On September 1, 2020, Transparency International – Bulgaria submitted a stand to the National Assembly on the proposals for changes in the Electoral Code.

As an organization that has been monitoring the election process since 2001 and has expertise in this area, we express our concern at the changes in the election legislation being discussed. We believe that a significant part of the proposed changes to the Electoral Code are ill-considered, contradictory, creating risks and in blatant contradiction with international standards for holding fair and democratic elections. Not only do they not meet the existing significant problems in the country’s electoral process, but they create conditions for further compromising the elections, for chaos in the actions of the institutions and for destroying the remnants of public confidence in the democratic process in the country.

We consider unacceptable proposals that:

  • The electoral system for the Grand National Assembly is being changed into a mechanically mixed one, and it is not even stated whether the majority election is held in one or two rounds, with all the negative consequences – reducing the representation of the constituent power in the country, creating insurmountable barriers to enter parliament in front of small parties, emerging parties and independent candidates.
  • The conditions for determining the number of mandates are ill-considered, discriminatory and impossible to implement: in multi-member districts, outdated population data from 2011 will be used, which will lead to a reduction in the number of seats in large cities, and in single-mandate districts with majority elections are mathematically unfeasible and do not provide an opportunity for Bulgarians living abroad to vote.

The changes in the electoral system and within the borders of the regions one year before the elections contradict the international standards of the Council of Europe, as well as Art. 10 of the Constitution of the Republic of Bulgaria, which provides for equal suffrage, including the right of voters living abroad to vote for candidates in single-member constituencies.

  • The ideas for video surveillance in the sections contradict Art. 10 of the Constitution, which guarantees the secrecy of the vote, and the international standards of the Council of Europe.
  • Extending the election day to 48 hours creates risks of misuse of ballot papers, organizational chaos and putting pressure on voters in the dark part of the day between the two days. A number of issues were not taken into account, including: who keeps the ballot papers at night; will the members of the section commissions be able to work for 48 hours and then to count the ballots correctly and to fill in the protocols without errors; whether changes in the composition of the commissions will be necessary on the second day due to fatigue and refusal of commission members; what will be the impact on the scale of the purchased and controlled vote, especially given the possibility of putting pressure on voters in the dark part of the day between the two election days.
  • The ideas for raising the threshold for validity of preferences to a level that makes voter preferences meaningless and reduces their role in the election of MPs.
  • Maintaining simultaneous voting with paper ballots and electronic machines, which makes the introduction of voting machines pointless and will make the work of the section committees more difficult than easier. Last but not least, the parallel use of the two technologies for voting and reporting the election results increases the risk of errors in filling in the protocols, as the commissions will continue to process manually two sets of information – electronic and paper and which must be combined.
  • Limiting the powers of the CEC to exercise control over the development of software and hardware of voting machines, due to the abolition of its power to give mandatory instructions to the performers of machine voting.
  • Eliminating the possibility for observers to inspect the machine voting system that has existed so far in the Electoral Code, thus in practice limiting the possibility of civilian control and building confidence in this component of the electoral process.
  • Simplification of the content of the protocols, which deletes the publicity of important data (eg number of unused and invalid ballots), which are important for the transparency of the election process and serve as a barrier against manipulation in reporting the election results.

We call on the MPs to be at the height of their position and to approach responsibly the adoption of changes in the law, which regulates the rules for the election of the basic democratic institutions of the country.

We believe that the only rational action is for the changes in the electoral legislation to be carried out in a calm atmosphere, based on expert discussion and a broad political consensus reached.

Bulgarian society, including political parties, needs not to create new problems, but to solve existing problems in the electoral process and to increase trust in political actors. In this regard, we emphasize the need for measures aimed at: 1. Creating an electoral register with accurate data on voters at this address. 2. Adequate rules for selection and quality training of the members of the section commissions. 3. Establishment of regional counting centers, equipped with optical scanners, which correctly report the election results and make the purchased and controlled voting meaningless. 4. Creating voting conditions for citizens quarantined for Covid-19. 5. Expanding the free access to the public media for the participants in the elections as a measure compensating for the anti-epidemic restrictions at mass pre-election events.

Please find the full text of the position of Transparency International – Bulgaria here.

This position is open to support from academics, election experts and civil society organizations.

Sofia, September 2, 2020








Assoc. Prof. Dr. Ognyan Minchev, lecturer at Sofia University “St. Kliment Ohridski ”

Dr. Vanya Kashukeeva-Nusheva, lecturer at Sofia University “St. Kliment Ohridski ”

Prof. Dr. Anna Krasteva, lecturer at NBU

Tsvetozar Tomov, sociologist, member of the CEC from 2014 to 2019.

Prof. Dr. Anthoniy Todorov, lecturer at NBU

Prof. Dr. Nikolay Naydenov, lecturer at Sofia University “St. Kliment Ohridski ”

Prof. Dr. Dimitar Vatsov, lecturer at NBU

Ph.D. Maria Pirgova, Sofia University “St. Kliment Ohridski ”

Assistant Professor Dr. Daniela Pastarmadzhieva, lecturer at the University of Plovdiv “Paisiy Hilendarski”

Assoc. Prof. Olga Simova, lecturer at NBU

Assoc. Prof. Milena Yakimova, Lecturer at Sofia University “St. Kliment Ohridski ”

Assoc. Prof. Dr. Daniel Smilov, lecturer at Sofia University “St. Cl. Ohridski ”

Assistant Professor Dr. Milen Lyubenov, lecturer at “St. Kliment Ohridski ”

Dr. Georgi Metodiev, political scientist

Assistant Professor Ruzha Smilova, lecturer at Sofia University “St. Cl. Ohridski ”

Assoc. Prof. Dr. Nataliya Kiselova, lecturer at Sofia University “St. Cl. Ohridski ”

Stoil Stoilov, election observer and consultant

Assistant Professor Dr. Aleksandar Aleksandrov, lecturer at UNWE

Assoc. Prof. Milena Stefanova, PhD, lecturer at Sofia University “St. Kliment Ohridski ”

Assistant Professor Denitsa Hinkova, lecturer at Sofia University “St. Kliment Ohridski ”

Assoc. Prof. Dr. Mihayl Ivanov, lecturer at NBU

Assoc. Prof. Dr. Lyubomir Stefanov, lecturer at NBU

Assoc. Prof. Dr. Albena Taneva, lecturer at “St. Kliment Ohridski ”

Assoc. Prof. Dr. Kostadin Nushev, lecturer at “St. Kliment Ohridski ”

Assoc. Prof. Dr. Emiliya Petrova, researcher at BAS

Daniel Stefanov, political scientist, election expert

Dr. Teodor Slavev, political scientist

Tatyana Tsanova

Antoaneta Lesenska

Aleksandar Politov, political scientist

Kameliya Dzhanabetska

Rosi Ivanova

Maria Petrova

Emiliya Burgazlieva

Victor Velchev

Mila Mancheva

Ani Ruseva

Nina Belcheva

Nadezhda Miteva

Stoyanka Lyuncheva

Anna Ganeva

Kostadin Kupenov

Ivan Petrov

Radost Karamihaleva

Kaloyan Velchev, political scientist

Kristina Stefanova

Dobromir Zhivkov, sociologist

Dr. Petya Georgieva, lecturer at NBU

Nikolay Tsolov