Bulgaria's official state policy continues to be the outright denial of the existence of the Macedonian minority, as well as of Macedonian identity, language, culture and history as a whole. It is this denial, along with the West's full endorsement of Bulgaria's anti-Macedonian policies, that has led to a dramatic rise in hatred and human rights violations against Macedonians in Bulgaria.

1
ANNUAL REPORT ON THE HUMAN RIGHTS CONDITIONS OF
THE MACEDONIAN MINORITY IN BULGARIA
2024
2024: 17 years from the date Republic of Bulgaria became EU member, 34 years since it became a
democracy, 61 years from the implementing the policy of negating, discrimination and
assimilation of its Macedonian minority.
Contents:
* Introduction: Situation of the Macedonian Minority and More Important Events in 2024
* Negation of the Macedonian Minority, Nation and Identity
* Hate Speech
* Violation of the Right to Freedom of Expression
* Violation of the Right to Freedom of Assembly
* Violation of the Right to Association
* Discrimination of Macedonian Organizations and Activists
* Lack of Protection and Cooperation by Institutions
* Refusal of the Authorities to Engage in Dialogue
* Conclusion and Recommendations

INTRODUCTION
Situation of the Macedonian minority and more important events in 2024

None of the rights stipulated in the Framework Convention on National Minority Rights have been
granted to the Macedonian minority and the tendency in that regard continued to be negative.
In schools, children do not learn anything about the Macedonian minority and nation; on the
contrary, children are provided with information in which there is no place for the existence of
the Macedonian nation and minority. The Macedonian literary language, literature and history
continued not being taught.¹ On television and in the media several methods are employed to present
the sole viewpoint, according to which there is no Macedonian nation, that everything Macedonian is
Bulgarian and that every differing opinion is “anti-Bulgarian”. On educational TV programs or
debates the Macedonian point of view is not represented. The very notion of Macedonian
consciousness (“Macedonianism” as it is labelled in Bulgaria) is considered to be an artificial
anti-Bulgarian ideology. The Macedonian point of view is not included in lectures

¹ PACE: Post-monitoring dialogue with Bulgaria, Explanatory memorandum by Mr Frank Schwabe and Mr
Zsolt Németh,
co-rapporteurs,http://assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-en.asp?fileid=27711&lang=en, 160:
“There is no Macedonian language or history in schools.”

and discussions about history. Macedonian consciousness itself (“Macedonianism” as it is labelled
in Bulgaria) is looked upon as an artificial anti-Bulgarian ideology. Macedonian consciousness (and
also the Macedonian nation as a whole) in Bulgaria is considered to be a product of a Communist
experiment or the result of hostile foreign propaganda. A climate of intolerance reigns in society
against Macedonians and they are the object of hate speech, which is often given wide exposure
through the media without being sanctioned by the institutions of the state and without
encountering any condemnation by the wider society.
By taking advantage of the artificially created atmosphere of intolerance, the Bulgarian state
successfully keeps representatives of the minority isolated from political and social life in the
country-both individually² and collectively by not registering Macedonian parties and organisations
which defend the rights of the Macedonians.
The number of pending Macedonian cases in the EHRC increased from 11 in 2022 to 21 in 2023 to 31
2024.³ 24 of them are already communicated before February 2024 – 20 about the refusal to obtain
registration and 4 for the violation of the right to peaceful assembly, and 7 a newly sent to the
court.
The Bulgarian authorities consistently stress that the decisions of the ECtHR and the Committee of
Ministers do not prescribe the automatic registration of Macedonian organisations and point out in
a detailed way the measures they have taken to remove the errors before the registration of
Macedonian organisations, but at the same time do not display any concern for the fact that their
“measures” have zero effect and have achieved absolutely nothing (something emphasized at the
Committee of Ministers decisions). At the same time. They consistently avoid taking measures,
either on their own initiative or when they are called upon to do so, which would remove existing
barriers. For example, by making a referral to the Constitutional Court for it to provided
interpretive decisions of articles of the Constitution which are constantly abused by the courts
as argumentation for the non-registration of Macedonian organisations; or for this same court to
rescind or provide a new interpretation of its decision of 29 February 2000 which mentions inter
alia that “there is no Macedonian ethnicity in the Republic of Bulgaria” and which is one of the
basic arguments used in decisions to refuse the registration the courts. In addition, the
authorities have not undertaken any action to withdraw the official views expressed by the
Parliament and ministries that there is no Macedonian minority in Bulgaria; on the contrary, these
same views are actively supported. In addition, the authorities display an extraordinary slowness
and lack of desire to implement the measures recommended to them by the Committee of Ministers
leaving them to a large degree to remain as merely a formal expression of wishing to do so.
During 2024 the Bulgarian state did not take any measures to improve the situation of the

² There is not one politically or socially influential personality in the country who publicly
states that he/she possesses a Macedonian consciousness, which shows that such persons are either
unable to achieve such a status or that they are forced to cover up their self-determination as
Macedonians because of a fear of negative consequences.
³ According to the statement by Macedonian MP Zaklina Peshevska from the VMRO-DPMNE party made on
27.02.2025 in Strasbourg, there are 89 cases related to the Macedonian minority in Bulgaria waiting
for implementation
https://nezavisen.mk/bugarski-evroparlamentarec-zamolchen-vo-makedonskoto-
sobranie/?fbclid=IwY2xjawIufntleHRuA2FlbQIxMQABHRLhCC7Fw0Cvrxl0lR7wt13-VELtyKJ-
wTcft31cJfJi1wI47s-OxDoSIg_aem_7rDZGRvLCKVBpsMFwouh3A.

2

Macedonian minority. On the contrary, it made efforts to prevent the recognition of a Macedonian
minority as well as each and every question in that regard.
Macedonians are not represented in state institutions, by elected representatives (due to the lack
of a registered political party) or by organisations. Not one of the registered parties in Bulgaria
defends the rights of the Macedonians in Bulgaria. Representatives from across society, with the
exception of a small section of civil society⁴ treat Macedonians, at best, as something non-
existent and not a serious category of persons and, at worst, as a danger to national security and
treason. There are no (and there have not been) any Macedonian representatives on the Commission on
Minorities. When ethnic groups in Bulgaria are officially spoken and written about, Macedonians are
not mentioned at all and Macedonian culture, language and history are not represented in any
government publication or official web site. Macedonians are not included in any programs
concerning ethnic communities and do not receive any type of assistance from the state for the
preservation and development of their culture and identity⁵.
This year as well neither the Commission Against Discrimination, the Ombudsman's office, or any
other organisation adopted an official stance regarding the situation of the Macedonians in
Bulgaria, despite the fact that the number of judgements against Bulgaria at the European Court of
Human Rights has risen to 14. In 34 years of democracy not one Bulgarian official institution has
done so.
Despite the large number of recommendations by international bodies, Bulgarian authorities
persistently continue to refuse to enter into a dialogue with the Macedonian minority.
The Republic of Bulgaria has made a concerted effort to make the raising of this issue within the
European Union impossible.

More important events during the year
From March 12th to 14ᵗʰ, the 1492ⁿᵈ meeting of the Committee of Ministers took place, where the
problem of the non-registration of the Macedonian organizations in Bulgaria was discussed.⁶
In its decision, the Committee expressed its dissatisfaction that the measures taken by the
Bulgarian government in 2018 so far, and 17 years after the first judgement, they have not led to
the cessation of the practice of cancelling the registration of organisations aimed at the
recognition of the Macedonian minority. Concern was expressed with the non-consequential arguments
used by the Bulgarian institutions as a justification for the dismissals, the speculation with
concepts such as organisation for private or public benefit and different formal requirements (4)
stressing that formal conditions must be applied proportionally and equally and that when errors
are detected, candidates should be given instructions so they can correct them. (5). The Committee
expressed serious concern about the lack of decisive measures for

⁴ Here we should mention the Bulgarian Helsinki Committee and the people grouped around the
"Marginalia" editorial office.
⁵ PACE: Post-monitoring dialogue, 160.
⁶ 1492 meeting, 12-14 March 2024 (DH) , H46-7 United Macedonian Organisation Ilinden and Others
group v. Bulgaria (Application No.59491/00) Supervision of the execution of the European Court’s
judgments.

