Transparency International Bulgaria submitted its statement to the National Assembly of the Republic of Bulgaria and the Committee on Constitutional and Legal Affairs regarding the draft law on transparency and integrity in governance (Ref. No. 51-654-01-31), which was introduced on February 27, 2026, by a group of members of parliament.
In our statement, we once again affirm our support for the fundamental goal of increasing transparency and accountability in governance, but we emphasize that, in its current form, the draft does not establish a comprehensive regulatory framework for “open government,” but rather amounts to the creation of a registry of individuals engaged in so-called “interest representation.”
There is a lack of alignment between the stated objectives and the content of the bill. The three main pillars of the modern concept of open government—transparency, accountability, and participation—are not systematically addressed. The bill also fails to take into account the existing regulatory framework (including the Administrative Procedure Code and the Law on Normative Acts), which creates a risk of conflicts and legal uncertainty.
We also express our serious concerns about the conflation of lobbying with civic advocacy, without a clear distinction between the protection of private economic interests and participation in the protection of the public interest. The lack of a classification of actors and of a proportionate regulatory framework puts fundamental rights and the principle of the rule of law at risk.
The proposed institutional architecture, in which registration, rule-making, and oversight functions are concentrated in a single body, as well as the provision for ethical rules without minimum legal standards and a clear legal nature, is problematic. In this regard, we would also like to recall the practice of the Constitutional Court of the Republic of Bulgaria regarding the requirement that the law contain complete and clear primary legislation, rather than delegating essential elements to subordinate legislation.
Transparency International Bulgaria calls on members of parliament not to pass the bill on first reading and to proceed with the development of a comprehensive, conceptually sound regulatory framework for transparency and open governance, drafted by experts in consultation with stakeholders.
Read the full text of the statement we submitted to the Committee on Constitutional and Legal Affairs of the National Assembly (in Bulgarian).