The topic of the switch to digital broadcasting is a difficult one to explain, but an important one for several reasons.

It is linked to hard-to-discern patterns of political and economic dependence, to non-transparent tenders without clear rules.

It is often spoken about in specialist terms that most people do not understand. Yet the stakes associated with the transition to digital broadcasting of television signal loom too large to be ignored.

As an European Union member state, Bulgaria has committed to switch from analogue to digital broadcasting within a certain time frame, under specific and clear criteria.

The state and companies involved in the switch must devote substantial financial resources to make it actually happen, which is why rules are important. Along the chain of significant factors, however, serious flaws and exceptions from rules are glaring.

Under the Electronic Communications Act, analogue broadcasting in Bulgaria is to cease on September 1 2013, with a public information campaign to publicise the switch mandated to conclude no sooner than November 30 2013.

Meeting these deadlines can only benefit the competition on the TV market and the general public, the recipients of advanced digital services. But is another delay possible?

A week ago, the Cabinet allocated 17.5 million leva to the Transport Ministry to cover costs related to the digital switch.

The funds were earmarked in the 2012 Budget and at least part of it will be used to purchase set top box digital decoders (which allow showing digitally-broadcast signal on analogue TV sets) for those who cannot afford such devices.

The rest of the funds will go to the public information campaign about the introduction of terrestrial digital television. In other words, this amount will cover the production costs of making campaign spots and to buy air time and print space.

It may seem that everything is progressing logically, but that is not the case, for several reasons.

Prior to approving Budget spending for the digital switch, there should be a clear plan for the transition, which is yet to be drafted, even though such a commitment was made last year.

The Transport Ministry told Capital that "the distribution of funds for the two activities (the purchase of decoders and the information campaign) will be part of the forthcoming discussions on the draft of the digital switch plan." During those discussions, the ministry said, it would consider the option of subsidising the purchase of decoders, rather than providing them free of charge.

Now, the interdepartmental working group will meet representatives of the Labour and Social Policy Ministry to establish the criteria to determine who should receive the set top box devices. One option under consideration is for the state to buy digital TV receivers for all citizens who already receive government assistance for winter heating and for people with disabilities.

According to Labour Ministry data made available to Capital, the number of people receiving heating benefits for the winter of 2011/12 is 219 760 people and the average monthly number of Bulgarians drawing welfare benefits is 47 842.

The number of people receiving disability benefits is 354 171 and there are several types of disability pensions, meaning that the number is hardly objective. It should also be noted that some people draw several types of welfare and disability payments, which puts them above the poverty line.

All of this clearly suggests that identifying the people who will get free decoders will not be easy. It would not be exactly fair to just add up the numbers of the three groups of people categorised as "socially in need."

But if that is the final decision, then the Cabinet will have to allocate a fabulous amount for the purchase of decoders. The lowest market price for set top box devices that merely ensure digital signal reception is 50 leva; the more sophisticated devices cost more and are better left to those who can afford them.

The Transport Ministry had a vague comment on the issue: "To meet the requirements of the Electronic Communications Act, the circle of people with special social needs will be determined based on the criteria specified in the plan. One of the main tasks of the participants in the drafting of the plan is to define the specific target group as well as allocate funds for conducting an information campaign."

After the working group decides the exact amounts for the purchase of set top boxes and the public information campaign, the Transport Ministry will have to call a tender to select the company that will provide and install the digital decoders. It should be so in principle, but that is not how it is happening.

"Before the public consultation on the digital switch plan and the subsequent adoption by the Cabinet, it is not realistic to set time limits for the announcement of the tender for the company that will buy the decoders because the announcement is in the implementation of the plan," the ministry said.

According to recent amendments to the Electronic Communications Act, within three months of the Cabinet approving the digital transition plan, the ministry will have to launch the public information campaign about the switch to digital broadcasting. By law, it must continue at least until November 30 2013.

But where is the plan that details how transition will be managed? Currently, the Transport Ministry's experts are working on the first draft of the aptly named "Plan for the introduction of digital terrestrial television broadcasting (DVB-T)", which will then have to be submitted for consideration of all parties involved in the process – state institutions, multiplex operators, broadcasters, regulatory authorities.

The ministry said that the plan would "go through interdepartmental consultations in accordance with the existing procedures in the state administration, prior to its submission for consideration by the Cabinet", but did not specify a date by which the plan will be ready.

So, the current situation is that there is no regulation of the stages of transition, but there is money that will be spent in an unclear fashion because there is no plan to manage the transition.

One final aspect of the digital switch has to be considered. Last summer, the European Commission criticised Bulgaria for the odds aspects of the switch to digital signal broadcasting, warning that it will start infringement proceedings against Sofia.

Whether this happens depends on the recent amendments to the Electronic Communications Act, which give the telecoms regulator the opportunity to hold a new tender to issue a licence for digital terrestrial television broadcasting with national coverage, allowing new players on the market.