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TO
THE MINISTRY OF EDUCATION AND SCIENCE
To the attention of: Mr. KRASIMIR VALCHEV Minister of Education and Science
From the Bulgarian Entrepreneurial Association — BESCO
Regarding: Draft Law on Amendment and Supplement to the Law on Pre-School and School Education
Dear Minister Valchev,
We share with you our position and proposals on the draft law on amendment and supplement to the Law on Pre-School and School Education as presented. The Bulgarian Entrepreneurial Association unites over 1,000 Bulgarian companies developing products and services with high added value, which have made a significant contribution to the growth of the Bulgarian economy. For years, Bulgarian entrepreneurs have had a stake in the topic of "Education" and we consider it to be the most important and foundational sphere of our society.
The shortage of quality labour has been a problem for many years and all industries suffer from the fact that our education system produces too many young people who are unprepared for life. Today, more than ever, the improvement of education is becoming a leading topic, due to the emergence of Artificial Intelligence and the speed at which the world in which we live is changing. We believe that we can no longer afford to postpone the bold reforms that have been discussed on more than one occasion both with the Ministry of Education and Science and with international partners, the civil sector and the wider public.
A year and a half ago we achieved an unprecedented business coalition, prompted both by the latest poor results connected with our current education system and by our firm conviction that reforms are needed in seven key priority areas of our education:
The proposals for changes and additions that we put to you would contribute to the realisation of the more ambitious reform in education that is so eagerly awaited by business, entrepreneurs and our society.
I. Language support for children and pupils who do not have a sufficient command of the Bulgarian language
The Bulgarian Entrepreneurial Association expresses support for the efforts of the Ministry of Education and Science to create a more structured and systematic framework for providing language support to children and pupils who do not have a sufficient command of the Bulgarian language. We regard the following changes in the proposal as positive:
At the same time, we draw attention to several significant risks and gaps:
1. Risk of excluding children from the school environment. The wording of the draft law allows for the possibility of children being enrolled in individual or distance learning solely at the discretion of the educational institution or the support team. This carries the risk of the permanent isolation of pupils from the normal school environment and the deprivation of socialisation and full-value education.
2. Lack of clarity and an overall vision. Key details of the implementation of the language support are left to be regulated by subordinate legislative acts (ordinances), which calls into question the consistency and sustainability of the policy. The changes should be presented as a package, so that the overall vision and the manner of implementing the measure are clear even during the public consultation.
3. Underestimation of the key factor — teachers. The most important element for successful language support is the teachers. If their skills for working with children who do not speak Bulgarian at home are not upgraded, there is a risk of reproducing existing deficits. International experience shows that in such cases teachers need to be trained in a special methodology for teaching the official language as a second language. Methodologies for teaching Bulgarian as a second language already exist in Bulgarian higher education institutions, and it is necessary for teachers who work with children with a different mother tongue to be trained in them.
In this regard, we propose the following specific additions to the LPSSE:
In Art. 16, a new para. 4 is created as follows: (4) The Ministry of Education and Science and the municipalities provide financial support for additional positions and training for teachers in kindergartens and schools where there are children and pupils who do not have a command of Bulgarian at a level that would allow their successful integration into the educational process.
II. The removal of attestation and the introduction of annual assessment of the work of pedagogical specialists
The Bulgarian Entrepreneurial Association (BESCO) expresses support for the intention to improve the mechanism for assessing the work of teachers and headteachers, as well as for the abandonment of formal criteria such as the documentation that pedagogical specialists are required to complete. We also welcome the fact that the results of the assessment will be used to determine additional remuneration, to direct towards qualification activities and to encourage good pedagogical practice.
At the same time, we are concerned by the following weaknesses in the proposed model:
1. Lack of measures for support in the case of a low assessment. The proposal provides for the direct dismissal of teachers and headteachers who receive the lowest assessment, without the possibility of diagnosing the causes, developing a development plan or providing professional support. This deprives the system of preventive mechanisms and creates the risk of demotivation and administrative arbitrariness.
