APPEAL

OF THE Federation of Transport Trade Unions

To the Government and Institutions in the Republic of Bulgaria

Regarding the upcoming restructuring of the control structures in road transport

The Federation of Transport Trade Unions /FTTU/ follows with particular attention the actions taken by the Government for the reform of road transport control and road safety.

By decision of September 9, 2026, the Council of Ministers approved an Action Plan providing for a significant change in the institutional and technological model – centralization of road control within the Ministry of Interior, creation of the Executive Agency "Road Transport Operator", change in the functions of the Executive Agency "Road Administration" and restructuring of the National Toll Administration. The concept officially presented by the Ministry of Transport and Communications also includes the construction of a unified national control system and a "Digital Core", as EA "Road Administration" ceases road checks and directs its capacity to licensing, examinations and control in enterprises, bus stations and periodic technical inspection stations.

FTTU does not dispute the need for reforms, modernization, digitalization and a more effective organization of state control. However, we believe that when a reform directly affects the structure, functions, jobs, status, remuneration and working conditions of hundreds of employees, social dialogue should not be a subsequent step, but an integral part of the very process of preparation and implementation of the reform.

This is not just a trade union appeal, but a principle embedded in national, European and international standards.

We recall that with a letter dated August 28, 2026, the CITUB requested the Government to include representative trade union organizations in the work of the Council for Administrative Reform, so that decisions affecting employment, staff numbers, status, remuneration and working conditions in the state administration are discussed with the representatives of the employees already at the stage of their preparation.

This approach also follows the principle of Art. 3 of the Labor Code, referred to in the letter of CITUB, according to which the state regulates labor and directly related relations in cooperation and after consultations with the representative organizations of workers and employees and of employers.

Also, Art. 44, para. 3 of the Civil Servant Act gives trade union organizations the right to protect the interests of civil servants through proposals, demands and participation in the preparation of acts regarding service relations, and Art. 46a, para. 3 explicitly states that all draft regulations related to service relations shall be coordinated with the trade union organizations of civil servants.

This approach is also in harmony with the European social model. Directive 2002/14/EC establishes a general framework for informing and consulting employees in undertakings and emphasizes timely information and consultation during changes in employment and in decisions leading to substantial changes in work organization. Although its scope does not directly cover the state administration as such, its inherent principle of preliminary social dialogue in restructuring is relevant as part of the European social model.

In the same direction is the international standard embedded in ILO Convention No. 151 on Labour Relations (Public Service). Although the Convention has not yet been ratified by Bulgaria, Art. 7 thereof establishes the principle of participation of civil servants' organizations in the determination of employment conditions.

From all this follows the appeal of FTTU:

We also recall that reforms must be made with the employees, not simply announced to them.

We insist that the representative trade union organizations be included in a timely manner in the discussion of specific structural and regulatory changes affecting the EA "Road Administration" and future structures. It is necessary that we receive full, accurate and reliable information about the upcoming changes and their impact on employees, so that we can promptly convey it to our trade union members.

For us, the guarantees for employment, status and legal relations of employees, remuneration and acquired social rights, staffing levels, professional development and qualification, as well as working conditions and safety are of particular importance. These are the very issues that FTTU already officially raised with the Minister of Transport and Communications on September 9, 2026, in its letter requesting a meeting.

We recall the appeal of CITUB for the creation of a permanent institutional mechanism for the participation of representative trade union organizations in the processes of administrative reform, including through participation in meetings and working groups when issues of employment, staff numbers, status, remuneration and working conditions are considered.

FTTU is ready for a constructive dialogue and active participation in the process. Our goal is not to hinder the necessary changes, but to contribute to making them well-prepared, socially responsible and sustainable.

We are convinced that the modernization of state control and the protection of workers are not opposing goals. On the contrary – successful reform requires both.

Therefore, we call on the Ministry of Transport and Communications, the managements of the affected administrations and all competent institutions to start a real, timely and permanent social dialogue with the representative trade union organizations and to include us in the process of preparation and implementation of the changes.

In this regard, we insist that the Ministry of Transport and Communications schedule a meeting with the leadership of FTTU in the short term, at which complete information about the upcoming restructuring will be presented and the consequences for the employees will be discussed. We also insist that FTTU be included in the respective sectoral, branch, working or other formats for social dialogue in which the specific changes will be discussed and prepared.

Because the people who will implement the reform in practice must also have a voice in its creation.

Federation of Transport Trade Unions