Bulgaria

II - Changes to the Budgetary Process

Budgetary process

II.1

Describe the main characteristics of the budgetary process (cycle, actors, instruments, etc.) in Bulgaria.

The regime of the budgetary process in Bulgaria is set out in three levels of norms. This is done at the level of (1) the Constitution of the Republic of Bulgaria (CRB), (2) laws and (3) regulations (norms standing lower than laws in the hierarchy of norms). There are four provisions in the CRB that relate to the budgetary process as such. First, Article 87 CRB sets out the exclusive power of the Council of Ministers to draw up and submit the draft Law on the State Budget (LSB) to the National Assembly. Second, Article 84 CRB sets out the power of the National Assembly to adopt the LSB and the Report on the Budget. Thirdly, Article 91(1) CRB provides that the Court of Auditors exercises control over the implementation of the budget. Fourth, Article 106 CRB states that the Council of Ministers manages the implementation of the budget.

There are several other provisions in the Constitution relating to the budget and setting out rules for the budgets of certain constitutionally defined organs. Under Article 62 CRB the National Assembly has an autonomous budget. Article 117(3) CRB states the same for the branch of the judiciary. The draft budget of the judiciary, according to Article 130a CRB, is proposed by the Minister of Justice and it is submitted to the Supreme Judicial Council which, according to Article 130(6)(4) CRB, approves the draft budget of the judiciary. Article 132a CRB provides for the creation of an independent Inspectorate which supervises the activities of the judiciary and the budget of this Inspectorate is approved by the National Assembly while being in the framework of the budget of the judiciary. Finally, Article 141 CRB states that the municipalities also have autonomous budgets and that the State supports the activities of the municipalities through inter alia the State Budget.

All of these constitutional provisions, however, need to be further supplemented and elaborated upon in order to be operationalised. This is done at the level of laws with the Law on the Public Finances (LPF).[1] Before going into the explanation of the budgetary process, it is first needed to explain the scope ratione materiae of the State Budget and its relationship with the other budgets that are set out in the CRB. According to Article 42 LPF the State Budget includes the central budget,[2] the autonomous budgets of the National Assembly and the judiciary, the budgets of the organs of the executive, the budgets of the other State organs and budgetary organisations excluding the autonomous budgets of the municipalities, social security funds and the budgets of the budgetary organisations under Article 13(3) and (4) LPF.[3] Although some budgets are excluded from the State Budget stricto sensu, they still have special relationship with the State Budget and are governed to a certain extent by the general provisions of the LPF but going in further detail on this point is beyond the scope of the present Report.

One of the said aims of the LPF, during the debates for its adoption, was to achieve a certain level of decentralisation, that is – to impose the obligations of following a budgetary discipline to a multitude of actors that hitherto participated in a certain way in the management of public resources through adopting a budget. As such, the LPF included a great number of entities in the budgetary process in one way or another. For the sake of clarity the current answer will focus only on the main actors. The main actors are summarised in Article 7(1) LPF. According to it, the Council of Ministers organises and manages the drafting, the submission to the National Assembly and implementation of the State Budget through the Minister of Finance and the primary authorising officers. Primary authorising officers are authorising officers that draft, implement and report a budget and are identified as such through law.[4] Article 7(1) is, of course, without prejudice to the special provisions on the Supreme Judicial Council, the National Assembly, the social security funds, the mayors and other authorising officers.[5] The Court of Auditors is another main actor, providing audits for the Report on the implementation of the State Budget. The Law for the Fiscal Council is still not adopted but when it is, that Council will also be one of the main actors in the budgetary process.

The cycle of the budgets is annual and the budgetary year starts on 1 January and ends on 31 December.[6] However, the cycle of a LSB is longer and can be divided in two – cycle of adoption and cycle of implementation. The cycle of adoption is divided by several temporal indicators. First, under Article 67(1) LPF, annually, until 31 January, the Council of Ministers acting on a proposal of the Minister of Finance adopts a budgetary procedure for the drafting of the medium-term budgetary forecast and the draft LSB. This procedure is adopted by a Council of Ministers’ Decision and represents the third level of norms that comprise the budgetary process. The Decision sets out the stages, the deadlines, the allocation of responsibilities and requirements for the drafting of the forecast and the draft Law in great detail. The Minister of Finance also provides Guidelines for the implementation of the budgetary procedure. In the framework of the budgetary procedure the Finance Minister prepares a spring and autumn macroeconomic forecast by 25 March and 25 September, respectively.[7]