3

the implementation of previous decisions of the Committee by the Bulgarian authorities (6). At the
end, he declared his determination that in the absence of serious progress, that he would reassess
their positions and the measures that should be undertaken in such case (8).
On 21 April the authorities started using new methods of torment and limitation of the right of
expression of the Macedonians in Bulgaria like unreasonable demanding of the organizers of peaceful
gatherings to sign warnings that they will not disturb the public peace and moral, stopping and
checking travellers to the gatherings, photographing their documents and confiscating flags and
banners. At the traditional gathering in Melnik there were no flags allowed.
On 4 May in the city of Sandanski there was a gathering organized under the title “Democracy for
all” as part of the election campaign of the European Free Alliance (EFA). The organizer was OMO
Ilinden PIRIN and as a guest there was the EFA President, Laurena Lopez and the commissioner
candidate Mailis Rosberg. Despite the ban to display flags on the date of the death of Macedonian
national hero Gotse Deltchev because of the presence of the European guests the authorities did not
dare to confiscate the displayed the flags of the participants.
On 22 July the Bulgarian Helsinki Committee introduced its position to the Committee of Ministers
regarding the non- registration of the Macedonian organizations in Bulgaria, in which it concludes
that:
“Despite numerous recommendations and other measures undertaken by the Committee of Ministers, we
do not see any serious commitment of the Bulgarian authorities to implement them. In the past, the
BHC has called on the Committee of Ministers to take a resolute step in the direction of
instituting of infringement proceedings against Bulgaria for systemic non- implementation of the
judgments in this group. As we see no other way to ensure their implementation, we reiterate this
call again.”
In fulfilment of the demands of the Committee of Ministers (CoM), on 2 September, by order of the
Minister of Justice, a working group was created in connection with the implementation of the ECtHR
judgements of the group of OMO Ilinden and others against Bulgaria. Officially, its task was to
make a comprehensive analysis of the necessary legal changes by 2 March 2025.⁷ As it will actually
be shown, its purpose is to collect and prepare arguments before the Committee of Ministers confirm
in front of the CoM that the state has undertaken all necessary measures and there is no
possibility nor necessity to undertake further steps since the blame for lack of registration is
with the Macedonian organizations.
From 17-19 September there was a new meeting from the increased monitoring of Bulgaria held due to
the non-fulfilment of the ECtHR judgements regarding the Macedonian organizations.⁸ The CoM again
stressed that it is a matter of unjustified denials for organizations registrations which goal is
recognition of the Macedonian minority, argued with concerns for national security, protection of
public order, the rights of the others, with a constitutional ban of organizations with political
goals and technical formalities (1). The CoM again expressed its dissatisfaction of the undertaken
measures by the Bulgarian authorities

⁷ 1507th meeting (September 2024) (DH) Item reference: Addendum to an Action Plan (13/09/2024)
Communication from Bulgaria concerning the group of cases of Umo Ilinden And Others v. Bulgaria
(Application No. 59491/00)
⁸ 1507th meeting, 17-19 September 2024 (DH) H46-7 United Macedonian Organisation Ilinden and Others
group
v. Bulgaria (Application No. 59491/00) Supervision of the execution of the European Court’s
judgments

4

which did not bring a stop to the practice of refusing the registration of such organizations
primarily due to disagreement with their goals (2). It strongly urged the authorities to take
decisive measures to implement the decisions of the Committee (4). It sought to inform the relevant
government officials that they have no right to cancel the registration of these organisations on
the grounds that have already been condemned by the ECtHR, and that they must reasonably and
consistently apply the legal requirements to them (5). It invited the authorities to prepare sample
forms with correctly filled documents for registration (6), and the Registration Agency to provide
instructions for corrections, as far as errors are concerned (7), and reiterated its readiness in
the absence of progress to re-examine its position and the necessity to undertake new actions (8).
On 10.10.2024 the Advisory Committee for the implementation of the Framework Convention for
Protection of the Rights of National Minorities adopted its fifth opinion for Bulgaria in which it
presents in many places the problems of the Macedonian minority in Bulgaria (§ 32, 35, 36, 38, 79,
93 - 97). They note the position of the authorities, that “Whereas persons can express their
subjective ethnic affiliation, their access to minority rights depends on the existence of a
minority, which is determined by the authorities” (30). Giving to this the following
recommendation: “36. …. In extending access to individual minority rights, decisive weight should
be given to the subjective choice of the individual to be treated as belonging to a national
minority rather than to what the authorities consider as objective criteria.”
The opinion also says:
35. the Advisory Committee finds it crucial that a pragmatic approach towards persons self-
identifying as Macedonians … based on the principle of free self-identification, finds it
particularly important that the Framework Convention is applied on an article-by-article basis to
persons belonging to those communities in areas such as, inter alia, non-discrimination and the
principle of equality and equal access to rights as well as the promotion of mutual respect and
understanding, particularly in education, culture and the media (Articles 4 and 6).
The Committee also expresses its hope that Bulgaria will start implementing the decisions of the
ECtHR, as well as those of the Human Rights Convention (art. 11) and the Framework Convention
(art.7) concerning the Macedonians in Bulgaria.

NEGATION OF THE MACEDONIAN MINORITY, NATION AND IDENTITY
From 1963 onwards the denial of the existence of the Macedonian minority has been an official state
policy and doctrine. On 29.02. 2000 the Constitutional Court promoted such a policy in its own
Judgement No 1 which banned OMO “Ilinden”-PIRIN and since then that has been one of the main
grounds and arguments used to violate the right of association of the Macedonians which moreover
this year developed into an official judicial practice and norm (see below). In 2019 and 2020 that
was converted into an official condition to be satisfied for the integration into European
structures of the Republic of Macedonia and one of the reasons for the blocking of negotiations
regarding Macedonia's membership of the EU. On 21 May and 16 June 2021, the caretaker government in
Bulgaria affirmed the position that one of the conditions for the integration into European
structures of the Republic of Macedonia was that Macedonia

5

renounce the Macedonian minority in Bulgaria.⁹
The concept “Macedonian minority” is often placed in inverted commas in published documents and is
regularly accompanied by the phrase “so-called” in official documents as well as in the media and
internet forums. Every similar request is being considered as an enemy action, and even the
hypothetical possibility for someone to raise the issue is viewed with alarm.
The denial not only of the Macedonian minority, but in principle the denial of the existence of
minorities in the country has been considered to be an argument for the non-registration of
minority organisations, which are considered to be directed against the territorial integrity of
the country.
The denial of the very existence of the minority, which is an official government position, has
also found its place in various judicial decisions. As an example, the Sofia Court of Appeal
commented that “The activity of the association is defined as defending the customs and interests
of an ethnic minority in the Republic of Bulgaria, which objectively does not exist as a separate
or other established group of people possessing a religious, linguistic, cultural or other
characteristic that distinguish them from the rest of the population in the country.”¹⁰ Similarly,
the Plovdiv Court of Appeal determined that the goals of OMO Ilinden – Plovdiv in favour of the
Macedonian minority are in contradiction of art.44 line 2 of the Constitution as an activity
against the territorial integrity and unity of the nation.¹¹ A similar position was determined also
by the Blagoevgrad District Court.¹²
From this it can be seen that the denial of the minority is an ideological basis for discrimination
before the law.
Since it is alleged that Macedonians lie about their identity against Bulgaria and in favour of its
enemies, the denial itself often appears as a reaction to events and statements by politicians
outside Bulgaria, be it at the European level or, as this year, in neighbouring Macedonia.
Statements by Macedonian politicians during an election campaign in Macedonia about the Macedonian
minority in Bulgaria caused a sharp reaction in Bulgaria, and on March 6, the Macedonian ambassador
was summoned to the Bulgarian Foreign Ministry because of "recent public comments by politicians
from the neighbouring country and false statements spread by them" regarding Bulgaria. On March 7,
the office of Macedonian President Stevo Pendarovski also confirmed the position that there is a
Macedonian minority in Bulgaria, as a fact confirmed

⁹ https://www.svobodnaevropa.bg/a/31266495.html - https://www.svobodnaevropa.bg/a/31310559.html,
https://www.svobodnaevropa.bg/a/31312202.html, https://www.svobodnaevropa.bg/a/31266495.html (cited
on 16/9/2021).
¹⁰ Решение № 67, 30.01.2024 Г. Апелативен Съд - София, 9-ти търговски, председател: Светла
Станимирова, Членове: Рени Ковачка, Васил Василев.
¹¹ Решение № 124, 15.03.2024 г., на Окръжен съд Пловдив, 19-ти състав, председател Галя Г.
Костадинова. Цитира аргументите използвани в 4 предишни решения срещу същото дружество от 2023 г.
(№ 80/24.02.2023, № 162/03.03.2023, № 335/09.08.2023, № 330/28.09.2023, виж доклада ни за 2023 г.),
¹² Решение № 78/29.05.2024 г. на Окръжен съд Благоевград Надя Узунова.

6

by the decisions of the ECtHR. These statements were considered a scandal in Bulgaria and caused a
storm of negative comments.¹³
VMRO BND, which on March 6 called "hate speech" a statement by Macedonian President Pendarovski:
"God forbid, not the next day, today, that we include the Macedonians in the Bulgarian constitution
- our minority, which has been tortured for decades, at least 70-80 years, has gone through
terrible tortures and golgothas...". It calls on the Bulgarian state to respond, and Pendarovski is
told that "Bulgaria is a mono-national country and there are no national minorities." The motto of
their address is "There are no minorities in Bulgaria, let alone "Macedonian, tortured”
minorities.”¹⁴
A classic example of hate speech is the statement on this occasion by Bulgarian MEP Angel Dzambazki
made on March 8, 2024, in which he called Macedonian President Pendarovski's claim about a
Macedonian minority in Bulgaria a "blatant lie" he stated; "There is no Macedonian minority in
Bulgaria, there never was, there never will be and there never can be." Since it is alleged that
Macedonians lie about their identity against Bulgaria and in favour of its enemies, the denial
itself often appears as a reaction to events and statements by politicians outside Bulgaria, be it
at the European level or, as happened this year in neighbouring Macedonia.¹⁵

HATE SPEECH
The denial of the Macedonian minority is the basis for the hate speech to which the Macedonian
minority is subjected. Without such denial all other accusations levelled against it would not be
possible. Accusations levelled against Macedonians, namely that they are anti-Bulgarian elements,
traitors, apostates, foreign agents, enemies of the nation, a threat to its unity and the
sovereignty and territorial integrity of the country, are based explicitly on the notion that such
a minority does not exist and claims to the contrary are able to be interpreted only as a hostile
act and betrayal of the state and nation by persons who have renounced their own people.
The treating of Macedonians as separatists and enemies of the state undoubtedly sows hatred towards
them amongst the majority of citizens.
One of the means employed for imposing stereotypes about the Macedonians is the use of terms
designed to denigrate the Macedonian nation, minority, identity and right to self-determination. In
order to achieve this goal, instead of correct terms being used, those such as “Macedonianism”,
“Macedonists” and other similar ones¹⁶ are employed, suggesting that in this case one is not
dealing with matters of ethnic affinity, self-determination and identity, but rather an artificial
ideology and those who adopt it. However, often that is not found to be

¹³ В България има македонско малцинство, твърди президентът Пендаровски, OFFNews 07 март 2024,
https://offnews.bg/politika/v-balgaria-ima-makedonsko-maltcinstvo-tvardi-prezidentat-pendarovski-
819250.html (visited 17.02.2025.)
¹⁴
https://novini247.com/novini/v-balgariya-maltsinstva-nyama-kamo-li-makedonsko-preminalo-prez-
macheniya-balgarskata_7570813.html.
¹⁵ https://www.youtube.com/watch?v=dW_m5_WgJag (visited 17.02.2025).
¹⁶
https://www.segabg.com/hot/category-bulgaria/omo-ilinden-probva-da-se-registrira-kato-sdruzhenie,
https://pirinnews.com/novina/14592/okruzhen-sud-blagoevgrad-otnovo-otkaza-registraciya-na-omo-ilinde
n/.