2. Lack of clarity regarding the assessment criteria. The draft does not contain a description of the instruments for objective and professional assessment. For the assessment to be effective and fair, it should be carried out on the basis of observation of lessons and pedagogical interaction, with clearly formulated standards and criteria.
In this regard, we propose the following specific amendments and additions to the LPSSE:
Art. 228 is amended as follows: (1) The assessment of the work of teachers and other pedagogical specialists is a process of evaluating the conformity of their activities with their professional profile, with the requirements for the performance of the position, with the state educational standard for quality management, as well as with the strategy for the development of the kindergarten, school or centre for personal development support.
(2) The assessment of the work of teachers and other pedagogical specialists is carried out each year by an attestation committee determined by the employer, in coordination with the pedagogical council.
(3) The composition of the committee may also include other members determined by the state educational standard for the status and professional development of teachers, headteachers and other pedagogical specialists.
(4) The procedure for appointing the committee under para. 2, the assessment scale, the criteria and the procedure for attestation are determined by the state educational standard for the status and professional development of teachers, headteachers and other pedagogical specialists.
(5) The assessment of the work of teachers may, in addition to career development, also serve for directing towards qualification activities and for encouraging the attested pedagogical specialist.
(6) Upon receiving an unsatisfactory assessment of the work of teachers, pre-determined in the strategy and development plan of the institution, the employer together with the attestation committee:
(7) In the cases under para. 6, the attestation committee sets a date for a new assessment of the work of the pedagogical specialist, no less than 16 school weeks after the unsatisfactory assessment was received. A repeat attestation of the person is carried out one year after the measures under para. 6, items 1, 2 and 3 have been taken.
(8) If the lowest assessment is again received at the assessment of the work of the teacher under para. 7, the person is dismissed from their position under the conditions of Art. 328, para. 1, item 5 of the Labour Code.
(9) At the discretion of the employer and the attestation committee, other degrees of assessment from the attestation may be determined that require the application of the measures under para. 6, items 1, 2 and 3.
A new Art. 228a is created as follows: (1) The attestation of headteachers is a process of evaluating the conformity of their activities with regard to guaranteeing and raising the quality of education provided by the institution within the meaning of this law and the state educational standard for quality management in institutions.
(2) The attestation of headteachers is carried out each year by the regional education authority.
(3) The assessment scale, the criteria and the procedure for attestation are determined by the state educational standard for the status and professional development of teachers, headteachers and other pedagogical specialists.
(4) The assessment from the attestation may, in addition to career development, also serve for directing towards qualification activities and for encouraging the attested pedagogical specialist.
(5) Upon receiving the lowest assessment from the attestation or one degree higher than the lowest, the regional education authority:
(6) In the cases under para. 5, the next attestation of the person is carried out no earlier than one year after the measures under items 1, 2 and 3 have been taken.
(7) If the lowest assessment is again received at the attestation under para. 6, the person is dismissed from their position under the conditions of Art. 328, para. 1, item 5 of the Labour Code.
III. Continuing professional development of pedagogical specialists
The Bulgarian Entrepreneurial Association (BESCO) expresses support for the Ministry of Education and Science's aspiration towards better structuring of the process of continuing professional development of pedagogical specialists, as well as for the introduction of flexible forms of internal and inter-institutional training connected to the specific needs of educational institutions and the individual needs of teachers.
We positively assess the following elements of the proposed changes:
Nevertheless, the current model contains several significant weaknesses that limit the effectiveness and meaning of the qualification system:
1. Lack of control and transparency in the awarding of qualification grades. In its current form, PKS (professional qualification grades) exert a strong influence on the remuneration and career development of pedagogical specialists, but no effective mechanism for external control over the quality and content of the process of acquiring them exists.
2. Outdated dependence on length of service in career development. The legislation still sets requirements for the number of years served as a condition for professional advancement. This demotivates young and highly effective teachers and slows the renewal of the system.
3. Inefficiency of the qualification credits system. The mechanical accumulation of credits often leads to formal participation in training without a real effect on teaching practice. A deeper change in the philosophy of professional development is needed.