Next, by 20 April the Council of Ministers, acting on a proposal of the Minister of Finance, approves the medium-term budgetary forecast and the revision of the Strategy for the management of the State debt.[8] The Minister of Finance also prepares, in collaboration with the primary authorising officers, the draft of the LSB and the draft of the revised medium-term budgetary forecast.[9] The Recommendations of the Council of the European Union and the divergences between the spring and autumn macroeconomic forecasts are reflected in the revised forecast.[10] The Council of Ministers approves the draft LSB and the revised medium-term budgetary forecast and adopts an Opinion that is prepared by the Minister of Finance on the budget of the judiciary. By 31 October the Council of Ministers submits the draft LSB to the National Assembly together with the revised medium-term budgetary forecast which serves as the explanations to the draft Law and the Opinion on the budget of the judiciary.[11] If the need arises the medium-term budgetary forecast may be amended by the Council of Ministers, acting on a proposal of the Minister of Finance, within a month of the promulgation of the Laws on the State Budget, the Budget for the Social Security and the Budget of the National Health Insurance Fund in accordance with the parameters of the adopted Laws.[12]

If the LSB is not adopted by 31 December, the revenues are collected in accordance with the applicable laws and the expenditures shall not be greater than the expenditures for the same period during the preceding year, unless the National Assembly or the Council of Ministers adopt acts providing for additional or decreased budgetary resources.[13] This regime can be applied for only three months after which the National Assembly adopts a Decision proposed by the Council of Ministers with which additional period of time is prescribed for collecting revenue and making expenditures.[14]

After the LSB is adopted and 31 December passes, the implementation cycle starts. The relevant point here is the oversight of the Court of Auditors and the preparation of the Report on the implementation of the State Budget. The Minister of Finance prepares the Report on the implementation of the State Budget and presents it to the Court of Auditors by 30 June. Together with the audits that are provided the Minister of Finance then submits the Report to the Council of Ministers by 30 September. The Report is then adopted by the Council of Ministers and submitted to the National Assembly. The National Assembly adopts the Report on the implementation of the State Budget by 31 December.

 

General change       
II.2
How has the budgetary process changed since the beginning of the financial/Eurozone crisis?

There have been two main stages of changes in the Bulgarian budgetary process in its broader meaning, since the beginning of the crisis. These two stages can be called pre-LPF adoption and post-LPF adoption.

Pre-LPF adoption

During this stage there was only one amendment of the budgetary process in its wider meaning at the level of laws. This was the amendment of the LPSB, which was made in mid-2011 and entered into force in 1 January 2012. The amendment put the fiscal rules of 2% deficit and a limitation of the State’s redistribution role at a level of up to 40% GDP in the LPSB as part of the Bulgarian self-imposed Pact for Financial Stability. This amendment changed the process by putting limits to the discretion of the Government while drafting the LSB. This amendment, itself, however, did not present a considerable change to the budgetary process stricto sensu. On a more subtle level, in order to appreciate the real change in the budgetary process, it is worth considering the Decisions of the Council of Ministers on the budgetary procedure and the Guidelines of the Minister of Finance since the beginning of the crisis. It is worth considering because these two instruments de facto channelled the budgetary process in the direction of the Euro-crisis measures, within the framework of the LPSB that was applicable at the time. In particular, in these instruments it can be seen how the Euro-crisis measures increasingly influenced certain parts of the budgetary procedure. The overview provided infra deals with the explicit references in one way or another to the Euro-crisis measures and not with integrated changes that are discussed in other answers.

The first mentioning of the financial crisis in one of these instruments was in the 27 August 2009 Guidelines for the preparation of the Three-year Budgetary Forecast (TBF) and the expenditure limits for 2010-2012 and the draft budgets of the authorising authorities for 2010. The Guidelines start with the need for the budgetary policy to be balanced between the goals for stimulating the economy and preserving macroeconomic stability. A recommendation addressed to the municipalities was also included. They were recommended to avoid structural deficits in their forecasts for 2010-2012 by optimising and limiting expenditures for local activities to the limits of the expected real revenues from own revenues and transfer from the central budget and other budgetary or extra-budgetary accounts and funds. There was no such recommendation addressed to the municipalities in the Guidelines for earlier years. The Guidelines from August 2010 make a less visible mentioning of the crisis but repeat the recommendation to the municipalities.

