Bulgaria’s opportunity to address energy and transport poverty: The Social Climate Fund challenge

To access funding under the Social Climate Fund, the Bulgarian government must submit a draft of its national social climate plan by 30 June 2025. The European Commission will then provide comments on the draft and, following a series of consultations, approve the final version by the end of the year. 

There is much at stake. In Bulgaria, energy and transport poverty are the result of a complex mix of economic, social, and cultural factors. But the task of addressing these issues is complicated by a lack of reliable data and clear definitions, making it difficult to target vulnerable groups and select the most effective measures.  

The preparation of the national social climate plan marks Bulgaria’s first serious attempt to respond to these challenges in a comprehensive and strategic way, with expectations understandably high. 

Civil society recommendations 

Over the past year, a coalition of Bulgarian civil society organisations – including Za Zemiata, WWF Bulgaria, and Habitat Bulgaria – as well as associations representing small businesses in energy efficiency and building renovation, has been actively engaging in the process.  

The coalition has already submitted three formal statements to the Bulgarian government, expressing their concerns about the organisation and coordination of the plan. Regrettably, the first two statements were disregarded, and the prospects for meaningful cooperation remain uncertain. 

In its most recent communication, submitted in March 2025, the coalition put forward a series of recommendations to various government ministers and parliamentary committees. These proposals aim to ensure that the reforms and investments underpinning the plan are delivered on time, and result in social and climate benefits. The coalition urged the government to: 

• create an open and transparent platform for dialogue that brings together the national coordination bodies responsible for drafting the plan and managing the fund, regional and municipal authorities with on-the-ground knowledge of local challenges, and civil society organisations and small businesses, whose close ties with communities offer valuable insights into citizens’ needs; 

• engage scientific institutions in these discussions at the earliest possible stage to ensure the data informing the plan is robust and reliable; 

• identify vulnerable groups and their specific needs through an inclusive and evidence-based process, ensuring that relevant measures and reforms are oriented to regional and local contexts; and 

• ensure that all proposed measures contribute clearly and measurably to emissions reductions in line with the goals of the Social Climate Fund.

Missed opportunities and unacceptable delays  

Unfortunately, instead of pursuing an inclusive, science-based approach, the process has fallen short – with less than a month remaining before the draft plan is due.  

In 2024, the Bulgarian government declined invitations from the European Commission’s Directorate-General for Climate Action to apply for technical assistance – support specifically designed to help national governments prepare and finance the development of their social climate plans. 

Much of that year was then consumed by internal governmental debates about which ministries should lead the process and which should play supporting roles. These discussions were further disrupted by multiple changes to institutional structures and civil-servant positions. 

Finally, in April 2025, the government published a framework document for public consultation, outlining the governance structure for developing the national social climate plan. Regrettably, this process failed to meet the minimum standards for transparency and participation. There were no open working groups for interested or affected members of civil society, no clear pathways for exchanging information or expertise, and no information on the application of data standards. 

Institutional resistance and poor strategic planning 

This is not the first time the Bulgarian government has resisted inclusive processes and shown reluctance to engage in meaningful reform and strategic dialogue on the root causes of the environmental and social challenges facing the country.  

Too often, the government has avoided adopting transparent procedures, clear timelines, and well-defined responsibilities for planning and implementation. Instead, decision-making has favoured the interests of entrenched ‘business-as-usual’ lobbies and centralised, state-controlled operations. 

The public is frequently left in the dark about missed opportunities for financial support that could enable greener, more progressive measures to improve their lives. This inertia has already resulted in inadequate planning and implementation across several EU investment and reform instruments, including the national energy and climate plan (currently the subject of a Commission infringement procedure), the Just Transition Fund, and the Modernisation Fund. It has also contributed to the effective shutdown of Bulgaria’s access to funds via the Recovery and Resilience Facility, with the second payment suspended for well over a year now. 

Short-sighted planning threatens long-term outcomes 

Public engagement in the planning process has been minimal. The first stakeholder consultation meeting took place on 5 February 2025, organised by the Directorate-General for Climate Action. However, this was not followed by a structured or inclusive process. 

The second consultation meeting, held on 13 May 2025 at the Council of Ministers, confirmed many of the concerns already raised by civil society. At the session, representatives from the responsible ministries acknowledged the systematic lack of data. And although several draft measures were presented – most of which broadly align with the requirements outlined in the Social Climate Fund Regulation – there was still no clear identification of vulnerable groups or their geographic distribution. 

At this meeting, officials also explained that all justifications would be elaborated further. However, deciding on measures before clearly defining the problems they are meant to address or identifying the groups of citizens and businesses most susceptible to energy and transport poverty is a clear sign of flawed planning.

Looking ahead 

There’s still time to prepare and submit an adequate, targeted plan that delivers social and climate benefits for Bulgarian citizens. Constructive input from interested partners and citizens remains essential. Equally important will be the role of the European Commission in upholding the standards set out in the Social Climate Fund Regulation, particularly regarding the quality of public consultation and the overall coherence of the plans.  

If used effectively, the Social Climate Fund could substantially improve the lives of Bulgaria’s most marginalised citizens. To ensure these people are not left behind, Bulgarian civil society will continue to propose constructive solutions and communicate them to national and regional authorities, as well as the relevant services of the European Commission.