Action Plan or Revisionism of the History of Bulgaria?

National Action Plan (in Bulgarian), screen shot from the draft document

The Bulgarian government is organizing a meeting on May 12, 2023 to discuss a document with the title


The document is misleading right from the title, as it diverts from the actual European plan on that subject.

This is not the first discussion of the National Action Plan (NAP). Another discussion took place in January this year. We will come back to that January meeting, but here’s a key point: Shalom, the organization of the Jews in Bulgaria, did not participate there, because they understood the absurdity of the document and didn’t want to legitimize it. You may understand further why, after reading the brief analysis of the NAP, provided below.

The title of the NAP is misleading: the second paragraph on p. 3 states,

The national plan complements the Bulgarian specificity in the European strategy for combating anti-Semitism and promoting the Jewish way of life from 2021.”

The European strategy is for “promoting the Jewish way of life“, and not “to preserve [the] Jewish heritage”, as the Bulgarian document title says.

Further, in the same second paragraph, last sentence, the NAP states,

The national plan also fulfills one of the national commitments made during the 2021 International High-Level Forum in Malmö, dedicated to the commemoration of the victims of the Holocaust (bold text by me, V.M.) and the fight against anti-Semitism.” 

But the Forum in Malmö, also agreed to:

Address rising Holocaust denial and distortion as a virulent form of contemporary antisemitism together with UNESCO by developing resources and trainings to support policymakers, civil servants, journalists and stakeholders from the field of education”

This did not happen in the NAP. Anyone reading the current article, will be able to understand what interpretation the NAP gives to this particular pledge. And it doesn’t commemorate the victims, regardless of the commitment, made in 2021.

On p. 4 the NAP states,

Bulgaria follows a consistent policy of public condemnation of the expression of anti-Semitism, identified on the basis of the working definition of the  International Holocaust Remembrance Alliance (IHRA) and the 11 examples of modern anti-Semitism specified therein.”

This sounds good, except that the “public condemnation” the NAP talks about is never followed by concrete actions – the Bulgarian prosecution is unwilling to press charges against hate crime, praise of Nazism or distortion of the Holocaust, regardless of the fact that there are provisions in the Penal Code punishing such crimes.

The NAP continues (p.4):

Bulgarian Jews are an integral part of Bulgarian society historically and in modern times.”

This would have been correct, should the NAP have included “fostering of Jewish life”, instead of focusing on the heritage only. This statement is in direct contradiction with the title of the draft document, which talks only about Jewish heritage, and not about fostering Jewish life (which is the European plan). Any objective reader will notice this contradiction. And if they continue reading, they will find more contradictions.

What follows further (last paragraph on p.4 and following paragraphs on p. 5), is an enormous revision of the history (or, to be more precise: a whitewashing!) of the participation of the kingdom of Bulgaria in World War II, starting with,

At the beginning of the Second World War, Bulgarian Jews numbered about 48,000, with greater presence in the trade, legal and medical professions. Despite the anti-Semitic legislation adopted under external influence, the Bulgarian society and state never adopted the ideas of anti-Semitism and the lives of all Bulgarian Jews were preserved during the Second World War.”

National Action Plan (in Bulgarian), screen shot from the draft document

The NAP claims that the antisemitic legislation has been adopted “under external influence”.

This is a distortion of the facts.

The laws are passed in 1940, as part of the general antisemitic policy of the government of tsar Boris III, headed by the primer-minister Bogdan Filov. While it could be said that the Bulgarian society didn’t widely adopt antisemitism (something, which became clearer with concrete examples by concrete people, who opposed the continuation of the deportation of the rest of the Bulgarian Jews in 1943), the same is not true for the Bulgarian state, the Bulgarian government and tsar Boris III. Further, it is not true that the lives of all Bulgarian Jews were preserved (which is shown further below).

The NAP continues,

Although during World War II Bulgaria was forced to abandon its policy of neutrality and introduce anti-Jewish legislation, anti-Semitism was never widely popular among the Bulgarian society.”

This is not factually correct. The kingdom of Bulgaria was not forced to abandon its policy of neutrality and introduce antisemitic legislation. The facts are that the kingdom first introduced the antisemitic legislation in 1940 (the law was signed by tsar Boris and published in the official State Gazette in January 1941), and only then it joined the Hitler’s alliance, on March 1, 1941. As for the “sympathy” towards antisemitism, one needs to understand that the antisemitic laws and regulations were the law of the land, and everyone complied with it. They were not laws that were passed under some (unmentioned) external force. The kingdom was neutral, and chose to pass the first law, the Law for Protection of the Nation, and not the other way around. Antisemitic legislation laws and regulations were passed regularly between 1940 and 1943.