The following year, the 2011 Decision on the 2012 budgetary procedure[15] and the 2011 Guidelines had even greater emphasis on the crisis and the focus was, naturally, more on the Euro-Crisis. The 21 January 2011 Decision, starts with listing the rules that were to be followed in the procedure. One of these rules states that, with reference to Council Decision 2010/442,[16] the fiscal policy is to be in accordance with the recommendations of the European Council for adopting measures to terminate the existing at the time excessive budgetary deficit in the determined temporal framework. As mentioned in the answer to Question VII.8, this Decision also referred to the European Semester. In particular, the aligning of the procedure to the European Semester was also one of the rules to be followed. This transpired also in the fact that with the 2011 Decision the budgetary procedure was divided in two stages, while before there was only a schedule of the procedure. However, this division did not seem to introduce any specific consequences as such, other than operational clarity and convenience.

In the actual elaboration of the procedure there are two references made with Euro crisis relevance and are connected to the European Semester. First, the Decision states that the TBFs for 2012-2014 by policies and programmes (which were to be prepared by 28 February 2011 by following the Guidelines of the Minister of Finance) are to be in accordance with the bottlenecks identified by the Commission in Bulgaria’s National Reform Programme (NRP).[17] Second, by 2 September 2011, the Ministry of Finance prepares the draft LSB for 2012 on the basis of inter alia the guidelines and recommendations of Commission towards the budgetary policies for 2012.[18] Here a reference is made again to the answer to Question VII.8 and figure contained therein with respect to the alignment of the de facto alignment of the budgetary process to the European Semester which was not mandated as such by law.

The 2011 Guidelines of the Minister of Finance for the preparation of the TBFs, as in the Guidelines from the previous two years, a recommendation was made to the municipalities not to allow a structural deficit.[19] In the section on the budgetary forecast for local activities of the municipalities for 2012-2014, two references were made to the financial and economic crisis with which increased caution was recommended when preparing the revenue and expenditure parts of the forecasts.[20]

The 2012 instruments dealing with the 2013 budget also followed suit. The 2012 Decision[21] on the budgetary procedure for the 2013 budget contains increased focus on the Euro crisis in its first part, where the procedural rules are listed. First, it states that the bases for the developing of the TBFs and expenditure limits include the Council Recommendations of 12 July 2011concerning the NRP of Bulgaria (2011-2015) and the Opinion of the Council on the Convergence Programme (CP) of Bulgaria (2011-2014).[22] Second, the Decision states that the bases for the development of the draft LSB include (1) the above mentioned Council Recommendations and Opinion, with specific reference to the Country Specific Recommendations (CSR) on the preventative arm of the Stability and Growth Pact (SGP), recommendations on the employment policies and structural reforms; and (2) guidelines of the Commission on the development and revision of the NRP and the CP in accordance with the timeline of the European Semester in 2012. Third, the Decision states that the fiscal policy is to be in accordance with (1) the 2010 Council Decision and Recommendation concerning the excessive deficit of Bulgaria;[23] (2) the Commission assessment of the actions addressing the excessive deficit of Bulgaria;[24] and (3) the Economic and Financial Affairs Council (ECOFIN) conclusions of 15 February 2011 on the assessment of the actions addressing the excessive deficit of Bulgaria. Fourth, the Decision again stated that the budgetary procedure is to be aligned with the European Semester timeline.

In the part of the 2012 Decision on the procedural timeline, it is stated that by 16 July 2012 the Ministry of Finance (1) considers the Commission Recommendations that are approved by the Council concerning the NRP and the CP of Bulgaria for 2012 and (2), if necessary, develops additional measures and mechanisms.[25] These measures must (1) remove inconsistencies between the Council’s Recommendations, on the one hand, and the NRP and the CP, on the other; and (2) reflect the Council’s CSR that are connected to the SGP’s preventative arm, the recommendations on the employment policies and the structural reforms, as well as the recommendations on the macroeconomic imbalances. These, among other things, are to be taken into consideration by the Ministry of Finance when developing the draft LSB.[26]

In the 2012 Guidelines[27] one can find the same Euro crisis references and recommendation to the municipalities as in the 2011 Guidelines. The new addition in 2012 was a reference to the above mentioned Council Recommendations and Opinion as one of the bases for the development of the TBFs.

