site.btaBulgaria Still Lacks Oversight of High-Risk AI Systems, Sanctions under AI Act Remain Unclear, Ministry Says

The Ministry of Electronic Governance, designated as the lead agency for the implementation of the Artificial Intelligence Act (AI Act) in Bulgaria, is in the preparatory stage of developing the national framework, with no final decisions yet on the coordination model, oversight of high-risk systems, and national implementation rules. This is stated in the Ministry's response to the BTA under the Access to Public Information Act concerning the implementation of the AI Act in Bulgaria.

The Council on European Affairs has assigned the Ministry of Economy and Energy the leading role in the implementation of the regulation, but so far, actions have been focused mainly on drafting decisions of the Council of Ministers, consulting with other administrations, and participating in European coordination formats.

Fundamental rights bodies determined but key regulatory functions not

As its main completed task, the Ministry of Electronic Governance reports the adoption of Council of Ministers Decision No. 398 of June 18, 2025, which designates seven competent bodies for the protection of fundamental rights, including the right to non-discrimination. These are the National Ombudsman, the Central Election Commission (CEC), the Commission for Protection against Discrimination (CPD), the Commission for Personal Data Protection (CPDP), the Commission for Consumer Protection (CCP), the State Agency for Child Protection (SACP), and the General Labor Inspectorate Executive Agency. According to the Ministry's assessment, Bulgaria has thus fulfilled one of the initial requirements of the regulation – to ensure the distribution of institutional competences in line with the impact of AI systems on rights related to non-discrimination, personal data, consumers, children's rights and labour rights.

At the same time, the Ministry's response to BTA's inquiry reveals that this step covers a limited segment of the application of the Artificial Intelligence Act and does not resolve issues related to the supervision of high-risk AI systems, the sanction regime, and the practical application of the regulation at the national level. 

Notifying authority and market supervision – "drafts prepared" but no decisions adopted

The Electronic Governance Ministry states that it has drafted a decision of the Council of Ministers to designate a national notifying authority under the AI Act, with this function to be assigned to the Bulgarian Accreditation Service Executive Agency. However, the draft has not yet been submitted to the Council of Ministers for consideration and adoption.

The situation is similar with regard to the supervision of the market for high-risk AI systems. The Ministry reports that it has held consultations and prepared a draft decision of the Council of Ministers, but the interdepartmental coordination procedure is still pending. Which authorities will carry out the actual supervision and how the powers will be distributed between them has not yet been determined.

Thus, one of the structural elements of the framework remains at the pending stage, it transpires from the Minitry's response to BTA.

Interdepartmental working group not yet operational 

The key interdepartmental working group, which is to develop the national regulatory framework for the implementation of the AI Act, is not yet operational. An order by the Minister of Electronic Governance for its formation was supposed to be issued by the end of 2025. 

The deadline for developing the national regulatory framework is March 2026. This means that during the first period of implementation of the regulation, Bulgaria will operate without a comprehensive national framework, including with regard to sanctions, coordination between institutions, and the specifics of the public sector.

No decision on national AI coordination centre

When asked whether there are plans to create a single national coordination centre for artificial intelligence, similar to the European AI Office at the EU level, the Ministry told BTA that no such decision has been made at this time. The coordination model is to be proposed by the future working group, which further delays clarity on the institutional architecture. 

The Ministry notes its participation in the European Artificial Intelligence Board and its subgroups, as well as approval for funding under the European Commission's Technical Support Instrument for 2024. At the same time, the Ministry reports a delay on the part of the European Commission in selecting a contractor for the project.

An additional project proposal for 2026 to build administrative capacity and an AI regulatory laboratory with a budget of EUR 213,520 has been assessed by the Ministry of Finance as a low priority according to a decision of the Council of Ministers of October 30, 2025. 

The Ministry of Electronic Governance has identified as key challenges the lack of sufficient expert capacity, the need for technical infrastructure, and the complex institutional interaction resulting from the horizontal nature of the Artificial Intelligence Act. An analysis of the specific needs of the administration and the individual competent authorities is to be carried out once their responsibilities have been clearly defined in the future regulatory framework. 

What is missing at the moment?

The response provided to BTA indicates that the implementation of the Artificial Intelligence Act in Bulgaria is mainly at the preparatory stage, with no completed national framework and no clearly defined responsibilities for the supervision of high-risk AI systems. At present, there are no decisions on the national coordination model, the specific market supervision authorities, the sanctioning regime, and the maintenance of a national register of AI systems. The interdepartmental working group responsible for developing these elements has been formally established, but the regulatory framework is not expected to be in place until 2026 at the earliest. This means that in the first period of implementation of the regulation, Bulgaria will rely mainly on temporary solutions and institutional coordination "under construction," with limited predictability for businesses, the administration, and control authorities. In this vacuum, the regulation will formally be in force, but its practical implementation will remain limited and difficult to predict.