Further, NAP states,

“…not a single Bulgarian Jew was deported to the Nazi death camps or killed in Bulgaria because of his religion or ethnicity.

This is not factually correct. All Bulgarian Jews, who happened to be within the borders of the European countries, occupied by Germany after September 1, 1939, were abandoned by the Bulgarian government, and sent to the concentration camps. The kingdom only requested that Germany would provide the names of the arrested Bulgarian Jews, so that the state can “take care” of their property.
Importantly, there are Jews in Bulgaria, who were prosecuted and/or killed – and these are not only the antifascist guerilla fighters, but also businessmen like Leon and Raphael Arie, as well as people, who died in the labor camps, where almost all male Jews were sent to after 1943.

NAP also claims that (p.5),

Along with this, the fact should not be overlooked that in the territories of Greece and Yugoslavia occupied by the German army, the appointed Bulgarian administration assisted in the collection of the local Jews from their homes and handed them over to the German wartime authorities, who deported them to the occupied by them Poland.

This is so wrong, on so many levels, that it’s amazing how such a text ever was written, and who gave the instructions for this distortion of the history and the role of the kingdom in the Holocaust!? Any objective reader would also notice that the NAP does not express any sorrow or any mentioning or commemoration of the memory of the innocent civilians, who were deported by the Bulgarian authorities and killed by the Nazis in Treblinka. The facts speaks for themselves:

Map from Yad Vashem (photo: Milen Radev)

Map from Yad Vashem (photo: Milen Radev), there were 60,500 Jews in Bulgaria, and 11370 were killed

  • In 1943 the mentioned territories were not occupied by the German army; as a matter of fact since April 1941 they have been occupied by the Bulgarian army, which two units were named – not joking – “occupation corps“. There was, of course, Bulgarian administration at all levels: the teachers were teaching the children, based on Bulgarian textbooks; newborn babies were given birth certificates by the Bulgarian Orthodox Church; the Bulgarian government was investing money in building infrastructure; the Jews were the only people in these territories, who were not given Bulgarian citizenship as the Bulgarian antisemitic laws did not allow that; etc., etc.
  • The “appointed Bulgarian administration” was assigned to their functions by the Bulgarian government; it was a fully functional administration with the same rights and responsibilities as the administration in any other part of the country.
  • The administration did not “assist” in the “collection of the local Jews“, but actually organized and executed the “collection” and deportation of all the Jews from the occupied territories.
  • The administration did not “hand them over” to the “German wartime authorities” – a statement so weirdly written that it sounds as if there were such authorities somewhere in Skopje, Kavala or Pirot. The fact is that the Jews were first sent to temporary concentration camps, built and managed by the Bulgarian authorities, and then by boat and trains (provided by the Bulgarian government) were sent further west, where the Germans took them, and further sent them to Treblinka.

The NAP ends this paragraph,

Unfortunately, despite assurances that they would be resettled and put to work, almost all Jews were murdered by the Nazis in the Treblinka and Auschwitz camps.

The Bulgarian government knew where the deported Jews are being sent (Prime-Minister Filov was warned in a conversation with the head of the Switzerland Embassy in Sofia that they are going to be executed; the government has agreed that it will not ask Germany to receive any of the deported Jews back, etc., etc.). Plus, then pro-Nazi government did not put any feelings in the deportation – they were desperate to deport them as quickly as and as many as possible. There are many historical books, explaining in details the history of that period, written** by respected historians and researchers, and there are reports – e.g. this one by the US State Department, providing the minimum required factual information. Finally, the Bulgarian President Georgi Parvanov has recognized the responsibility of the Bulgarian state for the deportation of the 11,343 Jews. His statement, combined with the recent attempts to present the role of tsar Boris and his prime-minister Filov in a positive way, as “saviors”, lead us to the conclusion that this is an attempt to revise the history of Bulgaria during World War II, and the draft NAP is just another step in that direction.
Deportation of civilians during times of war is a war crime and crime against humanity, as art. 6 of the Charter of the International Military Tribunal says.
To preemptively address some of the usual attempts to explain the deportation, let’s remind ourselves that:
1. The deportation is a crime regardless of whether Bulgarians, foreign nationals or people without any nationality are deported. The Jews in the occupied territories were not given Bulgarian citizenship; they were the only ones, who didn’t get it.
2. The deportation is a crime regardless of whether it was committed from the “old” borders of the Kingdom of Bulgaria or from the occupied (“joined”, “united”, “administered”) territories.
3. The deportation is a crime, no matter what the fate of the deported people would be – even if all of them had survived, this would not have turned the Bulgarian perpetrators into innocent people.
4. The deportation is a crime, regardless of whether tsar Boris III and Filov knew what the fate of the deportees would be.