Post-LPF adoption

The new LPF was adopted on 31 January 2013 and entered into force on 1 January 2014. However, certain parts of it were applicable to the formation of the budget for 2014 which was being done during 2013. This included the budgetary procedure for drafting the budgets. This is why it can be said that the second stage of the change in the budgetary process starts with the adoption of the LPF. The LPF is a new law which repealed and replaced the LPSB as well as the Law on the Budgets of the Municipalities. It also introduced amendments in about sixty other Laws. The LPF implemented most of the Six-Pack and the Fiscal Compact and included the budgetary rules that were included in the last amendment of the LPSB.

When the draft LPF was being presented in the Committee on Legal Affairs on 24 October 2012 by the Deputy Minister of Finance and the President of the Court of Auditors, it was stated that a big part of the LPF is restating to a great extent the two repealed laws and is effectively codifying established budgetary practices ulterior to the LPSB.[28] The LPF also synchronises the use of terms in the Bulgarian legal system when it comes to the management of public finances. As such the new aspects of the Law are not that many but they are just as crucial. In particular, next to the implementation of the Euro-crisis measures, the LPF puts in one framework any and all entities that directly influence the State deficit in accordance with the Eurostat rules and imposes a system of unified fiscal principles on these entities.

Accordingly, with respect to the budgetary procedure, the change that the LPF introduced is mainly a codification of the main procedural practices hitherto. Those were for the most part the ones already discussed supra in relation to the European Semester. The annual Decisions on the budgetary procedure, however, remained and continued to set out the procedure in full detail. The Decisions on the budgetary procedure also preserved their main structure of setting out rules in the first part and the actual procedure in the second part. The 2013 Decision on the 2014 budgetary procedure was adopted on 24 January 2013 (few days before the LPF entered into force) but it is better to be considered here as the procedure ended up being regulated by the LPF.

The 2013 Decision[29] contains four Euro crisis-related rules in its first part. First, it states that the medium-term budgetary forecast for 2014-2016 is to be prepared by the Ministry of Finance on the basis of inter alia the Council Recommendation concerning the 2012 Update of Bulgaria’s NRP and the Council’s Opinion on the Bulgaria’s CP (2012-2015).[30] Second, with respect to the fiscal policy, the Decision no longer makes references to the excessive deficit procedure but instead makes reference to Directive 2011/85 and Regulation 1466/97. Third, the 2013 Decision, as in the previous Decisions, states that the budgetary procedure is to be aligned with the European Semester timeline. In its elaboration on the procedure and with respect to the Euro crisis the Decision mirrors its 2012 version with the only difference in putting later dates.[31] 

Fourth, the Decision states that the preparation of the draft LSB and the medium-term budgetary forecast are to be based on inter alia (1) the Council Recommendation on the NRP; (2) the Council Opinion on the CP (including the specific recommendations in the context of the MEIP); as well as (3) the Guidelines of the Commission on the development and revision of the NRP and the CP in accordance with the timeline of the European Semester for 2013. With respect to the medium-term budgetary forecast, a further clarification was made: it should reflect the fiscal effects of the application of the measures and mechanisms that were designed to (1) remove inconsistencies between the Council Recommendations, on the one hand, and the NRP and the CP, on the other; and (2) reflect the CSR of the Council that are connected to the preventative arm of the SGP, the recommendations on the employment policies and the structural reforms, as well as the recommendations related to the preventative part of the MEIP.

The 2013 Guidelines[32] for the development of the budgetary forecasts for 2014-2016 also mirrored its previous versions with respect to the Euro crisis. However, there was one new development. In Annex № 2d the Primary authorising officers are supposed to fill out a form in which they have to state the resources relating to financing the priorities and measures for (1) reaching the goals in the NRP, (2) realisation of measures in response to the Country Specific Recommendations of the Council of 10 July 2012, (3) as well as other measures implementing the seven leading initiatives in Europe 2020, the Euro-Plus Pact and the Annual Growth Survey for 2013.