In this regard, we propose the following specific legislative change:
Art. 222, paras. 2, 3, 4 and 5 are repealed. (proposal for the removal of the qualification credits system)
Art. 224, para. 1 is amended as follows: (1) The raising of qualifications is carried out through programmes and in forms of the pedagogical specialist's choosing in accordance with the identified needs of pupils and the expected outcomes, the professional profile of the position held, the professional development of the pedagogical specialist, the result and recommendations from their work assessment, as well as the national, regional, municipal and school policy.
In Art. 224, a new para. 3 is added: (3) The raising of qualifications for headteachers is carried out through programmes and in forms of the headteacher's choosing with a focus on institutional management, human resource management and management of the educational process.
BESCO also recommends that in the long term the following directions for the development of the qualification system be considered:
IV. The powers of the public councils at kindergartens and schools
The Bulgarian Entrepreneurial Association (BESCO) expresses disagreement with the proposed amendments in the draft law on amendment and supplement to the LPSSE, which remove the obligation for public councils to coordinate the school curriculum and the choice of textbooks and teaching aids.
Public councils are among the few mechanisms for civic oversight and participation in the governance of educational institutions. Rather than being weakened, their functions should be strengthened in order to guarantee greater transparency, accountability and trust between the school and the parent community.
The main problem with the proposed changes is as follows:
Art. 266, para. 1 is amended as follows: (1) The public council consists of an odd number of members and includes one representative of the financing body, one representative of the regional education authority and three representatives of the parents of children and pupils from the respective institution. The composition of the public council of a school that provides training for the acquisition of professional qualifications also includes a representative of employers. In this case, the representatives of the parents of pupils number four.
Art. 270 is amended as follows: The conditions and procedure for the establishment, organisation and activities of the public council are regulated by rules issued by the Minister of Education and Science. Public councils are free to adopt their own internal rules, insofar as these do not conflict with the Rules.
BESCO believes that school autonomy must be balanced with active community participation. Strong public councils contribute not only to better education, but also to trust, accountability and a closer connection between institutions and families. We insist that instead of curtailing their powers, conditions be created for the strengthening and development of their role.
V. The status and functions of the heads of the regional education authorities (REA)
The Bulgarian Entrepreneurial Association (BESCO) does not support the proposed changes by which the heads of the regional education authorities (REA) will cease to be civil servants and will become bodies of the executive power with territorial competence.
The main problem with the proposed changes:
The change in the status of the heads of the REA creates conditions for increased political pressure on them and undermines the administrative independence necessary for the stable management of the education system. There is a serious risk that these positions will be politicised, being equated with the appointment and dismissal of regional governors — a common practice with changes of government. This threatens the consistency, professionalism and sustainability of educational policy at regional level.
BESCO advocates for an objective process for the selection and attestation of the heads of the REA, which includes a clear competency model for people in this position, transparent competitive procedures and assessment of the work of the heads, as well as measures in cases of failure to fulfil duties and responsibilities.
BESCO proposes the following specific drafting and additions:
Art. 252, para. 1 is amended as follows: (1) The regional education authorities are territorial administrations under the Minister of Education and Science, which provide methodological support to kindergartens, schools, regional centres for support of the inclusive education process and centres for personal development support in the respective region.
Art. 252, para. 2 is amended as follows: (2) The regional education authorities support pre-school and school management and teaching activities.
BESCO emphasises that the regional education administration must be expert and stable, not politically dependent. Only with a stable, professional and independent management layer at regional level can national policies be implemented with effectiveness, adaptability and care for the local context. We call for the preservation of the existing status of the heads of the REA as civil servants and the strengthening of their methodological and professional role.
VI. The rating system for training programmes for pedagogical specialists
The Bulgarian Entrepreneurial Association (BESCO) expresses support for the proposal in the draft law on amendment and supplement to the LPSSE introducing a rating system for additional qualification programmes for pedagogical specialists. This is an important step towards increasing the transparency, effectiveness and accountability of the public and private resources invested in teacher training.
