Regular procedure

Author

Bulgarian Helsinki Committee Visit Website

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 2023, the general 6 months deadline for issuing an asylum decision was observed in 100% of case.[3] According to the SAR, the average duration of asylum procedures on the merits ranges from 4 to 6 months,[4] although according to the available independent reports[5] the four-months deadline was observed in 95% of the monitored cases.

Since 2020, the country experienced a significant increase in the number of arrivals, which reflected on the number of asylum applications. In 2023, the number of new arrivals continued to increase, reaching a total of 22,518 asylum seekers (+10%), 20,407 asylum seekers in 2022 (+85%), 10,999 asylum seekers (+212% increase) in 2021 and 3,525 asylum seekers in 2020.

In 2023, SAR reached the highest ever annual number of decisions issued with 24,949 decisions in total, of which 106 decisions granting refugee status, 5,682 decisions granting humanitarian status, 2,950 refusals of international protection and 16,211 discontinuations of the procedure, mainly due to absconding.[6] Despite this, at the end of 2023 11,951 asylum cases were still pending, out of which 772 applications submitted in December, which made 74% annual decision-making rate.[7] This was likely due to the fact that the backlog of pending cases increased in previous years, going from 2,021 cases in 2020, 7,556 cases in 2021 to more than 8,000 cases at the beginning of 2022[8] SAR staff competent to issue eligibility decisions counted 32 case-workers.[9]

46% (16,211 persons) of all 33,703 asylum seekers with pending applications in 2023[10] abandoned their procedures in Bulgaria. This was a slight increase compared to 45% in 2022, but even more significant when compared to 26% in 2021 and39% in 2020, though still lower than 83% in 2019. 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 flight. 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 2023 the overall recognition rate once more lowered, going to 14 (5% refugee recognition / 9% subsidiary protection) with the rejection rate standing at 84%. This likely motivated most of them (68%),[11] though less than in 2022 (95%)[12] to abscond before their first instance decision, issued on the merits in just 2%[13] of the caseload.

Out of the 24, 949 decisions taken, 74% of asylum procedures were terminated (discontinued) in absentia:

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.[14] 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.[15] 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.[16] 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.[17] The law also introduced instructions on COI sources and information gathering.[18]

In 2023,[19] timely invitations for personal interviews were sent in 37% of monitored procedures;[20] in another 15%, asylum seekers[21] signed interview invitations without being given a copy thereof; the signed invitation was attached to their personal file. 3 of these cases concerned unaccompanied children. Therefore, it can be concluded that in 2023 the majority of asylum seekers did not enjoy timely notification regarding the date of their personal interview. This practice was particularly concerning at SAR’s reception centre in Banya, where just 2 out of 20 cases (10%) were properly notified of their invitations.

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 form adapted for asylum seeking children, including unaccompanied ones.[22] However, it was applied in practice only with respect to minor children, not the adolescent[23] ones whose interviews were conducted using the interviewing template for adult applicants. The monitoring demonstrated[24] that in the vast majority of the cases the use of interviewing template was counterproductive as case-workers 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.

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.[25] In 2023,[26] considering all the cases in which the case-worker and the asylum seeker were of different gender, only in 9% the asylum seeker was informed about the possibility to request that the interview be conducted by an interviewer of the same gender and only in 20% about the possibility to request an interpreter of 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.[27] 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).

Both at first and second instance, interpretation continued to present shortcomings in 2023, and its quality was often poor and unsatisfactory. Interpretation in determination procedures has remained one of the most serious, persistent and unsolved problems for a number of years. Interpretation is secured only from English, French and Arabic languages, and mainly in the reception centres in the capital Sofia. Interpreters from other key languages such as Kurdish (Sorani or Pehlewani), Pashto, Urdu, 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. The scarce fees paid for interpretation by the asylum agency SAR remain one of main reasons for the lack of proper interpretation during the eligibility interviews at first instance. Following the beginning of EC-Bulgaria pilot project on accelerated procedure in mid-2023, the Commission deployed additional interpreters to be used by SAR through the duration of the project. According to the Bulgarian Helsinki Committee’s evaluation however, it results that most of them were not properly instructed on national asylum procedures. In several anecdotal cases,[28] it appeared that Moroccan applicants whose application was processed in Pastrogor Transit Center were provided misleading information by the assigned interpreter, which resulted in failure to appeal within the deadline their negative first instance decisions.

With respect to those who speak languages without interpreters available in Bulgaria, the communication takes place in a language chosen by the interviewer, not the applicant. In the past, there were also cases where the determination was conducted with the assistance of another asylum seeker, but no similar issues were registered since 2021, therefore it can be concluded that this serious procedural gap was finally solved.[29] In previous years, concerns were raised regarding the behaviour and attitude of interpreters during asylum interviews (with similar issues registered in 0.7% monitored cases in 2022 and 11% of cases in 2022). No similar issues were reported regarding 2023.

