TO:
MR. RUMEN RADEV
PRIME MINISTER
OF THE REPUBLIC OF BULGARIA
and
MR. VASIL GOLEMANSKI
CHAIRMAN OF THE
FINANCIAL SUPERVISION COMMISSION
Regarding Your Ref. No. 92-00-213/15.05.2026
COPY TO:
MS. SONYA BOZHIKOVA
HEAD OF THE RECEPTION DEPARTMENT
AT THE ADMINISTRATION OF THE COUNCIL OF MINISTERS
Regarding Your Ref. No. 642/26 of 11.05.2026
MR. GALAB DONEV
MINISTER OF FINANCE
OF THE REPUBLIC OF BULGARIA
MS. MIHAELA DOTSOVA
CHAIRPERSON OF THE NATIONAL ASSEMBLY
OF THE REPUBLIC OF BULGARIA
MS. VELISLAVA DELCHEVA
OMBUDSMAN OF THE REPUBLIC OF BULGARIA
MR. ALEKSANDAR KOLYACHEV
ACTING CHAIRMAN OF THE
CONSUMER PROTECTION COMMISSION
MR. ROSEN KARADIMOV
CHAIRMAN OF THE
COMMISSION FOR PROTECTION OF COMPETITION
DEAR MR. RADEV,
DEAR MR. GOLEMANSKI,
In connection with the MEMORANDUM submitted to the Prime Minister of the Republic of Bulgaria, signed by me as the representative of 79 motorcycle clubs, groups and organizations of free motorcyclists in the Republic of Bulgaria, as well as in connection with the subsequent communication from the Financial Supervision Commission, I hereby state unequivocally that:
I HAVE NOT SUBMITTED AN INDIVIDUAL COMPLAINT TO THE FINANCIAL SUPERVISION COMMISSION.
In connection with the MEMORANDUM submitted to the Prime Minister of the Republic of Bulgaria, signed by me as the representative of 79 motorcycle clubs, groups and organizations of free motorcyclists in the Republic of Bulgaria, as well as in connection with the subsequent communication from the Financial Supervision Commission, I hereby state unequivocally that:
The official MEMORANDUM submitted to the Council of Ministers was addressed to the Prime Minister of the Republic of Bulgaria and signed and supported by 79 motorcycle clubs, groups and organizations of free motorcyclists. The remaining institutions were copied solely because of their competence regarding the different aspects of the issue and in order to keep them officially informed of the communication and the public concern surrounding the matter.
It is unacceptable for the institutions to speak about future legislative amendments when, at present, there is no sufficiently effective control over the implementation of the existing legislation and compliance with Article 489, Paragraph 4, Item 4 of the Insurance Code, where, following previous protests, the possibility was introduced to take into account the specific characteristics of category “L” motor vehicles.
The Insurance Code still allows a different approach to be applied to these vehicles. Nevertheless, for years the insurance sector continued to offer primarily one-year insurance policies with the option of payment in four instalments, under which a significant proportion of motorcyclists pay the first two or three instalments and then discontinue payments outside the active riding season.
This model did not emerge suddenly but existed for years and was visible to the supervisory authorities. Given that representatives of both the insurance sector and the FSC now publicly acknowledge that more than 50% of premiums are never collected and that the calculations do not balance, a legitimate question arises as to why the FSC failed to undertake timely and adequate supervisory and control measures much earlier, instead allowing the accumulation of this problem to be compensated through a sharp and economically unjustified increase in insurance premiums during a period of exceptional public and economic sensitivity related to the introduction of the euro in the Republic of Bulgaria.
The letter from the Administration of the Council of Ministers clearly shows that the MEMORANDUM was officially registered and forwarded, within the respective competencies, to the Ministry of Finance and the Financial Supervision Commission, with a copy to the representative of the motorcycle community, Krasimir Pargov, pursuant to Article 112 of the Administrative Procedure Code, in conjunction with Article 20, Paragraph 1 of the Administration Act and Article 65, Item 10 of the Rules of Procedure of the Council of Ministers and its Administration.
Under these circumstances, any subsequent communication should be carried out in accordance with the established administrative procedure and procedural sequence between the competent institutions, rather than through attempts at direct communication with representatives of the motorcycle community who are not the administrative addressees of the forwarded file.
The FSC, the Commission for Protection of Competition (CPC) and the Consumer Protection Commission (CPCP) failed to take timely and adequate action even after the reports and complaints submitted by Attorney Miglena Nikolova. Instead of real action, the motorcycle community received formal administrative responses, the shifting of responsibility between institutions, a lack of genuine oversight and conduct that created a serious public perception within the motorcycle community of a lack of impartiality and effective supervision over the insurance sector.
It is particularly telling that only at 4:50 p.m. on 15 May 2026, less than an hour and a half before the officially announced nationwide protest, the Chairman of the FSC sent a letter initiating dialogue, inspections and working groups. The opportunity for a timely and constructive response by the regulatory authorities had already been missed after the first reports and meetings.
At present, communication has reached an entirely different public and institutional level following the submission of the MEMORANDUM to the Council of Ministers, the official notification of the competent institutions, the nationwide protest involving tens of thousands of participants, the official data provided by the Ministry of Interior under the Access to Public Information Act, and the significant loss of public confidence in the actions of the regulatory authorities.
We further draw attention to the fact that the official data provided by the Ministry of Interior under the Access to Public Information Act do not demonstrate any statistical increase in road traffic accidents caused by drivers of mopeds and motorcycles that could justify such a drastic increase in insurance premiums.
Nevertheless, effective oversight over the implementation of the existing legislation remains lacking, as do adequate actions by the regulatory authorities to protect consumers, verify the methodology for determining prices, and guarantee compliance with the principles of transparency, good faith and economic justification.
At the same time, actions were observed on the part of the Road Infrastructure Agency and regional road administration officials involving attempts to obstruct and hinder lawfully notified protest actions. Following the initial notifications submitted to the Agency, identical letters were sent to numerous locations throughout the country containing warnings regarding prohibitions, administrative sanctions and restrictions, forcing the organizers to submit repeated notifications for the protest processions.
These actions created additional tension, difficulties in organizing the protests, and justified concerns regarding administrative pressure on the organizers and participants in lawfully declared civil protest actions. This raises an extremely serious issue regarding the protection of the fundamental constitutional right to protest and to freely express a civic position.
In contrast, we express our gratitude to the officers of the Ministry of Interior and the Traffic Police throughout the country, who professionally and responsibly ensured the safe conduct of the protest processions and maintained public order and the safety of the participants.
We call upon the Council of Ministers to carry out a comprehensive review of the actions and omissions of the above-mentioned institutions and to take the necessary measures within its powers.
In view of all the above circumstances, and on behalf of 79 motorcycle clubs, groups and organizations of free motorcyclists in the Republic of Bulgaria, WE DEMAND THE IMMEDIATE RESIGNATIONS of:
- the Chairman of the Financial Supervision Commission;
- the Chairman of the Commission for Protection of Competition;
- the Chairman of the Consumer Protection Commission;
- the Chairman of the Road Infrastructure Agency.
The leadership of these institutions has allowed a serious loss of public confidence, failed to fulfil in a timely and adequate manner its obligations to protect the public interest and the rights of citizens, responded only formally to the submitted reports, and allowed public tensions to escalate nationwide.
RESPECTFULLY,
KRASIMIR PARGOV
Representative of 79 motorcycle clubs and groups in the Republic of Bulgaria, in accordance with the attached list.