We support the following elements of the proposal:
Nevertheless, we draw attention to one serious omission in the proposed model:
The training programmes of higher education institutions and trade unions are not included in the rating register, despite the fact that:
This creates inequality, undermines transparency and deprives teachers of the real opportunity to make an informed choice based on proven results.
In this regard, BESCO considers it important that the programmes of higher education institutions, specialised service units and trade unions that provide training for pedagogical specialists and receive public funding also be included in the register with a rating system.
In this way it will be ensured that all training providers — regardless of their legal form — are subject to the same monitoring and public oversight. This is of essential importance for raising the quality of teaching in Bulgarian schools and kindergartens.
VII. Assessment of pupils
The Bulgarian Entrepreneurial Association (BESCO) supports the efforts to more clearly define the forms of assessment and to increase predictability and consistency in the national examination system. We consider that the introduction of definitions in the law and the clarification of the scope of assessments is a positive step.
We support the following proposals in the draft law:
Nevertheless, we express concern that the proposed changes are limited and do not address the systemic challenges in the field of assessment.
Recommendations: BESCO recommends that the following be included in future regulatory acts related to the implementation of the changes:
VIII. Mentoring of trainee teachers and methodological support
The Bulgarian Entrepreneurial Association (BESCO) supports the proposed changes aimed at more structured support for trainee teachers and the development of mechanisms for methodological assistance in schools and kindergartens.
Specifically, we support the following amendments:
BESCO considers that the proposed changes are only an initial step and that deeper structural solutions are needed:
1. Real change in the training of future teachers. Current university training is often theoretical and far from the reality of the classroom. A substantial reform is needed that includes extended, real and supervised practice in a school environment, with the active participation of base teachers.
2. Preparation of base teachers. In order to successfully fulfil the role of mentors, base teachers must undergo specialised training in which they develop skills for giving feedback, providing support and building teaching competencies in trainees.
3. Lack of a comprehensive mentoring system. The current approach relies on individual roles and possibilities, but lacks a consistent and integrated support system covering the period from the university placement to the first years of teaching service, and quality training for mentors is also lacking.
4. Need for new roles and professional positions. We propose that consideration be given to the normative introduction of new positions that address the diversity of needs in the school environment, including:
BESCO believes that for the teaching profession to be sustainable, attractive and effective, a strong system of support at the point of entry into the profession must be built. This includes not only administrative and methodological measures, but also a culture of collegiality, learning and professional responsibility.
IX. Preservation of the right of headteachers to return to their position after holding a political post
The Bulgarian Entrepreneurial Association (BESCO) does not support the proposal granting headteachers of educational institutions the automatic right to return to the position they previously held after having been elected or appointed to political posts such as members of parliament, ministers, mayors, regional governors or other single-person and collective bodies of power.
Main arguments against the proposal:
1. Political participation is a personal choice, not an institutional commitment. The decision to take up a political post is the personal right of every citizen. However, it should not be accompanied by an automatic right to retain a managerial position in a public institution. The education system must not be held hostage to political rotation.
2. Violation of the stability and autonomy of the school. The temporary nature of the appointment of a substitute for the headteacher who has taken up a political post, for an indeterminate period, creates a lack of predictability, blocks strategic planning and places the institution in a management vacuum that may last for years.
3. Potential for abuse of the position. The possibility of automatic reinstatement to a managerial position after participation in a political cabinet or body of power opens the door to political influence and pressure, which is contrary to the principles of professionalism, autonomy and political neutrality of the education system.
BESCO calls for:
X. Introduction of the subject "Virtues and Religions"
This topic was widely discussed both in society and specifically in business circles. After conversations with many entrepreneurs, we express our position that we do not support the proposal for the introduction of a compulsory subject "Virtues and Religions" in the compulsory lesson hours, nor the change permitting confessional education in the secular education system.
Although a choice between programmes with and without a religious element is proposed, the draft creates serious ambiguities and risks, including:
We consider that education must remain secular, inclusive and oriented towards knowledge and skills, without the introduction of compulsory subjects with the potential for division along religious lines.
