Address to the Intermarium Conference online

Role of NGO’s Promoting Individual Rights and Liberty in Light of the Geneva Consensus Declaration
April 29, 2021

Dear ladies and gentlemen,

It is my pleasure to be a part of this forum, and as co-organizers we welcome all the ideas presented here in favor of the traditional family, natural human rights, and individual liberty. (Many greetings from Dr. Viktor Kostov who could not join us for this event, and whose statement I will read, on his behalf.)

Freedom for All is a human rights organization and publishing group working since 2000 and formally, as a registered non-profit, since 2004. Our goal is to especially defend freedom of conscience and religion, and freedom of speech.

The Geneva Consensus Declaration is an important document which contains a number of provisions which enhance the role of women; protects their rights, and protects the traditional family. Such are article 2, emphasizing equal rights for women, article 3, that every human being has an inherent right to life, including the unborn; article 4, clearly stating that “in no case should abortion be promoted as a method of family planning,” and article 5, allowing for the state and society to view the natural family as the “natural and fundamental unit of society.”

We are also pleased that article 7 affirms the importance of national sovereignty and the primary role of national governments in making policy decisions regarding health care, the so called “universal health coverage” while keeping in mind the local context.

In addition, we are pleased that the Declaration refers to the obvious truth that there is no international right to abortion as there could not be a right to end another human being’s life. It is also commendable that the document has the goal to “advance supportive public health policies” not just for women but also for families.

The role of NGO’s in the fulfilling of the goals of this Declaration may be twofold.

Firstly, to promote the ideas, and especially those mentioned above, in the Declaration on the local and international level, as good policy markers. Those are the support for the natural family, individual and natural rights, support of the right to life for the unborn, and the individual and family right to privacy and conscience.

Secondly, the NGO’s have an important role to be a corrective to the centralization of thought and power, as their role is to approach any issues from the perspective of the citizenry they serve. Of course, that role depends on how concerned the entity is with the well-being of the people, and to what extent it remains financially independent of these networks, especially influential international bodies, so that a citizen’s organization, as is the NGO, can really speak truth to power.

We are concerned with certain formulations in the Declaration. For example, article 6 speaks of universal health coverage which is necessary for achieving the Sustainable Development Goals, related to well-being which is considered related to more than health. It is stated that “health is a state of complete physical, mental and social well-being.” This verbiage is sure unsettling as it aims to address more than one’s physical problems but also his or her mental, and, seemingly, spiritual well-being. One must remain aware that religious and Christian faith also aims, by the work and grace of God, at the wholeness of the person: physical, emotional, and spiritual. Religious or quasi-religious overtones may not be emanated in any form by any policy or document that seeks to help people and which are obviously not religious in their purpose. Help should not aim to control.

This so-called “holistic approach”, combined with bureaucratic mechanisms for its implementation may not be allowed to turn into a “total” and rather intrusive approach, which threatens individual rights, privacy and dignity. The sustainable development also looks into the wellbeing of the whole, of the corporate; and the well-being of the individual is somewhat buried in the grand project for control of future developments on a large scale.

It is our role, it is the role of human rights and religious freedom organizations, NGO’s, to safeguard the freedom and religious conscience and dignity of each one individual person, their privacy and their rights, and guard even against the UN programs on health and sustainable development hampering those rights. The role of NGO’s is crucial in maintaining the safeguards for natural individual freedoms.

The proper balance we seek can also be guaranteed by the strong language on national sovereignty found in the Declaration. It is our task to help ensure the UN remain within its initial goals, to facilitate the conversation between people’s and sovereign nations, and not turn into a totalitarian superstate overwhelming sovereign nations and individuals with health care, protection, and development plans that control rather than care.

We believe that if the Geneva Consensus Declaration is seen through those lenses it will fulfill the purpose to protect human faith, dignity, and purpose. It is our goal to do likewise. Thank you.

Viktor Kostov, Ph.D.
lawyer, missiologist

Website of the conference:


(Note: You can view and download a the PDF version of this text from the EU web site here



Re: The European Commission (EC) roadmap consultation on the inclusion of ‘hate speech’ and ‘hate crime’ as EU crimes (Article 83(1) TFEU).[1]

April 20, 2021

Freedom for All is a human rights and public debate organization dedicated to the defense of personal freedoms. We have participated in cases and written legal opinions for the ECtHR, Bulgarian Supreme Courts, the Constitutional Court and the National Assembly and defended such opinions and views in the public square on various relevant topics.

A Summary of Our Response to the Road Map Proposal

As mentioned in the Road Map, the Commission’s initiative will aim to trigger a Council decision to extend the list of EU crimes in Article 83(1) TFEU to include hate speech and hate crime. It is our view that the Council of the European Union must abandon criminalizing free speech and establishing discrimination and privileges in criminal justice with the introduction of the categories “hate speech” and “hate crimes” in Art. 83 of TFEU. Otherwise, it is inevitable that the EU, in violation of its own founding principles and adopted human rights protection laws, will turn into a totalitarian bureaucracy which opposes individual freedom and punishes citizens for thought crimes. Arguments follow.

Why the Concept of “Hate Crimes” Should be Abandoned

The idea of a “hate crime” is a legal and philosophical misconception. No crime, especially the ones perpetrated against the person, as causing physical or property harm, is committed out of love and respect for that person. Hate is behind most and such crimes. To label some crimes against the person as “hate” is to justify all other crimes as less repugnant and worthy of criminal prosecution.

