Author
General (scope, time limits)
The LAR sets a 6-month time limit for deciding on an asylum application admitted to the regular procedure.[1] The LAR requires that, within 4 months of the beginning of the procedure,[2] caseworkers draft a proposal for a decision on the asylum application concerned. The asylum application should firstly be assessed on its eligibility for refugee status. If the answer is negative, the need for subsidiary protection on the account of a general risk to the applicant’s human rights should also be considered and decided upon. The interviewer’s position is reported to the decision-maker, who has another 2 months for consideration and decision. If evidence is insufficient for taking a decision within 6 months, the law allows for the deadline to be extended for another 9 months, but it requires the whole procedure to be limited to a maximum duration of 21 months. Determination deadlines are not mandatory, but only indicative. Therefore, even if these deadlines are exceeded, this does not affect the validity of the decision.
In 2025, according to the available independent reports[3] the general 6 months deadline for issuing an asylum decision was observed in 99% of the cases.[4] According to the SAR, the average duration of asylum procedures on the merit ranges from 3 to 6 months[5].
In 2025, the number of new arrivals decreased to a total of 3,895 (-68%) in comparison with 12,250 in 2024 (-45%); 22,518 asylum seekers in 2023 (+10%); 20,407 asylum seekers in 2022 (+85%); 10,999 asylum seekers (+212% increase) in 2021 and 3,525 asylum seekers in 2020.
In 2025, SAR issued 7,090 decisions in total. Out of these, 62 were decisions granting refugee status, 897 decisions granting humanitarian status (i.e. subsidiary protection under the QD), 3,703 rejections and 2,428 decisions discontinuing the procedure, mainly due to absconding.[6] Despite this, at the end of 2025 1,632 asylum cases were still pending.[7] SAR staff competent to issue eligibility decisions counted 29 case-workers,[8] of whom 26 case-workers with competence to issue decisions on the substance of the asylum application and 3 case-workers with competence to issue decisions in Dublin procedure.
45% (2,428 persons) of the 5,527 asylum seekers with pending applications in 2025[9] abandoned their procedures in Bulgaria. This represented an increase (+16%) compared to the 30% (7,299) in 2024. The usual reasons motivating asylum seekers to abandon the asylum procedure in Bulgaria and abscond were the low recognition rate for certain nationalities, poor reception conditions, lack of integration opportunities, but most importantly their plans to reach other EU countries as a final destination from the onset of their migratory journey. While in 2022 the Afghan applicants for the first time in a decade enjoyed a significantly higher recognition rate than in previous years, with 49% overall recognition (14% refugee recognition / 35% subsidiary protection rate), in the following years recognition rates lowered once again, reaching 4% (0.3% refugee recognition / 3.7% subsidiary protection) in 2025, with the rejection rate standing at 96%. This likely motivated 78%[10] of them, much more than (32%) in 2024 and (68%) in 2023, though still less than 2022 (95%),[11] to abscond before their first instance decision, issued on the merits in 22%[12] of the caseload.
Out of the 7, 090 decisions taken, 34% of asylum procedures were terminated (discontinued) in absentia:
| First instance SAR decisions on asylum applications: 2025 | ||
| In-merit decisions | ||
| Refugee status | 62 | 4,662 |
| Subsidiary protection | 897 | |
| Unfounded | 2,137 | |
| Manifestly unfounded | 1,566 | |
| Abandoned applications | ||
| Terminated | 2,428 | |
| Total | 7,090 | |
Source: SAR.
Prioritised examination and fast-track processing
Prioritised examination is applied neither in law nor in practice in Bulgaria, although a specific procedure is applied with respect to Subsequent Applications.