Additional topics and proposals that we consider essential:
We consider that the Draft Law on Amendment and Supplement to the Law on Pre-School and School Education should also cover the following key topics, which are currently absent but are of decisive importance for the future of the Bulgarian education system:
In connection with these important topics, we make the following proposals for additional changes to the LPSSE:
Section I. Subject matter of the law
Art. 2, para. 4 is amended as follows: "(4) The participants in the educational process and the institutions partner with municipalities, parent and civil organisations, industry associations and other stakeholders."
Section II. Principles in the system of pre-school and school education
Art. 3, para. 2, item 1 is amended as follows: "1. a unified state educational policy for guaranteeing the right to quality pre-school and school education;"
Art. 3, para. 2, item 8 is amended as follows: "8. innovativeness in pedagogical practices and in the organisation of the educational process on the basis of scientific justification and forecasting of the results of innovations;"
Art. 3, para. 2, item 9 is amended as follows: "9. effectiveness and efficiency in pedagogical practices, the management of educational institutions and policies in the field of education at national and local level."
Art. 3, para. 2, item 10 is amended as follows: "10. transparency of governance and predictability of the development of pre-school and school education;"
Art. 3, para. 2, item 11 is amended as follows: "11. autonomy for the conduct of educational policies, self-governance and decentralisation;"
In Art. 3, para. 2, a new item 12 is created: "12. commitment of the state, municipalities and non-profit legal entities, employers, parents and other stakeholders and dialogue between them on matters of education"
In Art. 3, para. 2, a new item 13 is created: "13. institutional accountability and professional responsibility for achieved objectives and results at all levels in the system"
In Art. 3, para. 2, a new item 14 is created: "14. financial provision and efficiency with the aim of achieving all the above-listed principles"
In Art. 3, para. 2, a new item 15 is created: "15. Encouragement of shared activities between schools"
In Art. 3, para. 2, a new item 16 is created: "16. Use and analysis of information in the system of pre-school and school education."
Section III. Objectives of pre-school and school education
Art. 5, para. 1 is amended as follows: "(1) The main objectives of pre-school and school education are: 1. guaranteeing equal access 2. ensuring quality education for every child and every pupil, in every settlement and in every type of school."
Art. 5, para. 2 is amended as follows: "(2) Equal access means the provision of equal opportunities for admission and participation in the system of school and pre-school education, including an accessible, safe and stimulating physical environment, a supportive human environment, as well as inclusive education according to the individual needs of children and pupils.
Equal access also includes equally high quality of education in all different types of settlements in the country and in every school.
To ensure equal access, state and municipal institutions pursue a policy of improving the coverage of children and pupils in pre-school and school education and preventing the early dropout of pupils from school."
In Art. 5, a new para. 3 is added: "(3) Quality education means ensuring optimal conditions for the acquisition of competencies that contribute to successful personal and professional development according to the needs of modern society, and supporting the wellbeing of children and pupils."
In Art. 5, a new para. 4 is added: "(4) Competencies represent a combination of: 1. Knowledge, consisting of the facts, data, concepts, representations and theories that are already established and help the understanding of a specific field or subject. 2. Skills, representing the ability to reason and use existing knowledge to achieve given outcomes. 3. Attitudes, representing the values, predispositions and ways of thinking that motivate the attitude, action and reactions in a given situation."
In Art. 5, a new para. 5 is added: "(5) Competencies are divided into key competencies and competencies specific to pre-school and school education. Key competencies are necessary for every person, are developed through lifelong learning, in any conditions — in educational institutions, but also in the family, at the workplace and in society. Each of them is equally important relative to the others. They overlap and are interconnected.
Embedded in the key competencies are important transferable skills such as socio-emotional skills, critical thinking, problem-solving skills, teamwork, communication and negotiation skills, analytical skills, creative abilities and intercultural skills.
The key competencies, as well as minimum requirements for the results of their development in institutions at the end of each stage or level of education, are determined by the state educational standard for general education preparation."
In Art. 5, a new para. 6 is added: "(6) The wellbeing of children and pupils represents their physical and mental condition, as well as position in society, which contribute to the optimal development of their physical, emotional, cognitive and spiritual potential, and prepare them for a full and satisfying life in modern society.