100% of the monitored court hearings were assisted by interpreters in 2023.[30] The Administrative Court in Haskovo to some extent corrected its unlawful practice from 2022 to summon an interpreter for the first court hearing by telephone at the day of the hearing, if and when the appellant had already appeared in the court room. In 32% of monitored cases where the applicant attended the hearing the interpreter was properly summoned in advance.[31]

Despite the abovementioned improvements, the quality of interpretation continues to be substandard. Interpreters’ Code of Conduct rules adopted in 2009 are not applied in practice. As a result, quite often the statements of asylum seekers are summarised or the interpreters provide comments on their authenticity or likelihood. This problem is exacerbated by the fact that interview protocols are not based on the audio recording of the interview but on the caseworker’s notes. Therefore, the interpreters encounter difficulties to provide a full report of applicants’ statements and answers.

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.[32] The positive practice in this regard persisted in 2021, 2022 and 2023, as 100% of all 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.

In 2023,[33] the registration forms or the records from the interviews were not read out to asylum seekers in 22% of the monitored procedures, which was a regress in comparison with 2022, as this omission was made in 18% of the monitored cases, but represented an improvement compared to 24% in 2021. Compliance with EU standards[34] 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.[35]

Notwithstanding the small number of asylum seekers who presented any evidence to support their claims, in a small percentage of cases, caseworkers did not respect their obligation to collect these pieces of evidence with a separate protocol, a copy of which should be served to the applicant.  In 94% of monitored registrations,[36] asylum seekers were informed about their obligation to submit all the available evidence to support their statements, while in the remaining 6% this was not done. In 53% of monitored cases, asylum seekers submitted evidence in support of their asylum claim; in 62% of them the evidence was properly protocoled. Hence this important safeguard that the submitted evidence would be taken into consideration in the decision-making was not observed in 38% of the monitored cases. This marked a slight progress when compared to 2022, when this omission was made in 51%, but still worse than just 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 is obligated to, and actually does, provide information to rejected asylum seekers as to where and how they can receive legal aid when serving a negative decision, in the form of a list (see Regular Procedure: Legal Assistance immediately below).

Two levels of appeal  are accessible in the regular procedure,[37] 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.[38]

Appeal procedures are only judicial; the law does not envisage an administrative review of asylum determination decisions. Since a 2014 reform, 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.[39] Up to the present moment, however, the reform failed in significantly 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 busiest ones, 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,[40] 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. In 2023, the SAC issued negative decisions in 87% of asylum cases examined,[41] which still represents the majority of the asylum cases brought before this highest court instance. Thus, in practice, asylum seekers did not enjoy a two-instances court revision, as the control exercised from the Supreme Administrative Court’s 4th department in the vast majority of the cases continued to be purely formal and superficial.

First instance appeal courts must issue their decisions within one month. The Cassation Court 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 2023, this practice drastically changed, with both regional and Supreme administrative courts issuing their decision in a period of less than a month. If the court reverts the first instance decision back, the SAR has 3 months to issue a new decision,[42] complying with the court’s instructions on the application of the law. As in previous years, SAR did not fully observe these deadlines, although in 2023 it did not issue any repeated refusals going against the court’s instructions.[43] 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 2023 as in 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

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.[44] In practice, due to insufficient funding, free legal aid is only provided to vulnerable persons[45] upon their explicit request. Amendments to the law in 2020 also entrusted to registered legal aid lawyers[46] 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.[47] The amendment was adopted in December 2022 and entered into force on 26 December 2022.[48]

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[49] to include oral consultations at the national help line[50] or in regional legal aid centres. The condition for the legal aid to be provided is the applicants for legal aid to lack means and resources to engage a lawyer privately against remuneration.

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. However, access to free legal aid in first-instance procedures was in practice not possible as of the end of 2023.

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,[51] 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. In 2023, free legal aid was not provided to applicants, with the only exclusion of the statutory representation of unaccompanied asylum seeking and refugee children based on Article 25 LAR provision (see next paragraph). This represented a significant deterioration of relevant national practices, as 50 asylum seekers at first instance had been assisted with state provided legal aid in 2021, and 818 vulnerable applicants in 2020.[52]

Amendments to the law introduced at the end of 2020 foresee a major change in the legal representation of unaccompanied asylum seeking and refugee children.[53] 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.[54] 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. The selection and the following training of selected lawyers was carried out in May-June 2021. Since July 2021, 16 lawyers from the Sofia Bar, 8 lawyers from Haskovo Bar and 3 lawyers from Sliven Bar have been implementing the representation of unaccompanied asylum seeking and refugee children. In December 2023, NLAB conducted training of 18 additional lawyers vis-à-vis its planned expansion of Article 25 limited list of representatives. 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 report was based on a formal agreement,[55] endorsed by UNHCR and funded by UNICEF. It covered the period from 1 July 2022 until 31 August 2023 with feedback collected from 215 interviews with unaccompanied children at Sofia and Harmanli reception centres. The report provided both general findings about the overall quality of the legal representation as well as individual assessment of each 23 acting legal aid lawyers from the limited NLAB list. The general feedback from children 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.[56] On 14 March 2023 the NLAB Executive Committee will hold a review of the report to consider amendment of its internal rules to allow striking of underperforming representatives out of the limited Article 25 list.

