Information Services categorically objects to the outright manipulative and untrue statements published in mediapool.bg concerning Information Services in a material signed by the journalist Lily Granitska – Euro projects for digitisation and cyber protection for millions have been at risk since 23.03.2024. The publication of the journalist in question is full of unverified facts and subjective conclusions that aim to undermine the company’s prestige and deliberately try to mislead the public, and in particular the audience of mediapool.bg.

The author’s statement that “With the provision of Article 7c of the Electronic Governance Act, the state practically provides a legal monopoly to the “National System Integrator”, whose functions are performed by Information Services, on the market of IT services, experts commented“ is extremely manipulative and does not correspond to the truth.

In fact, only about 3 % of the total number of administrative bodies in the Republic of Bulgaria are within the scope of system integration under Article 7c of the Electronic Governance Act. In the performance of its functions as a system integrator under Article 7c of the Electronic Governance Act (EGA), when assigning system integration activities to third parties, Information Services acts as a public contracting authority under the Public Procurement Act, in strict compliance with the effective legislation. All public procurement documents announced by the company are publicly available in the information system CAIS GPP managed by the Public Procurement Agency, at: https://app.eop.bg/today

(for procurements announced after 13.06.2020), on the Buyer’s Profile on the official website of the company https://www.is-bg.net/bg/system-integrator/public-procurement and in the Public Procurement Register of (for procurements announced until 13.06.2020 inclusive).

When signing system integration contracts, the administrations and Information Services strictly comply with the Public Procurement Act, the Electronic Governance Act, the implementing regulations and the Guidelines for the Unification of the Practice for Determination and Application of System Integration Activities under Article 7c of the EGA, approved by Decision No 481 of the Council of Ministers of 14 July 2020.

The company also introduced a transparency mechanism and accountability of the system integrator and published on its website, at https://www.is-bg.net/bg/system-integrator, a full report on the activity and the public award, reports on the framework contracts with the administrations, the regulatory framework, etc.

It is a perplexity that behind these conclusions the publication author cites anonymous experts without any evidence of their claims.

We strongly disagree with the author’s assertions that “Information Services” has the final word for defining and sizing the needs, design of technical solutions for implementation of information and communication technologies, purchase of hardware and licenses. In addition, the state-owned company evaluates all these needs.”

The technical specifications for public procurement are drawn up by certified experts of the company and civil servants from different administrations, after a detailed analysis of the needs and requirements stated by the administrations included in the scope of system integration, in order to achieve maximum effectiveness and efficiency in spending budgetary resources and to achieve stability and security in the implementation of the legal business processes in the administrations. All technical specifications and/or projects in the field of e-government, information and communication technologies of administrative bodies with an estimated value equal to or greater than the value of the threshold referred to in Article 20(4)(2) of the Public Procurement Act, including those on system integration, are subject to a statutory public procedure pursuant to Articles 7e and 58b of the eGovernment Act. The obligation to manage the projects and technical specifications with the Ministry of eGovernment is entirely for the administrative authorities.

We also consider it important to note that Information Services awards the supply of equipment on the basis of Article 7c of the Electronic Governance Act through open public procurements, rather than subcontracting activities that are within the company’s core competence for products and systems created by it including installation, implementation, maintenance, monitoring, cyber protection, etc. Contracts for services related to the maintenance of software or system products by their manufacturer or its authorised representative in Bulgaria make exception, but are again awarded through a transparent mechanism under the Public Procurement Act.

As regards to one of the few specific “facts” in the material concerning Information Services, namely “...the procurement for the ICT system of the Cadastre Agency, conducted by Information Services”, where according to the publication “Analysis of the achieved price shows that the archiving software is 2 times more expensive than the recommended prices of the producer”, we would like to note that the quoted procurement was of the type “without available funding” and was terminated by Information Services in 2023 before there was any specific implementation and before any costs for the state were borne, namely because the company made a continuous analysis of the market prices with world producers and defended the state interest.

The author’s statement that “Furthermore, having consolidated information, “Information Services” could manipulate the market by negotiating projects with the management of the representative offices of large ICT manufacturers. They have to implement sales quotas and, if they want to work with “Information Services”, they have to agree with the prices indicated to them” is not true.

It should not be forgotten that Information Services is a partner fully controlled by the state, working for the benefit of the administrative authorities, and not for the main purpose – profit. In developed European countries, structures similar to Information Services are considered part of the country itself – extended arm of public administration.

When drafting the technical specifications and determining the budget of public procurement, the current product lists of at least three leading global producers are necessarily examined in order to avoid requirements that could be considered restrictive and achieve levels of discounts that are unattainable in public procurement conducted by the administrative authorities individually. In addition to the due diligence, the company sends the technical specifications to the world producers represented in Bulgaria in order to avoid obvious or hidden opportunities to restrict competition and obtain budget prices. It is important to note that the company communicates directly with the world’s manufacturers and not with their representatives-traders. These due diligences ensure full transparency and equal market opportunities for all potential participants, whether registered in Bulgaria or abroad. This procedure for planning the award of system integration is developed in detail in Chapter IV of the Guidelines for the Unification of the Practice for Defining and Implementation of System Integration Activities under Article 7c of the Electronic Governance Act, approved by Decision 481 of 14 July 2020. In particular, Chapter IV(5) describes the mechanisms for determining the estimated value of the services in detail, clearly stating that the forecast values are determined jointly by the administrative authority and the system integrator. I would like to stress that since the approval of the Guidelines so far, the Republic of Bulgaria has had 6 governments, including the present one, and in this period none of them has taken any action to change these Guidelines, which we comply with.