Personal interview
After registration is completed, a date for an interview is set. The law requires that asylum seekers whose applications were admitted to the regular procedure be interviewed at least once regarding the facts and circumstances of their applications.[13] The law requires that the applicant be notified in due time of the date of any subsequent interviews. If the interview is omitted, decisions cannot be considered in accordance with the law, unless it concerns a medically established case of insanity or other mental disorder.[14] In practice, all asylum seekers are interviewed at least once to determine their eligibility for refugee or subsidiary protection (“humanitarian status”). Further interviews are usually only conducted if there are contradictions in the statements or if some facts need to be clarified.[15] In 2020, amendments to the LAR extended the opportunity to gather expert opinions, including on age, gender, medical, religious, and cultural issues as well as such specific to children.[16] The law also introduced instructions on COI sources and information gathering.[17]
The SAR uses the standard set of questions used during eligibility interviews and relied entirely on caseworkers’ decision regarding whether to ask open questions. However, such type of questions are rarely, if ever, asked during the interview. The standardized interview form is applied to all, including unaccompanied children, without any adaptation or account to children’s level of maturity. This has resulted in a poor quality of examination of asylum claims (i.e. little investigation of the individuals’ statements and refugee stories). At the beginning of 2023, the new SAR management introduced an interview set of questions adapted for asylum seeking children, including unaccompanied ones.[18] In 2025, these adapted questions were used in practice only in 37% cases[19] of interviewed children, while the interviews with the rest 63% of them were conducted using questions prepared for adult applicants. The monitoring demonstrated[20] that in the majority of the cases the use of interviewing template was counterproductive, as caseworkers not only limited the investigation of the case to the pre-set list of questions, but also did not in general provided applicants an opportunity to present their accounts freely and without interruptions. In its reply[21] to the findings of this report, the SAR indicated that in 2025 a new interview questionnaire was developed by SAR in cooperation with EUAA, which included open-type questions that encourage the applicants to tell their story in a detailed narrative. All caseworkers of SAR have undergone a training on the use of the new questionnaire before its official implementation in September 2025. In addition, as a part of the activities planned within the Operational plan of EUAA with SAR, the SAR indicated that an EUAA senior expert/team leader provided peer-to-peer support on the new asylum interview template and shadowed a number of interviews with each and every caseworker in order to guide them on how to implement it properly and efficiently.
There are no guidelines or a code of conduct for asylum caseworkers to elaborate on the methodology for conducting interviews specifically. Similarly, there are currently no age or gender-sensitive mechanisms in place in relation to the conduct of interviews, except for the asylum seekers’ right to ask for an interpreter of the same gender.[22] In 2025,[23] considering all the cases in which the case-worker and the asylum seeker were of different gender, in 17% (13% in 2024) the asylum seeker was informed about the possibility to request that the interview be conducted by an interviewer of the same gender, and in 13% (45% in 2024) about the possibility to request an interpreter of the same gender. These percentages are far from the required standard of all asylum seekers being informed that they can request an interviewer and interpreted from the same gender.
Interpretation
The presence of an interpreter ensuring interpretation into a language that the asylum seeker understands is mandatory according to the LAR. The law provides for a gender-sensitive approach as interviews can be conducted by an interviewer and interpreter of the same sex as the asylum seeker interviewed upon request.[24] In practice, all asylum seekers are asked explicitly whether they would like to have an interviewer or interpreter of the same sex in the beginning of each interview, although cases when this obligation is omitted by the caseworker still occur in many cases (see above 1.3. Personal interview).
