Anti-COVID Measures Without a COVID Threat: Are They Necessary?

International and national health institutions are not concerned that COVID may return. Yet the Bulgarian Parliament, the Ministry of Education and Science, and the Ministry of Finance are introducing measures reminiscent of those used during the COVID pandemic – not to protect our health, but with the state budget in mind. What are the measures that are moving schools, kindergartens, Regional Departments of Education (RDEs), and all other educational institutions back to working online, at least until the end of 2026?

In fact, hardly anyone sees a serious threat of COVID returning. However, when adopting the State Budget of the Republic of Bulgaria Act for 2026, the National Assembly included Article 114, which requires budgetary organisations to move online for many of the activities that we believe they should be carrying out. The provisions state, for example:

“(2) The holding of working meetings, operational and other meetings, seminars and training sessions for employees of budgetary organisations outside the administrative buildings and premises placed under their management shall be suspended, except in the following cases:

  1. international events arising from bilateral or multilateral commitments, as well as events related to international organisations;
  2. events financed entirely by international programmes and projects under which the organisation is a beneficiary, insofar as the expenditure is explicitly provided for as eligible in the approved budget of the programme or project;
  3. training organised by public training institutions.

(3) Except in the cases referred to in paragraph 2, all inter-institutional and internal working meetings, coordination meetings and other meetings of employees shall be held exclusively in a digital environment (online), using the available institutional infrastructure.”

These provisions apply to all budgetary organisations, not only those in the education sector. Immediately after their adoption, however, they caused – and continue to cause – serious concern and differing interpretations among school and kindergarten principals, as well as among heads and experts of the Regional Departments of Education and other budgetary organisations in the education sector.

Center Amalipe issued a position statement immediately after the amendments were published, calling for clear and unambiguous instructions that would reassure the education system. Politicians and experts from the Ministry of Education and Science, however, remained silent, as in a poem by Veselin Andreev, and passed the ball to the Ministry of Finance, on the assumption that it would issue instructions on how to implement provisions that are absurd in themselves. But apparently they read V. Andreev there too…

What Do the Two Paragraphs Cited Above Mean for Educational Institutions and for the Start of the New School Year? The Most Conservative Interpretation of These Provisions Would Mean That:

