EUROPEAN CIVIC FORUM’s Civil Space Watch 2025 is published: a summary of the Bulgarian chapter

This summary is prepared by Emma Gurney, McGill University student and intern at BCNL

The full report available here:

Bulgarian Chapter prepared by BCNL here: https://civic-forum.eu/wp-content/uploads/2025/06/Civic-Space-Report-2025-Bulgaria.pdf

In 2024, Bulgaria’s civil society operated under mounting pressure amid a prolonged political crisis, rising far-right influence, and increasingly hostile legal and institutional environments. While media freedom and civic activism showed small gains, CSOs faced smear campaigns, stalled funding reforms, anti-LGBTQ+ legislation, and repeated attacks on freedom of expression and association. A proposed Foreign Agents Registration Act (FARA) and flawed lobbying reform efforts further threatened civic space. Yet, civil society responded with resilience by mobilizing against repressive laws, increasing public engagement, and pushing for structural reform. Key recommendations include repealing discriminatory laws, protecting civic freedoms, and restoring mechanisms for CSO participation and funding.

 CommentsTrend
Politics and ElectionsThe Bulgarian political crisis was resolved in early 2025.
Freedom of AssemblyFreedom of Assembly is generally in line with international standards.
Freedom of ExpressionA 2021 political shift led to a gradual improvement of Freedom of Expression.
The Right to PrivacyFar-right parties breach CSO members’ right to privacy with relative impunity.
Minority RightsMacedonian CSOs are continuously denied freedom of association, and anti-LGBTQ+ legislation was passed in 2024.
CSO FundingThere is a limited culture of charitable giving, and institutional roadblocks make it difficult for CSOs to access consistent funding outside of project-based stipends.
CSO–Government CollaborationThe political crisis led to the stalling of many promising advancements in CSO-Government collaboration.
  Legend   ↑ : improved  ­– : no change ↓ : worsened  

The State of Civil Society in Bulgaria

Political Crisis

Bulgaria experienced a state of political crisis from 2021 to early 2025. During this period, the country faced seven parliamentary elections: April 2021, July 2021, November 2021, October 2022, April 2023, June 2024, and October 2024. Though the April 2023 election showed promise with its novel rotational solution, this government failed in March 2024 after the first planned rotation of the prime minister and his deputy failed. This dissolution led to the June 2024 election, which was marked by the lowest voter turnout in Bulgarian post-communist history, which again failed to produce a regular government.[1]

Bulgaria’s final October 2024 elections, though yielding a regular government, were shrouded in scandal. The new Parliament is composed of eight parties, including a new populist party. Notably, the far-right Russophilic Revival Party earned third place in the election. However, another populist party, which was briefly a member of the Parliament after the elections in June the same year, failed to pass the threshold for parliamentary representation by just twenty-one votes. Consequently, the election results were challenged in the Constitutional Court. Following a four-month investigation, the Court found that the election of seventeen MPs representing various parties was illegal and ordered that these MPs be disqualified.[2]

The political crisis bled outside of the executive branch to other areas of government. Multiple public sectors and regulatory bodies operate with an expired mandate, and the position of ombudsman remains vacant. The Supreme Judicial Council, operating with an expired mandate, has started the procedure for a controversial single-candidate election for Prosecutor General, and has made two unsuccessful attempts to trigger an election for the President of the Supreme Administrative Court.

Freedom of Assembly

The Bulgarian legislation ensures the enjoyment of the freedom of assembly and protest largely in line with international standards.[3] Though two provisions ought to be improved: the ban on participation of masked people in protests, and the ban on assemblies from 22:00 to 8:00. However, there is no indication that these provisions are applied strictly or abused.

In November 2024, far-right groups and political figures organized a protest against what they perceived to be commentary insulting the Bulgarian army in a play. Despite indications that this protest could be a security issue and the affiliation of the organizing groups to multiple instances of disruption against cultural events of the LGBTQI+ community in the past,[4] no proper policing of the protest was provided. This lapse in protection allowed the protest to turn violent; several actors and audience members attempting to enter the theatre were attacked by the mob, and consequently, the play was closed to the general public.[5]

Freedom of Expression

Since 2006, Bulgaria’s media freedom has declined significantly, reaching its lowest EU ranking in 2021 (112th). This decline coincided with the dominance of the GERB party. A political shift in 2021 led to gradual improvement, with Bulgaria ranked 59th in 2024.[6] Nonetheless, media conditions remain troubling: 81.1% of journalists surveyed by the Association of European Journalists–Bulgaria reported widespread interference in their work.[7]

In April 2024, caretaker Interior Minister Kalin Stoyanov initiated a SLAPP lawsuit against two investigative journalists and released a manipulated surveillance video to discredit one of them.[8] In August, amid political infighting, the Movement for Rights and Freedoms (MRF) used state institutions to shut down a satirical website targeting MRF leader Delyan Peevski. After the October elections, Stoyanov became an MP under Peevski’s MRF faction, highlighting the Ministry of the Interior’s susceptibility to censorship and smear campaigns.[9]

Legislative reforms to prevent SLAPPs have stalled since the government dissolved in March 2024. In June 2024, the ECtHR ruled that Bulgaria violated journalist Rosen Bosev’s freedom of expression in a SLAPP case, underscoring the urgent need for reform.