In 2025,[25] considering all the cases in which the interpreter and the asylum seeker were of different gender, in 13% (45% in 2024) the asylum seeker was informed about the possibility to request an interpreter of the same gender, where in the remaining 87% (55% in 2024) of the cases this information was not provided. As a result, in 63% of the cases where the SAR failed to provide this required information, the female applicants were interviewed with the assistance of male interpreters.[26]
For many years since 2014, the low fees paid for interpretation by the asylum agency SAR remained one of main reasons for the lack of proper interpretation during the eligibility interviews at first instance. In 2023, the SAR attempted to solve this problem by using shared interpretation services with the Ministry of Foreign Affairs.[27] However, this approach proved inadequate due to significant delays in interpreters’ appointment in asylum procedures due to their workload and other MFA related commitments.[28] Following the beginning of EC-Bulgaria pilot project on accelerated procedure in mid-2023,[29] the Commission deployed additional interpreters to be used by SAR through the duration of the project. This support for interpretation was extended only until the end of 2024 under the EUAA and Bulgaria operational plan, signed in July 2023,[30] while the plan in itself was later amended and extended in December 2024 until the end of 2026.[31] Thus, in 2025, the SAR continued to be supported by the EUAA in securing the interpretation in asylum procedures at the first instance. However, this support exhibited certain problems mainly related to the EUAA selection of interpreters being applied without any specific requirements other than proficiency in the language in question. According to the Bulgarian Helsinki Committee’s evaluation, most of them were not properly instructed on national asylum procedures or appropriate and impartial behaviour. In several anecdotal cases in 2023[32] and 2024[33] asylum seekers hosted in the Pastrogor Transit Centre and Sofia reception centre complained that their assigned interpreters had been either providing misleading information or making inappropriate or abusive comments after the end of the interview. Following the submission of formal complaints to SAR, and subsequent communication to EUAA the contracts of the interpreters in question were terminated.[34] Similar reports were not submitted in the course of 2025. It should be noted that inadequate interpretation or delivery of wrong or misleading information is contrary to the main function of interpretation services in status determination procedure, where in worst cases it could result in failure to appeal on time negative first instance decisions.
Interpretation is provided mainly from English, French, Russian, Farsi, Dari, Pashto, Urdu and Arabic languages. Interpreters from other key languages such as Kurdish (Sorani or Pehlewani), Tamil, Ethiopian and Swahili are scarce and largely unavailable. In such cases, as well as in cases when an interpreter from the spoken language is available in another reception centre, the asylum administration organises videoconference interpretation. Communication interruptions and other technical problems are the most common obstacles during interpretation via videoconference. It often creates an environment which does not allow the applicant to present properly his accounts in a detailed and systematic way, thus preventing the case worker from clarifying the relevant facts and circumstances for the decision-making process.
100% of the monitored court hearings were assisted by interpreters in 2025.[35] In appeal proceedings before the national courts, in 90% of the monitored cases where the applicant attended the hearing the interpreter was present and assisting the appellant, and in 35% of these cases (55% in 2024) the court conducted documental verification of interpreters’ qualifications. [36]
The lack of adequate budget for interpretation also affects the translation of written evidence, in cases were written evidence is submitted by applicants. In view of making savings and accelerating the procedure, caseworkers are told to advise the applicants to pay for translation fees of their documents themselves so as be taken into consideration during the status determination or to accelerate the decision-making process.
Recording and report
The law provides for mandatory audio or audio-video tape-recording of all eligibility interviews as the best safeguard against corruption and for unbiased claim assessment.[37] This positive practice, instated from 2021, continued in the following years, as 100% of the monitored interviews were tape-recorded. This being said, the benefits of such a procedure are hindered by the fact that, in practice, caseworkers take a decision based on their own notes rather than the actual audio recording.
Videoconference interpretation during registration and eligibility interviews is also used, usually in Pastrogor, Harmanli and Banya (the reception centres outside the capital Sofia), where interpreters are harder to find and employ, in which case interviews are conducted with the assistance of the interpreters who work in Ovcha Kupel, Vrazhdebna and Voenna Rampa, the reception centres and shelters in Sofia. This type of interpretation creates additional difficulties for the applicants, as video communication significantly delays the process of statements’ collecting.
All interviews are conducted by staff members of the SAR, whose competences include interviewing, case assessment and preparing a draft decision on the claim. In practice, almost all interviews continue to be recorded also in writing by interviewers by summarising and typing questions / answers in the official protocol. A report of the interview is prepared and it shall be read to, and then signed by the applicant, the interpreter and by the caseworker.
