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. 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.
There are no specific measures either in law or in practice to address the specific needs of these vulnerable categories except some additional arrangements in practice to ensure medication or nutrition necessary for certain serious chronic illnesses, e.g. diabetes, epilepsy, etc. The law only requires that vulnerability be taken into account when deciding on accommodation, but this is applied discretionary and without any written criteria.
An applicant’s belonging to a vulnerable group has to be taken into account by the authorities when deciding on accommodation. In practice, separate facilities for families, single women, unaccompanied children or traumatised asylum seekers do not exist in the reception centres.
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, the final formal endorsement by the government has not been formally given yet, which makes the developed SOPs for unaccompanied children inapplicable in practice. As of 31 December 2019 no progress has been achieved in this regard. (see section on Identification).
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. In practice, none of these opportunities are used or applied.
A safe zone for unaccompanied children in the refugee reception centre (RRC) of Sofia at the Voenna Rampa shelter is available since mid-2019,  where children are provided round-the-clock care and support tailored to their needs. However, only unaccompanied children originating from Afghanistan are accommodated in this centre, while unaccompanied children from other nationalities remain in mixed dormitories in other reception centers. This being said, despite the availability of places in the operational safe-zone, some Afghan children were also accommodated in other reception centres such as the RRC of Harmanli in 2019. A second safe-zone at the RRC Sofia, in the Ovcha Kupel shelter, opened on 20 January 2020 and is supposed to accommodate children originating from Arab speaking countries. Both safe-zones are operated by the International Organisation for Migration (IOM) Bulgaria and funded by AMIF. However, the government has not yet proposed new measures which would foresee the sustainability and expansion of the safe-zones upon the termination of the AMIF project.
Moreover, at the end of 2017, the EEA Grants secured considerable funding for the State Agency for Child Protection as well as for the Bulgarian Red Cross to jointly establish and run an Interim Care Center for unaccompanied children, proposed and endorsed by UNICEF and UNHCR. As of 31 December 2019, however, this centre was still not established.
Many unaccompanied asylum-seeking children in Bulgaria continue to be accommodated in mixed dormitories and in many cases in rooms with unrelated adults. These children often complain to be deprived of sleep on account of noise, gambling or alcohol consumption during the night by the adults accommodated in their rooms, or by being forced to run errands for them such as shopping, laundering or cleaning.
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). In 2014 both agencies agreed that the SOPs need to be updated, as they have never been applied in practice, but also to include other categories applicants with special needs. The SOPs revision process is still ongoing, however.
 Additional Provision 1(16) LAR.
 Additional Provision 1(17) LAR.
 Article 29(4) LAR.
 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.
 Article 29(9) LAR.
 Standard Operating Procedures on sexual and gender-based violence, Exh. No 630, 27 February 2008.
 UNHCR, SGBV Task Force, established on 15 February 2014.