The Right to Privacy

In December 2024, the DPA found the Revival Party guilty of violating the privacy rights of civil society organization (CSO) representatives by publishing a list of over 800 names and personal ID numbers. However, despite clear legal breaches, the DPA imposed no penalties, and the decision came nearly two years after the incident.

Authorities continued to target the refugee aid group Mission Wings in 2024. After the organization revealed that three refugee children died near the Turkish border due to lack of state intervention, the Interior Ministry accused Mission Wings of interfering with official duties and launched an investigation against them for allegedly making false emergency calls.

Rise in Anti-LGBTQ+ Sentiment

In August 2024 the Parliament passed amendments to the Pre-School and School Education Act banning “any propaganda, promotion, or any other direct or indirect inducement to ideas and views related to non-traditional sexual orientation and/or designating a gender identity other than the biological one“[10] The homophobic and transphobic “Don’t Say Gay” amendment bares similarities[11] to restrictions adopted in Georgia in 2024,[12] in Hungary in 2021[13] and Russia in 2022.[14]

Shortly after the amendment, several Civil Society Organizations (CSOs) were summoned to a joint hearing of the youth and sports parliamentary commission and the commission on demographics, children and family[15] for a “Discussion of issues related to the distribution of materials and organization of events that promote LGBTI–activities that pose a threat to minors over the age of 14.” Following the hearing some of the CSOs were subject to an investigation by the National Data Protection Authority (the DPA is one of the many supervisory bodies functioning with an expired mandate) about an online inquiry on the safe space of LGBTQI+ pupils in schools.[16] In late September, one of the targeted CSOs announced that the DPA has not found any violations.[17]

In response to anti-LGBTQI+ legislation, teachers launched an online petition. In late August, a far-right pro-Russian group affiliated with the Revival Party published a “blacklist” of teachers from Varna who signed the petition, urging parents to confront their school principals.[18] Although the Prosecution and the Data Protection Authority (DPA) initially announced investigations, no sanctions followed.

Civil Society Organizations

Freedom of Association

The 2000 Non-Profit Legal Persons Act in Bulgaria establishes a relatively straightforward procedure for registering NGOs and limits the administration’s discretion in rejecting applications based on the organization’s goals. In recent years, this legal framework has contributed to a generally positive trend in the registration of CSOs. Data from the State Registration Agency shows a decrease in registration refusals from 1,055 in 2012 to 608 in 2022 and 632 in 2023. There has also been a modest rise in active CSOs, reflected in the increase in annual financial and narrative report submissions: 15,624 in 2023 compared to 13,847 in 2022.

Despite these improvements, serious concerns remain regarding Bulgaria’s longstanding violation of the right to freedom of association, particularly with respect to organizations advocating for the rights of the Macedonian minority. The Committee of Ministers of the Council of Europe issued another decision in 2024 urging Bulgaria to resolve the issue of routine registration refusals for such organizations. The problem stems from the UMO Ilinden group of cases before the ECtHR, which date back to the 1990s. Over 17 years since the first ECtHR ruling, Bulgaria has failed to comply, and as of February 2024, 24 new applications related to similar violations were pending.

The far-right Revival Party has launched multiple legislative attempts to curtail civil society through a proposed Foreign Agents Registration Act (FARA).[19] First introduced in January 2024 and resubmitted twice later that year, the bill aims to impose sweeping restrictions on CSOs receiving foreign funding. While promoted as a transparency measure, the bill includes prohibitions on engaging in educational and political activities and imposes a five-year designation period for those labelled as “agents.” Parliamentary debates surrounding the bill have served as a platform for vilifying civil society and promoting misinformation.

Efforts to regulated lobbying have also sparked concern. A draft published in December 2023 by the Ministry of Justice was initially well received, as it excluded advocacy and provided safeguards for CSOs.[20] However, a revised version issued in March 2024 eliminated these protections without public explanation or consultation with the CSO representatives who had contributed to the original draft. This revised concept was misleadingly referenced in the 2024 Rule of Law Report as having been adopted with proper consultation, which was not the case.

