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The "Baba Alino" case: The cadastral map includes all existing real estate, regardless of whether they were legally built or not

The law does not distinguish between a legally built building, facility or independent object and illegally built ones

Jun 22, 2026 11:53 46

The "Baba Alino" case: The cadastral map includes all existing real estate, regardless of whether they were legally built or not  - 1

Engineer Krasimira Bozhkova, head of the Service for Geodesy, Cartography and Cadastre - Varna, temporarily suspended from office until the circumstances of the inspections carried out around the "Baba Alino" case are clarified, came out with a position regarding media publications. Here is what it says:

"Regarding the media suggestions and statements of authorized persons circulated in recent weeks that when reflecting in the cadastral map the buildings with independent objects built in the area of "Baba Alino", SGKK - Varna and the head of SGKK - Varna have committed legal violations, I declare the following:

In accordance with the provisions of the Cadastre and Property Register Act, the cadastral map reflects and maintains up-to-date data on all existing real estate on the territory of the Republic of Bulgaria. According to it, these are: land; a building and a facility of the technical infrastructure, in which there is an independent object; an independent object in a building or in a facility of the technical infrastructure.

The law does not distinguish between a legally constructed building, facility or independent object and illegally constructed ones. The cadastral map reflects all existing real estate, regardless of whether they were legally constructed or not.

It is an unconditional obligation to enter in the cadastral map all existing buildings or facilities of the technical infrastructure on the terrain, in which there are independent objects, regardless of whether or not there are construction documents issued for them, including a building permit. With regard to the latter - those without a construction permit - this obligation is legally stipulated in Art. 74 of Regulation X• RD-02-20-5 of December 15, 2016 on the content, creation and maintenance of the cadastral map and cadastral registries.

The cadastral authorities cannot refuse to include existing buildings and independent objects in the cadastral map due to the fact that there are no construction documents issued for them. Historically, this procedure was also applied when creating the previous cadastral plans.

With regard to construction projects for which a certificate of tolerance has been issued, they may be the subject of a transfer transaction, in accordance with the text of § 16, para. 1, clause second of the P3P of the 3UT, therefore, on the basis of the above provisions, the cadastral authorities are obliged to enter them in the cadastral map. The case of the properties in “Baba Alino“ is no exception. They were entered in the cadastral map on the basis of regular official documents, signed by a legally competent person, who with his signature has certified their authenticity, as required by the regulations. For this, he also bears the corresponding responsibility before the law.

Maintaining the cadastral map and cadastral registers in an up-to-date state is a registration activity. The cadastral authorities are only and solely registration authorities and do not have the rights and obligations of either the control or the investigative authorities, for which our national legislation provides exclusive competence for this.

The employees of SGKK-Varna and the Head of SGKK-Varna have not committed any legal violations in the recording in the cadastral map of the buildings with independent objects built in the area “Baba Alino“, rp. Varna.

We present to your attention the facts – such as they are in the current regulatory framework, and with the confidence that they are implemented in practice in all cadastral agencies in the country. In this sense, the Opinion of the Management Board of the Chamber of Geodetic Engineers on the "Baba Alino" case is made on June 9, 2026.

It is incorrect and manipulative to assert false and convenient opinions and statements for someone, which undermine the trust of Bulgarian and foreign citizens, companies and organizations in the good faith of the employees and their managers of the state administrative institution and administrative state body, such as AGKK. As an employee and head of the agency, I am ready and will defend this with all the means given to me by law," says Krasimira Bozhkova.