Advocate Dr. Viktor Kostov's speech,
presented at a discussion held on February 14, 2020, 11:00,
at the 44th National Assembly, East Hall


Ladies and Gentlemen, Honorable Members of Parliament,

Freedom for All (FFA) is a human rights and publishing group, active since 2004. We work to protect basic human rights and the traditional family.

Here is a brief summary of our joint opinion submitted to the National Assembly in November 2019 on the issue with ROD. Our position is completely critical of the letter and spirit of the Social Services Act (SSA), which has been delayed until 1 July 2020.

We draw attention to the fact that there is still no satisfactory legally reasoned response to our extensive criticisms of the Social Services Law.

The new SSA is tyrannical and anti-democratic legislation of philosophy and concept. The Social Services Act is contrary to the European Convention on Human Rights (ECHR) and the Constitution (CRB).

As a matter of principle, the SSA (ZSU -- abbreviation in Bulgarian) is a total law which, instead of the “social assistance” referred to in the CRB, introduces a “social service” that is universal and comprehensive, and in many cases obligatory, that is, provided against the will of the beneficiary. ZSU threatens the right to privacy and family life, the right and obligation of parents to raise their children, the right to a fair trial, etc. fundamental rights - ECHR - Art. 8, Art. 6 - and of the Constitution - Art. 32, para. 1, and Art. 47;

ZSU puts in opposition to each other parents and children, introducing and further perverting the idea of ​​children's rights as opposed to those of their parents. In this way, millennial legal principles and the natural bond between parents and children are being violated and the traditional family is being deconstructed.

The law privatizes and makes a commercial profit of the idea of ​​human mutual assistance and virtue.

It enables foreign traders and legal entities to act on the territory of the country, including without a license, and in violation of national sovereignty. The law virtually deprives Bulgarian citizens living in Bulgarian territory of the protection of the Bulgarian Constitution and the European Convention.

Under ZSU complete and centralized databases with personal information of parents and their children are formed, with full access to those by local and foreign actors and organizations.

ZSU extends the powers of social services and providers of social services excessively and in violation of a number of laws, turning them into coercive bodies without adequate judicial control and supervision, and without adequate protection of the rights of parents and children.

In general, the ideological charge behind the SSA and related child protection legislation contains elements of social engineering and does not respect the millennial traditions of the Bulgarian people, religious customs and practices, as well as the fundamental essence of the natural family unit.

The shortcomings of the SSA are so significant and numerous that no attempts and draft amendments can correct the radical ideological and anti-democratic nature of the law.

The Social Services Act should be repealed in its entirety.



A view of one of the parental protests in 2019 against the anti-family policies and laws


2019 was marked by the emergence of a wide family rights movement in Bulgaria. Parents, distraught at the total neglect of their rights, and at the clear putting in opposition to each other their parental privileges and duties, on one side, and the "right of the child," on the other, pushed back against the government policies and new laws.

A brief chronology of the events in 2019: 

  • a homeschooling organization and our own Freedom for All publish statements and petitions critiquing the new National Strategy for the Child 2019-2030 and its anti-family ideology, Jan 2019;
  • a petition is added, it reaches over 30,000 signatures, Feb 2019;
  • A Facebook group is started by two concerned mothers, Feb 2019;
  • the Strategy is withdrawn by the government but applied in the newly adopted Social Services Act, March 2019;
  • the FB group grows exponentially to over 100,000 members, May 2019;
  • Street rallies and protests are held in various cities in the nation, May-June 2019;
  • First attempt at addressing the issues with members of Bulgarian parliament, July-Aug 2019;
  • A first international conference on child kidnapping by Social Services is held in Sofia, with guests from the UK, Austria, and most notably from Norway, whose notorious Barenevernet (Child Protection Services) is being sued in the European Court of Human Rights for parental rights and human rights violations on more than 30 cases, Sept. 29, 2019;
  • Generally, central media continuously ignore the serious arguments against the new SSA and its anti-family and totalitarian essence, depicting the family-rights groups as "extremist," "right-wing," and "religious sects," May-Oct 2019.
  • a non-profit organization is formed, Parents United for Children (ROD), to express the views of the movement and give it public legitimacy, the Facebook group grows to over 210,000 members, Oct. 2019;
  • Protests, meetings with representatives of parties in parliament, sympathetic to the cause continue. FFA and ROD submit a brief legal analysis (see below) insisting that SSA should be entirely revoked as totalitarian and anti-family and anti- basic human rights, to the National Assembly. One of the political parties in parliament introduces a law with a single provision: the revocation of SSA, Nov. 2019;
  • Dec. 2019 - parent' group's protests and critical publications continue media debates and conversations with politicians. The National Assembly postpones the enactment of SSA, due to become active on Jan. 1, 2020, for 6 months.

