Bulgaria

Public consultation quality

The public participation until now is according to the minimum requirements of the Regulation. It started too late and included three rounds of comments. CSOs submitted comments, but these were not well reflected, including proposals from February for the design of the public consultations process.

Cross-ministerial coordination & participation of social ministries

A number of government institutions are involved in the preparation and development of the first version of the Social Climate Plan. The Ministry of the Environment and Water has a leading role. The Ministry of Labour and Social Policy is also involved, in view of the social focus of the measures, as is the Ministry of Regional Development and Public Works, which is involved in building renovation policies. The Ministry of Energy is also involved in planning energy efficiency and decarbonisation measures.

Stakeholder consultation scope

Stakeholders were only consulted on selected measures after they had already been designed. However, the NGO sector was proactive, sending ideas for measures even before receiving any information.

Certain CSOs received unofficially the draft investment measures and replied, but their comments were largely not taken into account at the official draft published two-three weeks later. Some small tweaks were made, but without significantly changing the measures.

Consultation timing

Public information on the development of the draft SCP has been scarce, leading to CSOs scrambling for information from different sources. CSOs were not getting timely information, and when they did get information, their response had to be timely and quick in order to meet the unrealistic deadlines of the institutions they were getting it from. 

In one instance this meant the urgent need to mobilise experts from 13 partner organisations and engage them over the weekend to meet the requirements at extremely short notice. CSOs only succeeded thanks to the long-standing trust and good cooperation with these organisations, as well as the high sense of responsibility shown by their experts.

Stakeholder representation

The document states that the process was based on the principles of inclusiveness, transparency and early participation. Participants included:

• local and regional authorities,
• NGOS,
• social partners,
• youth, women's and environmental organisations,
• people with disabilities,
• groups at risk of social exclusion

However, CSOs cannot confirm this information because if indeed these consultations occurred, this happened behind closed doors.

Stakeholder feedback integration

Some of the recommendations that were sent by CSOs are reflected in the current Draft. How these recommendations will be integrated and subsequently implemented remains to be seen. 

Arrangement to set up a standing consultation/monitoring body for the Plan

As described in the current Draft, the Plan suggests the formation of a permanent monitoring and feedback structure, but does not explicitly mention a ‘monitoring committee’ with a broad membership of social and environmental organizations. 

Involvement of Local Authorities

The Draft document explicitly states that a consultative process was carried out in which representatives of the municipalities participated, including through the National Association of Municipalities in the Republic of Bulgaria. They have been engaged both in formal meetings and discussions and through additional forms of participation, including forums and focus groups. 

On the other hand, CSOs cannot give a definite opinion on the process as they were not direct observers.

Energy poverty definition

The definition of energy poverty in the Plan is consistent with the statutory definition under the Energy Act (EA), and includes two criteria - income below the official poverty line after deducting energy costs, and use of certain fuels (coal, gas, liquid fuels) that will be affected by the ETS2. This meets the requirements of the Energy Efficiency Directive (EED) which requires the definition to cover economic and energy aspects of vulnerability. 

Effective targeting of vulnerable households

The plan includes specific mechanisms to help the most vulnerable households through technical assistance, municipal mediation and specialised teams. The plan identifies the most vulnerable households through clear, EU-consistent criteria, combining economic, energy and social vulnerability. This allows targeting support where the need is greatest, including through mobile teams and technical assistance. Municipalities will play a central role in identifying households, informing them about support options, and in the process of submitting documents and implementing projects. On-site advice and assistance will also be provided in completing applications, technical reviews, technology selection and community outreach.

In addition, there will be the possibility of setting up a OSS within the municipalities where citizens can receive advice and assistance at all stages of the process. 

While the overall strategic approach is commendable, a key gap remains: how will Municipalities identify vulnerable households. 

Measures addressed to households that are not immediatedly impacted by ETS2

Direct financial support is also envisaged for households that heat with wood, (although by definition they are not covered by ETS2) as they are also economically vulnerable and affected by market fluctuations.

It is also noted that a significant proportion of the population uses electricity for heating, and some of the measures foresee the replacement of inefficient appliances with energy efficient ones in order to reduce electricity bills and improve access to more sustainable solutions. This demonstrates that the plan has a wider scope and is not limited to those directly affected by the extended scope of emissions trading.

Pass-on benefit guarantee (100% of benefits reaching vulnerable households)

The Bulgarian Social Climate Plan also allows for funding through entities that are not vulnerable households or micro-enterprises (e.g., municipalities or service providers), but contains a requirement that these entities use the funds for the benefit of the vulnerable. 

