Author
Since 2015, local municipalities are mandated to act as legal representatives of unaccompanied children.[1] Highly criticised when adopted, this approach proved to be more inadequate than previous arrangements. The municipalities lacked not only qualified staff, but also basic experience and expertise in child protection.[2] In addition to that, the number of legal representatives appointed – one or two per reception facility – was insufficient to meet the need of the population of unaccompanied children who, remained considerable in number.
At the end of 2020, amendments to the law introduced a major change in the legal representation of unaccompanied asylum seeking and refugee children.[3] The obligation to represent these children not only in the procedure, but also after the recognition and before all agencies and institutions regarding their rights and entitlements, was shifted from the municipalities to the National Legal Aid Bureau. It includes requirements related to the qualification of the appointed legal aid lawyers and representation implemented in the child’s best interest.[4] It aimed at addressing the absence of guardians and ensure proper legal representation and care for the best interests of unaccompanied children in asylum procedures to mitigate high rates of absconding and related protection and safety risks.
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 December 2023, UNHCR supported NLAB with training for legal aid lawyers vis-à-vis the planned expansion of the limited list of Article 25 representatives. In February 2024, NLAB recruited 20 additional lawyers (18 in Sofia and 2 in Haskovo) with a follow-up training, also organized and funded by UNHCR, held in December 2024. In December 2025, UNHCR held another training in cooperation with NLAB and Center for Continuing Education of the National Bar Association for legal practitioners, including Article 25 representatives. In April 2025, the non-governmental organisation Bulgarian Helsinki Committee communicated its second annual report covering the year of 2024, which assessed the quality of the representation provided by Article 25 legal aid lawyers. The general feedback from children continued to remain predominantly positive with respect to legal aid lawyers acting in Sofia reception centres, while it was mainly negative with respect to legal aid lawyers acting in Harmanli reception centre, with main concern related to required additional payment in violation of the law[5]. The next report, due in April 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. This report and monitoring are based on a formal agreement[6] between the Ministry of Justice and UNICEF; however, it will not be conducted in 2026 due to financial constraints. 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,[7] 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[8] 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)
In the past, the SAR used to significantly delay the notification to the National Legal Aid Bureau of the necessity to appoint a representative, reaching a period longer than 1 month in certain cases.[9] As a result, unaccompanied children left without a representative had no access to credible information on the asylum procedure and their rights, especially the right to be legally transferred under the Dublin III Regulation to other EU countries to reunite with their family members. In 2022 however, the practice in this respect improved significantly. NLAB agreed[10] with SAR to provide the latter with access to its automated individual database, which could be used not only to send an immediate notification by SAR to NLAB about requested new representative’s appointments but also allowing the SAR to obtain immediately and directly information about the appointed representative. However, in 2025 the appointment of a representative to unaccompanied children decreased to 3 calendar days on average following the registration of the children, for making the request by SAR to NLAB, and 5 calendar days on average by NLAB to appoint the representative and send back the appointment information to the SAR.[11] In total, NLAB appointed a legal aid representative for 97% (553 out of all 573) of the unaccompanied children who applied for asylum in that year. This was improvement in comparison to 2024, when a legal aid representative was appointed for 91%[12] of the children (2023: 72% of the children). However, the representation of 845 of these children was discontinued due to their abandonment of the procedure and absconding the country[13]. Therefore, just 181 unaccompanied asylum-seeking children were represented by NLAB legal aid lawyers from start to end of their status determination[14].