  • teacher training can only take place on school premises: if you are a school principal and have the good intention of taking your teaching staff away from the school so that the training can be more effective, postpone it until after the New Year (and let us hope that the new budget will not contain similar restrictions). Many would probably exclaim with delight, “an end to spa training sessions!” While I do not deny that the bad practice of using professional development funds for tourism without any genuine training does exist, I do not believe it should be addressed through a blanket ban on training outside the school. The fact that many good managers (not only in education, but in other sectors as well) prefer to take their teams away from their day-to-day environment and organise training in a less conventional setting clearly indicates that this is a good practice. I have tried organising training in the office, but it rarely works well – colleagues find it difficult to resist the temptation to open their laptops and start working on their everyday tasks…
  • if you are a school principal and want to visit another school to see how it deals with everyday challenges, postpone the visit until 2027 or do it online. I know the latter would have little effect, but “don’t shoot the messenger”: paragraph 2 of Article 114 was adopted by the Members of Parliament and published in the State Gazette. In fact, under a less conservative interpretation, visits to another school would probably not be prohibited, especially since travel expenses fall under an entirely different budget item… But “less conservative” means “liberal”, and that word seems to have become something of a dirty word for many of today’s politicians.
  • school principals often need to visit the Regional Departments of Education (RDEs) – for better or worse (and vice versa). That is how the education system is structured. But will the expenses for such visits be recognised by potential auditors until the end of 2026 (hallowed be their name – they are important people and not to be trifled with!)?
  • expect the September meetings for teachers and school principals, organised by the RDEs before the beginning of the school year, to be held online! It sounds absurd, but this is what a conservative interpretation of paragraph 2 requires. Will the education system suffer as a result? Many would probably answer “no”, based on their own experience of attending such meetings. But once again, in doing so, we are turning negative exceptions into the rule.
  • the RDEs often surprise schools and kindergartens with on-site visits. Now they will have to do so online. The inspectors from the National Inspectorate of Education (NIE) will have to do the same. (At this point I can already hear thunderous applause.) But is this really the best possible outcome? If the answer is yes, another question would probably arise: “Why not reduce the number of staff in these institutions?”
  • if you like the National Programme “Innovation in Action” and have been approved under it, do not celebrate just yet: until the end of the year, the visits will have to take place online. The same applies to “Bulgaria – Educational Routes”: if your school has been approved under the National Programme, students and teachers will have to wait. If you have been approved for the same type of activity under the Education Programme, however, you may have a chance! Paradoxically, for the very same activities, the law allows both prohibition and permission. The Members of Parliament were probably not aware of this. The Ministry of Education and Science itself uses the English titles “Innovation in Action” and “Bulgaria – Educational Routes” for these national programmes.
  • but that is not all! A conservative interpretation of paragraph 3 would require even Pedagogical Council meetings to be held online. If your reaction is “This is absurdity taken to the extreme,” consider the wording: “all inter-institutional and internal working meetings, coordination meetings and other meetings of employees shall be held exclusively in a digital environment (online)”. A Pedagogical Council meeting is precisely this type of meeting and, if you follow the “letter of the law” strictly, you should hold it online. You could even try something for which we often criticise Generation Z: gather your fellow teachers together, send them a Teams link or a link to another platform, and have everyone join from their phones. Perhaps the students are right when they do exactly the same thing?

And while we are following this line of thought, perhaps we should move entirely to learning in an electronic environment? That way, we could save money on the free transport of children and students from settlements where there is no kindergarten and/or school, as well as on covering the travel expenses of commuting teachers. (In 2025, the state had allocated nearly EUR 50 million for the transport of children, students and pedagogical specialists.) What is more, educational institutions would save on operating costs (electricity, water, heating), which the state could also claw back through the already well-practised mechanism, and so on.

More seriously, however, these provisions create significant problems and challenges for schools and other educational institutions.

  1. First, although they apply to all budgetary organisations and all schools, their impact will be most severe and disadvantageous for small and remote schools. Schools in large cities have much easier local access to universities, training providers, institutions and professional forums. For schools in small and remote settlements, participation in almost any regional or national activity entails travel, a business trip and often an overnight stay. For some, this is the only way to step outside their immediate environment. In some schools, staff numbers are too small for it to be efficient to organise separate training, making it necessary to combine training with another school. Article 114 effectively requires one of the schools to participate online, placing its staff at a disadvantage.
  2. Second, there is a risk to contractual and financial commitments that have already been undertaken. Some schools had already planned and paid for staff training before the State Budget Act entered into force and are now faced with financial losses on amounts paid in advance. At present, school principals are cancelling already planned off-site training sessions scheduled for the beginning of September on a large scale, while hotels and tour operators are refusing to refund the amounts paid.
  3. Third, we should not underestimate the restrictions placed on teachers’ and school principals’ participation in professional forums and exchange visits. We all have an interest in encouraging the professional development of teachers, mediators and other professionals. Professional development does not take place solely through formal qualification courses. Conferences, seminars, academies, round tables and other professional forums are an important mechanism for exchanging knowledge, presenting innovations, building professional communities and discussing pressing issues in education. These restrictions will also weaken professional networks.
  4. Fourth, the exceptions to the application of paragraph 2, particularly the third exception, create unequal treatment among providers of professional development. A restrictive interpretation of the term “public training institution” – understood as referring only to the institute in Bankya and universities – places different licensed providers of professional development on an unequal footing and undermines competition in the labour market. Organisations with professional development programmes approved and registered in IROPK – the Information Register of Approved Programmes for the Continuing Professional Development of Pedagogical Specialists – may effectively be excluded from the possibility of providing face-to-face training outside a school or kindergarten, while other providers are granted that opportunity solely because of their legal status. This clearly disrupts the existing market for professional development services and competition among licensed providers. The latter will certainly lead to a deterioration in quality. The Ministry of Education and Science uses IROPK for the official register of approved programmes for the continuing professional development of pedagogical specialists.
  5. Fifth, and particularly importantly, the provisions of Article 114 are by no means self-evident with “unquestionable clarity” (Kant). Many of them suffer from a lack of sufficiently clear distinction as to which activities and which expenditures fall within the restrictions imposed by Article 114. Once again, this has the unmistakable feel of the COVID period, when the phrase “Everyone decides for themselves” reigned supreme. Setting the irony aside again, this leaves school principals and accountants to determine for themselves whether particular expenditures are eligible, while facing a substantial risk of subsequent financial sanctions. This encourages excessive caution, which may restrict activities directly related to the quality of education. It is entirely possible that different Regional Departments of Education and different schools will apply the provisions in different ways, resulting in chaos.