The purpose of this article is not to go into details about the participation of the kingdom of Bulgaria in the Holocaust; this is well covered in the quoted literature.**

The NAP continues (p.7),

As of 2020, thanks to the consistent efforts of the Bulgarian state institutions, the xenophobic and neo-Nazi torchlight procession “Lukov March” was stopped.

This is misleading. While the mayor of Sofia, who is responsible for coordinating such public gathering, has expressed her disagreement with the night procession, the organizers have successfully challenged her disagreement in the Bulgarian courts. Neonazis from around Europe come year after year in Sofia, and participate in the procession, regardless of the public statements. The government never suggested any changes to the law, allowing such neonazi mob gathering to take place.

Then the NAP describes all the texts in the Bulgarian Penal Code, which deal with hate crimes, crimes with racist of xenophobic motives, crimes for spreading fascist or other non-democratic ideology, as well as crimes against “the justification, denial or gross belittling of a committed crime against peace and humanity.” It is important to again remind ourselves that since the deportation of peaceful population during war times is a crime against peace and against humanity, anyone, who tries to distort or revise the history of the participation of the kingdom of Bulgaria in the Holocaust, could be punishable under the texts of art. 419a* of the Penal Code. The Bulgarian prosecution has never***  pressed charges against anyone under these texts, and has never achieved any sentence under the text of art. 419a.

Recognizing the disparity and the lack of desire to take the responsibility for the deportation of the Jew, today’s Bulgarian government has created a website, with the plain name “Jewish Heritage“, as if again to avoid the need to show alignment with the European plans for fostering Jewish life.

The NAP states also that,

In January 2023, a public discussion of the draft national plan was organized.

What is missing from this information is a key fact: that Shalom – the Organization of the Jews in Bulgaria, refused to participate in the “public discussion”, thus providing perhaps the best verdict of the draft text. The draft from January does not differ much in the parts we have covered in this article.

There are so many errors in the draft text of the NAP, that the author is skeptical that the next public discussion on May 12, will be able to provide any substantive improvements.

The NAP should:

  • Not serve as a governmentally approved tool to revise the history of Bulgaria during World War II.
  • Be rewritten to reflect the fact that thousands of Jews are being born, study, work and live in Bulgaria. Today.
  • Focus on fostering Jewish life, while preserving the Jewish heritage.
  • Reflect the obligations Bulgaria undertook, when it was accepted as a member of IHRA.
  • Follow the text on the cover page of the country’s web presence at IHRA website: “Accession as a full member is not the end of the road but just another starting point. We still need – as a society and state – to come to terms with the events during the Holocaust that are now still seen by many as uncomfortable. Nations and societies that have successfully dealt with the past can face the present and the future with confidence and self-esteem.”

International Holocaust Remembrance Alliance – Bulgaria’s webpage (source, 17 April 2023)

The draft NAP could be downloaded here (PDF in Bulgarian).
But if I were you, I wouldn’t waste the time to read it, instead perhaps best is to email the Ministry of Foreign Affairs, which is the governmental body, responsible for the draft. There are several email addresses to use: (to send it to the minister) and (to send it to the PR/media folks at the Ministry). There are enough facts in this article, which can help you send a letter.

* – Art. 419a. (New – SG No. 33 of 2011, in force from 27.05.2011) (1) Whoever in any way justifies, denies or grossly belittles a committed crime against peace and humanity and thereby creates a danger of use violence or create hatred against individuals or groups of people united by race, skin color, religion, origin, national or ethnic affiliation, shall be punished by imprisonment from one to five years. (2) Whoever incites another to commit a crime under para. 1, is punishable by imprisonment for up to one year.
** – The author has also used information from these books, namely the two volumes by Roumen Avramov and Nadia Danova; Legal Aspects of the State Anti – Jewish Politics in the Kingdome of Bulgaria (1940-1944) by Zdravka Krusteva, Lea Cohen, as well as from other respected sources.
*** – The author is not aware of any such successful case; if the reader has information about such a case, please, leave a comment below.
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