It remains to be seen if the government will honor parental rights and concern or will yield to the pressure from the EU, Norway and big donors who insist on changing societal mores and values in small Eastern European nations, including Bulgaria.


Here you can download the full critical analysis of the Social Services Act of 2020, 8 pp., in English.


Protest of evangelical Christians in late December 2018 against the restrictive proposal for changes in the nation's religious law. The sign reads: The Law on Religions Does Not Guarantee National Security (Photo courtesy of the website:


Law for the Amendment and Supplements on Law on Religions, State Gazette, nos. 108 of 29.12.2018, enacted as of 01.01.2019 - A Step Backwards from Freedom of Religion and Conscience


The Law for the Amendments to the Religious Denominations Act (LASLR, adopted in 2002, last amended and supplemented as of 29.12.2018) was published in the State Gazette and entered into law as of January 1, 2019. A detailed analysis and comments are forthcoming. The law was hastily voted in right before the end of the year by the Bulgarian parliament, after months of opposition, letters of concern by foreign officials, organizations and individuals, and street protests and prayer vigils by protestant-evangelical churches.

Our conclusion, quite briefly, is that the vast majority of the most restrictive, utterly totalitarian texts were not accepted in the final version.* This is an extremely important achievement for free civil society and the human rights activists involved, including the evangelical churches and all the religious denominations. Problematic texts, however, do exist in the newly adopted amendments. 

Reasons for concern are the provisions that require religious denominations to maintain a registry of their clergymen and provide this to the public authorities for review. This requirement is reminiscent of the Communist Denominations Act, which required the maintenance of such registers to control and exert pressure on ministers and preachers related to their convictions and sermons.

It is also problematic that the state mandates as to how priests and clergy should legitimize themselves in order to represent the respective religious denominations they serve. The "representative power" is a part of the internal organization of religions and cannot be governed by the State under the European Convention on Human Rights and the Guidelines for the Adoption of Religious Legislation adopted by the Venice Commission and the Office for Democracy and Human Rights at the OSCE.

There is another purely communist-Nazi style approach to control and discriminate against foreign clergymen.  This is the requirement to notify the state if a non-Bulgarian clergy member participates in a worship service. Foreign clergymen can participate in the worship service "after the Directorate on Religions has been notified. When "participation" means to be "present during worship," then only the mere presence of an individual is sufficient to apply this administrative burdensome requirement. Registered religious denominations will first have to notify the state and then admit the foreign clergyman to the worship service. If there is no such notification, in order to comply with this law, the foreign clergyman must listen to the worship service outside of the building where it is held. Such provisions establish unlawful discrimination on multiple grounds and are adopted in violation of the Protection against Discrimination Act (religion and national origin).

The administrative burden for religious denominations has increased giving religious denominations only seven days after their registration to file the decision for registration by the court with the Directorate on Religions. In an age of "e-government", the seeming inability for communication between the Sofia City Court and the Council of Ministers to provide this information as a part of the internal information exchange between government bodies is only an excuse for further harassment of the religious communities that register as religious denominations.

The strange requirement to not use a sound system in open-air religious activities is formulated in a rather vague and confusing fashion but has managed to be entered into the new law.

Under a typical state-political model, so-called "big denominations" will receive a subsidy by the state. But funding seems to be the smallest problem of all the adopted changes - although it is absurd for taxpayers to be charged a tax to fund religious beliefs that they do not share (as is the practice with political parties).

