What prevents NGOs in Bulgaria from participating in ESF+ co-funded programs? (summary)

Context and Observation

The “Education” program 2021‑2027 launched its first grant procedure, “Promoting intercultural education through culture, science and sport,” with a budget over 31 million BGN. Despite that, the interest from potential applicants has been surprisingly low—particularly among NGOs and kindergartens. In the first and second deadlines, just 50 NGO and 23 kindergarten projects were submitted—well below expectations, and many were of compromised quality. Municipalities and schools showed moderate engagement, but NGOs and kindergartens were underrepresented. For NGOs, it’s a matter of systemic barriers created at the national level.

Key Barriers for NGOs

  1. The “de minimis” scheme

The application of the state aid “de minimis” regime to NGO projects is one of the most serious obstacles. It:

  • Imposes a €300,000 limit over three years, effectively restricting an organization to just one project.
  • Contradicts practices in other EU countries, where educational and social initiatives are exempt from such interpretation.
  • Is not mandated by the European Commission but results from decisions—or lack thereof—by the managing authorities and Ministry of Finance in Bulgaria.
  • Undermines NGOs’ motivation, placing them at a disadvantage position compared to municipalities and schools, which are not subject to these limits.
  1. No advance

Another major hurdle is the lack of advance payments: Previously, NGOs could get a 20% advance against a promissory note. However, in the present:

  • The Managing authorities do not accept promissory notes;
  • They require a bank guarantee or insurance, which is costly and often inaccessible for NGOs.
  • This puts organizations in a situation where they have to provide all the necessary resources in advance, work without an advance payment or not apply as lead beneficiaries but only as partners and rely on the goodwill of a partner municipality for partial funding.

The Paradox

Despite having both capacity and willingness, Bulgarian NGOs turn to other donor programs such as CERV, EEA grants, or the Swiss Contribution, because these:

  • Don’t apply de minimis limitation,
  • Provide significant advances (up to 80%),
  • Specifically promote civic participation and the involvement of NGOs.

Political Responsibility & Needed Change

The current situation is due to lack of political will. The changes that can improve the situation don’t need legal measures, but a will for action:

  • Revisit or remove the de minimis regime for non‑economic projects (e.g., in education, Roma integration), where no real market exists.
  • Reinstate advance payments via promissory note.
  • Invest in building the capacity of civic organizations, which are key partners in achieving ESF+ objectives.

Conclusion

Bulgarian NGOs have the potential and motivation to contribute effectively to EU-funded programs—especially in education, integration, and social inclusion. However, bureaucratic and administrative decisions made at the national level create artificial barriers. To fully realize the potential of ESF+, it is essential to remove these obstacles and restore trust in the process.

The whole analysis can be found here

The whole analysis in Eng – forthcoming

Photo by Nopparuj Lamaikul on Unsplash