The 2014 Decision[33] on the budgetary procedure for the 2015 budget, with respect to the Euro-crisis measures, mirrors almost completely the 2013 Decision. The only difference is in the part listing the rules of the procedure where it is stated that the fiscal policy is developed in accordance with the fiscal rules and limitations in the LPF without further reference to Euro-crisis measures. In the 2014 Guidelines[34] the Ministry of Finance has disposed of the innovation from the previous year introduced with Annex № 2d where the various authorising officers had to effectively identify financial resources for the Euro-crisis measures. It is not clear what the reason for the change was. For the rest, with respect to the Euro crisis, the Guidelines mirror the previous 2013 version.

The 2015 Decision[35] on the budgetary procedure for the 2016 budget is almost identical to its predecessor. Three of the changes made are of interest here. First, it is notable that one of the rules of the budgetary procedure that has been present in the Decisions for the previous two budgets is removed. This rule stated that the medium-term budgetary forecast is developed on the basis of inter alia “evaluation of the direct effect of the planned policies on the long-term sustainability of the public finances”.[36] Second, the lists of bases on which the LSB is to be drafted and the medium-term budgetary forecast to be updated was increased to include the approved by the Council of Ministers programmes for structural and functional reforms in the respective sectors.[37] Third, the part dealing with updating the medium-term budgetary forecast for 2016-2018 is missing the clarification introduced in the 2013 Decision (discussed above) that the medium-term budgetary forecast should also reflect the fiscal effects of certain measures and mechanisms adopted in light of the Council’s Recommendations.

 

In the 2015 Guidelines[38] there is scarce mentioning of the Euro-crisis measures. The only relevant one is that the primary authorising officers must develop their medium-term budgetary forecasts on the basis of inter alia the Council Recommendation of 8 July 2014 on the NRP and the Council Opinion on CP of Bulgaria (2014-2017). The directions towards the municipalities not to plan expenditures unless there are secured revenues have remained in the 2015 Guidelines as well.

Institutional change     
II.3
What institutional changes are brought about by the changes in the budgetary process, e.g. relating to competences of parliament, government, the judiciary and independent advisory bodies?

No institutional changes have been brought about by the changes in the way the budget is being made. The Fiscal Council has not yet been put in place and once it is, it will be the only change as a result of the legislative changes thus far.[39] The competences of the National Assembly, the Government or the judiciary did not change as a result of the legislative changes in any critical way. However, during the discussions of the LPF, some important developments have been identified with respect to competences. During the discussions in the Legal Committee its President – Iskra Fidosova (GERB) – questioned the actual extent of decentralisation, which was advocated to have been achieved in the (then) draft law. She considered that some of the independence of various organs has been taken away and given to the Ministry of Finance.

The Deputy Finance Minister – Vladislav Goranov – explained that the two are not mutually exclusive. The decentralisation that was being achieved with the draft law was with respect to the responsibility of the various organs that are participating in the State budget with their own budgets. This responsibility was also the underlying reason for the limited centralisation/loss of independence. The LPF includes provisions regulating the formation of the budget of inter alia certain constitutionally defined bodies by prescribing that they should observe certain rules and procedures with the aim to have a balanced budget. Such organs/bodies, for example, are the municipalities. Mr Goranov stated that the idea was not to interfere with the workings of those bodies but to give the Government a toolset for keeping under control the public finances as it was obliged to do under EU law. In particular, he stressed that in the current (at that time) framework, there was a mismatch between what was considered as State budget at the national level and what was being recorded as public finances at the EU level. Consequently, the balance of the budget that was voted upon in the National Assembly was different from what the European Commission puts down in its records. Therefore, the draft law was simply aligning the things considered at the national with those at the EU level and for that a limited level centralisation was needed.

Mr Goranov also mentioned that, in his opinion, with respect to the competences of the Finance Minister, they have actually been decreased with the new law. This was so because under the LPSB the Finance Minister could have unilaterally changed aspects of the budget after its adoption, while with the LPF for such changes the Minister needs an approval by the Government in the Council of Ministers. Such approval, according to Mr Goranov, requires a report that is public, which increases the transparency and hinders arbitrary changes.

Change of time-line
II.4
How has the time-line of the budgetary cycle changed as a result of the implementation of Euro-crisis law?

The timeline of the budgetary cycle has changed in terms of complexity due to the inclusion of the European Semester into it (see the figure in the answer to Question VII.8). The LPF to a large extent incorporated the temporal aspects of the practices that resulted from the incorporation of the European Semester.