Compliance with EU standards[38] in this respect is of paramount importance considering that, under such circumstances, the information recorded in the report of the interview could be prone to potential manipulation, and the applicant would require a phonetic expertise requested in eventual appeal proceedings to validly contest the content of the report in case of inaccuracies. Court expertise expenses in asylum cases have instead to be met by the appellants.[39]
Notwithstanding the small number of asylum seekers who presented any evidence to support their claims, in a small percentage of cases, caseworkers continued to omit at some instances their obligation to collect these pieces of evidence with a separate protocol, a copy of which should be served to the applicant. In 47% of monitored cases (98% in 2024),[40] asylum seekers were informed about their obligation to submit all the available evidence to support their statements. In the remaining 53% of monitored cases this was not done. In 32% of monitored cases, asylum seekers submitted evidence in support of their asylum claim; however, in none of them the evidence was properly protocoled. Hence, the important safeguard that the submitted evidence would be taken into consideration in the decision-making was not observed in 100% of the monitored cases, where applicants submitted evidence. This marked a regress when compared to 2023, when this omission was made in 38% of the cases (45% in 2024; 38% in 2023; 51% in 2022; 16% in 2021 and 12% in 2020).
Appeal
A negative decision taken in the regular procedure on the merits of the asylum application can be appealed within 14 days from its notification. In general, this time limit has proven sufficient for rejected asylum seekers to get legal advice, prepare and submit the appeal within the deadline. The SAR has to provide information – in the form of a list – to rejected asylum seekers as to where and how they can receive legal aid when serving a negative decision, an obligation that is respected in practice (see Regular Procedure: Legal Assistance).
Two levels of appeal are accessible in the regular procedure,[41] in contrast to appeal procedures for contesting decisions taken in Dublin: Appeal, Accelerated Procedure: Appeal and inadmissibility of Subsequent Applications procedures, where first instance decisions are reviewed in only one court appeal instance.[42]
Under Article 12 of Administrative Procedure Code asylum decisions, as other formal administrative decisions, are to be issued in Bulgarian language only. This obligates the administration to provide oral interpretation when the applicant does not speak Bulgarian. Therefore, the SAR does not translate its asylum decisions, but instead sends a summon to asylum seekers, when their decisions are ready, to come to the SAR reception centre, where their procedure was conducted in order to be served the decision with the assistance of an interpreter. The interpreter reads the decision aloud to the asylum seekers and signs the documents to verify it. In practice, the SAR organizes the serving of their first instance decisions on the date, when it is expected that the respective asylum seeker will appear in the SAR centre for some other administrative service, e.g. renewal of the temporary asylum card, which has 3 months of validity. In cases when the decision is not served within 14 days from the date of its formal issue by the SAR, the asylum agency is obligated by the law[43] to send a notification by post to the asylum seeker that the decision is ready. These notifications should be bilingual and should be sent only to asylum seekers who are not accommodated at SAR reception centres but live outside at the so called ‘external domiciles’ or ‘external address’. In such cases, when asylum seekers have been posted a notification to go to SAR to be served a decision but failed to appear in 7 days after receiving the notification by post, their decision can be considered served and becomes final[44] without asylum seekers having a copy of the decision in written or knowing its content. Decisions, if negative, mandatory provide information about the right to appeal before the court, which is the respective court, as well as the appeal deadline stated in calendar days. During their initial registration asylum seekers are also provided a leaflet with comprehensive translated information in respective languages (English, French, Arabic, Farsi, Dari, Pashto, Kurdish, Urdu, Russian) about their rights, the procedures that follow and list of NGO who provide different type of support, however this list is outdated as many of the NGOs do not operate anymore due to lack of project-based funding. Similar type of information leaflet is provided when the decision is positive.
Appeal procedures are only judicial; the law does not envisage an administrative review of asylum determination decisions. Since 2014, competence for appeals in the regular procedure is distributed among all Regional Administrative Courts, designated as per the residence of the asylum seeker who has submitted the appeal.[45] Up to the present moment, however, this model did not succeed in redistributing the caseload among the national courts, as the majority of asylum seekers reside predominantly in reception centres or in private accommodation in Sofia and Harmanli. Therefore, the Sofia and Haskovo Regional Administrative Courts continue to be the ones with the highest caseload, dealing with the appeals against negative first-instance decisions.