Specific methods for assessing wellbeing, as well as minimum requirements for its achievement in institutions in the system of pre-school and school education, are determined by the state standard for quality management and the state standard for inspection."
A new Art. 6a is created: "Art. 6a. (1) To achieve the objectives referred to in Art. 5 and apply the principles referred to in Art. 3, no less than 4% of gross domestic product is allocated for the pre-school and school education sector.
The average teacher salary may not be less than 125% of the average salary in the country.
The minimum amount of the remuneration of a headteacher is double the average teacher remuneration."
Chapter Three. STATE EDUCATIONAL STANDARDS
Art. 22, para. 1 is amended as follows: "(1) The state educational standards are drawn up in accordance with the principles referred to in Art. 3 and to achieve the objectives referred to in Art. 5."
Art. 22, para. 2 is amended as follows: "(2) The state educational standards ensure the principle of autonomy for the conduct of educational policies, self-governance and decentralisation, by setting common objectives and principles, without restricting educational institutions in the ways and methods of achieving them."
Art. 22, para. 3 is amended as follows: "(3) The state educational standards are a set of mandatory requirements for the results in the system of pre-school and school education, as well as for the conditions and processes for their achievement."
Art. 22, para. 4 is amended as follows: "(4) The state educational standards in the system of pre-school and school education are for: 1. pre-school education; 2. the acquisition of the standard Bulgarian language; 3. the curriculum; 4. general education preparation; 5. specialised profile preparation; 6. the acquisition of vocational qualifications; 7. inclusive education; 8. civic, health, environmental and intercultural education; 9. the assessment of the results of pupil learning; 10. information and documents; 11. institutions; 12. the physical environment and the information and library provision of kindergartens, schools and centres for personal development support; 13. cognitive books, textbooks and teaching aids; 14. the status and professional development of teachers, headteachers and other pedagogical specialists; 15. quality management in institutions; 16. the inspection of institutions in the system of pre-school and school education; 17. the financing of institutions; 18. the standardisation and remuneration of labour; 19. the organisation of activities in school education."
Chapter Six. SCHOOL EDUCATION Section II. School preparation — nature and content
Art. 76, para. 7 is amended as follows: "(7) The subjects under paras. 1, 2, 3, 4 and 6 are studied according to curricula approved by the Minister of Education and Science. The curricula determine the minimum number of lesson hours for their study."
Art. 77, para. 1 is amended as follows: "(1) General education preparation develops key competencies: 1. competencies in the field of the Bulgarian language; 2. skills for communication in foreign languages; 3. mathematical competency and core competencies in the field of natural sciences and technology; 4. digital competency; 5. skills for learning; 6. social and civic competencies; 7. initiative and entrepreneurship; 8. cultural competency and skills for expression through creativity; 9. skills for supporting sustainable development; 10. skills for a healthy lifestyle and sport.
The general educational competencies, as well as minimum requirements for their development in institutions at the end of each stage or level of education, are determined by the state educational standard for general education preparation."
Art. 78, para. 1 is amended as follows: "(1) On the basis of the state educational standard for general education preparation, the Minister of Education and Science approves framework curricula for each general education subject for each educational stage, specifying the competencies of pupils as expected learning outcomes."
Art. 80, para. 1 is amended as follows: "(1) The minimum general education preparation in the basic level of education and in the first high school stage is the same for all types of schools. Every school has the freedom to create its own curricula."
Art. 83, para. 1 is amended as follows: "(1) Specialised profile preparation develops competencies building on the key competencies, and covers in-depth competencies in a given profile. The specialised profile competencies, as well as minimum requirements for their development in institutions at the end of each stage or level of education, are determined by the state educational standard for specialised profile preparation."
Art. 84, para. 1 is amended as follows: "(1) Vocational preparation develops competencies building on the key competencies, and covers in-depth competencies in a given profile. The vocational competencies are necessary for the acquisition of vocational qualifications, as well as for the acquisition of the right to practise professions whose exercise requires such qualifications, including for the practice of regulated professions. The vocational competencies, as well as the minimum requirements for achieving the state educational standard for the acquisition of vocational qualifications, are determined in the Law on Vocational Education and Training."