7

sufficient such that these concepts have to be imbued with a greater number of even more degrading
connotations.
The negative rhetoric against Macedonian organizations and their activists in Bulgaria continues.
All organizations continue to be grouped under a common name and treated as a common illegal and
anti-Bulgarian entity. This organization is called “unlawful”, "illegal", "anti-constitutional",
"separatist", "Macedonistic",¹⁷ and attempts to register are treated as attempts by hostile
elements to circumvent or outwit the law.¹⁸
On May 31, former Deputy Prime Minister Krasimir Karakachanov will "alarm" that the party of the
Turkish minority has filled the election commissions in Pirin Macedonia with "members of the
separatist organization OMO "Ilinden" - Pirin, an anti-state organization, to be members of their
sectional committees just to get a vote."¹⁹
The organization of a meeting under the motto "Democracy for All" with the candidate for European
Commissioner of the European Free Alliance, Miley Rosberg, has been called in the media an
"anti-Bulgarian event" organized by the "anti-constitutional party OMO "Ilinden", which is a party
"of the separatists", and the event is a "provocation", which the media links to a Serbian attempt
to destabilize the Balkans in favour of Russia. The organiser, OMO "Ilinden"- PIRIN is presented as
being created and led by Serbia, and it is even claimed that "some of the participants in
tomorrow's forum are known for their extremely close ties to the authoritarian regime of Aleksandar
Vučić in Belgrade",²⁰ although the organiser actually has no ties to the Serbian state.
A classic example of hate speech is the statement on this occasion by the Bulgarian MEP Angel
Dzambazki made on March 8, 2024, in which, after describing the words of the Macedonian President
Pendarovski that there is a Macedonian minority in Bulgaria as a "blatant lie" and a slap in the
face to Europe and to the Bulgarian lackey politicians. According to him, "there is no Macedonian
minority in Bulgaria, there has not been, there will not be and there cannot be."²¹ Then he moves
on to attacks on the Macedonian nation: "Macedonianism is not a nation, but a hateful,
anti-Bulgarian, genocidal, anti-European ideology, an ideology conceived in Belgrade, imposed by
the Bolsheviks in the Kremlin, through the Communist International. Macedonianism is genocide and
ethnic cleansing of the Bulgarians in Macedonia." It began in 1912, and continues to this day
"anti-Bulgarian Macedonism is a crime against humanity and will be condemned as such along with all
its supporters, war criminals.“²²

¹⁷
https://www.segabg.com/category-bulgaria/evropeyci-idvat-na-gosti-na-zabranenata-omo-ilinden,
https://www.segabg.com/hot/category-bulgaria/omo-ilinden-probva-da-se-registrira-kato-sdruzhenie,
https://pirinnews.com/novina/14592/okruzhen-sud-blagoevgrad-otnovo-otkaza-registraciya-na-omo-ilinde
n/
¹⁸https://www.segabg.com/hot/category-bulgaria/omo-ilinden-probva-da-se-registrira-kato-sdruzhenie,
https://faktor.bg/omo-ilinden-pak-napira-za-registratsiya-no-poluchi-otkaz-ot-agentsiyata-po-vpisvan
iya,
https://pirinnews.com/novina/14592/okruzhen-sud-blagoevgrad-otnovo-otkaza-registraciya-na-omo-ilinde
n/ ¹⁹ Karakachanov: DPS arrange selection commission swith separatists from OMO "Ilinden",
The boughtv otecosts 150 BGN,
https://fakti.bg/en/bulgaria/885081-karakachanov-dps-redi-izbiratelni-komisii-
sas-separatistite-ot-omo-ilinden.
²⁰ Навръх Великден в Сандански ще се проведе антибългарска проява! Safe News, 03.05.24 21:08,
https://safenews.bg/navrah-velikden-v-sandanski-sthe-se-provede-antibalgarska-proyava/?noamp=availab
le.
²¹ https://www.youtube.com/watch?v=dW_m5_WgJag (visited 17.02.2025).
²² https://www.youtube.com/watch?v=dW_m5_WgJag (visited 17.02.2025).

8

VIOLATION OF THE RIGHT TO FREEDOM OF EXPRESSION
On April 21, a Macedonian festival was held in Melnik, authorized by the Municipality of Sandanski.
Two days before the event (and well after the legal deadline for refusal by the Municipality), the
police contacted the organizers with a request to sign a declaration that they would not cause
riots and would abide by the law, something that has never been a request before, nor have they
created riots in the past to be a reason for such a request.
On the day of the rally, the authorities exerted completely unnecessary pressure and harassed the
people. An abnormally large number of police officers were mobilized - about a hundred uniformed
and plainclothes police officers, which created an unpleasant atmosphere at the celebration. Buses
were stopped even 80 kilometers before the meeting place and the police took and photographed the
passengers' ID cards and the passenger’s luggage for the rally was checked and the flags of the
organizing organizations, as well as of the European Free Alliance
- a party with elected MEPs. It was not permitted to wave a flag and any attempt to do so was
prevented by force, and the flag was confiscated. Posters were also prohibited, and one man was
even asked to take off his sweater because it said "I love Macedonia", but when they found out that
he was not wearing anything underneath, they gave up. One of the buses was stopped twice and the
identity cards of the passengers were taken twice. Such police posts were set up at Papaz Chair,
the village of Delchevo, Melnik and Rozhen. There was an unusually large police presence at both
places for laying flowers - at the grave of Yane Sandanski next to the Rozhen Monastery, and at the
monument in Melnik. All those present were photographed up close by plainclothes police officers
without reason or explanation - the campaign had a clear aim to intimidate those present. No
document was shown of an order for and on what basis this was done. In some cases of confiscation,
documents were provided, but often they were written on forms for 'voluntary surrender', which does
not reflect the reality of what happened. When Ivan Kotomanov had his flag forcibly taken, he was
not given a seizure protocol, and the police behaved in a threatening and rude manner.²³
The flags were returned only after the rally, during which the confiscation documents given at the
first rally were taken back, so that no evidence remained - however, 7 of them were preserved and
used in the complaint filed against the police.
This follows the trend of restricting the right to peaceful assembly and expression observed in
recent years (see below).
The same warnings not to fly any flags other than the Bulgarian state flags were made to the
organizers of the laying of flowers at the monument to Gotse Delchev in the village of Delchevo,
Sandansko on May 4. The presence of a delegation of the European Free Alliance at the site prompted
the authorities not to touch the flags, but there was a large presence of police and civilian
agents and everything was filmed.

VIOLATION OF THE RIGHT TO FREEDOM OF ASSEMBLY

²³ Witness statement of Ivan Kotomonavo, 22 April 2024.

9

For the fourth year in a row, the alarming trend of returning to the violation of the right to
freedom of assembly continues. This concerns traditional celebrations of ethnic Macedonians,
planned to be held on a date and place of particular importance for their historical memory and
ethno-cultural identity. Once again, the violator of the law is the municipality of Petrich, but
this year the municipality of Kresna also joined in.
The chairman of the OMO "Ilinden" Kiril Tilev sent a notification to the mayor of the municipality
of Petrich that his organization plans to organize its traditional celebration dedicated to the
Ilinden uprising and the battle of Belasitsa - 1014, and the battle of Chaeronea on August 3 -
Saturday. The celebration is modest and only includes the laying of flowers and a speech lasting
half an hour. It was stated that, "measures will be taken to prevent a violation of public order
and to respect the legal rights and interests of citizens." On 22.07.2024, the mayor of the
municipality, Dimitar Brchkov, suggested to the organizers to change the time and place, since a
series of events were being organized all day Saturday in the "National Park- Museum of Samuil's
Fortress" (i.e. at the location) by the historical museum of Petrich. "The coincidence of your
event with the previously planned celebration ... will create a prerequisite for its impossibility
and will make it difficult to maintain public order and traffic safety in the area," the mayor
stated, although the modest laying of flowers could not realistically prevent any celebration.²⁴
On 22.07.2024, the mayor of the municipality Dimitar Brachkov suggested to the organizers to change
the time and place, since all day, Saturday, a series of events are being organized in the
“National Park-Museum of Samuil's Fortress” (i.e. at the same place) by the historical museum of
Petrich. “The coincidence of your event with the previously planned celebration… will create a
prerequisite for its impossibility and will make it difficult to maintain public order and traffic
safety in the area,” the mayor stated,²⁵ although the modest laying of flowers could not prevent
any celebration.
On 25 July, Kiril Tilev submitted a new notification that they would move the celebration to the
next day - Sunday, August 4. The event was held, and attendees noticed that the park- museum was
closed and under renovation, with no indication that any events had recently taken place there. The
invention of fictitious activities as an excuse to prevent Macedonian events has become a regular
practice by this municipality and this mayor (see our reports from previous years).
On October 4, Kiril Tilev submitted a notification to the Kresna municipality on behalf of OMO
"Ilinden" and OMO "Ilinden"-PIRIN that the traditional celebration of the Kresna Macedonian
Uprising was planned on October 20 with a program - flowers and speech in the town of Kresna, a
report on the uprising in the village of Stara Kresna, a memorial service for the dead in the
village of Oshtava.
On October 8, a response was received from the municipality, stating: "Regarding the received
letter with entry no. 4700-25/07.10.2024 and in connection with the activities of OMO "Ilinden" and
OMO "Ilinden"-PIRIN, which are in contradiction with the Constitution of the