Still, Article 114(2) provides for three exceptions to its application, creating a limited degree of flexibility. These exceptions relate to the implementation of international projects and commitments. Thus, if your school has an approved Erasmus project or a project under another international programme, you can implement it without concern. (This was not the case at the beginning of June, when the Ministry of Finance and the Ministry of Education and Science required funds to be withdrawn from the accounts of state schools, regardless of whether those funds were intended for state-delegated activities or came from approved projects…)

Of particular importance is that this exception also allows for the implementation of projects under Programme “Education” 2021–2027, co-financed by the European Social Fund Plus (ESF+). The opposite would mean bringing the entire Programme to a halt and losing funding. Programme “Education” is already struggling with this risk, and if projects under it were suspended even for four months, the loss of funds would be virtually guaranteed. You can therefore continue to implement professional development activities, exchange visits and all other activities approved under Programme “Education” – both under your own projects and under the systemic projects of the Ministry of Education and Science. The official English name of the programme is Programme “Education” 2021–2027.

For example, school projects for the prevention of aggression and bullying are currently starting (260 schools have been approved to work on this highly pressing issue), and these also include professional development for pedagogical specialists outside the school environment. You can likewise proceed with activities related to desegregation, the introduction of intercultural education (where the main emphasis is on activities outside the school), the development of students’ talents, and many others, provided that they are funded under Programme “Education”.

The same applies to Procedure BG05SFPR001-1.002 “Access to Education for Every Child”, financed under Programme “Education” 2021–2027, co-financed by the European Social Fund Plus (ESF+), and implemented by the Regional Departments of Education. The procedure’s official English title is “Access to Education for Every Child”.

If, however, such activities have been approved under a national programme, it is quite possible that you will not be able to implement them. The state budget will make savings, while the quality of education will undoubtedly suffer.

Of course, there is another possible scenario: the Ministry of Education and Science could stand up for schools, and the National Assembly could swiftly amend Article 114(2) and (3). Whether this is merely a hypothetical possibility or whether politicians will actually defend activities aimed at improving the quality of school education remains to be seen over the coming weeks. Many, however, are rather sceptical…

 

Additional concerns are also raised by the repeal of Article 281 of the Pre-school and School Education Act. In fact, many people have not yet noticed this change. Until now, Article 281 guaranteed that state-budget funds for financing activities in the system of pre-school and school education would be planned annually at a level no lower than in the previous year, both in absolute terms and as a percentage of gross domestic product. The repeal of Article 281 does not automatically mean a reduction in education funding in 2026, but it removes an important legal safeguard for the sustainability of education financing. Going forward, there will no longer be a statutory guarantee preventing funding for pre-school and school education from decreasing either in absolute terms or as a share of GDP. This creates a risk that, in future budgets, education funding may formally increase in nominal terms while actually declining as a relative share of public expenditure and failing to keep pace with economic growth, inflation and the rising costs faced by educational institutions. In this way, the long-standing target of 5% of GDP for education – which politicians invariably promise to achieve before elections and then forget about afterwards – moves even further out of reach. The Ministry of Education and Science uses Pre-school and School Education Act as the official English title of the law.

