Bulgaria’s Struggle with High-Risk AI Oversight
The Ministry of Electronic Governance in Bulgaria is tasked with implementing the Artificial Intelligence Act (AI Act). Currently, the ministry is in the preparatory stage of developing a national framework, yet critical decisions regarding coordination models, oversight of high-risk systems, and national implementation rules remain unresolved.
Current Status of Implementation
According to the Ministry’s response to an inquiry under the Access to Public Information Act, the Council on European Affairs has designated the Ministry of Economy and Energy to lead the regulation’s implementation. However, the ministry’s actions are largely focused on drafting decisions for the Council of Ministers and engaging in consultations with other administrations.
Protection of Fundamental Rights
One of the ministry’s significant completed tasks is the adoption of Council of Ministers Decision No. 398, which designates seven competent bodies responsible for protecting fundamental rights, including the right to non-discrimination. These bodies include:
- 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)
- The General Labor Inspectorate Executive Agency
This step fulfills one of the initial requirements of the regulation, ensuring institutional competences align with the impact of AI systems on rights related to non-discrimination, personal data, consumer rights, children’s rights, and labor rights. However, it does not address the oversight of high-risk AI systems or clarify the sanction regime.
Pending Decisions on Market Supervision
The Ministry has drafted a decision to establish a national notifying authority under the AI Act, which would be assigned to the Bulgarian Accreditation Service Executive Agency. Yet, this draft has not been presented to the Council of Ministers for approval. Similarly, the supervision of high-risk AI systems remains uncertain, as the ministry is still awaiting interdepartmental coordination.
Operational Challenges
Furthermore, the key interdepartmental working group tasked with developing the national regulatory framework is not yet operational. An order to form this group was expected by the end of 2025. The deadline for completing the national regulatory framework is set for March 2026, raising concerns about operating without a comprehensive framework in the interim.
Coordination and Future Plans
When asked about the establishment of a single national coordination center for artificial intelligence, the Ministry reported that no decision has been made, leaving the coordination model to be proposed by the future working group. This uncertainty further complicates the institutional architecture necessary for effective AI governance.
The Ministry’s involvement in the European Artificial Intelligence Board and its subgroups highlights its commitment to align with EU standards. However, a project proposal for 2026 aimed at building administrative capacity and an AI regulatory laboratory has been deemed a low priority by the Ministry of Finance.
Conclusion
In summary, the implementation of the Artificial Intelligence Act in Bulgaria is still at a preparatory stage, lacking a defined national framework and clarity on the supervision of high-risk AI systems. With no established coordination model, sanctioning regime, or market supervision authorities, Bulgaria faces the challenge of navigating the early implementation phase with temporary solutions, resulting in limited predictability for businesses and regulatory bodies.