²⁴ Notification to the mayor of Petrich Municipality to Kyril Tilev, president of OMO “Ilinden”,
25.07. 2024 г.
²⁵ Letter № 4-00-5480-006/22.07.24 of the mayor of municipality of Petric Dimitar Brchkov to Kiril
Tilev.

10

Republic of Bulgaria, 'directed against the territorial integrity of the country', the Kresna
municipality does not allow any events to be held on its territory." ²⁶
On October 14, without any reason or change in circumstances, the municipality sent a second letter
to Tilev, in which it cancelled its previous letter of refusal due to the alleged separatist and
anti-constitutional activities of the organizers, now indicating new reasons for refusal - the fact
that the holiday of the town of Kresna was being held at the same time and coincides. The holiday
was organized from October 18 to 20, as the Program of the holiday shows that the activities of the
municipality are planned for the 18th and 19th, and for the morning of October 20, no events
related to the holiday were planned in the town of Kresna, and activities for the holiday were not
planned at all in the villages of Stara Kresna and Oštava, where the Macedonian organizations had
planned 2/3 of their celebrations. However, the municipality banned the celebration and notified
the organizers, "that you can hold the events on another date that does not coincide with the
holiday celebrations organized by us."²⁷ For some reason, the alleged separatism and
unconstitutionality were no longer a problem and a reason for a ban, and the municipality even
agreed to hold the celebrations, but on a different date. Of course, the date is of great
importance for the holiday, as it is connected to a specific historical event. The change of
motivation was obviously made to cover up the fact that discrimination is being committed against
the organizers.
The formal motives for violating the rights of Macedonians change, only the violations and attempts
to violate them are constant.
Nevertheless, the events took place, and in the town of Kresna there was an abnormally large police
presence, who surrounded the people who came to the celebration in a tight cordon while they laid
flowers at the monument to Dimitar Pop-Georgiev and gave a short speech, but did not intervene or
stop them. Considering that there has never been any incident during this event in Kresna, the
strong police presence was clearly not intended to provide security, but to intimidate and harass.
Representatives of the security services were also present in the village of Stara Kresna. In the
village of Oshtava, however, the priest did not show up at all.

VIOLATION OF THE RIGHT TO ASSOCIATION
This year, six Macedonian organizations unsuccessfully attempted to register and collectively
received a total of at least 19 refusals. which have already won cases at the European Court of
Human Rights (ECtHR), received five refusals each: Society of Repressed Macedonians in Bulgaria -
Victims of Communist Terror, and OMO "Ilinden". The other four are: Association for the Protection
of Fundamental Individual Rights, with registration revoked (2), Macedonian Cultural Club "Nikola
Vaptsarov" (2), United Macedonian Organization Ilinden - Plovdiv (4), and United Macedonian
Organization Ilinden - Blagoevgrad (1).
Bulgarian courts continued denying registration to Macedonian organizations using the same reasons
and methods which have been condemned multiple times by the ECtHR and Committee of Ministers, for
example:

²⁶ Letter 4700 – 25 /1/ 08.10. 2024, of mayor of municipality Kresna Nikolay Georgiev, to Kyril
Tilev.
²⁷ Letter № 4700-25/2/14.10.2024 of mayor of municipality Kresna Nikolay Georgiev, to Kyril Tilev.

11

Non-existence of the Minority.
The claim that there is no Macedonian minority in Bulgaria and accordingly – there is no reason for
such organizations to exist.
A1. Using the preceding claim as a basis, the courts interpreted efforts in defence of a Macedonian
self-consciousness and traditions as an intention to impose a foreign ethnic consciousness on the
Bulgarian population.
A2. On the basis of point A1 efforts in defence of Macedonian self-consciousness and traditions are
interpreted as having the goal of creating division and confrontation on an ethnic basis.
A3. The goals of the organisations which work to defend the Macedonian minority are interpreted as
an effort to create privileges on an ethnic basis or contrary – to undermine the rights of the rest
of the citizens.
A4. By treating any mention of a Macedonian minority, ethnicity, or self-consciousness anti-
constitutional, and directed against the unity of the nation and the territorial integrity of the
country.
A5. Judges exceeding their legal competencies assigned themselves the role of “arbitrators of
history” when assessed the relevance and interrelatedness between historical dates and events that
applicants were supposed to celebrate and particular ethnic group or its history.
Formal arguments.
Mistakes in documentation
B1. Manipulations with unclear definitions of the concept “political goals”, goals which are
intrinsic to organisations with a social benefit and goals intrinsic to private organisations.
B2. Speculation as to alleged irregularities in the documentation, and the attempt to find such
irregularities leads to extremes and outright speculation and conditions which are not mentioned in
the law.
B2.1. Contrary to the law and the insistence of the Committee of Ministers - there are no
instructions given for the correction of alleged irregularities, while they are at the same time
said to be unable to be corrected and an outright refusal is issued.
B2.2. state institutions make a special effort to invent formal reasons and at each level an effort
is made to add even more, giving them prominence in opposition of the principle of justice.²⁸
Arguments used last year, but not this year, are the following:
B3. The Agency for Registration continued the practice which it had begun last year (2021); namely
to deal with every new application for registration by a given organisation through the prism of
previous refusals and since the goals of the organisation to fight in some way in defence or in
favour of persons with a Macedonian self-consciousness had not changed, to treat that as an
uncorrected error or irregularity and therefore on that basis to issue a refusal. In that way the
violation of the law by the courts and state institutions is converted into a law in and

²⁸ Position of the Bulgarian Helsinki Committee to the Committee of Ministers, July 22, 2024, & 9.

12

of itself, while the goals for the defence of the Macedonian minority are treated as an error which
must be removed from the application.
B4. The courts do not always base their decisions on the statute and documents presented but rather
strive to “uncover the true will of the founders” which it interprets arbitrarily and tendentiously
with a view to refusing registration.
B5. The courts oblige Macedonian organisations which have lodged an appeal against the Agency's
decisions to pay its court costs.

А. Denial of the Minority
Contrary to the decisions of the ECtHR and the Committee of Ministers, the Bulgarian judicial
system has created its own ideological interpretation of the law and built a system and framework
that makes it impossible to register an organization that sets among its goals any type of
protection of the rights of Bulgarian citizens with a Macedonian self-consciousness and the
interests of the Macedonian minority or concern for Macedonian identity and culture.
Examples of such of such argumentation this year can be found in the following rulings:
- Decision No. 67, 30.01.2024 Court of Appeal - Sofia, 9th Commercial Division, Chairperson: Svetla
Stanimirova, Members: Reni Kovachka, Vasil Vasilev. "Thirdly, the DLR has found that the
association's activities are aimed at officialising and promoting an ethnicity that the applicants
claim exists within the framework of a sovereign state. It has planned to organize national
Macedonian gatherings (celebrations of historical dates and events), without specifically referring
to them, in order to assess their relevance to a certain ethnicity or to the history of the
Bulgarian nation, including through the organization of regional gatherings on an ethical
principle." "The association's activities are defined as protecting the customs and interests of an
ethnic minority in the Republic of Bulgaria, which objectively does not exist as a separate or
other established group of people possessing religious, linguistic, cultural or other
characteristics that distinguish them from the rest of the population in the country." " “The
public promotion of such a minority through a non-profit association intended to meet their
specific needs, in essence, does not aim to protect their rights—since they are no different from
those of other citizens—but rather to cultivate among a certain group of Bulgarian citizens a
different ethnic self-awareness, one that has not been formed through a natural historical process,
and is therefore directed against the unity of the nation.” “The conclusions of the first- instance
court regarding the lawfulness of the refusal to register the association are correct, due to the
contradiction between the association's declared ideas, objectives, and means of achieving them,
and Article 44, paragraph 2 of the Constitution of the Republic of Bulgaria.” “Article 44,
paragraph 2 of the Constitution of the Republic of Bulgaria prohibits organizations whose
activities are directed against the sovereignty, territorial integrity of the country, and unity of
the nation, or aim to incite racial, national, ethnic, or religious hatred,²⁹ or to violate the
rights and freedoms of citizens.”

²⁹ The italics are the court's, marked words indicate that the court sees an intention to "incite
... ethnic ... enmity".

