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Bulgaria End-of-Term Report 2016-2018

Bulgaria’s third action plan was mostly oriented towards e-government and depended on the technical implementation of projects, which was often slowed down by changes in government and long public procurement procedures. At the end of the action plan cycle, over half of the commitments saw only limited completion or were not started, and most did not lead to any changes in government practice.

Table 1: At a Glance
  Mid-term End of term
Number of Commitments 35
Level of Completion
Completed 7 9
Substantial 6 6
Limited 14 13
Not Started 8 7
Number of Commitments with…
Clear Relevance to OGP Values 32 32
Transformative Potential Impact 2 2
Substantial or Complete Implementation 13 15
All Three (✪) 0 0
Did It Open government?
Major 0
Outstanding 0
Moving Forward
Number of Commitments Carried Over to Next Action Plan N/A

The Open Government Partnership (OGP) is a voluntary international initiative that aims to secure commitments from governments to their citizenry to promote transparency, empower citizens, fight corruption, and harness new technologies to strengthen governance. The Independent Reporting Mechanism (IRM) carries out a review of the activities of each OGP-participating country. This report summarizes the results of the period July 2016 to June 2018 and includes some relevant developments up to January 2019.

The Council of Ministers leads the OGP process in Bulgaria. During the reporting period, the political leadership and day-to-day responsibilities for Bulgaria’s OGP commitments changed twice. Former Deputy Prime Minister Rumiana Bachvarova became Head of the Political Cabinet of the Prime Minister after a short interim government period (late January–early May 2017), early elections (in late March), and formation of a new government. The two consecutive teams from the administration of the Council of Ministers coordinating the OGP process had little legal power to enforce policy changes within other government agencies. This was because neither the political lead nor the dedicated team had the ability to compel other agencies to enter into or implement commitments.

Civil society organizations (CSOs) participated in the action plan development, but the government did not organize a regular forum to consult stakeholders on implementation. By the time of writing of this report in early 2019, the government had not published a self-assessment report.

Less than half of the commitments were completely or substantially implemented. One of the frequent reasons for this was disruptions to the public procurement procedures related to implementation of commitments, often related to the reorganizations in government. The action plan lacked sufficient financing, and most commitments depended on EU programs and funds for implementation.

In September 2018, the OGP team from the Administration of the Council of Ministers organized a comprehensive and meaningful discussion on the future action plan commitments. All stakeholders had the chance to propose and discuss in-person with the OGP team and potential implementing agencies. At the time of writing this report, Bulgaria has not developed its fourth action plan.

Consultation with Civil Society during Implementation

Countries participating in OGP follow a process for consultation during development and implementation of their action plan.

The government did not organize a forum to consult stakeholders on implementation of the action plan. In a few cases, the lead implementing experts in different agencies consulted stakeholders on the implementation progress of individual commitments. This was generally initiated either by the government experts as informal individual meetings or as formal working groups on specific projects or draft legislation. In addition, in some cases stakeholders also took the initiative to meet with government officials and experts on OGP commitments and related projects as part of their advocacy campaigns. However, this was not the general practice for most of the action plan commitments.

Table 2: Consultation during Implementation

Regular Multistakeholder Forum Midterm End of Term
1. Did a forum exist? No No
2. Did it meet regularly? No No

Table 3: Level of Public Influence during Implementation

The IRM has adapted the International Association for Public Participation (IAP2) “Spectrum of Participation” to apply to OGP.[1] This spectrum shows the potential level of public influence on the contents of the action plan. In the spirit of OGP, most countries should aspire for “collaborative.”

Level of Public Influence during Implementation of Action Plan Midterm End of Term
Empower The government handed decision-making power to members of the public.    
Collaborate There was iterative dialogue AND the public helped set the agenda.    
Involve The government gave feedback on how public inputs were considered.    
Consult The public could give inputs.    
Inform The government provided the public with information on the action plan.    
No Consultation No consultation

About the Assessment

The indicators and method used in the IRM research can be found in the IRM Procedures Manual.[2] One measure, the “starred commitment” (✪), deserves further explanation due to its particular interest to readers and usefulness for encouraging a race to the top among OGP-participating countries. Starred commitments are considered exemplary OGP commitments. To receive a star, a commitment must meet several criteria:

  • Starred commitments will have “medium” or “high” specificity. A commitment must lay out clearly defined activities and steps to make a judgment about its potential impact.
  • The commitment’s language should make clear its relevance to opening government. Specifically, it must relate to at least one of the OGP values of Access to Information, Civic Participation, or Public Accountability.
  • The commitment would have a “transformative” potential impact if completely implemented.[3]
  • The government must make significant progress on this commitment during the action plan implementation period, receiving an assessment of “substantial” or “complete” implementation.

Starred commitments can lose their starred status if their completion falls short of substantial or full completion at the end of the action plan implementation period.

At the end of term, Bulgaria’s action plan did not contain any starred commitments.

Finally, the tables in this section present an excerpt of the wealth of data the IRM collects during its reporting process. For the full dataset for Bulgaria, see the OGP Explorer at

About “Did It Open Government?”

To capture changes in government practice, the IRM introduced a new variable “Did It Open Government?” in end-of-term reports. This variable attempts to move beyond measuring outputs and deliverables to looking at how the government practice has changed as a result of the commitment’s implementation.

As written, some OGP commitments are vague and/or not clearly relevant to OGP values but achieve significant policy reforms. In other cases, commitments as written appear relevant and ambitious, but fail to open government as implemented.  The “Did It Open Government?” variable attempts to captures these subtleties.

The “Did It Open Government?” variable assesses changes in government practice using the following spectrum:

  • Worsened: Government openness worsens as a result of the commitment.
  • Did not change: No changes in government practice.
  • Marginal: Some change, but minor in terms of its effect on level of openness.
  • Major: A step forward for government openness in the relevant policy area but remains limited in scope or scale.
  • Outstanding: A reform that has transformed “business as usual” in the relevant policy area by opening government.

To assess this variable, researchers establish the status quo at the outset of the action plan. They then assess outcomes as implemented for changes in government openness.

Readers should keep in mind limitations. IRM end-of-term reports are prepared only a few months after the implementation cycle is completed. The variable focuses on outcomes that can be observed in government openness practices at the end of the two-year implementation period. The report and the variable do not intend to assess impact because of the complex methodological implications and the time frame of the report.

Commitment Implementation

General Overview of Commitments

As part of OGP, countries are required to make commitments in a two-year action plan. The tables below summarize the completion level at the end of term and progress on the “Did It Open Government?” metric. For commitments that were complete at the midterm, the report will provide a summary of the progress report findings but focus on analysis of the ‘Did It Open Government?’ variable. For further details on these commitments, please see the Bulgaria IRM progress report 2016–2017.

Bulgaria’s third action plan contained 37 commitments, loosely grouped into six themes: e-government; access to information; open cities; civic participation; public integrity; and open data. One commitment—4a.1.5. Forums on Corporate Social Responsibility Strategy—was included only in the Bulgarian version of the action plan and not in the English version. The IRM researcher re-clustered three commitments into a single commitment: 6.1.1 (Improve Open Data Portal), 6.1.3 (Open data promotional events), and 6.1.4 (Open Data Usage Manual). These three were designed to be implemented together through the same EU-funded project. For the rest of the action plan, the IRM researcher maintained the government’s original order of the commitments.

[1] More information on the IAP2 Spectrum,

[2] IRM Procedures Manual,

[3] The International Experts Panel changed this criterion in 2015. For more information, visit


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