How Bulgaria’s New Lobbying Act Reconfigures the Legal Framework for NGO Advocacy

Private Clients Insights, Charities and NGOs

The new Bulgarian Transparency and Integrity in Governance Act (the Act) introduces a specialised regime for  representation  of interests before public authorities that clearly extends to NGOs, including charities, engaged in structured advocacy. For many organisations, policy work will now sit within an explicit public‑law framework, with registration and reporting obligations layered on top of existing regulation under the Non‑Profit Legal Entities Act and related regimes. 

Material and personal scope: NGOs as representatives of interests

The Act defines ‘representation of interests’ as any oral or written communication with specified public officials (Parliament, President, Council of Ministers, mayors, municipal councils and other bodies empowered to adopt normative or general administrative acts), carried out in favour of public, group or private interests, with the aim of influencing the creation, amendment or content of certain acts. It is expressly neutral as to the legal form of the actor and the type of interest, and it includes groups of persons expressing a group or public interest, so NGOs, coalitions and informal platforms all fall within the general scope.

NGOs are not among the categories expressly excluded from being representatives of interests (for example, public officials acting ex officio, public bodies, individuals acting purely in a personal capacity, or certain exempted actors such as trade unions, employers’ organisations, media and religious organisations). For a charity or foundation, recurring meetings with ministers or MPs on draft legislation, structured submissions of positions and model clauses, and coordinated campaigns targeting specific decision‑makers will therefore typically be representation of interests within the meaning of the Act.

Registration triggers: when must an NGO enter the Transparency Register?

Crucially, the Act does not require every representative of interests to register. Instead, s 13(1) limits mandatory entry in the to-be-created Transparency Register to those of them who carry out representation of interests:

• regularly by occupation; or  
• in a commercial manner for third parties; or  
• against remuneration.

This structure is particularly relevant for NGOs. Public‑benefit organisations that systematically advocate on legislation and policy as a core activity, especially where such work is project‑funded or otherwise remunerated, will need to assess carefully whether they meet one or more of these criteria. At the same time, the list of exemptions from registration – which covers, for example, trade unions, employers’ organisations, political parties, media and religious communities – does  not  include NGOs as such, which reinforces that civil‑society organisations are intended to be within the regulated population where the criteria are met. 

Legal obligations for registered NGO interest representatives

Where an NGO qualifies under s 13(1), it becomes subject to a set of explicit public‑law duties linked to the Transparency Register. These include: 

• Initial registration and ongoing data duties – The organisation must enter core identification data (name, legal form, UIC, representatives, contact details, sphere of activity and number of staff engaged in representation of interests). For each individual project, it must then separately register: the project in question, the authority addressed, the specific individual advocate, any principal on whose behalf it acts, whether the work is remunerated, and the period during which representation of interests is carried out.
• Updating obligations – Changes in registered circumstances must be recorded within short statutory deadlines (e.g. seven days for changes in data, one month from the occurrence of registration criteria).
• Possibility of deregistration  – An NGO may request deletion from the register once it has ceased the activity and the relevant conditions have not been present for at least six months.

These obligations apply cumulatively with existing requirements under the Non‑Profit Legal Entities Act, tax and funding‑transparency rules and, where relevant, AML/CFT legislation, and they directly affect how NGOs structure and document their advocacy portfolios.

Principles, “legislative footprint” and rights of registered NGOs

The Transparency and Integrity in Governance Act also codifies principles of openness, transparency, accountability, good faith and integrity in the interaction between public authorities and representatives of interests. It introduces a “legislative footprint” concept by linking: (i) public calendars of meetings with representatives of interests; (ii) the public consultations portal; and (iii) the National Assembly’s legislative documentation, thereby enabling the traceability of external interventions throughout the lifecycle of a normative act. 

Registered representatives of interests gain certain procedural advantages, such as rights to receive information on draft normative acts in their declared spheres of interest, to be invited to working groups or forums, and to request access to discussions on issues falling within those interests, subject to sectoral rules. For NGOs, this provides a legal basis for framing registration and compliance not only as a constraint but also as a route to institutionalised participation and enhanced transparency credentials.

Governance and risk management for NGOs under the Act

From a governance perspective, NGOs should treat the Act as a distinct compliance and risk‑management domain. First, they should determine whether representation of interests is carried out regularly by occupation or against remuneration, including where advocacy activities are embedded in donor‑funded projects. Where the answer is yes, proactive registration and systematic alignment of internal rules with the statutory framework will usually be the prudent course. 

Second, NGOs should adopt or revise written policies specifying who may act as representative of interests, how positions are authorised and documented, and how potential conflicts and links to other interested parties are declared (as required, for example, for participants in working groups and hearings). Simple internal registers of meetings, written submissions and mandates will be essential to support accurate project‑level entries in the Transparency Register and to respond to any supervisory checks. For larger entities or coalitions, allocating clear internal responsibility for lobbying compliance – at officer or committee level – will help integrate these new obligations into the broader governance architecture.

Conclusion

The Transparency and Integrity in Governance Act does not prohibit NGO advocacy, but it converts a large part of it into a legally framed, reportable activity that may trigger registration where it is regular, professional or remunerated.  For NGOs and charities whose missions depend on sustained engagement with lawmakers and public authorities, the key legal task will be to decide whether they fall within the registration triggers and, if so, to embed lobbying compliance into their governance, documentation and risk‑management systems, while using the new framework to reinforce their narrative of transparency, integrity and legitimate participation in public life.

At NBLO, we regularly advise NGOs on issues directly affecting their work. If you require assistance regarding the new Act or any NGO-related matters, please feel free to contact us.