Art. 86, para. 1 is amended as follows: "(1) Specialised preparation develops competencies building on the key competencies. The specialised competencies, as well as minimum requirements for the results of their development in institutions at the end of each stage or level of education, are determined after coordination between the respective specialised school, the Minister of Education and the respective Minister of Culture, Sport or, under the conditions and in accordance with the procedure of the religious denomination — in the case of religious education in theological schools."
Section VII. Assessment of the results of pupil learning
Art. 119, para. 3 is amended as follows: "(3) At the end of grades IV, VII and X, a national external assessment is conducted to establish the degree of achievement of the competencies for the respective stage, determined by the state educational standard for general education preparation.
The national external assessment serves for the evaluation of the results of the policies of the Minister of Education and Science, municipalities and other state bodies competent in the field of education. The assessment from the national external assessment is not entered in the diploma of pupils and may not serve for admission.
The examination questions for the national external assessment and state school-leaving examinations are prepared by professional institutions in accordance with good practices in psychometrics and the theory of item response."
Art. 119, para. 4 is amended as follows: "(4) The Ministry of Education and Science introduces a mechanism for publicity, transparency and annual analysis of the results of the national external assessments, which is used for developing policies and measures for guaranteeing a sustainable raising of the quality of education. All analyses and assessments of policies are published on the ministry's website within one week of their preparation."
Art. 121 is amended as follows: "The main components of assessment, the types and forms of assessment, as well as the organisation, conditions and procedure for carrying it out are determined by the state educational standard for the assessment of the results of pupil learning.
The state standard for the assessment of the results of pupil learning takes into account cognitive and non-cognitive skills, engagement and wellbeing, and is drawn up in a manner that encourages free thinking and limits the rote learning of study material."
Art. 145, para. 2 is amended as follows: "(2) The admission of pupils in grade VIII in schools under Art. 142, para. 3, item 1 and of pupils from combined schools in grade XI in schools under Art. 142, para. 4, as well as in the cases provided for in the state educational standard for the organisation of activities in school education, is carried out on the basis of the results of the admission criteria determined by the school. Schools have the right to prepare and organise their own entrance examinations."
Chapter Nine. CHILDREN AND PUPILS Section I. Basic rights and obligations
Art. 171, para. 1 is amended as follows: "(1) Children and pupils, respectively, have the following rights: 1. to have their rights and dignity respected; 2. to be taught and educated in a healthy, safe and secure environment; 3. to be respected as active participants in the educational process; 4. to choose the profile and profession; 5. to choose between the subjects or modules offered by the school for study in the elective and optional lesson hours; 6. to receive library and information services; 7. to receive information relating to their education, upbringing, rights and obligations; 8. to receive general and additional support for personal development; 9. to be informed and counselled in connection with the choice of education and/or profession; 10. to participate in project activities; 11. to give opinions and proposals regarding school activities, including the elective and optional lesson hours; 12. through the forms of pupil self-governance, to participate in decision-making affecting school life and the school community, including the school curriculum; 13. to receive assistance from the school and the bodies of local self-governance in expressing their opinion on matters that directly affect them, as well as in participating in the life of the community; 14. to be encouraged with moral and material rewards."
Chapter Fifteen. QUALITY MANAGEMENT
Art. 271, para. 1 is amended as follows: "(1) Quality management within the meaning of Art. 5 is a continuous process of organisational development, based on the analysis, planning, implementation of activities, assessment and introduction of improvements in the work of kindergartens and schools."
Art. 271, para. 3 is amended as follows: "(3) The state guarantees quality through the following mechanism of interconnected elements:
1. In accordance with the provisions of Art. 5, the main objectives of Bulgarian education are defined by the concepts of wellbeing and competencies. Minimum requirements for the achievement of the wellbeing of pupils in institutions in the system of pre-school and school education are determined by the state standard for quality management and the state standard for the inspection of kindergartens and schools. The competencies are grouped into categories, updated periodically, minimum national requirements for their development are set, and indicators and methods for reporting and assessing the results of learning in them are formulated. Responsibility for this lies with the Minister of Education and Science.