Both appeals before the first and second-instance appeal courts have automatic suspensive effect.
The first appeal instance conducts a full review of the case, both on the facts and the points of law. Asylum seekers are summoned and questioned in a public hearing as to the reasons they applied for asylum. Decisions are published,[46] but also served personally to the appellant.
If the first instance appeal decision is negative, asylum seekers can bring their case to the second (final) appeal court, the Supreme Administrative Court (SAC); in this case, the appeal can only regard points of law and does not entail an in-merit examination of the case. At the end of 2019, the Chairperson of the Supreme administrative court took the controversial decision to move the asylum cases from the 3rd to 4th department. While the 3rd department of the SAC had been dealing with asylum cases for more than twenty-two years since the establishment of the Supreme Administrative Court in 1997, the 4th department had never been assigned such cases prior to the decision. The arrangement led to a deterioration of the quality of the decisions issued on asylum cases at this highest court instance, whose jurisprudence sets the standards for all lower national administrative courts. Starting from the beginning of 2024 the SAC’s 3rd department resumed to deal with the asylum cases. However, in 2025 an increased number of appeals reached this highest court instance due to increased rejection rates, applied since mid-2024 to Syrian applicants[47]. Therefore, SAC first halted almost entirely the asylum hearings for nearly two months in February and March 2025, and then re-distributed asylum cases among all of its departments, including those of them which have never dealt such case. As a result, in 2025, the SAC issued negative decisions in 92% of the examined asylum cases,[48] the overwhelming majority of the asylum cases brought before this last court instance.
First instance appeal courts must issue their decisions within one month. The next and last court instance SAC is not bound by such deadline. However, even for the first instance court this deadline is indicative and therefore in the past it was not respected, with an average duration of an appeal procedure before the court at both judicial instances up to 12 months. In 2025, regional courts issued their decisions in a period of one month on average, while the Supreme administrative courts did it in a period between 1 to 3 months on average. If the court reverts the first instance decision back, the SAR has 3 months to issue a new decision,[49] complying with the court’s instructions on the application of the law. As in previous years, SAR did not fully observe these deadlines, but in 2025 it did not issue any repeated refusals going against the court’s instructions.[50] In the past, repeated appeal procedures against the second SAR negative decisions issued in breach of the court instructions, caused some asylum procedures to extend for over 2-3 years. Therefore, the fact that, in 2025, as in 2024, 2023 and 2022, SAR observed court instructions, significantly improved the effectiveness of the judicial control in particular, and in general the length of the asylum procedure.
Legal assistance
The general legal aid system was introduced in Bulgaria in 2005, extending it to court representation in all types of cases beyond its mandatory provision in criminal, child protection and tort disputes. In 2017 the scope of the legal aid was extended[51] to include oral consultations at the national help line[52] or in regional legal aid centres. The condition for the legal aid to be provided is for the person in need of support to lack means and resources to engage a lawyer privately against remuneration.
Since 2013, the Law on Legal Aid provides mandatory legal aid for asylum seekers at all stages of the status determination procedure, funded through the state budget.[53] In practice, due to insufficient funding, free legal aid is only provided to vulnerable persons[54] upon their explicit request. Amendments to the law in 2020 also entrusted to registered legal aid lawyers[55] the representation of unaccompanied asylum seeking and refugee children both during the procedure, but also after their recognition. Prior to 2022, the law did not explicitly provide that legal aid should be available for beneficiaries of international or temporary protection. The National Legal Aid Bureau in October 2022 put forward a draft proposal to amend the law and include these categories in the scope of the legal aid.[56] The amendment was adopted in December 2022 and entered into force on 26 December 2022.[57] Together with these amendments, the law included in the scope of the legal aid the legal counselling and the preparation of documents for initiating or conducting administrative proceedings, or to appeal the decisions, issued in such proceedings.[58]
Legal assistance at first instance
Asylum seekers have the right to ask for the appointment of a legal aid lawyer from the moment of the registration of their asylum application.
