BESCO Position Paper on the Draft Acts Amending and Supplementing the Preschool and School Education Act

To
THE 52nd NATIONAL ASSEMBLY

MR. DIMITAR ZDRAVKOV
CHAIR OF THE COMMITTEE ON EDUCATION AND SCIENCE

CC: THE COMMITTEE ON EDUCATION AND SCIENCE

from
The Association "BULGARIAN ENTREPRENEURSHIP ASSOCIATION" (BESCO), entered in the Register of Non-Profit Legal Entities kept by the Registry Agency, UIC 177239971, represented by its Executive Director Alexander Nutsov

Re: Draft Acts Amending and Supplementing the Preschool and School Education Act

DEAR MR. ZDRAVKOV,
DEAR MEMBERS OF PARLIAMENT,

We present the position of the Association "Bulgarian Entrepreneurship Association" (BESCO) on the three Draft Acts Amending and Supplementing the Preschool and School Education Act, reference nos. 52-654-01-104/23.07.2026, 52-654-01-52/03.06.2026 and 52-654-01-103/22.07.2026.

BESCO brings together more than 1,000 companies from a range of sectors. A significant share of them are among the country's largest employers, account for a large part of the economy, and work in the technology sector and in high-value-added industries. For us, education is a key part of the environment in which business develops, because it is the education system that lays the foundation of human capital, productivity and the economy's ability to create more benefits for society. For years, Bulgarian business has felt the direct consequences of the deficits in the education system: the shortage of people with the necessary knowledge, digital skills, critical and analytical thinking and adaptability has become a constraint on the development of companies, the attraction of investment and the creation of innovation.

To address these deficits, the entrepreneurs in the association create their own academies, training centers and internship programs, fund and structure bachelor's and master's programs, run courses and training in schools and universities, and invest in additional qualification and reskilling of their employees. The financial investment, as well as the investment of time and administrative effort, in these processes is substantial, but it is not enough to meet the systemic needs of high-value-added business, and it is an indicator of the need for fundamental reform of the education system.

At the end of 2023, BESCO and 24 other employer, sector and business organizations and bilateral chambers issued a joint position, concrete proposals and one very clear message: in the age of artificial intelligence, the world changes not over years but often within a matter of days. Old-fashioned teaching methods focused on accumulating facts and memorizing set knowledge do not match the development of the modern world or the skills children and students need to fulfill their potential in society.

We therefore support the efforts to improve access to and the quality of education, including the language support measures and the earlier identification of learning difficulties. For years, BESCO has advocated timely support for children with a different mother tongue (approximately one in four first-graders), who deserve the opportunity to learn and develop on equal terms with their peers. Bulgaria cannot afford to lose a quarter of its human potential at the very start, in the context of the national priorities of transforming the economy toward high value added, innovation and high-value-added industries.

At the same time, every change in education legislation should be judged not only by the problem it solves today, but also by whether it builds a system capable of preparing children for the economy and society of tomorrow. The data show that deficits in basic skills are already a systemic problem. According to the OECD's PISA 2025, 58% of Bulgarian 15-year-olds are below the baseline level in reading and 57% in mathematics, the lowest results for Bulgaria since it began participating in the survey. These results show that for a significant share of students, the system fails to build the fundamental skills on which all other competences are later developed. We propose that the provisions on language support in the three draft acts be merged, and we would like to set out the following recommendations for improving the measure.

I. Language support for children and students with a different mother tongue

BESCO supports and commends the efforts to introduce systematic language support. In our earlier position on the Preschool and School Education Act, we already backed standardized tools for assessing language level, framework programs according to level of proficiency, and specialized teaching materials. Insufficient command of the language of instruction is not a lack of ability but an educational barrier that the system must identify as early as possible and address in a targeted way. When this deficit is not overcome in time, it accumulates across all school subjects and leads to lower results, limited access to further education and fewer opportunities for fulfillment. Early language support is also a long-term investment in the quality of the workforce.

We view positively the provisions for standardized assessment of language level, support according to individual needs, a preparatory language class, continued support after entering first grade, and monitoring of progress. However, creating new forms of support will not be enough unless capacity for their quality delivery is built in parallel. Otherwise, the new obligations will be placed on schools and teachers within existing resources, with no real change in results.

2. Teacher training

Teaching Bulgarian as a second language requires specific knowledge, methods and approaches and should not be equated with the traditional teaching of Bulgarian language and literature. In the draft act we see a framework for language support, but not sufficiently clear guarantees that teaching professionals will have the training needed to deliver it. Its introduction should therefore be accompanied by specialized qualification of teaching professionals, development of methods and tools for teaching Bulgarian as a second language, additional teaching resources in institutions with a concentration of such students, targeted funding and clear minimum requirements for the quality of support. We cannot expect a different result if we introduce new tools but leave the system without the capacity to use them.