In particular, the plan specifies that when support from the Fund is provided through public or private entities, they must undertake measures or investments that will ultimately benefit vulnerable households, vulnerable micro-enterprises and transport users. In the majority of the cases of pass-on benefists the funded entity will be a municipality. Strict control mechanisms should be in place in order to ensure that the most vulnerable receive support.

Housing sector reforms & investments

The measures under the Social Climate Plan in Bulgaria deliberately address access barriers for home renovations for low-income households by:

• 100% financing to energy poor households;
• Opportunity for accompanying repairs;
• Active support from municipal administrations (by local OSS)

This represents a major advance compared to previous programmes which often excluded the most vulnerable due to complex requirements and financial constraints.

Moreover, the plan provides for the creation of local expert capacity in municipalities to assist vulnerable citizens through:

• Submitting applications;
• Collection of documents;
• Site visits (walkabouts);
• Signing contracts.

This “mobile” and service-oriented on-the-ground approach overcomes information and procedural barriers that often deter low-income groups from participating in programmes. This has been one of the major asks of civil society.

Heating & cooling sector reforms & investments

The plan contains quality investments in heating and cooling, both at the individual level (heat pumps) and through collectively owned energy communities (PV). This marks an important advance over previous policies that rarely included vulnerable groups in cooperative energy solutions. 

Municipalities will play a central role in identifying buildings and households to participate in these schemes. This has the potential to create tensions in society at the local level due to a lack of transparency about who is selected for funding and why. There is a lack of the long-promised national energy poverty observatory to accurately and clearly identify beneficiaries, particularly in the case of multi-family residential buildings.

Measures and investments for energy communities

The plan features a dedicated measure, specific budget allocation, and structural support for the development of energy communities. It priorities both physical infrastructure (PV systems) and the inclusion of vulnerable groups, with clear potential for scaling beyond the pilot phase. 

Initial implementation will take place in two municipalities – Gabrovo and Burgas – and, starting in 2027, further funding will be available to expand to other locations where capacity and interest have been developed in recent years, provided the pilots demonstrate successful outcomes. The plan provides for technical assistance through the municipalities and a one-stop shop for administrative support.

Public transport & active mobility

No specific measure, investment or intervention related to building or supporting cycling infrastructure or active mobility such as cycle lanes, pedestrian routes, etc. is mentioned in the Plan despite civil society recommendations.

All mobility interventions focus mainly on access to public transport through:

• delivery of electric vehicles,
• trains,
• on-demand transport for elderly and vulnerable groups,
• support for micro-enterprises with low-mileage fleets,
• building charging infrastructure.

At the same time, the identification of vulnerable users and the transport deprived at this stage is too general for the purposes of the Plan and should be completed and detailed before the document comes into force on 01.01.2026 in order to be able to set real and measurable indicators of the selected investments.

Vulnerable micro-enterprise support

The plan includes qualitative reforms and targeted funding to support vulnerable micro-enterprises in the service sector. It provides grants for fleet replacement with electric/hybrid vehicles and the construction of charging infrastructure, with simplified procedures and selection based on economic vulnerability. 

The measure has a clearly defined target group - around 4300 micro-enterprises, of which between 780 and 1032 would realistically be supported under different scenarios. It is structured as a social protection and economic buffer, with a predictable mechanism based on evidence from the NSI and with a simplified administrative procedure through a “de minimis” scheme.

Problematic investments

There are some investments in the plan that allow for hybrid or low emission technologies that do not guarantee the complete elimination of fossil fuels. These can be considered temporary or transitional solutions, but in terms of long-term climate goals - they risk locking in unsustainable technologies.

Direct payments (nearly 100-150 mln euros) are planned to be paid to vulnerable users for their gasoline and diesel consumption during the whole period (until 2032). 

Cost-supportive measure design

There are temporary bill subsidies in the plan that protect vulnerable households from the carbon price until they get first structural improvements (efficiency) and then heating decarbonisation. 

The Plan also states that the principle of additionally will be respected - the new support will not replace, but complement existing benefits such as social tariffs and heating allowances.

However, it is very important that these temporary measures remain only temporary and do not become a long-term crutch for the household with no other way to help address energy and/or transport poverty.

Strategic alignment & linkages with other major national strategies & plans

The plan is structurally linked to existing national and European policies (ex. Just Transition Fund, National Recovery and Resilience Plan, European Regional Development Fund), demonstrating efforts to build on existing programmes and address specific weaknesses identified in the implementation of the national energy efficiency programmes for multifamily buildings and similar measures, particularly in terms of reaching energy poor households. 

However, there is a high probability that various measures and investments included in the Plan will never materialise. 

Mobilisation of broader ETS2 revenues

The Plan not only assumes, but actively foresees the use of future ETS2 revenues as a tool to complement the already planned interventions under the Social Fund.