After the end of its 2017-mid-2021 AMIF funded project on provision of legal aid to asylum seekers during the administrative phase of the procedure,[59] the National Legal Aid Bureau agreed to continue representing vulnerable applicants under its general rules, which would require the asylum seekers to fill in and submit complicated legal aid applications. The NGO Bulgarian Helsinki Committee, funded by UNHCR, assisted the NLAB with the adaptation and translation of the legal aid forms in English, French, Russian, Arabic, Farsi, Dari, Pashto, Urdu, Kurdish and Turkish languages to facilitate the access to legal aid to vulnerable applicants. A problem persists, however, for those who are illiterate and where the assistance of case workers is the only way to get access to legal aid. Yet, some of them are reluctant to grant access to legal aid as it would mean that their role in and quality of the procedure would be assessed. Therefore, although 115 asylum seekers were identified as vulnerable or with specific needs by SAR in 2025, none of them, or any other applicants, was assisted to get free legal aid at first instance.[60] Over the last two years, this continued to be the most significant deterioration of national practices in this respect, vis-a-vis 50 vulnerable adult applicants assisted with state provided legal aid at first instance in 2021, and 818 vulnerable adult applicants in 2020.[61]
Amendments to the law introduced at the end of 2020 brought a major change in the legal representation of unaccompanied asylum seeking and refugee children.[62] The obligation to represent these children not only in the procedure, but also after the recognition and before all agencies and institutions with regard to their rights and entitlements, was shifted from the municipalities to the National Legal Aid Bureau.[63] The law also introduced conditions for the qualification of the appointed legal aid lawyers and requirements for a representation in the child’s best interest. Starting from July 2021, 16 lawyers from the Sofia Bar, 8 lawyers from Haskovo Bar and 3 lawyers from Sliven Bar began implementing the representation of unaccompanied asylum seeking and refugee children. In February 2024, NLAB recruited 20 additional lawyers (18 in Sofia and 2 in Haskovo), vis-à-vis its planned expansion of the Article 25 selected list of representatives.[64] In September 2023, the non-governmental organisation Bulgarian Helsinki Committee communicated its first annual report assessing the quality of the representation provided by Article 25 legal aid lawyers. The general feedback from children in 2025 remained predominantly positive with respect to legal aid lawyers acting in Sofia reception centres and predominantly reserved to negative with respect to legal aid lawyers acting in Harmanli reception centre, although certain slight improvement were reported with respect to assistance to appeal negative decisions.[65] The monitoring was extended in 2025, based on a formal agreement[66] between the Ministry of Justice and UNICEF. The next report, due in May 2026 has to provide both general findings about the overall quality of the legal representation as well as individual assessment of acting legal aid lawyers. On 14 March 2024, the NLAB Executive Committee decided that quality assessments of legal aid providers ought to be introduced in the law in order to allow striking of underperforming representatives out of the limited Article 25 list. Such amendments had been already proposed and included in the draft law, submitted by SAR in February 2024,[67] however the draft never made to the Parliament due to the continued constitutional crisis experienced by the country since mid-2022. The national plan for the EU Migration and Asylum Pact’s Implementation[68] adopted on 19 December 2024 envisaged a revision of the ordinance’s provisions to make them correspond to the Pact’s rules and procedures with a deadline for these amendments set for December 2025. Such amendments however were not formally adopted until 31 December 2025 (see Overview).
Other asylum seekers, who were not recognised as having specific vulnerabilities, did not enjoy access to legal aid at the first instance of the asylum procedure even in previous or following years.
Legal assistance in appeals
The aforementioned AMIF-funded pilot project on legal aid, which was carried out up until 31 January 2021, also covered assistance in the preparation of appeals before the court. As mentioned above, it ended on 31 July 2021.
