OFFICIAL PROPOSAL ON BEHALF OF BATA

to the new Government of the Republic of Bulgaria of the “Progressive Bulgaria” coalition

Dear Ladies and Gentlemen,

The Bulgarian Association of Travel Agencies (BATA), as the first and oldest industry organization, established in 1992, and as the nationally and internationally representative organization of tour operators and travel agents, congratulates the new government of the “Progressive Bulgaria” coalition and expresses its readiness for constructive partnership in the interest of the sustainable development of Bulgarian tourism.

1. The need for consistency and continuity in tourism governance

In recent years, the sector has suffered from the frequent change of leadership in the Ministry of Tourism, which has led to the interruption of ongoing initiatives, lack of institutional memory, and the inability to plan long‑term.

BATA has repeatedly sent alerts, opinions, and proposals to the Consumer Protection Commission (CPC), political parties, the Ministry of Tourism, the Tourism Committee of the National Assembly, the Ministry of Foreign Affairs, and other institutions. Despite this, many of the issues raised remain unresolved precisely due to the lack of continuity.

2. Main unresolved problems of tour operators and travel agencies

• Visa policy and administrative barriers • The grey economy, generating turnover of more than half a billion euros • Unequal treatment between different segments of the tourism sector • Outdated regulatory framework • Lack of a long‑term strategy • Insufficient support for small and medium‑sized agencies

3. BATA’s proposal for a Tourism Guarantee Fund (TGF)

BATA supports the creation of a TGF, but without additional financial burdens for tour operators.

Our proposal:

• Companies with an annual turnover of up to EUR 4,000,000 should remain covered only by insurance, as is currently the case. • Companies with higher turnover should be included in the TGF.

This model is fair, proportional, and aligned with market realities.

4. Additional specific proposals by BATA

4.1. Digitalization and modernization of administrative services

• Introduction of electronic visas (e‑visa) for key markets • A unified digital portal for all tourism‑related services • Automated document‑processing systems • Reducing administrative burden through digitalization

4.2. Reform of the Tourism Act

• Clear rules for online platforms offering tourism services • Proportional requirements for insurance and guarantees • Enhancement of the “Tour Operator Liability” insurance so that it is valid in cases of force majeure both in Bulgaria and abroad • Synchronization with European regulations • Timely notification of the industry about upcoming changes and mandatory consultation with the sector • Updating the definitions of tour operator and travel agent activities

4.3. Combating the grey economy

BATA insists on full government support in combating the grey economy, which includes:

• Individuals offering tourism services without registration, license, or insurance • Legal entities performing tour operator or agent activities in violation of the Tourism Act • Entities hiding turnover and not paying taxes, with the total volume of this unregulated market exceeding half a billion euros

BATA proposes:

• An inter‑institutional control mechanism (Ministry of Tourism, Ministry of Finance, National Revenue Agency, CPC, Ministry of Interior) • Monitoring of online platforms and social networks • Fast procedures for sanctioning and blocking illegal offers • A public register of identified violations

4.4. Improving the business environment

• Reducing administrative fees for SMEs • Tax incentives for companies developing inbound tourism • Easier access to financing for digitalization • Training and qualification programs for staff • Improved coordination between institutions

4.5. A national 20‑year strategy for tourism

The strategy should include:

• Goals for the development of inbound, outbound, and domestic tourism • Visa policy aligned with global trends • Mechanisms for sustainability and crisis management • Development of new markets • Annual monitoring and public reporting

4.6. Establishment of a permanent Consultative Council on Organized Tourism

With participation from:

• Ministry of Tourism • Ministry of Foreign Affairs • Ministry of Transport • Ministry of Finance • Consumer Protection Commission • National Revenue Agency • BATA and other industry organizations

Functions:

• Monitoring the implementation of identified issues • Developing policies based on expert analysis • Coordination between institutions during crises • Ensuring continuity during leadership changes • Annual progress reporting

5. Conclusion

BATA believes that through consistent policy, dialogue, and partnership between the state and the industry, sustainable development of Bulgarian tourism can be achieved. Tour operators and travel agents are the backbone of organized tourism, and their role must be recognized and supported.

BATA expresses its readiness for an immediate meeting with the new leadership of the Ministry of Tourism and all relevant institutions to discuss concrete steps.