13

“According to Article 4, paragraph 1, item 2 of the Statute, the association has set itself the
goal of: ‘Protecting the human rights of Macedonians and other ethnic minorities in Bulgaria....’
However, in Bulgaria, there is no Macedonian ethnic minority as defined in Recommendation 1134
(1990) of the Parliamentary Assembly of the Council of Europe (PACE), i.e., as a distinct and
recognized group within the territory of the country, whose members are citizens of the state and
possess distinguishing religious, linguistic, cultural, or other characteristics that set them
apart from the majority of the population.” "Therefore, the public promotion of such a minority
through a non-profit association intended to satisfy their specific needs does not, in essence, aim
to protect their rights - since they are no different from those of other citizens - but rather to
cultivate among a certain segment of Bulgarian citizens a distinct ethnic self-awareness that has
not been formed through a natural historical process, and is thus directed against the unity of the
nation. In this sense, it contradicts Article 44, paragraph 2 of the Constitution of the Republic
of Bulgaria. Moreover, some of the means listed in Article 4, paragraph 2 of the Statute for
achieving the association's goals do not point to the protection of significant public rights and
interests of a distinct group of people, but to the separation of groups of Bulgarian citizens on
an ethnic basis not recognized by the country's Constitution."
"The court considers that “the refusal to register the association cannot be defined as
discrimination against the members of the association based on their ethnic origin, but rather is
issued because the association’s goals and means of achieving them contradict Article 44, paragraph
2 of the Constitution of the Republic of Bulgaria. Since the request is for registration of an
association directed against the unity of the nation, it justifies the necessity of restricting the
right to association in a democratic society."
- Decision No. 124, 15.03.2024, of the Plovdiv District Court, 19th Panel, Presiding Judge Galya G.
Kostadinova. The ruling cites the arguments used in 4 previous decisions against the same
association from 2023. (Nos. 80/24.02.2023, 162/03.03.2023, 335/09.08.2023, 330/28.09.2023,
see our report for 2023) that the objectives of the society in favour of the Macedonian minority
are in contradiction with Art. 44 para. 2 of the Constitution for activities directed against the
territorial integrity and unity of the nation and considers that the society falls within the
exceptions of Art. 11.2 of the Convention and Art. 22, para. 2 of the International Covenant on
Civil and Political Rights.
- Decision No. 78/29.05.2024 of the Blagoevgrad District Court, Nadya Uzunova vs. the Association
of Repressed Macedonians: “According to the court, the goals formulated in the Statute suggest that
the association's activity is directed against the unity of the nation.” The court assumes the role
of arbiter and interpreter of history, treating the association's aim to preserve Macedonian
history as problematic: “The court’s assessment of the disputes over Bulgarian historical figures
and events is considered by the court to be an activity directed against the unity of the Bulgarian
nation.” Furthermore, the court ruled that Article 11 of the European Convention was on its side,
as it sees “a need to protect the rights and freedoms of the other citizens who are not part of the
association.”
This is the final ruling this year that uses such arguments. The decrease in arguments directed
against the minority itself is likely linked to the Committee of Ministers’ decisions against
Bulgaria in March (especially points 1 and 7). The turning point occurred in May, with the last

14

ruling using such reasoning dated 29 May, and the first instances where courts began refusing to
comment on those arguments occurring on 15 May.
However, this does not mean these arguments have been abandoned—it is a case of deliberate omission
and conscious avoidance. Appellate courts in particular now directly state that reviewing “the
remaining conditions is pointless” or that it “excludes the need to assess the lawfulness of the
association’s objectives”—euphemisms behind which hide precisely the arguments of ethnic
discrimination and suppression concerning the ECtHR rulings and explicitly mentioned in the
complaints submitted by the discriminated organizations to the respective courts. We find such a
situation in the decisions related to the Repressed, OMO 'Ilinden', OMO 'Ilinden' – Plovdiv, and
OMO 'Ilinden' Blagoevgrad, the Repressed Macedonians.
However, the fact that the same discriminatory arguments continue to prevail is clearly evident
from the case of the Repressed Macedonians, who submitted a statute and documents identical to
those of another association that had already been registered earlier that same year—only changing
the objectives and means. The Registration Agency did not comment on the objectives and means, but
instead identified irregularities in the documentation that it had not identified in the registered
association and which are not required by law.³⁰ Although these circumstances were presented to the
Blagoevgrad District Court, the same court repeats and expands the technical remarks of the AB and
refuses to comment on the substance, stating that this is ethnic discrimination disguised behind
fabricated formal reasons. According to the court: “The fact that the Registry Agency has
registered another association … is irrelevant and has no bearing on the legality of the challenged
refusal.” The Company’s explicit request “for the disqualification of all judges from the
Blagoevgrad District Court, stating that they have ruled repeatedly on requests for registration of
a non-profit association of Macedonians in Bulgaria, which is why they are biased… and that the
case be sent for consideration to the Kyustendil District Court” was rejected.³¹
This reflects a new political line also seen in recent letters from the Bulgarian government to the
Committee of Ministers (early 2025), in which the line is defended that there is no ethnic
discrimination, and the problem lies in technical errors allegedly made on purpose and with
political goals by Macedonian organizations, so that they could not be registered.
The coordination between the arguments used by the judiciary and those used by the executive
against Macedonians in Bulgaria is a highly worrying phenomenon, which exposes the often- used
argument but false claim that the executive could not do anything about the registration issue
because the judiciary was independent (the latter is a well-known untruth).
B. Technical errors
The institutions continue to look for formal reasons to refuse registration of Macedonian
organizations. Usually, there is speculation about the issues of the representative power of the
chairman and the annual meeting, property activities, often purposefully mixed with the

³⁰ Refusal № 20241029143700/31.10.2024г. of the Agency.
³¹ Decission № 164 from 04.12.2024 г. Blagoevgrad District Court – Seventh Chamber, President:
Gyulfie Yahova.

15

procedure for liquidation of the association.
Very often, there is speculation about the lack of a place and time of the constituent meeting in
the protocol as an argument that the concurrency of the founders' will cannot be confirmed,
although this is not provided for in the law, it was challenged in a decision of the PAS and the
common will of the founders is clearly expressed in their signatures under the protocol and the
statute of the association.
On this point, Decision No. 194, dated 15.05.2024 of the Plovdiv Court of Appeal, Presiding Judge
Vera Iv. Ivanova, states: “We do not agree with what the district court said about the need for
more specific individualization of the place of establishment of the association, which would be
reflected in the founding protocol and in a protocol – the decision of the Managing Board (to
indicate a specific address). Such a requirement is not contained in either the Law on Legal
Entities or in Art. 33 of Ordinance No. 1/14.02.2007 on keeping, storing and accessing the Register
of Legal Entities of Non-Governmental Organizations”.
This and similar examples show that some of the arguments accepted by some courts are rejected by
others. In addition, from the example of the Repressed Macedonians³² it is quite clear that the
courts apply double standards to Macedonian organizations, different from those applied to other
organizations, with the preliminary aim of denying them registration.
Macedonian organizations are treated unequally in Bulgaria.
An example of how institutions look for reasons to refuse registration of Macedonian organizations
is evident from the case of OMO "Ilinden" - Refusal No. 20920808115855/09.08.2024 AB, as
the registry agency abused the use of a double way of recording a date in two different documents
such as 04.08. and 08.04., both of which are used in Bulgaria (the first is common, and the second
is used by the Supreme Court), which was accepted as an independent reason for refusal, without the
possibility of correction or clarification, contrary to the regular practice of giving instructions
for correcting such inaccuracies and technical inconsistencies. The same is repeated by the
Blagoevgrad District Court, despite the fact that the error was explained in the appeal.
After the criticism from the Committee of Ministers, speculation regarding whether an organisation
served the public or private interest decreased, but still occur. These arguments were clearly
condemned by the Plovdiv Court of Appeal: “It should be noted that the first ground for refusal, as
accepted by the registration official—that registration was sought for an association with
private-benefit activities, while at the same time the objectives and means of achieving them
correspond to an association with public-benefit activity—is contrary to the legal framework.
Namely, Article 2, paragraph 1 of the Non-Profit Legal Entities Act, which provides that non-profit
legal entities are free to define their goals and may self-designate as organizations for public or
private benefit.” ³³
The Registration Agency continues to insist, in violation of the law, that appellants pay its legal

³² Refusal № 20241029143700/31.10.2024г. od the Agency; Decission № 164 from 04.12.2024 г.
Blagoevgrad
District Court – Seventh Chamber, President: Gyulfie Yahova.
³³ Decission № 29 Plovdiv, 26.01.2024 г. Court of appeal, 3th citizens chamber, President Vera Iv.
Ivanova:

16

costs, although this year courts have begun to reject such demands. 34
"The invention of formal reasons and demands which are not applied in the cases of other
organisations, have as a goal to be used before the Strasbourg institutions for covering the actual
ethnic motivation for the discriminatory decisions taken.”
***
The only constant in the practice of the Bulgarian courts in relation to Macedonian organizations
is the refusal to register them.

List of refusals and arguments used

The refusals together with the arguments used are as follows

1. Association of Repressed Macedonians in Bulgaria Victims of Communist Terror
1.1. Refusal No. 20240311104154/13.03.2024 AB- = B2, B2.1.
1.2. Decision No. 78/29.05.2024 of the District Court of Blagoevgrad Nadya Uzunova = A2, A4, A5
B2.2,
1.3. Decision No. 477, 16.07.2024 Court of Appeal - Sofia, 6th Commercial, Chairman: Ivan Ivanov
Members: Nikolay Metanov, Valentin Boykinov = B2. B2.2.
1.4. Refusal No. 20241029143700/31.10.2024 AB = B2, B2.1, B2.2.
1.5. Decision No. 164, 04.12.2024 Blagoevgrad District Court – Seventh Chamber, President: Gyulfie
Yahova = B2, B2.