Otherwise, for regular applicants on appeal, national legal aid arrangements only provide for state-funded legal assistance and representation after a court case has been initiated, i.e. after the appeal has been drafted and lodged. In principle the law allows legal aid to be requested and awarded by the National Legal Aid Bureau (NLAB) before that, which for asylum seekers mean that they can approach NLAB and be assigned legal aid for submission of an appeal against served SAR refusal, especially after the amendments of the law[69] in 2022. However, NLAB is situated solely in the capital Sofia without regional offices across the country, and it functions with 23 staff members who are also responsible for all other national caseload where legal aid should be mandatory rendered, e.g. criminal trials, parental disputes, etc. Therefore, in practice it is impossible for refused asylum seekers to secure legal aid for submission of an appeal in the very tight 7- or 14-days deadlines.
As a result, since the establishment of the national asylum authority in 1994, asylum seekers rely entirely for their access to the court, namely for drafting and lodging the appeal, on NGOs or private practitioners for those who have sufficient financial means to afford it. Therefore, main support in this respect has ever been rendered by the non-governmental organisation Bulgarian Helsinki Committee as UNHCR’s prime legal partner since 1994. However, due to UN financial crisis BHC was forced to close its legal reception offices on 1 January 2026 and thereafter[70], thus leaving asylum seekers without a reliable free of charge legal assistance for access to court and timely submission of appeals before the court against negative decisions refusing or revoking international protection. The only free-of-charge legal assistance that remained readily available in this respect[71] is weekly in Sofia at the Red Cross’s Information Bureau every Thursday from 10:30 to 12:30, provided by the non-governmental from Centre for Legal Aid – Voice in Bulgaria, as well as also weekly in Harmanli at UNHCR’s COMPASS centre, provided by one BHC lawyer.
[1] Article 75 (1) LAR.
[2] Article 74 LAR.
[3] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.
[4] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.
[5] SAR, reg. №ПО-02-115 from 22 February 2026.
[6] SAR, reg. №ПО-02-115 from 22 February 2026.
[7] SAR, reg. №ПО-02-115 from 22 February 2026.
[8] SAR, reg. №АД-07-7 from 14 January 2025: in total 5,527 cases pending determination, of which 3,895 new applications and 1,632 applications cases pending from 2024.
[9] Ibid.
[10] SAR, reg. No. №РД05-31 from 15 January 2024: 1,969 discontinued procedures out of all 6,159 Afghan applicants pending in 2023, of whom 1,980 applied in 2024 and 4,179 were pending from 2023.
[11] See, AIDA 2023 and 2022 Updates on Bulgaria.
[12] See, Table Statistics, pages 12-13 of this report: 327 Afghan decisions on the merits.
[13] Article 63a (3) LAR.
[14] Article 63a (7) LAR in conjunction with Article 61a (5) LAR.
[15] Article 63a (5) LAR.
[16] Article 61a (2)-(4) and (6) LAR.
[17] Article 63(3) LAR.
[18] SAR, reg. №РД05-40 from 16 January 2023.
[19] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.
[20] Ibid.
[21] SAR, reg. № КП-04-2611 from 5 May 2026.
[22] Article 63a (6) LAR.
[23] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.
[24] Article 63a(6) LAR.
[25] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.
[26] Ibid.
[27] SAR, reg. No. №РД05-31 from 15 January 2024.
[28] 126th Coordination Meeting, held on 5 October 2023.
[29] See, AIDA 2023 Update on Bulgaria.
[30] EUAA, Operational Plan 2022-2023 agreed with the European Union Agency for Asylum and Bulgaria, July 2023, available at: https://bit.ly/3Ie14fb.
[31] EUAA, Operational Plan 2024-2026 agreed with the European Union Agency for Asylum and Bulgaria, as amended in December 2024, available here.
[32] Bulgarian Helsinki Committee, 2023 Annual Report on Human Rights, available in Bulgarian at: https://bit.ly/3SX3ST7.
[33] Bulgarian Helsinki Committee, reg. №Б-29 from 2 October 2024.
[34] SAR, reg. №ЦУ-16-446-3 from 28.06.2024.
