There are two specific points where the European Commission's regular report on Bulgaria has failed to be critical, and where the Bulgarian government still needs to prioritise reform.

This was included as part of the brief assessment of the European Commission's 2004 Regular Report on Bulgaria's progress towards accession made by Laura Parker, programme director for Bulgaria from Save the Children UK- one of the NGOs which have prepared an Alternative Regular Report on Bulgaria's Progress Towards EU Accession.

According to Parker no mention is made by the EC of the continuing high number of children in institutions (although the EC report does criticise the conditions in institutions and notes the lack of strategy in this area). "And there is no recommendation for greater transparency in the international adoption system," she said wrapping some of the critics for the report. .

In general, the coalition of Bulgarian based NGOs that produced the alternative report with expertise in the field of social and human rights, said they are very pleased to see that the EC shares their assessment of the overall situation regarding child welfare in Bulgaria. "And in particular support its conclusion that there is no comprehensive approach to the closure of institutions on the basis of agreed criteria and to develop and promote alternative forms of care," Parker told The Sofia Echo.

However, criticism for the number of children in institutions does not exhaust the criticism of the EC regarding discriminatory double-pricing of foreigners.

"As regard the right for establishment and the freedom to provide services, efforts are required to unequivocally eliminate the remaining restrictions and discriminatory measures on foreigners despite some corrective actions," the EC regular report said.

It continued as regards to free movement of persons, progress was limited and considerable further work is needed concerning mutual recognition of qualifications (especially as regards curricula and training requirements) and the establishment of the necessary administrative bodies for the future co-ordination of social security systems. "Concerning the right of establishment and freedom to provide services, Bulgaria made further progress as regards the non-discriminatory regime of national treatment for foreigners performing economic activities in Bulgaria," report said.

Existing practices in the Bulgarian tourism sector, namely double pricing, are discriminatory measures according to the acquis and should therefore be abolished," report said.

As The Sofia Echo wrote in its edition on September 17 the implementation of the Protection against Discrimination Act from January 1, 2004 is not put into force and this is criticised by the EC. According to the legislation, any discrimination based on gender, race, religion, faith, beliefs, political affiliation, nationality or citizenship will be subject to the imposition of a fine, and the penalty ranges between 250 to 2000 leva.

Fears of European Affairs Minister Meglena Kuneva that implementation of the 90-per cent EU- harmonised legislation will be reflected in the report from earlier in September were reflected in the regular report.

Further, according to the report Bulgaria has made further progress in establishing a general, non-discriminatory regime ("national treatment") for foreign nationals and companies performing economic activities in Bulgaria.

On the other hand, however, the implementing legislation for the Law on Foreigners was amended in February 2004, imposing additional requirements on foreigners, including EU citizens, regarding the funds to be held for each day of their stay when entering Bulgaria and knowledge of Bulgarian when seeking to obtain a permanent residence permit.

Report said that regarding the right of establishment and freedom to provide services, the amendments made to the Law on Investment Promotion are a step on the road towards eliminating discriminations. "As regards the Law on foreigners, amendments are required to unequivocally exempt EU citizens from the rule whereby the granting of long-term residence permits is conditional on the creation of ten jobs for Bulgarian nationals," report said.