Lawyers as well as representatives of NGOs and UNHCR have access under the law and in practice to the detention centres during visiting hours but also ad hoc without prior permission when necessary or requested by asylum seekers. Some NGOs have signed official agreements with the Migration Directorate and do visit detention centres for monitoring and assistance once a week. In practice the Bulgarian Helsinki Committee is the only NGO which visits both detention centres on a weekly basis without exclusions. Other NGOs do random visits to Busmantsi detention centre, but none except BHC visits the centre in Lyubimets. Media and politicians also have access to detention centres, which is authorised upon written request.
NGOs’ and legal aid providers’ right to access to asylum seekers is explicitly regulated and expanded to also include border-crossing points and transit zones. However, the Bulgarian Helsinki Committee was the only NGO in 2020 and 2021 visiting border and detention centres regularly as well as the SAR closed facility as all the rest refrained from visitations due to COVID-19. In 2022, some of the NGOs re-established their visits to Busmantsi detention centre near Sofia, although still not on a regular basis.
 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.
 Bulgarian Helsinki Committee, Bulgarian Red Cross, Nadya Centre, Centre for Legal Aid-Voice in Bulgaria, Foundation for Access to Rights, etc.
 Article 23(3) LAR.
 Center for Legal Aid-Voice in Bulgaria, available at: https://bit.ly/3ntNoW9.