Further, a new working group within the Ministry of Justice began drafting a lobbying law that fails to distinguish between advocacy and lobbying, includes CSOs in its scope, and explicitly exempts entities like law firms and business associations. It also proposes regulating grassroots lobbying and banning any lobbying directed at the judiciary or the Constitutional Court. These provisions reflect a growing trend toward legal repression of civil society, raising alarms that the lobbying law may become another tool, like the proposed FARA, for shrinking civic space and enabling censorship under the pretense of transparency.

Funding

In 2024, Bulgaria failed to make any substantive progress in addressing CSO access to funding. Core challenges–such as the lack of diversified funding opportunities, the absence of a functional public funding scheme, and the underutilization of EU resources–remained unaddressed. Bulgaria also continued to perform poorly in the World Giving Index, ranking 133rd out of 142 countries in both 2023 and 2024, a stark drop from its 54th place in 2022.[21] This decline reflects a limited culture of charitable giving and volunteering. Although CSOs have long advocated for a law to regulate and support volunteering, and despite nine different draft bills over the past 12 years, no such legislation has been adopted. A roundtable in December 2024 brought together political parties to pledge support for a volunteering law. However, no concrete action followed.

A major obstacle to accessing EU funding is the misapplication of the de minimis rule under EU Regulation 651/2014 by national authorities, who incorrectly treat CSOs as commercial enterprises subject to state aid restrictions. This problem was acknowledged in the 2024 Rule of Law Report by the European Commission. The 2022 establishment of the Council for Civil Society Development which was tasking with overseeing public funding for CSOs was a promising development. However, this council held no official meetings in 2024, and the funding mechanism outlined in the Non-Profit Legal Persons Act was never activated. Additionally, the process for electing new CCSD members did not begin, despite the requirement that it be launched no later than three months before the current mandate expires in February 2025.

Efforts to reform the legislative framework for social entrepreneurship, which could expand access to subsidies for CSOs, also stalled. Although a reform bill was passed at first reading in February 2024, it was never brought to a final vote, and the heavy reliance of CSOs on project-based funding schemes became a critical vulnerability during this period. Crucially, this model left organizations ill-equipped to react quickly to fast-moving legislative developments, such as the surprise adoption of anti-LGBT legislation in August.

Dialogue and Cooperation Between NGOs and Government

Another example of stalled civic engagement occurred within the newly created National Council for Prevention and Protection against Domestic Violence (NCPPDV) under the Council of Ministers. Although five CSOs applied for four designated seats, only one organization that directly serves domestic violence victims applied, largely due to a provision disqualifying Council members from receiving state funds under domestic violence programs. Moreover, the Council of Ministers’ administration initially attempted to exclude CSO representatives from funding discussions, citing potential future conflicts of interest. This exclusion was eventually reversed following sustained advocacy by civil society. However, the process for electing new CSO representatives was deeply flawed: instead of beginning by November 2024 as required, it was abruptly opened on January 2, 2025, and closed just five days later, resulting in only two applications.

Parliamentary mechanisms for CSO participation also remained ineffective. Although the Parliamentary Commission on Direct Citizen Participation and Interaction with Civil Society initiated steps in May 2023 to create a Civil Council, the process was delayed multiple times due to a lack of CSO applicants in several fields. The Civil Council was eventually formed in September 2023 but never convened with the Parliamentary Commission, in violation of the Rules of Procedure of the National Assembly. With the dissolution of the government in March 2024, the Council’s activities came to a complete halt. No efforts were made to re-establish this participatory body following the parliamentary elections in June or October 2024, indicating a continued erosion of institutional support for civil society engagement.

Resilience and Progress

Despite ongoing challenges, CSOs in Bulgaria have made substantial progress. Following the adoption of the anti-LGBTQI+ legislation in 2024 and proposal of a FARA in September, CSOs took steps to self-organize to push back against restrictive and violating human rights legislative acts. Consequently, a legal opinion against FARA gathered more than 2500 signatures within days.[22] Furthermore, in October of 2024, a conference on cross-sector collaboration to fight restrictive legislative acts was attended by more than 300 representatives from CSOs and businesses.[23]

Further, according to a 2024 survey, there is slow but steady growth in civic activism. The public also feels more represented by CSOs, although the rates remain low: in 2018, only 4.4 % of the respondents said that they felt represented by a CSO, in contrast to the 15 % in 2024. Similarly, in 2024, 61.1 % of the respondents shared that they’ve never had contact with a CSO, in contrast to 90.8 % in 2018. 