2. UMO “Ilinden”
2.1. Refusal No. 20240122102617/23.01.2024 AB = B1, B2, B2.1,
Decision ruled by the Registration Agency with respect to the application for registration lodged
by United Macedonian Organisation “Ilinden”, dated from 23.01.2024. B1, B2, B2.1.
2.2. Decision No. 66, 02.05. 2024 Blagoevgrad District Court, 4th Chamber. Petar Uzunov = B2, B2.2,
2.3. Decision No. 483, 17.07.2024 Court of Appeal - Sofia, 9th Commercial Division, Chairman:
Svetla Stanimirova Members: Reni Kovachka Vasil Vassilev = B1, B2, B2.1, B2.2
2.4. Refusal No. 20920808115855/09.08.2024 AB = B1, B2.1, B2.2,

³⁴ Decision № 67, Sofia, 30.01.2024, Court of appeal – Sofia, 9th Commercial, Chairman: Svetla
Stanimirova; Decision № 29, 26.01.2024 Court of appeal – Plovdiv, 3rd civil division, Chairman Vera
Iv. Ivanova; Decision
№ 202, 27.03.2024 Court of appeal – Sofia, 9th Commercial, Chairman: Svetla Stanimirova; Decision №
194,
Plovdiv 15.05.2024 Court of appeal – Plovdiv, 3rd civil division, Chairman Vera Iv. Ivanova.

17

2.5. Decision No. 125, 05.09.2024 Blagoevgrad District Court, 16th Panel, Milena Kamenova
= B1, B2, B2.1, B2.2

3. OMO "Ilinden" - Blagoevgrad
3.1. 29.03.2024 Decision No. 205, 29.03.2024 Court of Appeal - Sofia, 6th Commercial, Chairman:
Ivan I. Members: Nikolay Metanov, Valentin Boykinov = B2, B2.2,

4. Macedonian Cultural Club "Nikola Vaptsarov"
4.1. Refusal No. 20240529140828 of 31.05.2024 of AV-RYULNTS = B, B2.1.
4.2. Decision No. 126/10.09.2024 District Court - Blagoevgrad, Eleventh Panel, Presiding Judge:
Vladimir Kovachev = B, B2.2

5. OMO "Ilinden" - Plovdiv
5.1 Decision No. 29 / 26.01.2024 - Plovdiv Court of Appeal, 3rd Civil Division, Presiding Judge:
Vera Iv. Ivanova, Members: Katya St. Pencheva, Todor Ilk. Hadzhiev = B2, B2.1, B2.2
5.2 Decision on application by United Macedonian Organization "Ilinden" - Plovdiv, dated 26.01.2024
= B2, B2.1, B2.2
5.3 Refusal No. 20240301125050 / 06.03.2024 - RA = B2, B2.2
5.4 Decision No. 124 / 15.03.2024 - Plovdiv District Court, 19th Panel, Presiding Judge: Galya
G. Kostadinova = B2, B2.2
5.5 Decision No. 194 / 15.05.2024 - Plovdiv Court of Appeal, 3rd Civil Division, Presiding Judge:
Vera Iv. Ivanova = B2, B2.2

6. Association for the Protection of Basic Individual Human Rights 2023
6.1 Decision No. 67 / 30.01.2024 - Sofia Court of Appeal, 9th Commercial Division, Presiding Judge:
Svetla Stanimirova, Members: Reni Kovachka, Vasil Vasilev = B1, B2, B2.2
6.2 Decision on application by the Association, dated 30.01.2024 = B1, B2, B2.2
6.3 Decision No. 202 / 27.03.2024 - Sofia Court of Appeal, 9th Commercial Division, Presiding
Judge: Svetla Stanimirova, Members: Reni Kovachka, Vasil Vasilev = A, A1, A2, A3, A4, A5, B1, B2,
B2.2

DISCRIMINATION OF MACEDONIAN ORGANIZATIONS AND ACTIVISTS
This year, too, we observe examples of harassment and unprovoked negative treatment towards
Macedonian activists in Bulgaria.

18

On March 19, the chairman of the OMO "Ilinden" Kiril Tilev was summoned to the Ministry of Interior
in Sandanski. At first, they asked him to come without a summons, but when he asked for one, they
refused to give him one. When he stated that in that case he would not come, they threatened to
arrest him. When they saw that he would not back down, they gave him a summons. At the police
station, Inspector Atanasov and another police officer made him write a statement and answer
questions about why he had written to the government, what function he performed in the Macedonian
movements, was he the chairman of the OMO "Ilinden" and the like. The interrogation took place in
response to Kiril Tilev's open letter to Prime Minister Djankov and Deputy Prime Minister Maria
Gabriel about the situation of the Macedonian minority in Bulgaria, but the questions were directed
at him personally and as an accused person, and not at the situation of Macedonians in Bulgaria,
and the police officers behaved rudely and nervously. When he wrote that he had exercised his
constitutional right with the letter to the government and given them the sheet – they threw it
away and threatened him. Tilev left.³⁵
Examples of harassment are the checks of buses and cars when going to public events, taking
pictures of personal documents, taking pictures of those present, taking away flags and posters,
which was discussed elsewhere. Harassment on this basis was committed because, without any reason,
the authorities decided that the regular gathering organized by the Macedonians in Melnik for 35
years, and at which there have been no incidents for 18 years, and even before that there had been
no incidents by the organizers, the authorities have now determined that it is an event with a
“high degree of danger” despite the fact that the only arguments were that many people would
attend, that the organizers were two Macedonian organizations in Bulgaria and that guests from the
Republic of Macedonia were also expected, and even the long handles of the flags were considered as
such which “predisposed to a violation of public order”.³⁶
During the gathering, there were instances of rude behavior by police. After his flag was forcibly
taken by several officers, Ivan Kotomanov described the following:
“When I started talking to the police about human rights and turned on my phone to record, one
officer brazenly attacked me from behind and forcefully grabbed my phone. When I asked why, he
replied I had no right to film him. I told him I was filming in a public space. He said I had no
right to film because he was in uniform. I told him no such prohibition exists. Realizing they were
breaking the law, he handed my phone to a subordinate and told him to issue me a citation and check
the footage. The subordinate then said it was just their job and asked me to delete the recording
in exchange for not issuing a fine. When I showed there was no recording of them, they gave me back
the phone. Before I even left, another group came and demanded my ID. When I presented it, they
took it and began making threats—especially after seeing my name and address. I had to wait another
30 minutes for them to return the flag, claiming the car it was in was elsewhere. The threats
continued the whole time, especially after most people had dispersed, leaving more police than
attendees.”³⁷

³⁵ Testimony of Kiril Tilev, 19.03.2024.
³⁶ Court hearing transcript, 11.02.2025, Blagoevgrad Administrative Court, Judge Ivan Shekerliyski.
³⁷ Testimony of Ivan Kotomanov, 22.04.2024

19

Another method of harassment is summoning organizers to the police and coercing them into signing
warnings not to violate the law.
On April 19, immediately before the All-Macedonian gathering in Melnik and long after it was
approved by the municipality, the police in Sandanski summoned the chairman of the OMO "Ilinden",
Kiril Tilev, first without a summons, and then at his request - with, and made him sign an Order
handed to him by the employee of the Ministry of Internal Affairs, Atanas Pavlov Atanasov, which
reads:
“Pursuant to Article 64 of the Ministry of the Interior Act and in execution of my duties to combat
crime and ensure public order, protect citizens’ rights and freedoms, and safeguard their lives,
health, and property, I order Kiril Serafimov Tilev... to strictly adhere to the Law on Assemblies,
Rallies and Demonstrations, and not to engage in unlawful actions— specifically not to engage in
indecent conduct that grossly violates public order and shows blatant disrespect for society. This
is in connection with the gathering organized by OMO 'Ilinden' and OMO 'Ilinden-Pirin' in Rozhen
and Melnik.”³⁸
An identical order was issued on 2 May in connection with a planned celebration in Novo Delchevo at
the monument of G. Delchev.³⁹
According to the Blagoevgrad Administrative Court, although these orders cite Article 64, they
essentially fall under Article 65, paras. 1 and 2 of the same Act, which allows police to issue
oral or written warnings to individuals suspected of potentially committing crimes or disturbing
public order. For written warnings, a protocol is issued, warning the individual of legal
liability.⁴⁰
This judicial interpretation presumes that there is sufficient data to believe that Tilev, OMO
“Ilinden,” or OMO “Ilinden-Pirin” are likely to commit a crime or disrupt public order—yet no such
data has ever been provided. In the past 35 years, there has never been an instance where the
organizers disrupted public order or committed a crime during such events.
This confirms that the orders were issued in violation of Article 64, which allows such measures
only when necessary for fulfilling police functions—clearly not applicable here, as the police
themselves admitted during delivery that the organizers had never caused trouble, but they were
“following orders from above.”
Even more insulting are the wording of the police warnings, which cite the Assembly Act but
actually refer to Article 325(1) of the Penal Code concerning “acts grossly violating public order
and showing blatant disrespect for society,” punishable by up to two years in prison or probation,
and public censure.
Treating Macedonian activists as criminals without any reason and taking them to the police and
forcing them to sign insulting and unprovoked warnings is just another form of harassment directed
against the organizers of Macedonian public gatherings in Bulgaria

³⁸ Order, 19.04.2024, Sandanski MVR, Ref. 339 r – 7158/19.04.24.
³⁹ Order R – 8057/0205.24, MVR Sandanski, Officer Todor Petrov Angelov.
⁴⁰ Ruling No. 2118, 27.06.2024, Blagoevgrad Administrative Court, Judge Ivan Petkov.

