Millions Behind the Curtains, Part II: New Evidence of Public Procurement Violations at Cultural Institutions

The second part of the investigation Millions Behind the Curtains of the Anti-Corruption Fund Foundation (ACF) reveals new evidence of collusion and rigged public procurement tenders at cultural institutions.

The evidence is contained in the replies of the implicated persons – company owners, directors and experts who organised the tenders – whom the ACF has approached for comments.

The first part of the investigation revealed a suspected scheme in which linked firms were awarded refurbishment and construction supervision contracts through rigged tenders.

The tenders, worth an estimated EUR 5 million in total, were for contracts in four entities under the umbrella of the Ministry of Culture: State Theatre of Satire Aleko Konstantinov, Drama Theatre Lovech, City Theatre Behind the Channel, and the National Cultural Education Complex and School for the Study of Italian Language and Culture.

In May 2026, the ACF published comments by Petar Dyulgerov and Lyudmila Krumova – respectively owner and director of two of the companies implicated in the scheme. Also published were comments by Ivan Sotirov, an attorney who, together with his son Kristian Sotirov, was hired as an external expert to help prepare the public procurement tenders. Ivan Sotirov and Kristian Sotirov were also members of the evaluation committees which chose the winning contractors.

The comments provided to ACF contain new evidence of violations and confirm the suspicions of rigged tender procedures:

• Crypto Energy Ltd, a company belonging to Petar Dyulgerov, participated in the preparation of a public procurement tender by the State Theatre of Satire. Subsequently, its bid was chosen as the winning one.
• Multi Stroi Comers Ltd, a company linked with Dyulgerov, was contracted by the School for the Study of Italian Language and Culture despite failing to meet the financial criteria outlined in the tender documents.
• The same lawyer represented the contractors – Petar Dyulgerov and Multi Stroi Comers – and the contracting party, namely the School for the Study of Italian Language and Culture.

How a private company helped prepare a tender call and then submitted the winning bid

In the first part of its investigation the ACF revealed how Crypto Energy obtained key information about an upcoming public procurement procedure for the detailed design and supervision of the refurbishment of the State Theatre of Satire building. Crypto Energy obtained the information at least six days prior to the official announcement of the tender call. Subsequently, it was awarded the contract.

In his comments to the ACF, Ivan Sotirov, who was hired as an external expert by the theatre, provided an email correspondence which showed that not only did Petar Dyulgerov’s company receive information about the tender prior to its announcement, but it also participated in preparing the public procurement procedure. 

On 13 May 2025, nine days before the tender call was announced, project manager Elena Trichkova requested the relevant technical information from Ivan Lapatov, an architect hired by Crypto Energy.

Two days later, Mr Lapatov sent the requested documents referring to “an agreement to edit the documentation and all relevant annexes”. He further stressed that the documents’ content had been coordinated with the contracting party.

The law stipulates that external experts and companies can help prepare public procurement procedures but only if full transparency is maintained. The contracting party is obligated to make all information, exchanged in the process, public and to guarantee equal treatment of all bidding companies — something which did not happen in this case.

“The failure to disclose Crypto Energy’s participation in the preparatory stages not only contravenes the Public Procurement Act but also shows that the company benefitted from an unfair advantage over the other competitors in the procedure,” said Daniela Peneva, a legal expert with the ACF.

In his comment, Mr Sotirov claimed that “no one had been informed about Crypto Energy’s participation in the tender procedure”. However, as a member of the evaluation committee, he was aware that Crypto Energy had participated in preparing the tender call. It remains unknown why the committee did not disqualify Mr Dyulgerov’s company from the procedure considering the failure to take steps ensuring the legally required equal treatment of all candidates.

How a company was contracted despite failing to meet tender call’s financial criteria

The company Multi Stroi Comers, also linked with Petar Dyulgerov, was contracted to renovate the building of the National Cultural Education Complex and School for the Study of Italian Language and Culture. This happened despite the fact that the company   lacked the required financial capacity as per the tender call.

The above fact was confirmed as the ACF compared financial information that Multi Stroi Comers had provided to the contracting party (the school administration was obliged to share this information following an access to public information request by the ACF) with the company’s annual financial reports in the Commercial Register.