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. As a result, asylum seekers rely entirely on NGOs for their access to the court, namely for drafting and lodging the appeal.

[1] Article 75 (1) LAR.

[2] Article 74 LAR.

[3] SAR, Annual report on procedures for international protection in 2023, available in Bulgarian at: https://bit.ly/3wDKXoU. 

[4] SAR, reg. No. №РД05-31 from 15 January 2024.

[5] Bulgarian Helsinki Committee, 2023 Annual Refugee Status Determination Monitoring Report, 31 January 2024, available at: https://bit.ly/3SX3ST7.

[6] SAR, Annual report on procedures for international protection in 2023, available in Bulgarian at: https://bit.ly/3IgTCjm.

[7] SAR, reg. No. №РД05-31 from 15 January 2024: 33,703 applications pending decision, of which 22,518 submitted in 2023 and 11,185 pending from 2022; source: SAR.

[8] Teleconference with SAR Deputy on Procedure from 20 January 2023.

[9] SAR, reg. No. №РД05-31 from 15 January 2024.

[10] Ibid.

[11] SAR, reg. No. №РД05-31 from 15 January 2024: 6,205 discontinued procedures out of all 9,156 Afghan applicants pending in 2023, of whom 5,906 applied in 2023 and 3,250 were pending from 2022.

[12] See, AIDA 2022 Update on Bulgaria, March 2023.

[13] See, Table Statistics, page 7 of this report: 194 Afghan decisions on the merits.

[14] Article 63a (3) LAR.

[15] Article 63a (7) LAR in conjunction with Article 61a (5) LAR.

[16] Article 63a (5) LAR.

[17] Article 61a (2)-(4) and (6) LAR.

[18] Article 63(3) LAR.

[19] Bulgarian Helsinki Committee, 2023 Annual Refugee Status Determination Monitoring Report, 31 January 2024, available at: https://bit.ly/3SX3ST7.

[20] Ibid., 2022: 24% of monitored cases served timely invitation for an eligibility interview.

[21] Ibid., 2022: 27% of monitored cases.

[22] SAR, reg. №РД05-40 from 16 January 2023.

[23] Articles 3 and 4 Law on Persons and Entities: 0-13 minors / 14-17 adolescents.

[24] Bulgarian Helsinki Committee, 2023 Annual Refugee Status Determination Monitoring Report, 31 January 2024, available at: https://bit.ly/3SX3ST7.

[25] Article 63a (6) LAR.

[26] Bulgarian Helsinki Committee, 2023 Annual Refugee Status Determination Monitoring Report, 31 January 2024, available at: https://bit.ly/3SX3ST7.

[27] Article 63a(6) LAR.

[28] Bulgarian Helsinki Committee, 2023 Annual Report on Human Rights, available in Bulgarian at: https://bit.ly/3SX3ST7.

[29] Bulgarian Helsinki Committee, 2023 Annual Refugee Status Determination Monitoring Report, 31 January 2024, available at: https://bit.ly/3SX3ST7.

[30] Ibid.

[31] Ibid.

[32] Article 63a(3) LAR.

[33] Bulgarian Helsinki Committee, 2023 Annual Report on Human Rights, available in Bulgarian at: https://bit.ly/3SX3ST7.

[34] 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.

[35] Article 92 LAR.

[36] Bulgarian Helsinki Committee, 2023 Annual Report on Human Rights, available in Bulgarian at: https://bit.ly/3SX3ST7.

[37] Article 85(4) LAR

[38] Article 85(3) LAR in conjunction with Article 84(1)-(2) LAR.

[39] Article 84(2)-(4) LAR in conjunction with Article 133 Administrative Procedure Code.

[40] 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).

[41] SAR, reg. No. №РД05-31 from 15 January 2024. 

[42] Article 85(5) LAR.

[43] SAR, reg. No. №РД05-31 from 15 January 2024.

[44] Article 22(8) Law on Legal Aid.

[45] §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.

[46] National Legal Aid Register, available in Bulgarian at: https://bit.ly/42Syzxe.

[47] 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.

[48] State Gazette No.102 from 23 December 2022.

[49] Articles 30d to 30o Law on Legal Aid, as amended St.G. №13 from 7 February 2017.

[50] National Legal Aid Bureau, tel. 0700 18 250.

[51] National Legal Aid Bureau, ‘Обява за конкурс за адвокати за работа по проект’, 29 January 2018, available in Bulgarian at: http://bit.ly/2DP376C.

[52] SAR, reg. №РД05-40 from 16 January 2023.

[53] 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.

[54] Article 25 LAR.

[55] Tri-Partite Note of Understanding on the Provision of Legal Assistance to Persons in Need of International Protection in Status Determination Procedures, signed on 3 May 2017 among the National Bureau for Legal Aid, UNHCR and Bulgarian Helsinki Committee.

[56] Bulgarian Helsinki Committee/UNICEF, Monthly Progress Report on child protection, 10 January 2024.