NGOs, lawyers and UNHCR staff have unhindered access to all border and inland detention centres and try to provide as much information as possible related to detention grounds and conditions. Despite that, the subject of detention remains hard to explain as an extremely high percentage of asylum seekers claim that they do not understand the reasons why they are kept in detention.
The LAR provides that where there are indications that the individuals in detention facilities or at border crossing points may wish to make an asylum application the government shall provide them with information on the possibility to do so. The information should at least include how one can apply for asylum and procedures to be followed, including in immigration detention centres and interpreted in the respective language to assist asylum seekers’ access to procedure. This obligation is not fulfilled in practice as none of the SAR staff is visiting or consulting potential asylum seekers who are apprehended at the border or in immigration detention centres, where the provision of information depends entirely on legal aid NGOs’ efforts and activity.
In those detention facilities and crossing points, Bulgaria is also legally bound to make arrangements for interpretation to the extent necessary to facilitate individual access to the asylum procedure. Such interpretation, however, is not secured and the only services in this respect are provided by the Bulgarian Helsinki Committee under UNHCR funding. Although Article 8(2) of the recast Asylum Procedures Directive, allowing organisations and persons providing advice and counselling to asylum applicants to have effective access to applicants present at border crossing points, including transit zones at external borders, is transposed in the national law, in practice there are no other NGOs besides the Bulgarian Helsinki Committee which provide regular legal assistance in these areas. Other NGOs such as Center for Legal Aid – Voice in Bulgaria and Bulgarian Lawyers for Human Rights provide project-based and targeted legal assistance in the Busmantsi pre-removal detention centre. At the end of 2016 the International Organisation for Migration (IOM) Bulgaria received AMIF funding among many others to also provide legal counselling on status determination procedure to asylum seekers in reception centres and to irregular migrants in detention centres with regard to assisted voluntary return. This assistance is not conditioned by requirements about the qualifications of assistance providers and is ensured by shifting mobile teams on a weekly schedule.
As regards urban asylum seekers and refugees living in the Sofia region, UNHCR has funded an Information Centre, located in Sofia, which will be maintained throughout 2020.
 For more information, see General Directorate Border Police, UNHCR and BHC, 2015 Annual Border Monitoring Report: Access to territory and international protection, July 2016, available at: http://bit.ly/2jsyglh, para 1.1.3.
 This has been a systematic concern. See JRS Europe, Becoming Vulnerable in Detention (Detention of Vulnerable Asylum Seekers – DEVAS Project), 2010, National Chapter on Bulgaria, 147 – points. 3.1 and 3.2.
 Article 58(6) LAR; Article 8(1) recast Asylum Procedures Directive.
 Article 23(3) LAR.