Opinion of Caritas Bulgaria

Opinion of Caritas Bulgaria on the publicly announced draft Ordinance on the conditions and procedure for concluding, implementing and terminating the agreement for the integration of aliens with granted asylum or international protection.

We make our comments and suggestions based on our belief that people who have been granted asylum or international protection and want to establish themselves in Bulgaria have a contribution to Bulgarian society and that in order for this to happen in practice there is an important role to play in ensuring adequate and effective integration measures. We express our position and relying on the experience of our member organizations in providing support for initial adaptation and integration through our work on the territory of the reception centers and in the Caritas specialization unit for integration support “Sv. Anna”.

We would like to draw attention to the fact that Caritas understands the meaning of replacing a non-working provision with a new regulation in that the new normative act to regulate a working mechanism to ensure a successful integration process. We appreciate some positive steps, such as the proposal to provide indicators for assessing the effectiveness of the integration process in chapter two and the introduction of a coordination unit (Article 19, paragraph 1) in chapter four, but we consider that this project as a whole it does not achieve a significant change.

We believe that it is necessary, before such an ordinance is adopted, that it will be carefully considered and agreed upon. In this regard, we propose that an expert working group be set up, including representatives of non-governmental organizations, including the National Association of Municipalities, as well as the municipalities themselves, to prepare a draft text of the Ordinance to be proposed for adoption.

With regard to these texts, we offer the following suggestions and comments:

• It is necessary to guarantee the delivery of targeted financial support for integration support, financially and sustainably, such as the provision of this Ordinance. It is of utmost importance to provide for Bulgarian language education, whose certificate of successful completion is recognized by the state institutions; Financial support for renting a home and payment of utility costs; Socio-cultural orientation; Social mediation, including translators; Monthly allowance for children, etc. It is particularly important to provide additional support tailored to the specific needs of people and families in vulnerable situations. The indicators foreseen for assessing the process effectiveness (in Chapter Two) cannot be measured and reported as successful unless the integration measures are productive. The obligations of asylum seekers or international protection under Article 17, resulting from the signing of the integration agreement (failure to comply with which leads to a sanction), cannot be fulfilled if there is no targeted work and preparation and guaranteed integration measures are provided.
• It is necessary to provide a mechanism to motivate, prepare and support the municipalities in fulfillment of their assigned duties and to avoid the risk of missing municipalities willing to rejoin the integration process. Integration activities should be guaranteed in the long term and financially; to ensure the financial security of the work on integration, including the provision of support from mediators, translators and the outsourcing of the activities of the agreement to non-governmental organizations. Currently, non-governmental organizations are the linking, facilitating, and implementing integration unit.
• The positive idea of appointing a coordinator under Article 19, paragraph 1, Chapter Four should be further developed and clearly showing how this body will interact with the different stakeholders involved in the integration process and its responsibilities as a guarantor for implementing the signed agreements.
• It is necessary to clarify the procedure for providing funds for the integration of asylum seekers or international protection after relocation and resettlement provided as for in Chapter Seven Article 33, paragraph 2. It should be clear when and to whom the International Projects Directorate will provide the targeted funds and how they will reach municipalities and direct users.
• It is necessary to precise the term “suitable work” (for example, Article 31, paragraph 1, section 3, Article 17, section 3), as the refusal to do so is accompanied by sanctions related to non-compliance with obligations on the part of the asylum seeker or international protection, which would lead to the termination of the integration agreement. Suitable work needs to meet the applicant’s needs, aspirations and skills, and take into account the risk of documentary obstacles to proving educational and professional qualifications.
• The deadline for submitting an application for an agreement on integration to be extended to 1 year.
• We propose that an individual integration plan be drawn up for each member of the household, whether it is an adult or underage family member, and not as provided for in Article 3, paragraph 3 – only for minors. As an appendix to the agreement, these individual plans will show the specific needs, goals, activities and responsibilities to achieve for each individual member, which will inevitably differ in part for individual family members. On the basis of these plans, it will be possible to measure the indicators for assessing the integration process provided for in Chapter Two.

We remain available for further information on our proposals and we are willing to actively participate in the process of drafting an Ordinance that provides a working mechanism and guarantees proper integration support.