The adoption of a regulatory framework to govern transparency and integrity in interactions between public institutions and interest representatives is, in principle, a positive and necessary step for Bulgarian society. Despite the stated good intentions and the crystal-clear need for such a bill in the context of the National Anti-Corruption Strategy and our country’s commitments, the proposed bill is imprecise, lacks depth, and unequivocally raises more questions than it answers. The text creates a risk of distorting the original intent and poses significant obstacles to legitimate public dialogue and the expert assistance that the civil society and business sectors can provide to institutions.
The presence of numerous highly critical and negative opinions from various sectors of public and economic life is a clear indication of the draft’s insufficiently developed nature and the urgent need for its fundamental refinement.
In this regard, the American Chamber of Commerce in Bulgaria largely shares the critical concerns and arguments expressed in the statements of a number of other stakeholders, including the Business Integrity Club of the Transparency Without Borders Association, the British-Bulgarian Chamber of Commerce, the National Organization of Customs Agents, and nationally represented associations – members of the National Food Council under the Minister of Agriculture and Food, among others.
The main weaknesses of the bill, which necessitate its refinement between the first and second readings, can be summarized under the following key themes, without this fully exhausting the substantive and technical shortcomings of the bill:
- Unclear scope and intended recipients
- Lack of distinction between professional lobbying and civic advocacy
- Excessive and disproportionate administrative burden
- Lack of symmetry in responsibilities and fragmented oversight