20

Following the participation of a European Free Alliance delegation at the 4 May gathering in
Delchevo, these police practices ceased.
Such examples clearly demonstrate the treatment of people with Macedonian identity and their
activities as potentially criminal. They also reveal misuse of institutions and legal procedures to
deliberately harass and restrict the rights of Macedonian activists—particularly when no external
observers are present.

LACK OF PROTECTION AND COOPERATION BY INSTITUTIONS
During this year several Macedonian organizations (Macedonian Organization-Ilinden, Association of
Oppressed Macedonians in Bulgaria-Victims of Communist Terror and Macedonian Culture Club “Nikola
Vaptsarov”) attempted to action the rights mechanisms in the state but in vain. All complaints sent
to the Ombudsman, Discrimination Protection Committee, Ministry of Internal Affairs ended either
with transfers of the cases to other instances or outright rejection.
On 24.01. 2024, the Supreme Prosecutor's Office upheld the refusal of the lower prosecutor's
offices to initiate pre-trial proceedings on the complaint of the chairman of the Repressed
Macedonians in Bulgaria, Stoyan Gerasimov. The complaint concerned the actions of private
individuals—allowed by the authorities—during the opening ceremony of the Macedonian Cultural Club
"Nikola Vaptsarov," whose conduct significantly disrupted the event and disturbed the peace of its
participants. According to the Prosecutor’s Office, these actions “are not of such a nature as to
lead to the dissolution or obstruction of a rally.⁴¹
On 25 March 2024, the Ombudsman, Prof. Dr. Diana Kovacheva, responded to a complaint by the
chairman of OMO "Ilinden," Kiril Tilev (in essence, an open letter addressed to several
institutions, including the Ombudsman herself). In his letter, Tilev highlighted the traditionally
dismissive attitude toward the obligation to respect the human rights of Macedonians in Bulgaria.
He called for the recognition of the Macedonian minority in the Constitution, an end to hate speech
and public disrespect, the introduction of Macedonian language education, protection of Macedonian
heritage and culture, and Macedonian-language radio and television broadcasting.⁴² In her response,
the Ombudsman merely stated that she does not have the authority to initiate constitutional
amendments (ignoring the fact that she does have the ability to recommend such changes). She added
that in her annual report she had addressed the increased monitoring by the Committee of Ministers
concerning Bulgaria's refusals to register Macedonian organizations and cited the Committee’s
latest decisions. However, she made no mention whatsoever of why the reports of her own institution
fail to address violations of minority rights, hate speech, and discrimination against Macedonians.
The Macedonians in Bulgaria are completely absent from the Ombudsman's reports, and no mention is
made of what

⁴¹ Decree of the Supreme Prosecutor's Office № 736/2024, PRB 2024 225597760, Sofia 24.01.2024,
prosecutor Danail Shostak.
⁴² Open letter of UMO “ilinden” 5.02.2024 г.; Response № 1522/25/03/2024, ombudsman Dilyana
Kovacheva, signed by Cvetana Mitova Nikolovaва.

21

she is doing regarding the same issues. She ignores all other essential points raised by Tilev as
well.
After the Ministry of Interior began, to apply the practice in April and May of summoning the
organizers of Macedonian public assemblies and making them sign an order they must "strictly comply
with the Law on Assemblies, Rallies and Demonstrations and not commit unlawful actions — including
indecent acts grossly violating public order and showing clear disrespect for society,"⁴³ and given
that the orders themselves stated they could be appealed under the Administrative Procedure Code
before the Administrative Court in Blagoevgrad, Kiril Tilev submitted an appeal to that court.
On 27 June 2024, the court issued a decision rejecting the complaint, arguing contrary to the
statements in the Orders and Article 64 of the Ministry of Interior Act, on which the Orders were
based that "the order cannot be appealed under the judicial administrative procedure."
To justify this, the court unlawfully reclassified the Orders issued under Art. 64, which according
to paragraph 7 provides that “Orders issued in writing may be appealed in accordance with the
procedure of the Administrative Procedure Code” (something also stated in the Orders themselves),
as if they had been issued under Art. 65, which does not contain such a provision. But even if this
arbitrary interpretation were to be accepted, the Orders would still have to be annulled, because
they were issued without following the legal procedure. Art. 65 provides that such an order must be
signed by both an official and a witness, whereas the contested Orders were signed only by an
official, as is appropriate under Art. 64.
Furthermore, the Court performs logical gymnastics, by arguing that the requirements in the Order
are, in principle, obligations for all citizens.⁴⁴ The problem with this argument is the fact that
usually such Orders are not issued, but only in special cases and circumstances, which were not
present in this instance. Such Orders are issued only when “sufficient data and it is presumed that
the person will commit a crime or breach of public order... the person is warned of the
responsibility for committing the respective crime or breach of public order” (Article 65, para.
1), which was not the case here, nor have there been past events that would give rise to such
concerns. The offensive nature of the Orders is also ignored, as they contain the claim that the
organisers are preparing to commit a crime. Additionally, the Order does not contain any
justification for its issuance, as required by Article 64, para. 5, item 3 of the Ministry of
Interior Act and the general requirements of Article 59, para. 2, item 4 of the Administrative
Procedure Code, which in itself constitutes a serious violation and grounds for cancellation.⁴⁵
On 05.09.2024, the Commission for Protection against Discrimination (CPD) finally rejected the
complaint of Stoyan Gerasimov, filed due to offensive statements made by journalist Nina Spasova on
the state national television BNT, regarding the members of the delegation, representatives of
Macedonian organizations in Bulgaria and fighters for the rights of

⁴³ Order from 19.04.2024 of Regional police district of Ministry of interior affairs г. УРИ 339 р –
7158 / 19.04.24, Order Р – 8057/0205.24 of Regional police district of Ministry of interior
affairs, official Todor Petrov Angelov from 02.05.2024 г.
⁴⁴ Ruling № 2 2118, Blagoevgrad 27.06.2024, Administrative Court – Blagoevgrad 6th Chamber, Judge
Ivan Petkov.
⁴⁵ Private cassation appeal to the Supreme Administrative Court by Kiril Serafimov Tilev, against
ruling №.
2118/27.06.2024 of the Administrative Court - Blagoevgrad, issued under adm. case № 697/24.

22

Macedonians in Bulgaria, who visited Macedonian President, Stevo Pendarovski on behalf of the
Macedonians in Bulgaria. In this statement, journalist Nina Spasova stated about the members of the
delegation that these were: "people dug up from somewhere, quite old, quite bad-looking, with a
candle as if they were being searched for". The CPD “dismissed” the complaint and “Establishes that
… Nina Spasova … did not discriminate on the grounds of ‘belief’ and ‘ethnicity’ … and did not
‘incitement to discrimination” (p. 7). According to the CPD, the words did not constitute ethnic
slurs or calls for violence or hatred based on ethnicity, nor were they directed specifically at
the complainant (one of the delegation members). And even though the broadcast may have been
“watched by a wide audience,” the statements made were still not equivalent to harassment or
incitement to discrimination, and "the analysis of Spasova's comment requires a conclusion that it
does not give indications of forming public disapproval towards persons who, according to Vassilev,
self-identify as Macedonian, and the statement does not specifically mention the names of the
addressees. The panel establishes that Spasova's statement itself lacks (has not been used)
qualifications that would harm the honor and dignity of persons who self-identify as Macedonian, in
particular the applicant, and according to the moral norms adopted by society, are not indecent,
cynical or vulgar" (p. 6).⁴⁶ (There is a certain sad truth in the latter statement, since in
Bulgarian society the degrading language used towards Macedonians and especially towards Macedonian
activists is not seen, according to the “moral norms accepted by society, to be indecent, cynical
or vulgar”).
In the entire decision, all of Gerasimov’s statements as well as his self-definition are carefully
formulated to make it clear that these are his statements and claims, but the Commission is in
distancing itself entirely from them.
The request in Stoyan Gerasimov's complaint, item 4, "To publish an independent report and
recommendations in accordance with domestic and international legislation on issues related to
discrimination against the Macedonian ethnicity in Bulgaria. The report should be consistent with
the opinions of international human rights organizations with norms ratified by the Republic of
Bulgaria. To provide information to the public through the mass media about the current national
and international provisions in the field of ethnic rights and protection from discrimination." The
Commission has been petitioned many times to conduct such a study and publish a report, but has
never responded, nor has it done so, despite the existence of clear and systemic discrimination
from the judgments in Strasbourg.
However, in 2024 there was one positive case. The Blagoevgrad Administrative Court, with ruling No.
1764 of 31.05.2024, overturned as unlawful, the refusal of the Commission for Protection against
Discrimination on the complaint of Stoyan Gerasimov and Kiril Tilev, against the Kanzurov family,
and returned the case back to the CPD.⁴⁷ This came after a series of procedural delays and remands
through various courts in 2023 (see our reports from the past two years). Such decisions are very
rare and usually involve returning a case for retrial, rather than a decision with a final positive
result for the Macedonians.