[35] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.
[36] Ibid.
[37] Article 63a(3) LAR.
[38] See Court of Justice of the European Union (CJEU), Case C-348/16 Sacko, Judgment of 26 July 2017, para 35; Case C-249/13 Boudjlida, Judgment of 11 December 2014, para 37; Case C-166/13 Mukarubega, Judgment of 5 November 2014, para 47.
[39] Article 92 LAR.
[40] Bulgarian Helsinki Committee, 2024 Annual Report on Human Rights, available in Bulgarian at: https://bit.ly/3SX3ST7.
[41] Article 85(4) LAR
[42] Article 85(3) LAR in conjunction with Article 84(1)-(2) LAR.
[43] Article 76(3) LAR.
[44] Article 76 (4) LAR.
[45] Article 84(2)-(4) LAR in conjunction with Article 133 Administrative Procedure Code.
[46] The Court decisions are available at: https://bit.ly/2OZU62r (Sofia court), https://bit.ly/39nuVjv (Haskovo court), https://bit.ly/2MOgihu (Sliven court) and https://bit.ly/2XxkioP (Supreme administrative court).
[47] See, AIDA 2024 Update on Bulgaria; also, Table Applications and granting of protection status at first instance, page 8 of this report.
[48] SAR, reg. №ПО-02-115 from 22 February 2026.
[49] Article 85(5) LAR.
[50] SAR, reg. №ПО-02-115 from 22 February 2026.
[51] Articles 30d to 30o Law on Legal Aid, as amended St.G. №13 from 7 February 2017.
[52] National Legal Aid Bureau, tel. 0700 18 250.
[53] Article 22(8) Law on Legal Aid.
[54] §1(17) from Additional Clauses LAR, namely: children, unaccompanied children, disabled, elderly, pregnant, single parents taking care of underage children, victims of trafficking, persons with serious health issues, psychological disorders or persons who suffered torture, rape or other forms of psychological, physical or sexual violence.
[55] National Legal Aid Register, available in Bulgarian at: https://bit.ly/42Syzxe.
[56] National parliament, Draft amendment of the Law on Legal Aid, reg.No. 48-202-01-19 from 28 October 2022, available in Bulgarian at: https://bit.ly/3ygoCei.
[57] State Gazette No.102 from 23 December 2022.
[58] Article 21 (1) Law on Legal Aid, as amended St.G. №102 from 2022.
[59] National Legal Aid Bureau, ‘Обява за конкурс за адвокати за работа по проект’, 29 January 2018, available in Bulgarian at: http://bit.ly/2DP376C.
[60] SAR, reg. №ПО-02-115 from 22 February 2026.
[61] SAR, reg. №РД05-40 from 16 January 2023.
[62] National Parliament, Amendments on the Law on Asylum and Refugees (LAR), State Gazette No.89 from 16 October 2020, available at: https://bit.ly/2LoUMiG.
[63] Article 25 LAR.
[64] It is important to note that not all listed legal aid lawyers can serve as representatives of unaccompanied children. Only those who meet certain additional criteria, when recruitment is announced by NLAB, can be listed among the limited number of those selected as fit to represent unaccompanied children.
[65] Bulgarian Helsinki Committee/UNICEF, Annual report on quality of legal representation of unaccompanied children, 10 January 2025.
[66] Memorandum of Understanding and Cooperation between Ministry of Justice of the Republic of Bulgaria and the United Nations Children’s Fund (UNICEF), signed on 19 September 2024.
[67] SAR, reg.№ЦУ-04-408 from 14 February 2024.
[68] COM №883 from 19 December 2024, available in Bulgarian here.
[69] Article 22, Para 1(8) of Law on Legal Aid (St.G.№102/2022).
[70] Bulgarian Helsinki Committee, The BHC Legal Aid Reception for Refugees and Migrants ceased its operation on 1 January 2026, published on 12 January 2026, available here.
[71] UNHCR Representation in Bulgaria, Legal Awareness, available here.