR. Project description available at: https://www.farbg.eu/en/projects/legal_aid_financially_disadvantaged_refugees_immigrants_in_%20pandemic

[108] Foundation for Access to Rights – FAR. Project description available at: https://www.farbg.eu/en/projects/building-accessible-network-legal-aid-displaced-persons-ukraine-bulgaria-and-preventing

[109] Foundation for Access to Rights – FAR. Project description available at: https://www.farbg.eu/en/projects/effective-legal-aid-refugees-and-migrants-bulgaria-under-active-citizens-fund

[110] National network for children. All refugee children must be trated as children. 14.06.2022, available at: https://nmd.bg/vsitchki-detsa-bezhantsi-tryabva-da-badat-tretirani-parvo-kato-detsa/, last visited on 25.09.2022.

[111] AIDA. Country Report: Bulgaria. 2021, p. 98.

[112] Ibid.

[113] LAR, Art. 29, para. 3.

[114] The Sofia Globe. Ukrainian refugees expected to move to Bulgaria’s interior as hotel scheme nears end. 26.08.2022; https://sofiaglobe.com/2022/08/26/ukrainian-refugees-expected-to-move-to-bulgarias-interior-as-hotel-scheme-nears-end/, last visited on 25.09.2022.

[115] Euractiv. Bulgaria to hold snap election on 2 October. 1.08.2022; https://www.euractiv.com/section/elections/news/bulgaria-to-hold-snap-election-on-2-october/; last visited on 25.09.2022.

[116] Euronews. Two police officers dead after migrant bus ploughs through roadblock. 25.08.2022; https://www.euronews.com/2022/08/25/two-police-officers-dead-after-migrant-bus-ploughs-through-road-block, last visited on 25.09.2022.

[117] See ftn 97.

[118] Nova. Because of the migration pressure: Partial emergency declared in Bugras, Haskovo and Yambol. 25.09.2022; https://nova.bg/news/view/2022/09/23/383866/заради-мигрантския-натиск-обявиха-частично-бедствено-положение-в-бургаско-хасковско-и-ямболско/, last visited on 23.09.2022.

[119] See Main research challenges.

[120] The Guardian. Bulgaria’s pro-western government collapses after just six months. 22.06.2022; https://www.theguardian.com/world/2022/jun/22/bulgaria-government-collapses-kiril-petkov, last visited on 24.09.2022.

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