⁴⁶ Decision for Committee for protection gainst Discrimination Gerasimov - Nina Spasov, Decisionе №
244,
Sofia, 05.09.2024.
⁴⁷ Ruling № 1764, Administrative Court Blagoevgrad, VII Chamber, 31.05.2024, Judge Dimitar
Dumbanov.

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This is also what happened in the following case too. On 05.11.2024, the Commission for Protection
against Discrimination again rejected the complaint of Kiril Tilev and Stoyan Gerasimov, leaders of
the OMO "Ilinden" and the Association of the Repressed Macedonians in Bulgaria, against Viktor
Kanzurov. This time the arguments were for procedural inadmissibility (contrary to its previous
decisions), and they even refer to the principle that a person should not be punished twice for the
same act (regardless of the fact that the Kanzurovs have not been sanctioned, even once) and the
principle of separation of powers, in the sense that the court's decisions are binding on the CPD
as part of the executive branch, which essentially means that the Commission refuses to react to
cases of discrimination committed by the courts.⁴⁸
On 23.10. 2024 Blagoevgrad Administrative Court dismissed Kiril Tilev's appeal because on October
8, the mayor of Kresna banned the holding of celebrations in honor of the Kresna Macedonian
Uprising, because "the activities of OMO "Ilinden" and OMO "Ilinden"-PIRIN, which are in
contradiction with the Constitution of the Republic of Bulgaria, 'directed against the territorial
integrity of the country', are not permitted to organise any events on the territory of Kresna
Municipality.”⁴⁹
The consideration of the appeal filed in the Blagoevgrad Administrative Court was delayed until
October 23, when it was dismissed because in the meantime the municipality had cancelled the letter
of refusal and had made a refusal with a different motivation (see Violation of the Right to
Peaceful Assembly"). The core issue in the original refusal regarding treating the complainants as
separatists and unconstitutional actors was ignored by the court.⁵⁰
***
This year, the reality remains unchanged, that it is impossible for Macedonians to find protection
against hate speech and the violation of their rights to expression, assembly and association
through Bulgarian institutions: whether the courts, the Ombudsman, the Commission for Protection
against Discrimination, or the Prosecutor’s Office. The arguments for denying justice to
Macedonians may shift - the only constant is the absence of justice for them.

REFUSAL OF THE AUTHORITIES TO ENGAGE IN DIALOGUE
Dialogue between the representatives of the Macedonian minority and the authorities is regularly
recommended in the monitoring reports on Bulgaria. This year again the authorities did not make any
attempt to implement the recommendations in the reports of the Parliamentary Assembly of the
Council of Europe, the Commissioner for Human Rights, the European Commission for the Fight Against
Racism and Intolerance and the Consultative Committee for the Application of the Framework
Convention on National Minorities for the start of a dialogue with the Macedonian minority. On the
contrary, not one reply was received to the many written requests from Macedonian organizations for
meetings and talks with

⁴⁸ Decision № 333/05.11.2024 of a five-member extended panel of the Commission for Protection
against Discrimination, chairwoman Vladimira Stoimenova.
⁴⁹ Letter 4700 – 25 /1/ 08.10. 2024, from Nikolay Georgiev, Mayor of Kresna Municipality, to Kiril
Tilev.
⁵⁰ Ruling №. 3239 of 23.10.2024 of the Administrative Court of Blagoevgrad – I Chamber, Judge
Stoyanka Pishieva – Sahatchieva.

24

Bulgarian institutions. In cases where, instead of receiving requests for meetings, they received
signals and complaints, they either did not respond, or rejected them (like the Commission for
Protection against Discrimination), or gave evasive answers. An example of the latter is Kiril
Tilev's complaint to the Ombudsman, who in his response only indicated that the issues raised were
not within the competence of her institution, which otherwise follows the intensified monitoring
carried out by the Committee of Ministers, something that was not put in Tilev's complaint. Such a
practice of answering but not in substance and circumventing requests to start a dialogue are
characteristic of this institution’s behaviour in recent years, and in general all institutions
directly or indirectly refuse to start a dialogue on issues of discrimination and the rights of
Macedonians in Bulgaria.⁵¹
A particularly indicative, telling case is the response to Kiril Tilev's open letter of 15.02.2024,
to the institutions. Instead of receiving a written response or an invitation to meet with a
competent institution on human rights issues, Tilev was summoned to the police in the town of
Sandanski, shown the letter to the government, and asked to write a statement about who he was,
what Macedonian organization he was a member of, and why he wrote the letter. ⁵²

CONCLUSIONS AND RECOMMENDATIONS
The violation of the right to association as well as the hate speech and discrimination that
Macedonians are subjected to are based on the dominant ideology from the time of the communist
regime, according to which a key role is played by the denial of the Macedonian minority and the
treatment of the mere idea that such a minority exists as hostile to Bulgaria.
Given the existing situation in the country, it does not appear probable that the situation of the
Macedonians in Bulgaria can be improved without serious external intervention, especially on the
part of European institutions. This problem is very old and serious and requires emergency
measures.⁵³ The denial of and discrimination against the Macedonian minority represents the last
vestige of totalitarian policy in the European Union.
In order for the current problems of the Macedonian minority in Bulgaria to be solved the following
changes should occur in Bulgaria:
1. The decision of the Constitutional Court of 29 February 2000 and the Declaration of the
Bulgarian Parliament of 6 March 1990, which officially postulate that in Bulgaria there is no
concrete Macedonian ethnic group, as well as the parliamentary declaration of 9 November 2019, must
be rescinded. These decisions serve as an ideological and legal basis for discrimination. The
government should officially declare that the Macedonian minority will no longer be denied or
discriminated against and that its rights will be defended.
2. The state should officially recognise the existence of national minorities in the country and
the concept “national minorities” should be included in the Constitution. The state should take the
necessary legal measures so that the principle of the unity of the nation cannot be interpreted to
deny the very existence of national minorities and their rights. If possible, national minorities
should be listed by name

⁵¹ Response № 1522/25/03/2024, to Complaint № 1522/2024, signed by Tsvetanka Mitova Nikolova.
⁵² Witness testimony of Kyril Tilev, 19.03.2024 г.
⁵³ For the same recommendation see:
https://www.civicsolidarity.org/article/1639/respect-and-recognition-
acedonian-minority-bulgaria-strong-condemnation-announcements, accessed on 16 March 2020

25

26
in order to avoid any possibility of misinterpretation of the Constitution and denial of
minorities.
3. Measures should be taken so that the constitutional prohibition on forming organizations on an
ethnic basis is not interpreted and used to oppose the right of minorities to form their own
organizations.
4. The law on the registration of non-government organizations should be changed and articles
included in it which would make it impossible to interpret the self-determination of minority
groups as an anti- constitutional, anti-state act which threatens territorial integrity and
justifies denial of registration.
5. Bulgaria should implement the judgements of the ECtHR and Macedonian organisations should be
registered. The obstacles preventing registration of Macedonian organisations should be removed-
the implementation of the decisions of the ECtHR are of fundamental significance in order to ensure
the supremacy of the law.⁵⁴ The existing blockade on the registration of Macedonian organization
should be lifted.
6. An active dialogue must be initiated between the state and the representatives of the Macedonian
minority in order to solve current problems and there should be a Macedonian representative on the
Commission on Minorities.⁵⁵. This dialogue should begin immediately, without waiting for the
recognition of the Macedonian minority as „recognition by the state as a minority is not a
prerequisite to qualify for the protection of the Framework Convention“ and should focus on the
application of the Framework Convention to the Macedonians in accordance with specific articles of
the Convention.⁵⁶.
7. The Census documents in the future should contain a separate column for “Macedonian” and during
the conduct of the Census it is to be publicly and officially announced that everyone who
self-identifies as a Macedonian can freely do so.⁵⁷ The same advice should be contained in the
directions given to the Census takers.
8. Measures should be taken for the promotion of tolerance vis-à-vis the Macedonian minority and
for its protection against hate speech and institutional discrimination.
9. The study of the Macedonian literary language, culture and history should be included in
curricula for children belonging to the Macedonian minority. At the same time basic school
curricula should be modified so as not to exclude references to the Macedonian nation and its
history, culture and language (something which is not new, and which was done in the past in
Bulgaria, but which has now been abandoned).

Committee for the Defence of Human Rights “Tolerance” with the Support of: OMO ”Ilinden”- PIRIN,
OMO “Ilinden”, The Association of Repressed Macedonians, Victims of Communist Terror, The
Association for the Defence of Fundamental Civil Rights, The Civil Initiative for the Recognition
of the Macedonian National Minority in Bulgaria and Defence of the Rights of Bulgarian Citizens
with a Macedonian Consciousness, Macedonian Club for Ethnic Tolerance in the Republic of Bulgaria,
Macedonian Human Right Movement International

⁵⁴ Report of the Commissioner for Human Rights of the Council of Europe following her visit to
Bulgaria on 25-
29 November 2019, 31/03/2020, & 6,
https://ec.europa.eu/migrant-integration/librarydoc/report-of-the-
commissioner-for-human-rights-of-the-council-of-europe-following-her-visit-to-bulgaria-on-25-29-nove
mber- 2019, & 49
⁵⁵ Commissioner, & 49
⁵⁶ Advisory Committee on the Framework Convention for the protection of National minorities, Fourth
Opinion on Bulgaria-adopted on 26 May 2020, ACFC/OP/IV(2020)001Final,
https://rm.coe.int/4th-op-bulgaria- en/16809eb483, & 25 - 27.
⁵⁷ Cf. Advisory, & 31 – 36.