Author
The law provides a definition of vulnerability. According to the provision “applicant in need of special procedural guarantees” means an applicant from a vulnerable group who needs special guarantees to be able to benefit from the rights and comply with the obligations provided for in the law.[1] Applicants who are 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 are considered as individuals belonging to a vulnerable group.[2]
There are no specific measures either in law or in practice to address the needs of these vulnerable categories, except for some additional practical arrangements in place to ensure the provision of medication or nutrition necessary for certain serious chronic illnesses, e.g. diabetes, epilepsy, etc. The law only requires that vulnerability has to be taken into account when deciding on accommodation, but this is applied discretionally, and no guidelines on the application of such a criterion are provided by the SAR. In 2018, the SAR adopted new internal rules of procedure whereby social experts provide assistance to its staff during the initial medical examination so as to enable the early identification of vulnerable applicants and their special needs.[3] If an applicant is identified as vulnerable, the new rules foresee that the vulnerability will be added to the registration form, including a detailed explanation and a follow-up assessment to be described in an appendix. Additionally, an early identification questionnaire was established for applicants who experienced traumatising experiences in order to determine their special needs and to facilitate the referral to adequate psychological or medical care.[4]
Monitoring in 2025
In 2025, both vulnerability assessments and identification – as well as all follow-ups on identified cases -, remained substandard, to the point this continued to represent the most significant violation of existing obligation in the context of the asylum procedure in the course of already several years.[5] SAR social workers conducted a total of 273 vulnerability assessments and identified 115 applicants[6] with vulnerabilities or special needs. SAR acknowledged[7] to have dealt with 1,127 applicants with vulnerabilities as defined by the law in 2025. These figures obtained through monitoring indicated that just 24% of all asylum applicants with vulnerabilities received proper assessments of their needs. Moreover, SAR affirms[8] that the social experts who carry out the vulnerability assessment do file their assessments and support plans in the case management registry for the case worker to be able to review and collect them into the respective individual file, while copies of these documents remain with the social experts for subsequent work with the vulnerable person, according to the planned activities. In 2025, the monitoring of these processes established[9] that in 88% of the cases, an initial assessment form was present in the file of asylum seekers who were falling within the vulnerability definition under national law.[10] Thus, vulnerability assessments and support plans were still missing in 12% of the monitored cases of asylum seekers, who otherwise should have been assessed and supported as persons with specific needs or vulnerabilities. The subsequent support plan however, was present in just 20% of the cases, and in 100% of them no information was available whether any of the support measures, included in the plan were actually implemented or not. Therefore, in 2025 need assessments as well as planning and provision of support measures with respect to applicants with identified vulnerabilities were still carried out unsystematically.
The situation of an applicant belonging to a vulnerable group has to be taken into account by the authorities when deciding on accommodation.[11] In practice, except the two safe-zones for unaccompanied children, other separate facilities for vulnerable applicants, families, single women or traumatised asylum seekers do not exist in the reception centres.
Families, single women and traumatised asylum seekers are not accommodated in separated facilities, but in separate floors in the reception centres’ facilities, mainly due to the overall lack of SAR reception capacity.[12] There is no formal policy to prevent mixed-sex accommodation, however in practice the single women and the families are accommodated in separate floors in Sofia centres and separate buildings in Harmanli reception centre. These floors are equipped with separate toilets and bathrooms. No specific measures are put in place in reception centres to prevent gender-based violence, except separate accommodation of single women, families and safe-zone for the unaccompanied children. All SAR social workers are female; however, the interviewers and the interpreters often are not from the same sex as the asylum seeker, and the information about the right to have an interpreter or interviewer from the same sex is not provided in all cases. In 2025, just 17% of the cases the applicant was informed about the possibility to request an interviewer of the same gender, and only in 13% about the possibility to request an interpreter of the same gender.[13]
Reception of unaccompanied children
In July 2017, the State Agency for Child Protection and national stakeholders developed SOPs to safeguard unaccompanied migrant and refugee children identified to be present in Bulgaria. Although the SOPs for unaccompanied children were endorsed by the National Child Protection Council,[14] the final formal endorsement by the government has not been formally given up to the moment, which makes the developed SOPs for unaccompanied children inapplicable in practice. In 2025, despite the regular government which governed for the majority of the year from 16 January 2025 to 19 February 2026 (see, Overview of the main changes) in practice no legal or institutional arrangements were put forward in the field of asylum and international protection. As of 31 December 2025, no progress was achieved in this regard (see section on Identification).