Miscellaneous
II.5
What other information is relevant with regard to Bulgaria and changes to the budgetary process?

No other relevant information.

[1] Law on the Public Finances, SG 15 of 15 February 2013.

[2] The central budget is administered by the Minister of Finance in accordance with the LPF, the LSB and, according to Article 12(1) LPF, acts of the Council of Ministers.

[3] Article 13(3) refers to the Bulgarian Academy of Science, the public institutions of higher education, the Bulgarian News Agency, the Bulgarian National Television and the Bulgarian National Radio. Article 13(4) refers to the budgetary parameters of other economically defined entities and structural units that are included in the consolidated fiscal programme. These entities and structural units were not determined during the research.

[4] Law on the Public Finances (LPF), SG 15 of 15 February 2013, art 11(3). Such are, for example, (1) for the National Assembly – its President, (2) for the judiciary – the Supreme Judiciary Council, (3) for the municipalities – the mayors and (4) for the Ministries – the respective Ministers.

[5] Ibid., art 7(2)-(7).

[6] Ibid. art 10.

[7] Ibid. art 68(1).

[8] Ibid. art 72.

[9] Ibid. art 78.

[10] Ibid. art 79(1)(2).

[11] Ibid. art 79(5)(4).

[12] Ibid. art 79(5)(7).

[13] Ibid. art 87(1).

[14] Ibid. art 87(2)-(3).

[15] Council of Ministers, Decision № 40 for the Budgetary Procedure for 2012 of 21 January 2011.

[16] Council Decision (EU) 2010/422 on the existence of an excessive deficit in Bulgaria [2010] OJ L199/26.

[17] Council of Ministers, Decision № 40 for the Budgetary Procedure for 2012 of 21 January 2011.

[18] Ibid.

[19] Guidelines for the preparation of the budgetary forecasts for the period 2012-2014, of 4 February 2011, 7.

[20] Ibid., 16-17.

[21] Council of Ministers, Decision № 41 for the Budgetary Procedure for 2013 of 20 January 2012.

[22] Council Recommendation on the National Reform Programme 2011 of Bulgaria and delivering a Council Opinion on the updated convergence programme of Bulgaria, 2011-2014 [2011] OJ C 209/5.

[23] Council Decision (EU) 2010/422 on the existence of an excessive deficit in Bulgaria [2010] OJ L199/26; Council Recommendation 11307/10 to Bulgaria with a view to bringing an end to the situation of an excessive government deficit.

[24] Commission, Current state of the excessive deficit procedure in the Member States and assessment of the action taken by Cyprus, Finland, Bulgaria and Denmark in response to the Council Recommendations of 13 July 2010 with a view to bringing an end to the situation of excessive government deficit, COM(2011) 22 final, Brussels, 27 January 2011.

[25] Council of Ministers, Decision № 41 for the Budgetary Procedure for 2013 of 20 January 2012.

[26] Ibid..

[27] Guidelines for the preparation of the budgetary forecasts for the period 2013-2015, of 30 January 2012.

[28] Committee on Legal Affairs, Protocol № 147 of 24 October 2012.

[29] Council of Ministers, Decision № 48 for the Budgetary Procedure for 2014 of 24 January 2013.

[30] Council Recommendation on the National Reform Programme 2012 of Bulgaria and delivering a Council opinion on the Convergence Programme of Bulgaria, 2012-15 [2012] OJ C 219/9.

[31] Council of Ministers, Decision № 48 for the Budgetary Procedure for 2014 of 24 January 2013.

[32] Guidelines for the preparation of the budgetary forecasts for the period 2014-2016, of 1 February 2013.

[33] Council of Ministers Decision № 57 for the Budgetary Procedure for 2015 of 4 February 2014.

[34] Guidelines for the preparation of the budgetary forecasts for the period 2015-2017, of 10 February 2014.

[35] Council of Ministers Decision № 62 for the Budgetary Procedure for 2016 of 30 January 2015.

[36] Council of Ministers Decision № 57, for the Budgetary Procedure for 2015 of 4 February 2014.

[37] Council of Ministers Decision № 62 for the Budgetary Procedure for 2016 of 30 January 2015.

[38] Guidelines for the preparation of the budgetary forecasts for the period 2016-2018, of 11 February 2015.

[39] See the answer to Question VII.2.