Overview
Bulgaria’s approach to the regulation of artificial intelligence (Al) is characterized by a dual focus on European integration and the development of a competitive national digital ecosystem. As a member of the European Union, Bulgaria’s regulatory philosophy is deeply rooted in the concept of “Trustworthy AI” which emphasizes that Al systems must be lawful, ethical, and robust. The foundational document for this approach is the Concept for the development of Artificial Intelligence in Bulgaria until adopted by the Council of Ministers in December 2020. This document serves as the strategic North Star, positioning Al not merely as a technical tool but as a primary driver of socio-economic transformation and administrative modernization. The Bulgarian government views Al as essential for closing the digital gap with other EU member states, as measured by the Digital Economy and Society Index (DESI). The maturity of Bulgaria’s Al landscape has progressed from high-level theoretical frameworks to concrete operational roadmaps. Initially, the Bulgarian Academy of Sciences (BAS) played a pivotal role in drafting the national framework, which has since been adopted and expanded by various ministries. Today, the Ministry of Electronic Governance (MEG) serves as the central coordinating body for national Al policy. Bulgaria’s strategy is increasingly focused on practical implementation, evidenced by the 2025 Draft
National Strategy for Al and the creation of specialized research institutions like the Institute for Computer Science, Artificial Intelligence and Technology (INSAIT). This evolution reflects a shift from general digital transformation goals to specific, risk-based regulatory requirements that align with the EU’s evolving legal standards. Furthermore, the Bulgarian government has emphasized the importance of linguistic sovereignty, supporting the development of national large language models to ensure that Al services are accessible and culturally relevant to Bulgarian citizens.
Regulatory Approach
Bulgaria employs a hybrid regulatory approach that combines horizontal, cross-sectoral rules with emerging sectoral strategies. The horizontal layer is dominated by the EU Al Act (Regulation (EU) 2024/1689), which is directly applicable in Bulgaria. This regulation introduces a strict risk-based classification system, ranging from prohibited practices (such as social scoring) to high-risk systems (such as those used in critical infrastructure or law enforcement) and minimal-risk applications. This horizontal framework ensures a uniform level of protection for fundamental rights and safety across all industries. Complementing this, Bulgaria is developing sectoral policies, most notably in the field of education, where a draft strategy proposes specific risk tiers for pedagogical tools and administrative automation in schoots. The distinction between binding law and soft law is critical in the Bulgarian context. While the EU Al Act provides the binding legal requirements and sanctions, national documents like the Digital Transformation of Bulgaria 20-30 and the Programme Digital Bulgaria 2025 function as strategic coordination instruments. These soft law policies guide public investment, procurement priorities, and inter-ministerial cooperation. However, recent legislative initiatives, such as the draft Al Act presented by the Da, Bulgaria’ party in late 2025. suggest a move toward codi9ing national-level enforcement mechanisms and support structures that go beyond the baseline requirements of EU law, particularly regarding the use of public archives for training local Al models. This approach aims to balance the need for rigorous safety standards with the desire to foster a vibrant local Al ecosystem that can compete on a global scale.
Key Al Legislation
The legislative landscape in Bulgaria is a tapestry of European regulations and national strategic initiatives. At the core is Regulation (EU) 2024/1689 (EU Al Act), which serves as the primary binding legal framework. It establishes comprehensive risk categories, prohibited practices, and mandatory requirements for high-risk Al systems, ensuring that any Al deployed within Bulgaria meets stringent safety and ethical standards. Supporting this is the Concept for the Development of Artificial Intelligence in Bulgaria until 2030, a foundational national policy document adopted by the Council of Ministers in 2020. This concept defines the strategic pillars for Al research, nfrastructure, and ethics, providing a long-term vision for the country’s technological advancement. Another critical component is the Digital Transformation of Bulgaria for the period 2020—2030, a cross-sectoral strategy that integrates A} into the broader national digital transition and infrastructure development. This is complemented by the National Programme ‘Digital Bulgaria 2025’, which acts as a roadmap for modernizing public services and digital skills, including specific measures for cybersecurity and Al innovation. More recently, the Draft National Strategy for Artificial Intelligence (2025 Proposal) has been introduced as an updated operational roadmap designed to translate the 2020 Concept into concrete actions aligned with the EU Al Act. Finally, the Draft Strategy for Al in Bulgarian Education (2025) represents a specialized policy framework targeting the safe and ethical integration of Al in schools and universities, highlighting Bulgaria’s commitment to preparing its workforce for an Al-driven future.
