Dear Organizers of The Status of the Translation Profession in the European Union project,
I am a sworn translator in Serbian, Croatian and Slovenian languages in Bulgaria. I hold a Master’s degree in Serbian and Croatian languages and Serbian, Croatian and Slovenian literature. My colleague Mia Dintinyana told me about your project and I noticed that you still do not have any information about Bulgaria. I do not know if you expect information from any official authority in the country, but the information provided in the study is rather incomplete and does not offer a proper insight into the situation. I would therefore like to provide you with a brief description of the situation with sworn translators, authorized to translate official documents in Bulgaria.
1. The Ministry of Foreign Affairs of Bulgaria is the body which gives authorization and decides which translator can perform sworn translations, validated with a seal, based on his or her qualifications.
2. However, in order to be permitted to carry out sworn translations, the sworn translators must submit documents for translation to one of the onen thousand six hundred and eighty-four (1684) translation agencies with which the Consular Affairs Directorate of the Ministry has signed a contract for performance of official translations.
3. This means that the translator himself can never apply for such a permission on his own and that sworn translators completely depend on the will of translation agencies which may or may not choose to work with him and to submit his documents in the Consular Affairs Directorate of the Ministry!
4. Translators must thus submit documents to translation agency. For every translation agency the translator goes to, he must separately get a notary-certified copy of their diplomas, as well as a sworn declaration for each translation agency stating that the translator is fully and legally responsible for the translations performed. This means that translators in Bulgaria are constantly paying fees to notaries for certification of their diplomas and sworn declarations, but do not have any guarantee in return that the translation agency will submit these documents to the Consular Affairs Directorate and that a translation agency will decide to assign a translation to the respective translator.
5. A translator in Bulgaria becomes a sworn translator only within the specific translation agency which has submitted his or her documents to the Consular Affairs Directorate. Thus a translator can work as a sworn translator only for two or three agencies just because other translation agency might not be willing to submit his ot her documents to the Consular Affairs Directorate. On the other hand, a person holding a Master degree in English philology (or any other language) might never get a chance to work as a sworn translator if no agency cares to submit his or her documents to the Consular Affairs Directorate. This same translator has to be approved by each one of the one thousand six hundred and eighty-four translation agencies separately and can carry out sworn translations only and solely through the translation agencies. So the translator is supposed to prepare his notary certified documents for each translation agency separately, meaning that he or she will have to pay 30 BGN notary fees each time, for each set of documents. 30 BGN multiplied by 1684 agencies equals 50 520 BGN (27 222 E) – this is the amount for just one sworn translator.
6. Each translated document by translator is given from translation agancy to the Consular Affairs Directorate where the signature of the translator has to be certified in the absence of the the translator, because the translations are submitted by translation agencies, printed on a form of the agency with a logo and a stamp of the agency, but signed by the sworn translator who has performed the translation. For this certification of the signature of the translator the Consular Affairs Directorate charges a state fee. It turns out that in Bulgaria the environment for forging signatures of translators is very favourable. The sworn translator, whose signature is on the document, might have not translated the document, but his signature could be easily faked by a translation agency and submitted to the Consular Affairs Directorate for certification. Thus, the Consular Affairs Directorate certifies our signatures in return of a state fee and in our absence!
7. The Consular Affairs Directorate of the Ministry of Foreign Affairs does not sign contracts directly with the translators, meaning that we do not have the right to perform official translations without the intermediation of translation agencies, and we do not have the right to submit our own translations to the Consular Affairs Directorate where to certify our own signature. This means that the translation agencies dictate the cost of translation, usually charging over 50% commission, without any guarantee that the translator will get paid for his work by the translation agency.
8. Since we are in a situation of dependency, translatos in Bulgaria have to register their own firms – translation agencies – in order to perform official translations in the languages they have mastered. The situation changed in May 2012 when the Consular Affairs Directorate of the Ministry of Foreign Affairs issued a new Decree that from the beginning of 2013 the Directorate will sign contracts for official translations only with firms, certified in BDS EN 15038:2006, which have a rented office and have contracted two philologists on a permanent employment basis.
The Ministry of Foreign Affairs works with a very old normative base – it has not changed since 1958, and the new “changes” AGAIN put the translators in Bulgaria in a dependent situation. Is there any other country in the EU where the translators, who want to practice freely their profession, must have an agency, certified in a quality standard such as BDS EN 15038:2006 and also required to hire two philologist on a permanent emplyment basis? Translators in Bulgaria have the right to register as freelancers, to pay taxes, but we cannot work freely as certified translators. Our work should always be performed through the intermediation of a translation agency.