Skip Navigation

Bulgaria Action Plan Review 2022-2024

Bulgaria’s fourth action plan renewed national engagement in the open government process. It includes a promising commitment on COVID-19 anti-corruption efforts. Reformers inside and outside government will need to adapt to a fractious political period to successfully implement commitments.


Participating since: 2011

Action plan under review: 2022–2024

IRM product: Action Plan Review

Number of commitments: 14

Overview of commitments:

  • Commitments with an open government lens: 13 (93%)
  • Commitments with substantial potential for results: 1 (7%)
  • Promising commitments: 1

Policy areas Carried over from previous action plans:

  • Access to Information
  • Open Data
  • Direct Democracy

Emerging in this action plan:

  • Open Government Strategy
  • Internet and Artificial Intelligence Governance
  • Livestock Oversight
  • Metrology Data
  • Rights of Volunteers
  • Consumer Protection
  • Education Quality

Compliance with OGP minimum requirements for co-creation: No

Bulgaria’s fourth action plan includes 14 commitments focused on transparency and access to information, good governance and anti-corruption, open data, and civic participation. This 2022–2024 action plan renewed the country’s open government process after a hiatus since 2018. Most of its commitments engage new policy areas.

Bulgaria’s co-creation process saw improvements compared to previous cycles but did not meet the minimum requirements of the updated OGP Participation and Co-Creation Standards.[1] Bulgaria’s multi-stakeholder Transitional Council on Coordination on OGP did not meet for the last seven months of the co-creation process. To meet OGP requirements during the implementation period, Bulgaria needs to ensure that its Multi-Stakeholder Forum (MSF) convenes at least every six months.

Bulgaria briefly began a consultation process in 2018 and restarted its co-creation process in 2021. The government opened a six-week public call for commitment submissions during June to July 2021, eliciting 38 submissions, evenly split between government and civil society proposers. The government held a second public consultation in September to allow for voting on the proposals. It then formed a Transitional Council on Coordination on OGP, with working groups made up of all civil society and government stakeholders that had proposed commitments. The Council’s working groups met in November and December to draft the action plan, narrowing down to 18 commitments based on criteria set by the government.[2] Then, the government held a month-long public consultation on the final draft from December 2021 to January 2022. The Council did not meet again, but before the action plan was finalized in July 2022, planned financial resources for implementation were reduced, and four commitments were removed from the plan. One of these commitments was implemented before July, and the other three others were withdrawn by their drafters. Efforts to disseminate information on the finalized plan did not begin until May 2023. Through the three public consultations and the working group discussions, Bulgaria offered more opportunities for participation than it had in previous co-creation processes. Overall, civil society stakeholders reflected positively on the level of collaboration during the co-creation process and see the renewed OGP process as an opening to work with government.

One of the action plan’s commitments lays out a promising anti-corruption reform. Commitment 6 aims to establish a national COVID-19 task force, which would be Bulgaria’s first body to specifically focus on developing anti-corruption measures for emergencies like the pandemic. The commitment also plans to consolidate and publish data on expenses related to the pandemic.

The remaining commitments continue existing work plans or anticipate modest results. Several commitments offer incremental steps in impactful policy areas but do not envisage major changes to existing government practice—such as Commitment 2 on access to official documents, Commitments 8 and 9 on open government data, or Commitments 13 and 14 on consultations for consumer protection and education. Others could go further to outline necessary mechanisms for change. Commitments 1 and 3 plan reviews of internet governance and strategy documents’ relevance to open government principles but do not set clear guarantees on corresponding actions to be taken in response to these reviews. Commitment 12 would offer an online petition tool to state institutions but could improve its impact if these institutions were to formulate clear voluntary rules and procedures to guarantee proper consideration for petitions. Commitments 4, 5, 10, and 11 need to gain buy-in from implementing institutions to achieve results. In particular, plans for legislative changes face a context in which political uncertainty and lack of involvement by parliamentary parties in design of the commitments are risk factors to implementation. Additionally, Commitment 7 on metrology could be more impactful if its open government lens were strengthened.

Implementation of this action plan is expected to be impacted by the fallout from Bulgaria’s recent elections and economic situation. The 2023 national elections were the fifth in two years, but no party gained enough political support to form a governing coalition, leaving a caretaker government in place.[3] In addition to a fractious political period, Bulgaria also faces economic problems following the height of the COVID-19 pandemic and accentuated by the war in Ukraine. This may draw implementers’ attention away from commitments that do not directly address these issues. Although many of the commitments can be carried out by government experts and civil society stakeholders, the initiation, adoption by the legislature, and long-term impact of the reforms depend on engaging political support. In the wake of recent elections, government and civil society implementers will need to come together to implement the action plan.

Promising Commitments in Bulgaria’s 2022–2024 Action Plan

The following review looks at the commitment that the IRM identified as having the potential to realize the most promising results. Promising commitments address a policy area that is important to stakeholders or the national context. They must be verifiable, have a relevant open government lens, and have modest or substantial potential for results. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan.

Table 1. Promising commitments

Promising Commitments
6. COVID-19 Task Force: This commitment aims to establish Bulgaria’s first body specifically focused on developing anti-corruption measures for an emergency like the COVID-19 pandemic. It also plans to consolidate and publish data on expenses related to the pandemic.

[1] “2021 OGP Participation and Co-Creation Standards,” Open Government Partnership, last modified 24 November 24 2021,

[2] The following criteria was used to determine the commitments in Bulgaria’s action plan (see

  1. To cover the OGP values
  2. To be specific, with clear financial parameters and measurable results
  3. To be implemented in a two-year timeframe
  4. To include cooperation between a government institution and a civil society organization at the planning, implementation, or control of the commitment
  5. To have a transformative potential for the functioning of government

[3] Stoyan Nenov, “Bulgaria Set for Tough Coalition Talks After Fifth Inconclusive Election,” Reuters, 3 April 2023,


No comments yet

Leave a Reply

Your email address will not be published. Required fields are marked *

Open Government Partnership