Recommendations

  1. Repeal the amendments to the Pre-school and School Education Act that ban “any propaganda, promotion, or any other direct or indirect inducement to ideas and views related to non-traditional sexual orientation and/or designating a gender identity other than the biological one.”
  2. The Foreign Agents Registration Bill (FARA) and similar proposals that contradict Bulgaria’s human rights obligations should be scrutinized during parliamentary debates and explicitly rejected, rather than left pending.
  3. The state should demonstrate a clear commitment to civic engagement by adopting a new Civil Society Strategy (the last expired in 2015).
  4. The lobbying law must be developed through an open and transparent process and must include exceptions for advocacy activities and CSOs working in the public interest.
  5. Procedural safeguards against Strategic Lawsuits Against Public Participation (SLAPPs) must be introduced and implemented to protect civic voices.
  6. Police officers and public administration officials should receive additional training to ensure the correct application of the right to freedom of assembly, with a particular focus on peaceful protest.
  7. Authorities must ensure the regular and effective functioning of the Council for the Development of Civil Society (CDCS).
  8. Parliament should take further steps to promote and strengthen collaboration with the Civil Council to the Commission on Direct Citizen Participation and Interaction with Civil Society.
  9. Civil society organizations must be guaranteed meaningful participation, free from undue obstacles, within the National Council for Prevention and Protection against Domestic Violence under the Council of Ministers.
  10. The implementation of the de minimis rule must be revised to ensure CSOs are not unfairly treated as commercial entities in the allocation of EU funds.
  11. A law on volunteering should be adopted to support and regulate volunteer engagement in Bulgaria.

[1] https://results.cik.bg/europe2024/aktivnost/index.html

[2] https://balkaninsight.com/2025/03/13/bulgarias-constitutional-court-disqualifies-election-of-17-mps/; https://sofiaglobe.com/2025/02/27/bulgarias-constitutional-court-orders-adjustment-of-october-2024-election-results/

[3] See: General comment No. 37 (2020) on the right of peaceful assembly (article 21)

[4] For information about disruption of cultural events of the LGBTQI+ community in the past see the last years report – https://civic-forum.eu/wp-content/uploads/2024/05/CIVIC-SPACE-REPORT-2024-BULGARIA.pdf

[5] https://balkaninsight.com/2024/11/08/bulgarian-nationalists-disrupt-premiere-of-john-malkovich-directed-play/

[6] https://rsf.org/en/index?year=2024

[7] https://aej-bulgaria.org/wp-content/uploads/2024/11/Jurnalistika-pod-stres.pdf

[8] https://aej-bulgaria.org/slapp-kstoyanov/; https://aej-bulgaria.org/23042024/

[9] https://aej-bulgaria.org/%d1%81%d0%b2%d0%b0%d0%bb%d1%8f%d0%bd%d0%b5%d1%82%d0%be-%d0%bd%d0%b0-%d1%81%d0%b0%d1%82%d0%b8%d1%80%d0%b8%d1%87%d0%b5%d0%bd-%d1%81%d0%b0%d0%b9%d1%82-%d0%be%d1%82-%d0%bc%d0%b2%d1%80-%d0%b5-%d0%be%d0%bf/

[9] https://hudoc.echr.coe.int/eng?i=001-238048

[10] See also: https://www.amnesty.eu/news/bulgaria-ban-of-lgbti-propaganda-in-schools-is-attack-on-the-entire-lgbti-community/

[11] See also: https://www.context.news/money-power-people/new-russian-style-anti-lgbtq-law-in-bulgaria-censors-teachers

[12] https://www.politico.eu/article/georgia-signs-sweeping-anti-lgbtq-bill-into-law/

[13] https://www.amnesty.org/en/latest/news/2024/02/hungarypropaganda-law-has-created-cloud-of-fear-pushing-lgbti-community-into-the-shadows/

[14] https://www.reuters.com/world/russias-parliament-passes-law-banning-lgbt-propaganda-among-adults-2022-11-24/

[15] https://www.parliament.bg/bg/parliamentarycommittees/3395/sitting/12706

[16] See also: https://www.svobodnaevropa.bg/a/lgbt-uchenitsi-prouchvane/33072544.html

[17] https://www.facebook.com/story.php?story_fbid=837878818555314&id=100069996106701&_rdr

[18] https://www.svobodnaevropa.bg/a/prokuratura-varna-vazrazhdane-proverka-uchiteli/33088809.html

[19] https://www.parliament.bg/bg/bills/ID/165772

[20] The draft concept available here: https://www.strategy.bg/PublicConsultations/View.aspx?@lang=bg-BG&Id=7969

[21] https://www.cafonline.org/docs/default-source/inside-giving/wgi/wgi_2024_report.pdf

[22] https://docs.google.com/document/d/1QXx-H7luYmL1b2pshTg4PCAX43YQWavq-4q-jw8IW7w/edit?tab=t.0

[23] See the website of the conference here: https://civicspacebg.com/en/