Access to documents under Regulation 1049/2001 – Al-Khalidi case (Bulgaria)
Dear Justice and Consumers,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:
I request access to all documents (emails, letters, notes, minutes, briefings, internal memos, inter-service consultations) held by the Commission (DG HOME, DG JUST, Secretariat-General and the Commission Representation in Sofia) since 01.10.2021 that:
(a) contain any of the following identifiers: “Abdulrahman Al-Khalidi”, “Abdulrahman Abdullah Mohammed ALBAKR (Al-Khalidi)”, including transliterations and Bulgarian/Arabic variants listed in the annex; and/or
(b) refer to his case in connection with administrative detention in Busmantsi, “classified security files”, State Agency for Refugees (SAR), SANS (State Agency for National Security / DANS), or the Directorate of Migration, including references to court rulings/orders for release and non-refoulement.
Please also include the preparatory documents for the Commission’s reply to EP written question E-001410/2025 (draft replies, internal notes, inter-service consultation outcomes, meeting minutes).
If any exceptions apply, please grant partial access with targeted redactions and provide a document list (title, date, originator, reference) and a reasoned decision under Article 4 of Regulation 1049/2001, taking into account the overriding public interest in disclosure. I consent to processing of personal data under Regulation 2018/1725.
Yours faithfully,
Victor Lilov
Dear Sir or Madam,
We are writing to you concerning your request for access to documents sent
on 04/09/2025 and registered on 05/09/2025 under case number 2025/4487.
Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.
You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.
Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.
Why do we need your personal postal address?
Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:
• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.
The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.
Yours faithfully,
Directorate-General for Justice and Consumers - Access to Documents
European Commission
References
Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...
Subject: Access to Documents Request – Case 2025/4487
Dear Justice and Consumers,
Thank you for your message of 05/09/2025. Please find below my full postal address for the purpose of handling my request under Regulation (EC) No 1049/2001:
Postal address:
Lilov Victor
Angel Karaliychev 19
1700 Sofia
Bulgaria
For the avoidance of doubt, and to facilitate accurate identification of the requested documents, please note that the case concerns:
Name variants (EN): “Abdulrahman Al-Khalidi”; “Abdulrahman Abdullah Mohammed ALBAKR (Al-Khalidi)”; “Abdulrahman Al-Baker / Al-Bakr”; “Abdurrahman Alkhalidi”
Arabic: “عبدالرحمن الخالدي”؛ “عبد الرحمن عبد الله محمد البكر”
Bulgarian (approx.): “Абдулрахман Ал-Бакр Ал-Халиди”; “Абдулрахман Ал Халиди”; “Ал-Халиди”
Institutions/places/terms: Busmantsi; State Agency for Refugees (SAR) (BG: Държавна агенция за бежанците – ДАБ); SANS / DANS (BG: Държавна агенция „Национална сигурност“ – ДАНС); Directorate of Migration (BG: Дирекция „Миграция“ – МВР); administrative detention; secret security files; non-refoulement; EP E-001410/2025; LIBE / DROI; Charter Arts 4, 19(2), 47.
I kindly ask you to proceed with the registration and processing of my request.
Yours faithfully,
Victor Lilov
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 04/09/2025 and registered on 05/09/2025 under the case number
2025/4487.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 26/09/2025. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Justice and Consumers - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Dear Applicant,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/4487.
Please acknowledge the receipt of this message by return email.
Kind regards,
JUST ATD team
Dear Justice and Consumers,
Dear Ms. Gallego,
Thank you for your detailed response and for clarifying that DG JUST does not hold any documents corresponding to my request. I appreciate the information and will follow the procedure outlined for a confirmatory application with the Secretariat-General.
Kind regards,
Victor Lilov
Dear Sir or Madam,
We hereby acknowledge the receipt of your confirmatory request for case
2025/4487, sent on 22/09/2025 and registered on 22/09/2025.
We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 13/10/2025. We will let
you know if we need to extend this time limit for additional 15 working
days.
Yours faithfully,
Secretariat-General - Access to Documents
European Commission
Dear applicant,
We are writing concerning your confirmatory request for access to
Commission documents for case 2025/4487 registered on 22 September 2025.
We are currently working on your confirmatory request. However, we have
not yet been able to gather all the elements necessary to carry out a full
analysis of your request. We will not be able to send you the reply within
the prescribed time limit expiring on 13 October 2025, due to ongoing
internal consultations.
Therefore, in line with Article 8(2) of [1]Regulation (EC) No 1049/2001 we
need to extend this time limit by 15 additional working days. The new time
limit expires on 3 November 2025.
We apologise for any inconvenience this may cause.
Kind regards,
Secretariat-General - Access to Documents
European Commission
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
Subject: Confirmatory Application – Case 2025/4487 (Access to documents: Al-Khalidi case, Bulgaria)
Dear Secretariat-General,
I am writing to formally submit a confirmatory application (request for internal review) concerning case number 2025/4487. My original request for access to documents under Regulation 1049/2001 was submitted on 4 September 2025 and subsequently registered.
The prescribed legal timeframe for a response to my confirmatory request expired on 13 October 2025, even after an extension as permitted under Article 8(2) of Regulation 1049/2001. To date, I have not received a final substantive reply. By law, under all circumstances, the Commission should have responded by now.