Governance & Enforcement Bodies
The governance of Al in Bulgaria is a multi-layered architecture designed to ensure inter-ministerial coordination and expert oversight. The Ministry of Electronic Governance (MEG) is the lead executive body responsible for the coordination of national Al policy and the integration of Al into e-government services. MEG works in close collaboration with the Ministry of Innovation and Growth (MIG), which focuses on the economic aspects of Al, including support for SMEs and the mobilization of EU funding. To ensure scientific rigor the Bulgarian Academy of Sciences (BAS) and the Institute for Computer Science, Artificial Intelligence and Technology (INSAIT) provide technical expertise and contribute to the development of national language models and ethical guidelines. Enforcement is distributed among several competent authorities depending on the nature of the AI application. The Commission for Personal Data Protection (CPDP) remains the primary watchdog for AI systems that process personal data, ensuring compliance with both the GDPR and the Personal Data Protection Act. Under the EU Al Act, Bulgaria is required to designate a National AI Coordinator and a market surveillance authority. These roles are expected to be filled by specialized units within the Ministry of Electronic Governance or a dedicated new agency, which will have the power to inspect high-risk systems, order the withdrawal of noncompliant products, and coordinate with the European Al Office. This governance structure is designed to be agile, allowing the government to respond quickly to technological advancements while maintaining a high level of public trust.
Penalties & Enforcement
Penalties for non-compliance with Al regulations in Bulgaria are primarily governed by the tiered fine structure established in the EU Al Act. For the most severe violations, such as the use of prohibited Al practices (e.g., unauthorized biometric surveillance or socia[ scoring), entities can face administrative fines of up to 7% of their total worldwide annual turnover, whichever is higher. Violations of obligations related to high-risk Al systems or transparency requirements can result in fines of up to EUR or 3% of turnover. For the provision of misleading information to regulatory bodies, fines of up to EUR or 1% of turnover may be imposed. These penalties are designed to be effective, proportionate, and dissuasive, with specific considerations for SMEs and startups to ensure that the regulatory burden does not stifle innovation. Beyond financial penalties, Bulgarian enforcement bodies have the authority to impose corrective measures, including the suspension of Al system deployment or the mandatory withdrawal of a product from the market. The legal framework also ensures that individuals harmed by Al systems have access to judicial remedies. Appeals against the decisions of national regulators like the CPDP or the future AI market surveillance authority are handled through the Bulgarian administrative court system which provides a robust mechanism for legal recourse. Furthermore, the draft national legislation proposed in 2025 suggests the creation of whistleblower channels and specific remediation pathways for fundamental rights violations caused by automated decision-making systems in the public sector, ensuring that citizens are protected against algorithmic bias and errors.
Data Protection Framework
The data protection framework in Bulgaria is anchored by the General Data Protection Regulation (GDPR), which is supplemented by the national Personal Data Protection Act. This framework is central to the regulation of Al, as most Al systems rely on the processing of vast amounts of data. The Commission for Personal Data Protection (CPDP) is the independent supervisory authority responsible for monitoring compliance. In the context of Al, the CPDP emphasizes the necessity of Data Protection Impact Assessments (DPIAs) for high-risk processing activities. The Bulgarian framework also includes specific safeguards for the processing of sensitive data, such as biometric and health data, which are frequently utilized in Al applications. Bulgaria’s data strategy also focuses on the concept of “Open Data” and the creation of common data spaces. The “Digital Transformation 20-30 strategy outlines measures to unlock the value of public sector data while maintaining strict privacy standards. This includes the implementation of FAIR principles (Findable, Accessible, Interoperable, and Reusable) for data sharing. National policy encourages the use of anonymization and pseudonymization techniques to facilitate Al training without compromising individual privacy. Furthermore, the draft Al education strategy highlights the need for enhanced protections for children’s data, including local data residency requirements and strict limitations on profiling within educational environments. This comprehensive approach ensures that the development of Al in Bulgaria is built on a foundation of privacy and data sovereignty, fostering public confidence in new technologies.