It is yet to be established what action is to be taken by the denominations and by the Protestant churches in view of the restrictive texts adopted in the LASLR 2018. Despite the victory won for freedom of religion due to exclusion of the most extreme proposals in these amendments by the legislature, the remaining restrictive texts adopted into law are a retreat from the principles of freedom of conscience and religion in a democratic and free society. They are an expression of a totalitarian and discriminatory state attitude towards religion and freedom of expression and are in violation of the European Convention on Human Rights.

The full text (in Bulgarian) of the law can be found here, and here in PDF format with the underlined changed text in it.

*Note: Our group, Freedom for All, actively opposed the bill, as we were representing 12 evangelical-protestant denominations. Briefly, our contribution was that we entered a Declaration on May 28 into parliament, a petition supporting the Declaration of almost 10,000 people worldwide, in November, published a 15-page legal Analysis of the bills, and participated in workgroup meetings at the commission on religions and human rights in parliament, and in a number of TV shows denouncing the philosophy of the bill and its specific restrictive provisions. We also filed an application to request the Venice Commission opinion addressing it to the Secretary General of the Council of Europe, on behalf of the 12 denominations; our thanks go to ADF Europe for their excellent counsel and help with the application.


Above: Explaining the threat of the new religious law amendments in a Bulgarian Christian Television talk show
Watch the show on Facebook here.

Update: Analysis of the bills in English added on Nov. 11, 2018. See links at the end.

During the first half of May
, the BSP (Bulgarian Socialist Party), GERB (Citizens for the European Development of Bulgaria) and MRF (Movement for Rights and Freedoms) parliamentary groups, as a unified group of sponsors, and separately the coalition of nationalist parties, the United Patriots, submitted draft amendments to the Law on Religions.

In October, despite the clear, critical, and united opposition to the totalitarian bill by all faiths in the country, and by our human rights organization, the parliamentarian Commision on Religions and Human Rights (leading) voted for the bill without any hindrances, and the proposal was submitted for voting in entered the plenary session. On October 11 the National Assembly also voted "for" the bill at first reading, accepting the draft law in principle, without any particular debates.

On October 19, 2018, with a report by the leading committee, the two projects were brought together into a single one.

After November 16, 2018, when the extra-parliamentarian discussion on the proposal will be exhausted, there is a serious risk that the draft will be voted at the second reading and become enforceable legislation. Such will still be contrary to the Constitution, international law and the principles of freedom and democracy.

If the Parliament does not listen to the voice of reason, the higher laws guaranteeing the basic human rights, and the piling criticisms against the proposal, this totalitarian and anti-Christian law will come into effect.

We unambiguously and categorically oppose the introduction of tyrannical and totalitarian measures against fundamental and inalienable human rights and freedoms, aimed primarily at limiting religious belief and its public preaching, sharing, and practicing.

In order to prevent the passage of these unapologetically tyrannical bills into law, on May 28, 2018, together with the National Alliance "United God's Churches", we submitted a protest declaration to the National Assembly, whose text is fully published here. Twelve evangelical-Protestant faiths and religious communities joined the declaration. The declaration was slightly amended on 1.11.2018 to reflect current developments.

On October 18, we published an Analysis of draft laws to further critique the anti-democratic and anti-constitutional and anti-democratic nature of the project.

Tens of evangelical-protestant denominations are planning to exercise their right to a peaceful protest before parliament on Nov. 11, 2018, to express their disagreement with the anti-religious draft law. 



Analysis of the Draft Law for Amendments on the Law on Religions, in English. Written on Oct. 18, 2018. Updated and translated in English on Nov. 11, 2018. (Please, This email address is being protected from spambots. You need JavaScript enabled to view it. to let us know that you have downloaded and used this document.)

Link to the text of the Declaration in English, with the possibility to sign the petition in support. First drafted on May 28, 2018, updated on November 1, 2018.

Memorandum by Alliance Defending Freedom Europe submitted to the Bulgarian Parliament, regarding the proposed bill, explaining the European Convention and Cases Defending Freedom of Religion before the European Court of Human Rights

The proposed bill in English with highlights of problematic areas