UPEE participated in the working meeting with the OECD for Bulgaria held on 18.06.2021 to review the reform of public administration – regulatory policy and environment, reducing the administrative burden, active participation of business in policy making and the legislative process, and reducing corruption.
In our opinion, we take the position that frequent changes in the laws continue to create uncertainty in business and unpredictability in economic life and lead to the conclusion of poor quality legislation.
Micro and small businesses continue to have difficulty in meeting their administrative responsibilities for the following reasons:
- Frequent changes in the regulatory framework;
- The existence of different regulatory and administrative procedures before different bodies, without interaction with each other;
- Long administrative procedures;
- Delay in the establishment of electronic links between the systems of the various departments, due to which some administrative procedures continue to be implemented, although there is a regulatory framework for their elimination (eg the link between the Property Register and the Cadastre, the link between the Property Register and Local Revenue Directorates). also poor functioning of some of the electronic service systems – for example the electronic services of the directorates for administration of local revenues in the CA);
- Забавяне на електронното правителство като цяло.
Register reform is extremely important to unleash the potential of e-government to improve the business environment. It must optimize the organization of the registers in the state administration so as to ensure the official exchange of information and data for the provision of quality services; the possibility to provide services based on registers kept by other administrative bodies; and the quality, completeness and security of the data. The digitization of paper files will allow the transition to data-driven governance and the provision of secure, convenient, integrated end-to-end e-services to citizens and businesses.
In our opinion, the expert principle is insufficiently represented in the legislative process. Impact assessment is a mandatory element of the legislative process (introduced through the amendments to the Law on Normative Acts in 2016) The study of the legislative activity of the 44th National Assembly, conducted by the National Center for Parliamentary Research (data cover 663 bills) submitted during the eleven parliamentary sessions for the period 19 April 2017 – 25 March 2021 which are subject to impact assessment) shows that only 6.7% of the bills cite different types of reasons for the legislative initiative / grounds for adoption analyzes and scientific expertise.
The SSE expressed the position that the powers of the Institute of Public Administration at the Council of Ministers should be expanded, as it would be entrusted with additional functions for preparing studies, analyzes and forecasts for the needs of strategic planning. Each specific department undoubtedly maintains databases in the field of its competence, but for the process of strategic planning it is necessary to perform centralized observations and analyzes of key processes and policy areas in order to be able to provide adequate initial information.
In this regard, the use of new technologies for the analysis of large databases, for the creation of public sector database networks to facilitate and support strategic planning activities should be encouraged.
In our opinion, progress in terms of coordination between the various institutions in the fight against corruption will be achieved in the implementation of the new National Strategy for Prevention and Counteraction to Corruption (2021-2027), as well as the Roadmap to it. Regarding Priority 5 Exemption of citizens from “petty” corruption, the measure Limiting the interference of the human factor in the provision of administrative services through the further development of electronic administrative services and the measure Upgrading the capacity of institutions related to the prevention of corruption in the field are correctly envisaged. of public procurement. As an employers’ organization, we believe that the state should pay special attention to the implementation of these two measures.
Appropriate action needs to be taken to ensure prevention and through accompanying criminal repression means. The state should carry out active and purposeful socio-economic prevention by influencing the legal consciousness and building the legal culture of the citizens. In connection with Priority 6 Creating an environment for public intolerance to corruption, we assess as positive the inclusion of the specific measure Involvement of business to create an environment intolerant of corruption through honest behavior (integrity).
We believe that the activity of the National Council for Anti-Corruption Policies should be continued and the cooperation between the specialized bodies for prevention and counteraction of corruption (PRB, KPCONPI) should be strengthened in order to improve the policies for prevention of corruption. The problem with corruption is not the lack of criminal legislation, but the prevention, detection and punishment of this negative social phenomenon.