In this political and institutional context, as described in the paragraph above, preparations for the implementation of the EU Pact on Migration and Asylum stalled. According to the National Plan for Pac implementation adopted by the government[1] , alongside other technical and organizational measures, two key legislative amendments were envisaged: the drafting of an entirely new Law on Asylum and Refugees, with a deadline for adoption of 31 December 2025[2], as well as amendments to the provisions of the primary and secondary immigration legislation in order to establish rules for screening and detention of third-country nationals after the expiry of the 24-hour police arrest period, again with a deadline for adoption[3] by 31 December 2025. Other measures in the Plan provided for the establishment of screening centres under the General Directorate Border Police (GDBP) in Elhovo and Dragoman, as well as the construction of three screening centres for the immigration police (Directorate Migration, DM) — two for unaccompanied minors: one in Sofia, with a capacity of 50 places, and one in Elhovo, with a capacity of 90 places; and one screening centre in Lyubimets for irregular third-country nationals identified within the interior of the country, with a capacity of 540 places.
As of the date of this report, none of the measures described above had been implemented. While the delay in establishing the screening centres is not critical, given that the police authorities are adapting for this purpose buildings within already existing police detention facilities, the fact that relevant legislation has not yet been amended might lead to missing the deadline of 12 June 2026. Nevertheless, amendments to the primary immigration legislation have been finalized by the Ministry of Interior, and their publication for public consultation is expected in March 2026, with submission to Parliament planned[4] for April 2026. However, the adoption of the new Law on Asylum and Refugees has been drastically compromised. On 24 February 2025, an inter-institutional working group under the State Agency for Refugees began work on the draft law, and by mid-May 2025 four chapters had been prepared and agreed upon. Following the dismissal of the Agency’s leadership on 4 June 2025, the inter-institutional working group did not hold a single meeting until 7 November 2025, when the participating government stakeholders were invited to be presented with a final version of an entirely different draft law prepared by legal experts of the Agency. Despite the predominantly negative opinion expressed on this draft by the members of the inter-institutional working group, in January 2026 the caretaker government published the draft law for public consultation[5] without having conducted the formal inter-ministerial coordination procedure with the ministries and other competent authorities. By the close of the public consultation procedure on 25 February 2026, all opinions submitted on the draft law were against its adoption.[6]
[1] Legal Information Portal of the Council of Ministers of the Republic of Bulgaria, Decision №883 from 19 December 2024 adopting Plan for Implementation by the Republic of Bulgaria of the European Union’s Pact on Migration and Asylum, published on 21 January 2025, available here in Bulgarian.
[2] Decision №833 from 19 December 2024 adopting Plan for Implementation by the Republic of Bulgaria of the European Union’s Pact on Migration and Asylum, published on 21 January 2025, available here in Bulgarian, point 3.1.1.
[3] Decision №833 from 19 December 2024 adopting Plan for Implementation by the Republic of Bulgaria of the European Union’s Pact on Migration and Asylum, published on 21 January 2025, available here in Bulgarian, point 2.1.1.
[4] Teleconference with MOI Legal and Information Directorate on 2 March 2026.
[5] Portal for Public Consultations, Law on International Protection draft, published on 26 January 2026, available here in Bulgarian.
[6] Ibid.