The two safe zones for unaccompanied children at the Sofia reception centre continued to be maintained under an IOM project, funded by AMIF until the end of 2025. In May 2024, a third safe zone dedicated to hosting children with a capacity for 98 places was open[15] in the biggest reception centre in Harmanli, following a collaboration with UNICEF and IOM, funded by the Swiss State Secretariat for Migration (SEM). Overall, the conditions in the safe zones were better compared to all other SAR accommodation premises. The abovementioned serious security problems existing in reception centres and their surroundings in 2025 however affected the overall safety of unaccompanied children as well, although improvements in this respect are expected following the security being handed over to the police in November-December 2025 (see Conditions in reception facilities). In 2025, the number of unaccompanied children who sought protection in Bulgaria decreased by 48%.[16] Despite this drop, the capacity of the three safe zones (a total of 386 places[17]) would still be insufficient to shelter all newcomers were it not for the extremely high (92%) absconding rate for this group of asylum seekers.
The LAR provides that unaccompanied children are accommodated in families of relatives, foster families, child shelters of residential type, specialised orphanages or other facilities with special conditions for unaccompanied children.[18] In practice, none of these opportunities was used or applied until 2022, when the SAR began to actively search 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.[19] Starting from 2022, SAR has finally begun investing systematic efforts to accommodate unaccompanied children to specialized child care facilities, and in 2025 continued to gradually increase[20] the number of the children who were able to benefit by this type of accommodation that is well suited to address children’s needs. As a result of this positive practice, in 2025 41 unaccompanied children were accommodated in specialized childcare centres. Out of this number, 11 were asylum seeking children and 30 children granted international protection. Altogether eleven 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, some challenges emerge in practice: first of all, the staff of the childcare centre lacks specialized training to work with unaccompanied children seeking or granted protection; secondly, the provision of interpretation services is not always ensured, at least for the initial period of accommodation and adjustment. Altogether ten 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.
Reception of victims of violence
Back in 2008, the SAR and UNHCR adopted standard operating procedures (SOPs) with respect to treatment of victims of Sexual and Gender-based Violence (SGBV).[21] In 2014, both agencies agreed that the SOPs need to be updated,[22] as they have never been applied in practice, but also to include other categories applicants with special needs. At the end of 2021, SAR endorsed the revisions, but the NGOs monitoring could not confirm any implementation of the SGBV SOPs in practice until the end of 2025.[23]
[1] Additional Provision 1(16) LAR.
[2] Additional Provision 1(17) LAR.
[3] Article 29 SAR Internal Rules of Procedure; SAR, Internal Rules of Procedure for assessing and granting international protection, adopted on 17 December 2018.
[4] Early Identification and Needs Assessment form (ФИОН), Individual Support and Referral Plan form (ФИПП) and Social Consultation form (ФСК).
[5] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7; see, also AIDA 2024 and 2023 Country Updates.
[6] SAR, reg. №ПО-02-115 from 22 February 2026.
[7] Ibid.
[8] Ibid.
[9] Bulgarian Helsinki Committee, 2025 Annual RSD Monitoring Report, 31 January 2026, available at: https://bit.ly/3Jkd3t0.
[10] §1(17) Additional Provisions, LAR.
[11] Article 29(4) LAR.
[12] See Overview of the main changes since the previous report update.
[13] Bulgarian Helsinki Committee, 2025 Annual RSD Monitoring Report, 31 January 2026, available at: https://bit.ly/3Jkd3t0
[14] State Agency for Child Protection, ‘Тридесет и шестото редовно заседание на Националния съвет за закрила на детето се проведе в зала „Гранитна“ на Министерски съвет’, 11 July 2017, available in Bulgarian at: http://bit.ly/2FzwLxk.
[15] SAR, Откриване на сигурна зона за непридружени деца-бежанци в РПЦ-Харманли, 16 May 2024, available in Bulgarian here.
[16] 2024: 2,601 unaccompanied children; 2023: 3,843 unaccompanied children / 2022: 3,348 unaccompanied children / 2021: 3,172 unaccompanied children.
[17] SAR reg. №АД-07-7 from 14 January 2025.
[18] Article 29(10) LAR.
[19] 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.
[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] Standard Operating Procedures on sexual and gender-based violence, Exh. No 630, 27 February 2008.
[22] UNHCR, SGBV Task Force, established on 15 February 2014.
[23] Bulgarian Helsinki Committee, 2025 Annual Refugee Status Determination Monitoring Report, 31 January 2026, available at: https://bit.ly/3SX3ST7.