Multi Stroi Comers shares an address with Crypto Energy. In addition, Dyulgerov’s phone number is listed in Multi Stroi Comers’ entry in the central professional register of building companies.

As per the tender procedure, Multi Stroi Comers was supposed to provide the contracting party with its annual financial reports or information about its turnover. Instead, the company provided a summary of the outstanding payments due from its clients. 

“This document does not contain the required information about the company’s turnover. Meanwhile, its annual financial reports clearly show that Multi Stroi Comers does not meet the criteria for minimal turnover and should have been disqualified,” said Peneva.

In addition, the tender documents reveal that the previous experience requirements have been lowered for this procedure compared to a previous public procurement procedure by the same contracting party. This gave an additional advantage to Multi Stroi Comers.

A tender call from February 2025, for the construction of a large gymnasium, stipulates that when disclosing previous experience based on work as subcontractors or participants in consortia, candidates should describe specifically which aspects of a project they were responsible for. Two months later, however, a similar requirement was missing from a subsequent tender call. This allowed Multi Stroi Comers to submit a bid and thus win the contract.

The ACF has reviewed documents showing that, in 2020, just five months after it was founded, the company formed a consortium with D&D Ltd. That consortium was awarded a contract to refurbish a student housing building belonging to The National Academy of Theatre and Film Arts “Kr. Sarafov”. While D&D Ltd has the relevant construction industry experience, it is not clear what Multi Stroi Comers’ capacity was at the time the contract was awarded and what experience the company then acquired so it could subsequently participate in the public procurement procedure of the School for the Study of Italian Language and Culture.

“Instead of providing an even playing field, it seems that the tender requirements were formulated in a way that made it possible for a certain candidate to submit an offer. This candidate was then selected even though it failed to prove it had the necessary financial and technical capacity,” said Peneva.

How does the suspected scheme look like?

Two public procurement procedures, from 2019 and 2020, for the refurbishment and construction supervision of the dormitory of the The National Academy of Theatre and Film Arts outline the scheme of undue influence which was then replicated in the tender calls from 2024 and 2025 investigated by the ACF.

In 2018, Crypro Energy performed an energy audit and created technical passports for the building of The National Academy of Theatre and Film Arts and its dormitory. A year later, this work served as the basis for the public procurement procedure for the construction supervision and refurbishment of the dormitory building. Duylgerov’s company was selected as the contractor for the project.

In 2020, the consortium Primo Grad was awarded the contract, worth EUR 1,512,000, for the refurbishment of the dormitory. Partners in the consortium were Multi Stroi Comers, D$D and Klimakomers.

“The facts point to a model in which Dyulgerov’s company was first contracted to help prepare the public procurement procedure and to overseeing the refurbishment of the student housing building. Then, the refurbishment work was assigned to companies connected to Dyulgerov,” said Peneva.

“We see this model seemingly replicated in the public procurement procedures by other cultural institutions which we analysed in the first part of our investigation.”

The same attorney represents the contracting party and its contractors

An analysis of documents provided by the School for the Study of Italian Language and Culture and by Lyudmila Krumova, the director of Multi Stroi Comers, on behalf of Petar Dyulgerov shows that all three parties were represented by the same attorney — Svetlina Yolcheva.

In addition, a check in the registry Bulstat shows that Svetlina Yolcheva submitted the documents to register the consortium Primo Grad.

“In 2024, Crypto Energy completed the technical passport of the building of the School for the Study of Italian Language and Culture and was also contracted the design and construction supervision of the refurbishment of the theatre in the city of Lovech. Meanwhile, Primo Grad was contracted to refurbish the theatre hall,” said Peneva.

In 2025, Multi Stroi Comers was awarded the contract for the refurbishment of the building of the School for the Study of Italian Language and Culture.

“The fact that the same attorney represents the contracting party and its contractors raises additional concerns about rigged tenders,” said Peneva.

Boyko Stankushev, director of the ACF, said that the new information points to an established model of coordinated actions by a network of companies aiming to distort competition in public procurement procedures.

“We expect that the relevant institutions will follow up on our investigation,” he said.