As to how many and which economic entities apply for a public contract in the absence of any restrictions and barriers, this is only a matter of market principle and Information Services cannot control this process. The results of more than 4 years as a public contracting authority have been over 550 public procurements and only two complaints (https://www.is-bg.net/bg/benefits/2023, slide 8), one due to a technical error on the part of the company, and the second complaint was withdrawn before the ruling of the competent state authority and is by a legal entity with which Information Services has no relationship to date.

Of course, this probably contrasts sharply with other practices in other procedures of other institutions, which prefer the lack of competition “by assignment”, choosing secret, classified and other similar procurements as their method of purchasing even standard computer equipment. All this information is available in the centralized platform for public procurement realized by Information Services and partners.

And since we speak of facts, let’s emphasize a few – in the last 3 years a number of audits of the work of the company have been carried out by the competent state authorities, such as the National Revenue Agency, the State Financial Control Agency, the internal audit of the Ministry of eGovernment. Some of the procurements that the company manages are subject to ex-ante control by the Public Procurement Agency.

We also strongly disagree with the statement that “from the verified public procurements awarded by Information Services, there are indications that between 15-20 % of the usual rebates granted by producers for government projects and large volumes of supply are lost for certain projects; it is clear from the PPA data.”

In fact, the facts point to the opposite – an analysis of the data on the public procurements carried out by the company for the supply of hardware and standard software shows savings of nearly BGN 70 million compared to values of identical equipment purchased under other procedures and from other contracting entities outside Information Services (https://www.is-bg.net/bg/benefits/2023, slide 7). As just a few of the many examples, we can point out that in 2022 the Ministry of the Interior purchased computers and peripheral equipment through Information Services with an end value almost 20 % lower than the value planned by the Ministry, and with significantly better technical parameters. And in 2023 the NHIF bought desktop computer configurations, at a price 60 % higher in comparison with the prices agreed by Information Services for configurations, with better technical parameters, which the Fund acquired through the company just a few months later, thanks to the NHIF’s entry into the scope of the National System Integrator. Another example of savings – at the beginning of 2023, the NHIF planned to upgrade its Oracle infrastructure for nearly BGN 8.5 million. Following detailed analysis and negotiations with the team of Oracle Bulgaria and Greece, Information Services has also proposed and optimised a technical offer of just over BGN 1.9 million, thus achieving a saving of BGN 6.6 million from the NHIF budget. Price optimisation would not have been possible if the company’s specialists had not undertaken activities on optimisation of the NHIF systems, consisting of improving the quality of software code and optimisation of processes, even with a significant increase in the volume of work due to the COVID-19 crisis and legal changes. The technical solution has been delivered and is put into real operation and works flawlessly.

Information Services is a company with a cause. We have been able to digitize the health system, with unprecedented results for Europe, in just 2 years, something that many have tried and exercised on without success in 30 years and have caused huge losses to the state. Technologically and in terms of processes Bulgaria owns the best national electronic health information system in Europe at a cost of about 6.5 million euro. For comparison, Switzerland has just begun the process of creating a system identical to the Bulgarian, with a budget of about EUR 400 million.

In less than 2 years we have merged into a single centralized information system all 153 general and specialized courts, fully digitizing the litigation processes in the judicial system. We have created a new Unified e-Justice Portal, which provides a 24/7 access to the documents on a case and the execution of procedural actions in electronic form through the Internet, thus achieving full transparency, traceability and publicity of the procedural actions of the participants in court proceedings.

In the last few years, the company has optimized public spending by state authorities within the scope of the National System Integrator for ICT and Cyber security significantly after it began acting as an integrator. It’s probably prejudicial to a number of interests. Perhaps these interests are important to someone, but they are not in the interest of the state.

But for sure, the work and integrity of Information Services have been spotted abroad. These results are also one of the reasons why just a month ago the company was accepted as a full member of the European Association of Public IT Suppliers EURITAS (https://www.euritas.eu/category/members/) your media wrote about. The company is on par with other similar companies and organisations from countries such as Germany, Switzerland, Denmark, Finland, Austria, Italy, Malta, Croatia and the Netherlands. This, in itself, it is a huge recognition of our work and the results we have achieved.

Information Services has always been open to conversation on all topics of interest to Mediapool and has always provided the information that was needed by journalists. The fact is that only in the last few years it was in the information site you managed that a number of news about the company’s work on significant projects that it implements has been found.

In this regard, we find it puzzling that a respected professional like the signed author of the material Lily Granitska has not observed an alphabetical principle in journalism to seek for comment Information Services for fact-checking during the preparation of the article. And since it is impossible that an authoritative media such as Mediapool publishes materials not created by the signed author and the editor, I assume that this is a technical omission. However, blind confidence in the “expert” opinion of anonymous experts has clearly led to inaccuracies and errors.

We also find it disturbing that manipulative theses and unverified facts are contained in a publication that was created under the initiative "Lights on Power: media monitoring in support of European rights and values", funded by the European Union and the Open Society Institute – Sofia Foundation (OSIS).

In conclusion, we express our sincere hope that the speculations in the article concerning Information Services are accidentally allowed, dictated by misunderstanding and ignorance, and not with the purpose of deliberately misleading and tuning the society and audience of Mediapool.