The 2026 State Budget Act, including Article 114(2) and (3), as well as the repeal of Article 281 of the Pre-school and School Education Act, are now a fact. What, then, can still be done?

The most natural course of action would be for Parliament to amend these provisions. For example, the exceptions permitted under Article 114(2) could also include official business travel and approved national programmes in education, while point 3 could cover not only a “public training institution” but also all providers registered in IROPK, among others. In addition, it would be important for the Ministry of Education and Science and the Ministry of Finance to issue instructions providing clear guidance on what educational institutions may and may not do until the end of 2026.

It is important for this to happen as soon as possible – the school year is about to begin – and for it to be done with students and the quality of the education they receive in mind. And, of course, it is particularly important that the 2027 State Budget Act should not contain similar restrictions.

Center Amalipe works with 259 schools across the country, united in the “Mission Achiever: Inspired to Succeed” network. As early as 31 July, the day on which the 2026 State Budget Act was published, many of them were concerned about the adopted provisions – all the more so because some Regional Departments of Education immediately informed schools that they had to suspend professional development activities and travel outside the school.

On 12 August, we held a meeting at the Ministry of Education and Science on a wide range of issues concerning schools with a concentration of vulnerable groups, including the State Budget for 2026 and 2027. The network was represented by principals of four schools, as well as by the leadership of Center Amalipe. We met with Minister Prof. Valchev, Deputy Minister Pancheva, directors of directorates and experts from the Finance Directorate, the Inclusive Education Directorate, and the Project Management and Implementation Directorate.

The meeting did not leave us with the impression that the key to solving these problems lies with the Ministry of Education and Science. Rather, we realised that we need additional swimming lessons to stay afloat in the new environment – after all, the task of rescuing those who are drowning always falls first and foremost to the drowning themselves. And perhaps additional Bulgarian language lessons for students as well: the main response the principals received to their proposals was that it is important for students to have a good command of Bulgarian (something that has long been a fact in the participating schools).

The changes that the 2026 State Budget Act introduces to education legislation and to the school education system are also a cause for concern in the context of broader negative trends affecting schools. At the beginning of June, state schools were required temporarily to part with the funds held in their accounts and to operate on one-twelfth of the previous year’s budget. This was introduced as a temporary measure pending the adoption of the 2026 State Budget. The fact remains, however, that funds provided under approved projects were also withdrawn – temporarily, with schools being given the possibility to request, with justification, part of those funds when payments needed to be made. In practice, the delegated budgets of these schools were suspended for two months – a measure without precedent so far.

Article 114 of the 2026 State Budget Act imposes further restrictions on the autonomy of schools and kindergartens. (The restrictions also apply to the Regional Departments of Education, the National Inspectorate of Education and a number of other institutions, which is hardly reassuring…) The overall trend is worrying, as is the lack of response from the Ministry of Education and Science – how far might this go?

Personally, I hope that these are temporary restrictions and that they were not introduced with the intention of limiting the quality of education or the autonomy of school principals and pedagogical specialists. I hope that the Members of Parliament simply failed to take the negative consequences into account and will amend the provisions quickly, while ensuring that similar restrictions are not introduced through the 2027 State Budget Act. I also hope that the Ministry of Education and Science and all educational institutions will be much bolder in defending the work of schools and kindergartens: one of the few issues on which there is a broad public consensus is the importance of investing in education!

Author: Deyan Kolev

 

See also:

POSITION STATEMENT CONCERNING THE 2026 STATE BUDGET ACT