The immediate and written provision of information to unaccompanied children regarding the appointment of the respective representative and their contact details is a legal obligation of the SAR.[15] Fully omitted until the very end of 2021, when such information began to be partially provided in Ovcha Kupel and Voenna Rampa safe-zones, in 2025 in 99% of the relevant cases monitored, children were duly and timely informed about the appointment of their representative.[16] This represented an improvement in comparison to the 2024 practice, when 91% of unaccompanied children were duly provided this information, respectively 81% in 2023, and 96% in 2022.[17]
Since mid-2022 the SAR has been actively searching for opportunities to accommodate unaccompanied children in licensed family-type children’s centres (ЦНСТ). During the procedure such efforts were undertaken with regard mainly to minor asylum-seeking children, children with special needs or such identified as being at increased risk of trafficking or harm. After the recognition, these efforts targeted all unaccompanied children, excluding those in family reunification procedures, who were allowed to wait the reunification with their parents or other family members in SAR reception centres.[18] As a result of this positive practice, throughout 2025, 41 unaccompanied children were accommodated in specialized childcare centres. Out of the total, 11 were asylum seeking children and 30 children who had been granted international protection.[19] In this respect, it can be noted that the children positively impacted by these measures continued to gradually increase[20] with more of them able to benefit by this type of accommodation compared to previous years. Altogether thirteen licensed childcare centres have engaged in this practice in localities across the country, namely in Sofia, Burgas, Vidin, Ruse, Kardzhali, Novo Selo and Zvanichevo. At the same time the lack of specialized training of the childcare centre’s staff to work with unaccompanied children seeking or granted protection should be acknowledged and taken into account as well as the lack of secured interpretation at least for the initial period of accommodation and adjustment.
The number of unaccompanied child applicants continued to decrease to 573 in 2025, compared to 2,601 in 2024; 3,843 in 2023; 3,483 in 2022; 3,127 in 2021; 799 in 2020; 524 in 2019; 481 in 2018; 440 in 2017 and 2,772 in 2016:
| Unaccompanied asylum-seeking children: 2025 | |
| Country of origin | Number |
| Algeria | 1 |
| Congo | 1 |
| Egypt | 75 |
| Morocco | 31 |
| Senegal | 1 |
| Tunisia | 3 |
| Afghanistan | 257 |
| Iran | 35 |
| Iraq | 105 |
| Pakistan | 5 |
| Syria | 58 |
| Stateless | 1 |
Source: SAR.
Out of all unaccompanied children whose asylum claims were assessed on the merits in 2025, none was recognised as a refugee, 20 were granted subsidiary protection, 161 were refused protection and 845 children absconded prior to being notified the decision, and therefore their procedures were terminated.
Hence, despite unaccompanied children being better informed about their rights and the asylum procedure, the vast majority (82%) still abandoned the asylum procedure and moved irregularly to the countries of their destination.[21]
[1] Former Article 25(1) LAR.
[2] Bulgarian Helsinki Committee, 2012, 2013, 2015 and 2016 Annual Refugee Status Determination Monitoring Reports, available at: https://bit.ly/49TvJdp.
[3] 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.
[4] Article 25 LAR.
[5] Bulgarian Helsinki Committee/UNICEF, Monthly Progress Report on child protection, 10 January 2024.
[6] 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.
[7] SAR, reg.№ЦУ-04-408 from 14 February 2024.
[8] COM №883 from 19 December 2024, available in Bulgarian here.
[9] Bulgarian Helsinki Committee, 2021 Annual RSD Monitoring Report, available at: https://bit.ly/3Ad4wlt.
[10] Teleconference with NLAB Chair Natalia Ilieva on 22 December 2022.
[11] Bulgarian Helsinki Committee, 2025 Annual RSD Monitoring Report, 31 January 2026, available at: https://bit.ly/3Jkd3t0.
[12] 2024: 2,392 out of all 2,601 unaccompanied children appointed legal aid and representation.
[13] Including backlog cases, pending from 2024.
[14] Bulgarian Helsinki Committee, 2025 Annual RSD Monitoring Report, 31 January 2026, available at: https://bit.ly/3Jkd3t0.
[15] Article 25(5) LAR.
[16] Bulgarian Helsinki Committee, 2025 Annual RSD Report, 31 January 2026, available in Bulgarian at: https://bit.ly/3SX3ST7.
[17] Bulgarian Helsinki Committee, 2024, 2023 and 2022 annual RSD reports, available at: https://bit.ly/3SX3ST7.
[18] SAR, Rules and procedures on the accommodation of unaccompanied children granted international protection in foster families, social or integrated socio-medical care facilities for children of a residential type, adopted in October 2022.
[19] SAR, reg. №ПО-02-115 from 22 February 2026.
[20] Ibid., 2022: 26 children (2 asylum seeking and 24 granted protection); 2023: 43 children (2 asylum seeking and 41 granted protection); 2024: 62 children (4 asylum seeking and 58 granted protection).
[21] SAR, reg. №ПО-02-115 from 22 February 2026.