3. Language support must lead to real inclusion

We support the flexible organization of language teaching, including group and individual formats according to students' specific needs. However, we have reservations about the possibility that remote learning could replace in-person teaching because of organizational difficulties or an insufficient number of students for a group. Language is not acquired solely in lessons: daily interaction with teachers and peers and participation in the school community are part of the process and build key social and communication competences. The guiding principle should be that resources are organized around the student's needs, rather than the student being removed from the educational environment because of the system's organizational limitations. Where a separate group cannot be formed, solutions should be sought through resources shared between schools, mobile specialists, regionally or municipally organized support and combined formats with in-person teaching as the lead.

4. The link between diagnosis, support and outcome

Standardized assessment of language level is an important prerequisite for moving from general assumptions to data-based decisions. For the system to be effective, the link between entry language level, form and intensity of support, required resources, expected outcome and follow-up assessment must be clearly defined. Key parameters such as language levels, minimum intensity, curricula, methods and monitoring rules should be clearly set out, so that schools, parents and society can understand what is actually being provided and how success is measured. Otherwise, diagnosis risks remaining an administrative tool without leading to a different approach to teaching.

In summary, we make the following recommendations for building on the proposal:

• Standardized entry assessment and individualized support. The language level of every child should be established through a standardized tool, with the result determining the form, intensity and duration of support, as well as the expected progress.
• Specialized training of teachers in Bulgarian as a second language. A minimum competence profile, mandatory introductory training and follow-up methodological support should be introduced for the teaching professionals who provide language support.
• Language support should continue after the preparatory class. Additional classes, language support within other subjects and periodic monitoring of progress should be provided even after the child joins a regular class.
• A maximum duration for the preparatory language class. The preparatory class should be a temporary measure with a clearly defined maximum duration, not a separate long-term educational pathway.
• Periodic assessment and clear criteria for moving to a general class. The need to continue language support should be assessed regularly, and the child should move to general education as soon as the established language level allows.
• Maximum participation of the child in the general school environment. Even during intensive language preparation, students should take part alongside their peers in all learning and extracurricular activities for which their language level allows.
• In-person delivery should remain the lead format. Where student numbers are insufficient, instead of fully remote teaching, specialists shared between schools, mobile teams or regionally organized support should be used.
• Introduction should be tied to the readiness of the system. The new model should start only when standardized assessment tools, curricula and materials, trained teachers and the necessary funding are in place, and a pilot of one or two years in different types of schools should be run before national introduction. The practical challenges will differ: from schools with a high concentration of children with a different mother tongue, through classes in which only individual students need language support, to small schools where the number of children will not allow a separate preparatory class to be formed. The pilot should cover precisely these different situations, in order to establish which organizational models work best: a separate preparatory class, support within the general class, specialists shared between several schools, or regionally organized support. The results of the pilot period should be used to refine the rules, the staffing and financial resources required, and the criteria for implementation before the model is introduced nationally.
• Targeted funding and measurement of results. Separate resources should be provided for language support, and not only the number of children covered should be tracked, but also the duration of support, their successful transition to general classes and their subsequent educational progress.

We propose that the provisions on language support in the three draft acts be merged into a single text that combines the best solutions and fills the gaps in each of them.

Conclusion

Since its founding, BESCO has worked for the transformation of the Bulgarian economy through reforms and effective policies focused on creating products and services with higher added value, developing innovation and high-value-added industries, and building the country's export potential. In this context, education policy cannot be separated from Bulgaria's long-term economic development goals. If the country has the ambition to build a modern economy, it needs a system that gives all children basic literacy, good command of Bulgarian, mathematical and digital competence, critical thinking, empathy, communication skills and the ability to learn independently. Deficits in these areas affect the whole economic chain, leading to a shortage of qualified staff, higher training costs for employers and limited innovation capacity. Business cannot and should not replace the functions of the state education system, but it has a legitimate interest in taking part in developing the policies that determine the quality of future human capital.

We support the development of language support and the measures for earlier overcoming of learning difficulties, but we believe that concrete efforts toward fundamental reform of education must urgently be undertaken. The success of the education system is measured not by the number of enrolled students or hours taught, but by what students actually know and can do, and whether the system gives them a foundation for full participation in the society and economy of the future.

We thank you for your attention and declare our readiness to continue the expert dialogue for more accessible and higher-quality education in Bulgaria.

Yours sincerely,
ALEXANDER NUTSOV
EXECUTIVE DIRECTOR
BULGARIAN ENTREPRENEURSHIP ASSOCIATION