On this basis, I respectfully request:
Immediate attention to and resolution of this outstanding request;
The provision of a complete and reasoned decision regarding the existence and accessibility of the requested documents;
If any documents are withheld, a list of such documents (title, date, originator, reference) and a justification under Article 4 of Regulation 1049/2001, with consideration for overriding public interest in disclosure.
I reserve my rights to further appeal to the European Ombudsman or EU Court of Justice should a satisfactory resolution not be provided within the next prescribed period.
Yours faithfully,
Victor Lilov
A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/request/access_...
[1]RE: Internal review of access to documents request - Access to
documents under Regulation 1049/2001 – Al-Khalidi case (Bulgaria) -
Ares(2025)10190315 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Mr Lilov,
Thank you for your e-mail.
Please note that on 22 September 2025 you already introduced a
confirmatory request for case 2025/4487. On 13 October 2025, the
Secretariat-General extended the deadline to reply to your confirmatory
request to 3 November 2025. However, we have not yet been able to finalize
the reply to your request.
We sincerely apologize for the failure to reply within the statutory time
limit.
We would like to confirm that the internal consultations in relation to
your application are fully ongoing. Therefore, we cannot commit to a
specific timeframe within when the reply will be adopted.
However, we would like to assure you thatwe are doing our utmost to
provide you with a reply as soon as possible.
Please accept our apologies for the inconvenience this delay may cause to
you and thank you for your understanding.
Kind regards,
European Commission
Access to Documents Team - dd
Dear Mr Lilov,
We are writing regarding cases EASE 2025/4487 and 2025/4488, which are
currently at the confirmatory stage.
You may recall that these cases relate to EASE 2025/4489, for which DG
HOME issued its initial reply on 28 January 2026. In that case, you
requested the same documents as those sought in EASE 2025/4487 and
2025/4488.
As DG HOME's initial reply included four documents partially disclosed to
you, we would be grateful if you could confirm whether you still wish to
proceed with your confirmatory applications in EASE 2025/4487 and
2025/4488. If not, we will close these cases administratively.
Please note that the administrative closing of cases EASE 2025/4487 and
2025/4488 would not affect your right to submit a confirmatory application
in respect of case EASE 2025/4489, should you be dissatisfied with DG
HOME's reply.
Thank you for your cooperation. Should you require any further
clarification, please let us know.
Yours sincerely,
SG.A2 - Access to Documents team
European Commission
Dear Mr Lilov,
We are writing regarding cases EASE 2025/4487 and 2025/4488, which are
currently at the confirmatory stage.
You may recall that these cases relate to EASE 2025/4489, for which DG
HOME issued its initial reply on 28 January 2026. In that case, you
requested the same documents as those sought in EASE 2025/4487 and
2025/4488.
As DG HOME's initial reply included four documents partially disclosed to
you, we would be grateful if you could confirm whether you still wish to
proceed with your confirmatory applications in EASE 2025/4487 and
2025/4488. If not, we will close these cases administratively.
Please note that the administrative closing of cases EASE 2025/4487 and
2025/4488 would not affect your right to submit a confirmatory application
in respect of case EASE 2025/4489, should you be dissatisfied with DG
HOME's reply.
Thank you for your cooperation. Should you require any further
clarification, please let us know.
Yours sincerely,
SG.A2 - Access to Documents team
European Commission
Dear Mr Lilov,
We are writing to kindly remind you of our previous correspondence
regarding your confirmatory applications for cases EASE 2025/4487 and
2025/4488, sent on 3 February 2025 (under reference Ares(2026)1220482).
As DG HOME's initial reply included four documents partially disclosed to
you, we would be grateful if you could confirm whether you still wish to
proceed with your confirmatory applications in EASE 2025/4487 and
2025/4488. If not, we will close these cases administratively.
Please note that the administrative closing of cases EASE 2025/4487 and
2025/4488 would not affect your right to submit a confirmatory application
in respect of case EASE 2025/4489, should you be dissatisfied with DG
HOME's reply.
If we do not receive a reply from your part within five working days, we
will proceed with the treatment of your confirmatory cases EASE 2025/4487
and 2025/4488.
Thank you for your cooperation. Should you require any further
clarification, please let us know.
Yours sincerely,
SG.A2 - Access to Documents team
European Commission
Dear Mr Lilov,
We are writing to kindly remind you of our previous correspondence
regarding your confirmatory applications for cases EASE 2025/4487 and
2025/4488, sent on 3 February 2025 (under reference Ares(2026)1220482).
As DG HOME's initial reply included four documents partially disclosed to
you, we would be grateful if you could confirm whether you still wish to
proceed with your confirmatory applications in EASE 2025/4487 and
2025/4488. If not, we will close these cases administratively.
Please note that the administrative closing of cases EASE 2025/4487 and
2025/4488 would not affect your right to submit a confirmatory application
in respect of case EASE 2025/4489, should you be dissatisfied with DG
HOME's reply.
If we do not receive a reply from your part within five working days, we
will proceed with the treatment of your confirmatory cases EASE 2025/4487
and 2025/4488.
Thank you for your cooperation. Should you require any further
clarification, please let us know.
Yours sincerely,
SG.A2 - Access to Documents team
European Commission