2. The indicators and methods for reporting and assessing the results of learning in the respective competencies, by educational stage and level, formulated in the respective state educational standards, are the basis of the instruments for national external assessment and the state school-leaving examinations. Responsibility for this lies with the Director of the Institute of Education and the Minister of Education and Science.
3. Information in the system of pre-school and school education is collected, processed, stored and used through the National Electronic Information System for Pre-School and School Education (NEISPSSE) according to the principle of minimum administrative burden relative to maximum functionality and interoperability. NEISPSSE ensures maximum public access to information, in compliance with the Law on Personal Data Protection, with the aim of effective civic oversight of the work of institutions in the system of pre-school and school education. The rules for the collection, processing, storage and use of information in the system of pre-school and school education are determined by the state standard for information and documents for the system of pre-school and school education. Responsibility for this lies with the Minister of Education and Science.
4. Teachers and other pedagogical specialists are attested in accordance with the deadlines, procedures and requirements of the state educational standard for the status and development of teachers, headteachers and other pedagogical specialists, and under the conditions of Art. 228. The main indicators in the attestation are the educational value added, measured through the national external assessment instruments, as well as objective data that can be verified through NEISPSSE. Responsibility for this lies with the headteacher of the institution.
5. The headteacher is attested in accordance with the deadlines, procedures and requirements of the state educational standard for the status and development of teachers, headteachers and other pedagogical specialists. The main indicators in the attestation are the educational value added of the institution, measured through the national external assessment instruments, objective data that can be verified through NEISPSSE, as well as the reports from the inspection of the institution. Responsibility for this lies with the Public Council of the institution.
6. Institutions in the field of pre-school and school education carry out internal quality assessment under the conditions and in accordance with the procedure determined by the state educational standard for quality management in institutions. The main indicators in self-assessment are the educational value added of the institution, measured through the national external assessment instruments, and objective data that can be verified through NEISPSSE. Responsibility for this lies with the headteacher of the institution.
7. Institutions in the field of pre-school and school education are inspected under the conditions and in accordance with the procedure determined by the state educational standard for the inspection of kindergartens and schools. The main indicators in the inspection are the educational value added of the institution, measured through the national external assessment instruments, and objective data that can be verified through NEISPSSE. The main function of the inspection is to verify the conformity between the information submitted by the institution and the actual conditions, processes and attitudes connected to the work of the institution. Responsibility for this lies with the Director of the National Inspectorate of Education.
8. The regional education authorities provide support to pedagogical specialists when such a need is declared by the headteacher; to the headteacher when deficits in their work are identified during the attestation, as well as for the implementation of the guidelines of the National Inspectorate of Education. Responsibility for this lies with the Minister of Education and Science."
Art. 271, para. 4 is amended as follows: "(4) Self-assessment is carried out no less than once every two years under the conditions and in accordance with the procedure determined by the state educational standard for quality management in institutions, and inspection — under the conditions and in accordance with the procedure determined by the state educational standard for the inspection of kindergartens and schools."
Chapter Sixteen. FINANCING AND PROPERTY Section I. Financing
Art. 280, para. 3 is amended as follows: "(3) The funds from the state budget are for: 1. the maintenance of the activities for the upbringing and education of children and pupils; 2. supporting equal access and personal development support; 3. the development of kindergartens, schools and centres for personal development support; 4. the assessment of the results and quality of education and the effectiveness of educational policies through external impact assessments; 5. the implementation of national programmes for the development of education."
12 June 2025 Sofia
Yours sincerely,
Dobromir Ivanov Executive Director Bulgarian Entrepreneurial Association BESCO
Leadership & Advocacy Academy doesn’t only develop individual participants. For BESCO, it is a long-term investment in a stronger ecosystem - building capacity where it matters most: within the organizations, institutions, and communities that shape the public environment.
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