Registration of the asylum application


Country Report: Registration of the asylum application Last updated: 21/04/23


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An asylum application can be made either before the specialised asylum administration, the SAR, or before any other state authority, which will be obligated to refer it immediately to the SAR.[1] Thus, asylum can be requested on the territory, at the borders before the Border Police staff, or in detention centres before the Migration Directorate staff of the Ministry of Interior. The asylum application should be made within a reasonable time after entering the country, except in cases of irregular entry or residence when it ought to be made immediately.[2] Failure to make an application within a reasonable time or immediately in those cases can be a ground for rejecting it as manifestly unfounded under the Accelerated Procedure.[3]

If the asylum application is made before an authority different than the SAR, then status determination procedures cannot legally start until the asylum seeker is transferred from the border / detention centre and accommodated in any of the SAR’s premises for registration to lodge the claim in person.[4] Under the law, this personal registration is to be implemented in any of the territorial units (see Types of Accommodation) of the SAR and within 3 working days after the making of the asylum application. Exceptions to this deadline are allowed only in cases where the asylum application is lodged before a different government authority or institution, in which case the deadline is set at 6 working days.[5]

No significant delays were noted with respect to the release and registration of asylum seekers who applied while in immigration detention centres. In 2022 the average Duration of Detention decreased to 6 calendar / 4 working days.[6] For comparison in 2021 the average detention duration was 7 calendar / 5 working days. Registration took place without any delay compared to the established EU minimum standard.[7]

An important improvement, monitored  in 2022[8] related to the access to procedure of the so called ‘self-reported asylum seekers’, i.e. those who managed to enter and travel in Bulgaria undetected by the police to turn up on their own directly at a SAR reception centre (Sofia, Banya, Harmanli or Pastrogor) and seek protection. Since 2016 the SAR has been refusing to register the self-reported asylum seekers, instead it has been alerting the local police departments. As a result, the asylum seekers subjected to this practice have been arrested and detained in MOI pre-removal centres. During the previous 2021 this malpractice affected 196 newly arrived asylum seekers, among whom families with minor children and pregnant women. The registration of these asylum seekers in immigration detention centres was, and still is carried out within the same day. In 2022, the new management of the SAR reverted to a great extent to the use of this malpractice.[9] In the period from 1 January to 31 May, this practice affected 72 out of 7,924 persons (0.9%) who had lodged an asylum application by that time, after the SAR management was replaced,[10] in the following period from 1 June to 31 December, the number of refused registrations drastically dropped to 0.1% (corresponding to 22  out of 12,483 persons lodging an application for international protection during that period of time).[11]

Another improvement with respect to registration of asylum seekers in 2022 related to registrations and status determinations carried out – in violation of the law – by SAR in MOI immigration detention centres. Under existing legal provisions,[12] while SAR can in fact detain asylum seekers pending the asylum procedure, it has the power to do so solely in closed SAR reception centres. Since 2015. SAR began to carry out registrations and asylum procedures in MOI immigration detention centres instead. In 2022, SAR almost entirely discontinued this unlawful practice, carrying out only 1 registration and 1 procedure in a MOI immigration detention centre.[13]

At the end of the process, the asylum seeker receives a registration card (регистрационна карта) in paper format. It should be noted, however, that the registration card is not issued to subsequent applicants.[14]

Under the law,[15] the SAR must inform the State Agency for National Security (SANS – Държавна агенция “Национална сигурност“) of the registration of every asylum application. The SANS then conducts security assessments based on interviews with applicants, which are often held as soon as they are arrested by police, border and immigration officers. In practice, the SAR follows these assessments without conducting further investigations and rejects applications accordingly, even when the information is classified. The national courts notoriously refuse to check or verify the facts raised by the SANS as security concerns in individual cases. As a result, in the past the European Court on Human Rights (ECtHR) repeatedly ruled that Bulgaria has been regularly violating the right to an effective remedy.[16]




[1] Article 58(4) LAR.

[2] Article 4(5) LAR.

[3] Article 13(1), items 11-12 LAR.

[4] Article 61a(1) LAR.

[5] Article 61a(1) LAR in conjunction with Article 58(4) LAR.

[6] Article 6(1) recast Asylum Procedures Directive.

[7] Article 6(1) recast Asylum Procedures Directive.

[8] Bulgarian Helsinki Committee, 2022 Annual RSD Monitoring Report, published on 1 March 2023, available at:

[9] Ibid.

[10] The SAR leadership was replaced in March-April 2022.

[11] Bulgarian Helsinki Committee, 2022 Annual RSD Monitoring Report, published on 1 March 2023, available at:

[12] Article 45(b) etc. LAR.

[13] Bulgarian Helsinki Committee, 2022 Annual RSD Monitoring Report, published on 1 March 2023, available at:

[14] Article 76c(3) LAR.

[15] Article 58 (10) LAR.

[16] ECtHR, Al-Nashif and other v. Bulgaria, Case N50963/99, 20 September 2002; Musa and other v. Bulgaria, Case N61259/00, 11 January 2007; Hassan v. Bulgaria, Case 54323/00, 14 June 2007; Bashir and other v. Bulgaria, Case N65028/01, 14 June 2007; C.G. and other v. Bulgaria, Case N1365/07, 24 April 2008.; Raza v. Bulgaria, Case N31465/2008, 11 February 2010; Kaushal and other v. Bulgaria, Case N1537/08, September 2010; GC and other v. Bulgaria, Case N1365/07, 24 June 2008; O.D. v. Bulgaria, Case N34016/18, 10 October 2019 ; M.A. and other v. Bulgaria, Case N5115/18, 20 June 2020.

Table of contents

  • Statistics
  • Overview of the legal framework
  • Overview of the of the main changes since the previous report update
  • Asylum Procedure
  • Reception Conditions
  • Detention of Asylum Seekers
  • Content of International Protection
  • ANNEX – Transposition of the CEAS in national legislation