Particularly sensitive is the issue of the criteria concerning the figure of the Prosecutor General
The Association of Prosecutors in Bulgaria has expressed “serious concern” regarding the “Competency Model for Senior Positions in the Judiciary” presented by the Ministry of Justice on April 9. In a statement, the association said that the lack of transparency surrounding the discussion of the model raises serious questions.
According to the association, the manner in which the model was presented and discussed leaves the impression of a perfunctory consultation, without sufficient clarity as to whether, and how, the professional proposals made were actually considered and reflected.
The document itself states that, in its development, written opinions from various organisations were taken into account, including those of the Association of Prosecutors in Bulgaria, as well as conclusions from a consultation held on 19 March 2026. However, it does not specify which proposals were accepted, which were rejected and on what grounds, nor what opinions were expressed, what objections were raised, and what was actually discussed.
According to the association, the proposed model does not provide sufficient guarantees of objectivity.
The issue of the criteria relating to the position of Prosecutor General is particularly sensitive. In relation to this post, the document itself acknowledges a high concentration of power, influence over staffing and significant risks, which makes the existence of precise, verifiable and publicly defensible standards all the more necessary.
Further concern is raised by the lack of editorial and structural precision within the document itself. In a text presented as the basis for such a sensitive personnel matter, this inevitably raises questions as to whether it has been prepared and refined in a manner that inspires confidence.
The association is calling for the publication of the minutes of the discussion held, a full record of all submitted opinions and proposals, clarification of which comments were accepted and which were rejected, and for the criteria for key positions – particularly that of Prosecutor General – to be revised with the genuine participation of the professional community, alongside the development of a genuinely verifiable methodology, rather than a framework of general formulations and indicative indicators.
According to the organisation, reform in the judiciary cannot be built on untraceable decisions and incomplete transparency. It requires open debate, clarity regarding the proposals made, and demonstrable transparency at every stage.
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