Sector-Specific Rules
While horizontal rules provide a baseline, Bulgaria is increasingly developing sector-specific guidance for Al. In the healthcare sector, the National Al Concept identifies Al-driven diagnostics and personalized medicine as top priorities. Regulatory focus here is on ensuring the safety and clinical validity of Al medical devices, aligning with the EU Medical Device Regulation (MDR). In the agricultural sector, the government promotes “Intelligent Agriculture” through pilot programs that use Al for crop monitoring and resource optimization. These initiatives are often supported by the Ministry of Agriculture and Food and are subject to specific environmental and data sharing standards. The most developed sectoral framework is currently in education. The Draft Strategy for the Development and Integration of Al in Bulgarian Education (2025) proposes a comprehensive set of rules for schools and universities. This includes a classification of educational Al uses by risk, mandatory human-in-the loop requirements for high-stakes decisions (such as grading or admissions), and a national registry of approved Al tools. Similarly, in the public administration sector, the Ministry of Electronic Governance has issued guidelines for the use of Al in administrative services, focusing on transparency, explainability, and the prevention of bias in automated decision-making processes affecting citizens’ rights. These sector-specific rules are designed to address the unique challenges and opportunities of Al in different domains, ensuring that the technology is deployed in a way that is both effective and socially responsible.
International Alignment
Bulgaria’s Al regulatory framework is designed to be fully interoperable with international standards, particularly those of the European Union and the OECD. As an EU Member State, Bulgaria participates in the European Artificial Intelligence Board and coordinates its national investments through the EU Coordinated Plan on Artificial Intelligence. This alignment ensures that Bulgarian Al providers can access the Digital Single Market without facing fragmented regulatory barriers. The country also adheres to the OECD Council Recommendation on Artificial Intelligence, which promotes human-centric, trustworthy Al and international cooperation on research and development. Beyond the EU, Bulgaria seeks to position itself as a regional hub for Al excellence in Southeast
Europe. This is evidenced by its participation in cross-border initiatives and European Digital Innovation Hubs (EDIHs). The establishment of INSAIT in Sofia, in partnership with leading Swiss technical universities (ETH Zurich and EPEL), demonstrates Bulgaria’s commitment to high-level international scientific alignment. National strategies explicitly reference the need for Bulgaria to contribute to global standardization efforts, ensuring that Bulgarian-developed Al models, such as the BgGPT national language model, meet international benchmarks for robustness, cybersecurity, and ethical alignment. This international outlook is crucial for Bulgaria’s ambition to become a leader in the global AI economy, attracting investment and talent from around the world.
Future Developments
The next few years will see a significant expansion of Bulgaria’s Al regulatory infrastructure as the country fully operationalizes the EU Al Act. A key upcoming milestone is the formal designation of the National Al Coordinator and the establishment of a National Al Council. This body will be tasked with overseeing the implementation of the 2025 National Al Strategy and coordinating between various sectoral ministries. Legislative activity is expected to peak in 2026 as the government finalizes the horizontal Al Act proposed by parliamentary groups, which aims to provide additional national safeguards and incentives for Al research using public archives. In the sectoral domain, the finaf adoption and rollout of the Al in Education Strategy will be a major focus. This will involve the creation of a national competence framework for teachers and the launch of regional pilot programs for Al-assisted learning. Furthermore, the Ministry of Electronic Governance is expected to release updated procurement guidelines for Al in the public sector, emphasizing sovereign AI solutions and the use of open-source models. As Al technology evolves, Bulgaria also anticipates the need for new rules regarding generative Al and deep fakes, particularly in the context of protecting democratic processes and combating disinformation, as outlined in the Digital Transformation 2030 strategy. These future developments reflect Bulgaria’s proactive stance in shaping the regulatory landscape to support both innovation and the protection of fundamental values.
Key Regulations- see the original
Enforcement Bodies – see the original
Skills You Will Gain
