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Architect Diana Ilieva discusses her participation in a Ministry of Regional Development working group on construction rules, including requirements for façades, windows and doors, and thermal insulation. She and host Stoyan Todorov argue that Bulgaria’s construction framework has gaps and ineffective or excessive requirements, and that rulemaking should be guided more clearly by the public interest.

Consumers’ interests are often overlooked

Ilieva says construction decisions affect everyone—not only those commissioning a building or renovation, but also those who live and work in the built environment. The speakers argue that rules should account for consumers’ safety, health, finances and quality of life, including the needs of people with fewer resources.

The working group may lack key perspectives

Ilieva says architects were generally absent from the meetings she attended and that she had not seen a representative of the Chamber of Architects. She considers this a significant omission because architects can bring the client’s perspective and account for the long-term effects of buildings and their surroundings. She is preparing a report to inform the profession about the group’s work.

Concerns about dividing design into separate project parts

Ilieva describes the division of design into separate “project parts” as fragmented, potentially weakening coordination and obscuring responsibility for the overall result. Drawing on his experience in Germany, Todorov advocates appointing a lead designer—usually an architect for buildings or an engineer for infrastructure—to coordinate specialists throughout the process.

Mandatory rules may be overused

Ilieva argues that broadly imposing requirements before they have been tested can lead to overregulation. The speakers say that accumulating rules that are difficult to meet may encourage people to ignore or circumvent them, potentially contributing to illegal construction.

They suggest voluntary standards as an intermediate option: clients could adopt them contractually where appropriate, while requirements with clear public-safety implications could remain mandatory.

The role of private interests in rulemaking

Todorov asks whether industry or business interests may be influencing the proposed approach. Ilieva acknowledges that participants may have both sincere goals and sectoral interests, but says she cannot establish that any particular interest is driving the work.

The speakers argue that consumer organizations are needed to balance industry voices and that the public interest should be clearly defined in construction law.

Restrictions on professional roles

Todorov warns against restricting work such as façade design to a narrowly defined professional group without assessing the actual quality of the work or its public benefit. He says such restrictions could conflict with EU proportionality requirements for regulating professions.

He also says Bulgaria has not properly implemented the relevant EU rules and that the European Commission has taken the matter to the EU Court. Ilieva notes that accountability for such decisions is rarely discussed in working groups.

The interview concludes with a call to reconsider the construction system’s purpose and responsibilities. The speakers say a better-designed framework could improve professional collaboration, strengthen consumer protection and create a more pleasant living environment.

Presenters and contributors

  • Dr. Architect Stoyan Todorov — Host; Chairman of the Board of the Alliance for High Construction Culture
  • Architect Diana Ilieva — Guest; Board member of the Alliance for High Construction Culture

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