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Annotation
The article puts forward a package of specific, drafting-ready amendments to the Bulgarian Administrative Procedure Code and the Judiciary System Act aimed at accelerating and improving administrative proceedings. The principal proposals include extending the principle of consistency and predictability to bound-discretion acts and to case law, mandatory registration of all key legal entities in the secure electronic service system coupled with a presumption of notification where registration is omitted, a reformulation of Art. 22(1), and the repeal of the conflicting legal definition of "administrative authority" in § 1(1) of the Supplementary Provisions. Central to the article is a proposed new Art. 29g, which would govern the issuance of administrative acts by automated systems without human intervention in cases of bound discretion and undisputed proceedings, in line with Regulation (EU) 2024/1689 (the AI Act), the author maintaining that a separate national AI statute is unnecessary. The article further argues for the statutory designation of the gravest combination of procedural violations — failure to notify a party of the opening of proceedings and the resulting non-participation — as an unconditionally material ground for annulment, following the French administrative law model. Finally, it substantiates the introduction of junior administrative judges into the Judiciary System Act, together with changes to the composition of the competition panel so as to balance tenured academics and sitting judges.
Keywords
Administrative Procedure Code; artificial intelligence in administrative proceedings; material procedural violations; secure electronic service of documents; junior administrative judges
