Bulgaria: The (digital) vaccination certificate – is Bulgaria getting back to the (new) normal?

How is the vaccination sequence regulated in Bulgaria?

The vaccination campaign was launched in Bulgaria on 27.12.2020 in accordance with the respective order of the Minister of Health. With the national vaccination plan, some vaccination phases were determined according to risk levels: A. Medical personnel; B. Personnel of social institutions, educators, etc.; C. Personnel whose work is associated with the functioning of basic social life activities (military, etc.); D. Elderly persons 65 years of age or older and persons with other diseases; E. Population groups who are at risk due to their living conditions. The opening of temporary vaccination centres in the country was regulated by further regulations. 302,151 vaccine doses were used as of 10 March. The Health Act did not assume COVID vaccines to be voluntary and free of charge. The cost-free nature of the recommended vaccinations was incorporated in the vaccination regulation on the act.

Should there be special rights for "vaccinated persons" in Bulgaria?

At the state level, there are no regulations against measures taken by individuals (including employers), which include access or other restrictions for non-vaccinated persons (employees). However, many general principles of the fundamental rights regulations indicate that such restrictions and exceptions will be highly controversial from a legal perspective, unless they are enshrined by law. Thus, the latter would probably be practicable until the Bulgarian courts issue an explicit counterstatement in any court proceedings that places such restrictions on the subject matter of the dispute. This topic is not yet discussed very intensively from a legal point of view, but it is clear that the option to vaccinate is not a legal but a practical obligation in view of the expected restrictions.

Is the (digital) vaccination certificate coming to Bulgaria?

There is still no legal discussion on the introduction of a vaccination certificate in Bulgaria. According to the verbal statement of the Bulgarian Prime Minister, which was made at the end of February 2021, Bulgaria would support the introduction of vaccination certificates. Currently, there is no specific data available on the sentiment regarding the introduction of a vaccination certificate.

Autor: Cornelia Draganova