Reading time: 8 minutes

Why is it important for civic organisations to participate in the public consultation about the Law on Transparency and Integrity in governance? 

Until August 25th 2025 the Ministry of Justice is conducting a public consultation regarding the future Law on Transparency and Integrity in governance, that aims to regulate the representation of interests (commonly referred to as lobbying) – or in other words, the interaction between public authorities and those that aim to influence political and legal decisions.

The Transparency and Dignity draft law is in fulfilment of Bulgaria’s commitment to regulate “lobbying activities” under the Recovery and Resilience Plan. In addition, the Organisation for Economic Co-operation and Development (OECD), which Bulgaria is currently seeking to join as a key foreign policy goal, is also urging the adoption of such regulation.This means that adoption of the law is highly plausible.

The law for transparency and integrity in governance has the potential to ensure better transparency in policy making and normative acts. This would also contribute to the advocacy work of civil society organisations.

In the meanwhile, such regulation, if it does not meet good standards, can turn into a repressive instrument, similar to the Law on the Registration of Foreign Agents. This risk is absolutely real and in 2024 it looked like this would happen:

In 2025, following advocacy efforts by us and other organisations, and with the support of the new Minister of Justice, we achieved significant progress in steering the process back toward drafting a law that genuinely ensures transparency, rather than yet another variant of a “Foreign Agents Act” aimed at silencing civic participation.

That is why now it is incredibly important for us as civic organisations,  to take part in the public consultation and to share our positions and opinions about the appropriate boundaries for protection of civic participation if such regulation is accepted.

Here are some of the main risks we need to look out for:

Lobbying – a term that has acquired a rather negative connotation

Lobbying is a legitimate and common activity in every democracy. The problem with the term is that it has acquired a negative connotation, often being associated with corruption – an illegal practice of influence – or linked to deliberately concealed influence by individuals with significant economic interests.

Therefore, the creation of a “lobbyists’ register” by law is dangerous because an organization’s presence in such a register makes it an easy target for smear campaigns. Essentially, in Bulgaria today, it is almost equivalent whether you accuse someone of being a “foreign agent” or call them a “lobbyist.”

As of now, the risk appears to have been overcome. Although the questionnaire for the current consultation conducted by the Ministry of Justice uses the term lobbying, it is clear that the new regulatory concept is to use the term “representation of interests” and for the register to be a register of representatives of interests.

Regulation of “indirect lobbying”

The December 2023 proposal by the Ministry of Justice contained an excessively broad definition of lobbying:

any communication with citizens, including publications and interviews through mass media or through direct communication which are aimed at persuading these members of the public to communicate directly with a person holding public office, in an attempt to influence that person to support a certain position

Such a formulation of the definition of “lobbying”, combined with the envisaged administrative obligations such as registration, naturally poses a risk of restricting the right to freedom of expression. The idea has already been rejected and should not reappear.

Who is a lobbyist and what can we insist on


Similar to most other laws about regulating representation of interests (lobbying) that are already adopted in Europe, in Bulgaria there are entities explicitly excluded from the scope of law, even though they carry out representation as legally defined . Common examples, currently accepted by the Ministry of Justice, include:

  • registered trade unions when acting to protect their member’s interests in the fields of labour and social security;
  • registered employers’ organisations acting to protect the economic interests of their members;
  • representatives of registered religious communities and institutions engaged in activities related to the exercise of the right to freedom and religion.

A substantial risk for civic organisations arises if there are too many exceptions, yet legal entities with a non-profit purpose (associations, foundations, and community centers) are not among them. This could result in regulation primarily targeting these organisations labeling them generally as “lobbyists”, without recognising that they are instruments for exercising the right of association, through which many civic rights are realized, and that those designated to operate in the public interest actually protect the public good.

If an exception is provided for the employers’ organisations, trade unions, and religious communities as organisations that by their nature are expected to represent interests on certain topics, similarly and justifiably, such an exception can be requested for civil society organisations as well. Naturally, excluding organisations is not an end in itself and should be combined with appropriate measures to ensure transparency in advocacy activities. One such measure could be an explicit obligation for non-profit legal entities operating in the public interest to indicate in their annual activity reports whether they have engaged with the addressees of lobbying activities and what the outcome of those interactions was. These reports are published in the Register of Non-Profit Legal Entities, which creates sufficient transparency. This is already a good practice adopted by many organizations, and regulating it as an explicit obligation would not be an excessive burden but rather an effective approach to achieving the main goal of the future law – transparency.

You can submit a completed questionnaire until 25.08.2025.

 You can find the Council of Ministers’ questionnairehere.

Here you can find BCNL’s answers to the questions raised in the framework of a public consultation, and here we have provided brief orientation information for your convenience.

Due to the lack of a clearly indicated email address for submitting your input, we advise you to use:

priemna@justice.government.bg while copying in s.minkov@government.bg