Position of the Amalipe Center on the National Strategy for Roma Inclusion and Participation




We welcome the fact that the Bulgarian government is proposing a draft National Strategy of the Republic of Bulgaria for Roma Inclusion and Participation 2021 – 2030, which will replace the current National Strategy of the Republic of Bulgaria for Roma Integration. In view of the indisputable fact that the process of Roma integration has not yet fully achieved the planned results, the approval and implementation of a new National Strategy is extremely necessary. We also welcome the fact that the proposed document is not based on populist and nationalist ideas, but makes an attempt – albeit unconvincing, to transpose to the Bulgarian context the main ideas of the European Roma Strategic Framework.

At the same time, we should emphasize that the proposed draft National Strategy steps back to many of the options recommended by the European Commission through the Communication from the Commission to the European Parliament and the Council of 7 October 2020 “Equality Union: EU Strategic Framework for Roma Equality, inclusion and participation ”, as well as its annexes“ Guidelines for planning and implementation of the national Roma strategic frameworks ”and“ Portfolio of indicators, as well as some of the most important assets of the previous National strategy for Roma integration. Among the main weaknesses of the proposed draft National Strategy we can point out

  • It is envisaged that the National Strategy will be adopted only by a decision of the Council of Ministers, and not by a decision of the National Assembly, as in the previous strategy. This is a serious departure from one of the important merits of the previous National Strategy, which was adopted by a decision of the National Assembly on March 1, 2012.
  • The national strategy is not accompanied by an Action Plan outlining the specific activities, responsibilities and funding. Without an action plan, the strategic document is just a set of intentions. The previous National Strategy was developed together with an action plan, which contained many shortcomings, but still set certain responsibilities. The current strategy states that such a plan will exist, but it is important that its approval, at least for the first period, takes place now together with the approval of the strategy itself.
  • The specific problems of the Roma woman, who is often subject to double and even multiple discrimination, are not adequately reflected. The new European framework and the Guidelines for the development of national strategies require in-depth attention to the diversity of the Roma community, including the problems of the Roma woman.
    The requirements for promoting Roma participation have not been transposed. The planning guidelines contain special requirements for the promotion of Roma participation, which are not included in any form in the draft National Strategy
  • The requirements for overcoming anti-Roma discrimination have not been adequately transposed. Priority 5 Rule of law and non-discrimination reflects a small part of the recommendations of the European Framework and the Planning Guidelines on tackling anti-Roma discrimination. Most of the other priorities of the National Strategy also do not contain anything in this direction
  • The level of abstraction and lack of specificity of the proposed National Strategy is too high. For each priority, a strategic goal and general goals are formulated, but there are no specific goals, priority measures.
  • Part Mechanisms for implementation of the integration policy repeats the main provisions of the current strategy and does not provide a new institutional and consultative framework, although the current ones have shown their ineffectiveness. The set funding mechanisms also replicate the current texts. They are too general and their added value is negligible.
  • The Monitoring of Implementation section does not transpose in any form the recommendations of the European Framework and the Annex Portfolio of Indicators. The envisaged monitoring is in practice weaker than the current one.
  • Although most of the common priorities by priority can be defined as consensus, there are no important common objectives on all priorities.

To overcome these weaknesses we offer:

  1. Preparation and inclusion in the National Strategy of the priority Equality of the Roma woman and of the priority Promotion of the Roma participation. They should contain strategic goals, general goals, specific goals and measures in accordance with the challenges of the Roma community in Bulgaria. At the same time, they must transpose what is proposed in the Planning Guidelines.
  2. Complement specific goals and priority measures to each of the priorities.
  3. Preparation of an Action Plan with activities, responsible institutions and funding. The plan should be prepared in parallel with the National Strategy, at least for its first part.
  4. Fundamental changes are needed in the part Mechanisms for implementation of the integration policy. They must be related to:
    4.1. Reform of the National Council for Cooperation on Ethnic and Integration Issues at the Council of Ministers,
    4.2. Creation of administrative capacity for implementation of the integration policies in each of the line ministries through the establishment of an administrative unit at the level of a minimum department
    4.3. formulation of mechanisms for real partnership with civil society organizations, including the level of delegation of activities
  5. Preparation and inclusion of an Annex describing sample operations under the operational programs, the Rural Development Program, the EEA Financial Mechanism, the Swiss contribution, as well as the state budget for the implementation of the National Strategy;
  6. Qualitative change in the part Monitoring of the implementation, including determination of additional indicators to the existing system and additional mechanisms, taking into account the possibilities for receiving information from citizens, local groups and non-governmental organizations;
  7. Complementing the Education priority with the general objectives:7.1. Overcoming the existing segregation and prevention of the secondary segregation in education. 7.2. Inclusion in digital education, including introduction of  digital intercultural education.
  8. Priority changes Rule of law and anti-discrimination aimed at full transposition of proposals from the Planning GuidelinesIn
  9. View of the necessary numerous additions and changes, as well as the need for a real consultative process, we insist on extending the term for public discussion by at least two months;
  10. We propose that after its adoption by the Council of Ministers, the National Strategy of the Republic of Bulgaria for Roma Inclusion and Inclusion be voted on by a Decision of the National Assembly. This is the way to involve municipalities and institutions such as the Commission for Protection against Discrimination, the National Ombudsman and other institutions outside the executive branch.