Assoc. Prof. Iva Pushkarova, a lecturer in Criminal Law, warned that Bulgaria’s decision to make part of the National Registry of Pedophilia public raises serious human rights concerns. Speaking to Bulgarian National Radio, she stressed that no European country maintains such registries, unlike in the United States, where they have generated numerous human rights issues. Pushkarova emphasized that the move conflicts with the European Convention on Human Rights and is unlikely to have a sustainable future. Instead, it risks exposing Bulgarian citizens to increased social pressure, fear, and hostility, undermining the trust and cooperation essential to a democratic society.

Further reading: Bulgaria Makes Pedophilia Registry Partially Public to Protect Children

According to Pushkarova, preventive measures should remain the focus of child protection policies rather than post-crime public exposure of offenders. She highlighted that current European supranational guidance offers ample direction on prevention, aiming to shield children from becoming victims rather than targeting perpetrators after crimes occur. Measures that provoke negative social effects, she noted, only deepen societal distrust and fear in Bulgaria.

Pushkarova also stated that Bulgaria does not need a separate Child Justice Act, as existing legislation already provides for the protection, assistance, and criminal prosecution of children. She referenced the 2021 murder case of Evgeniya Vladimirova, in which public protests arose after the Sofia Court of Appeal reduced Orlin Vladimirov’s sentence from life imprisonment to 20 years and fully acquitted his father, Plamen Vladimirov. Pushkarova noted that the principle of personal concealment, which shields close family members from punishment if they help offenders evade justice, remains a traditional institution in Bulgarian law.

She criticized recent legislative proposals aimed at increasing penalties for sexual crimes against minors and raising the age of consent from 14 to 16. Pushkarova argued that the changes appear unprincipled and populist, lacking proper analysis or consistency. She noted that the Bulgarian Penal Code already meets supranational requirements and includes clear rules for determining punishments, but current proposals risk distorting penal policy by punishing minor offenses more harshly than serious crimes, potentially incentivizing offenders to commit graver acts to reduce their liability.

Regarding the statute of limitations, Pushkarova warned that recent proposals could weaken criminal prosecution by undermining established European practices that allow continuation of cases after victims reach adulthood. She emphasized that alternatives discussed in ministry working groups would offer stronger protections and more balanced policies than the current legislative approach. Overall, Pushkarova concluded that the proposed measures risk worsening child protection in multiple ways rather than improving it.