For the state and law enforcement to act as the judge of intent and morality and to impede on the idea that hate and love can be mandated by the state is absurd on its face. Morality and thought are a part of the individual’s freedom and they cannot be mandated or even strictly regulated by the state. The state in a democratic society can only regulate actions, and especially harmful actions. To mandate people what to think, and respectively, to exclude bias from their inner life is beyond the role of a state bureaucracy and law enforcement.

Those crimes addressed by the EU in this roadmap can be rectified not by creating a new penal category and new crime standards, but by applying proportionate penalty for the severity of the crimes committed. Creating new crime categories for crimes committed against each minority group will result in a fragmented and ineffective, and also highly discriminatory, criminal and prosecutorial system in the member states. Prosecution will inevitably also become politicized beyond any measure acceptable in a democratic and free society.

“According to the Organization for Security and Co-operation in Europe (OSCE) Office for Democratic Institutions and Human Rights (ODIHR) hate crimes are “criminal offences committed with a bias motive”. This widely recognised definition is also the one used in this study.”[2] Even this definition shows how inept is the attempt to attach an emotional and worldview element to criminal intent and action. Are criminals who commit a certain crime not allowed to have bias? They have gone so far as to commit usually violent physical attacks on persons and property recognized as crimes, and yet we expect them to have the proper thought process to alleviate their punishment for the crime? If a “bias motive” should be included as an element of the crime, then re-education must be part of the punishment. This concept becomes especially dangerous when the so-called “hate speech” becomes the hate crime itself (as seems to be proposed in the Road Map). In such a case re-education prisons or concentration camps will become necessary to punish people for the wrong thought and expression, according to that one institution, body, or authority that defines what thoughts are hateful, and which are not.

“Hate crime” laws will only impose regulations in the criminal jurisprudence which are incompatible with the criminal system of a free society but rather fit a tyrannical regime. To legislate the “morality” of the day in a pluralistic society to such an extent as to define what the acceptable emotional feelings and judgments are, and regulate the psyche of the individual, is beyond the task of any democratic legislation.

Why the Concept Of “Hate Speech” Laws Should Be Abandoned

Firstly, hate speech laws will likely be in violation of Art. 6 of the Treaties of the European Union (TEU), which commits the Union to the value of the European Convention on Human Rights. Similarly misconstrued is the idea of, and the plan to introduce “hate speech” laws that criminalize expression. As per the above mentioned “hate crimes” can we empower the government to decide in a pluralistic society what is “hate” and what is “love?” Can the state, or even the majority in a democratic society, impose values and emotional conditions that are not accepted voluntarily by all, as to how all should feel, and what level of moral approval or outrage should all exhibit in regards to certain speech, without the state and that society ceasing to be democratic and free? Of course, it is the state that most likely will adopt this role of an “arbiter” of various views, and will have to establish a “state ministry of truth” to control who hates and who loves. People can be easily offended and they can easily accuse anyone of “hate” who does not espouse their view on a given subject. We have seen this, and continue to witness it today, many times over. The result is prolonged, unnecessary litigation that eventually ruins the lives of people.

Secondly, the criminalization of speech on the EU level will collide with laws and principles of guarding freedom of speech. The member states have already adopted internal and international laws that protect free speech. EU member states recognize the European Convention on Human Rights and the respective Court in Strasbourg. Many other international treaties protect the free expression of opinions and views. Adoption of EU regulation in this realm will go against the strict description of limitations on free expression of the European Convention.

There are other concerns about “hate speech laws,” besides the clear contradiction with ECHR and other laws protecting freedom of expression and thought.

Who decides what “hate speech” is? Such laws require the judicial assessment of the content of certain speech, but the criteria for such assessment is unclear (moral and legal). The wording “hate speech” is vague, fluid, and subject to arbitrary interpretations and applications, resulting in injustices through the legal process.[3]

In this regard we must emphasize that “hate speech” laws are essentially subjective and work through approximations. The Council of Europe’s definition of hate speech employs such ambiguous concepts like “promote,” “justify,” “other forms of intolerance,” “hostility,” and “aggressive.” “Hate speech” is labeled such by the hearer and relies on his or her perceptions and feelings which makes it vague and elusive. No respectful democratic society will impose limitations on one of the main pillars of freedom, free thought and expression, by basically criminalizing opinions and a robust public debate.

“Hate speech” will increase state power by bestowing on state authorities to use those vague definitions to arbitrarily decide with what falls into the category of “hate,” and thus to justify policing of people’s opinions and even thoughts.

The adoption of “hate speech” laws on such a broad and far-reaching scale, criminalizing speech, not actions, and imposing such an ominous standard on the member states within the EU will starkly pave the road for the EU turning into a sinister force for oppression as a totalitarian super-state. The EU was never created with the intention to abandon reason, legal tradition, and individual rights in favor of establishing a monstrous bureaucratic thought-control machine. 

Any adoption of regulations on “hate speech” will be an unnecessary imposition of non-democratic principles onto a societal environment which needs robust and honest discourse. Criminalizing “hate speech” under Art. 83 of TFEU will be a heavy blow against the very principles on which the EU is built: of protection of democratic principles and individual rights as the stalwart of a free and democratic society.


Our Recommendations

Ideas and opinions should be freely expressed in a democratic society, as it is inevitable that individuals or groups will be offended by ideas they fundamentally disagree with. Any limitation of speech and expression has to be narrowly-defined, clearly defined, proportionate, legitimate, pursuing a clear aim and must ensure that less restrictive means do not exist. To make speech a crime, not physical actions and attacks, is a step toward policing indiscriminately the thought life and the freedom of expression of people.

Thus, no legislation limiting or criminalizing the so-called “hate speech” should be adopted. Speech must be regulated only when it is used to cause and/or incite imminent physical harm to others.

Any limitation on speech should be assessed objectively, by including the context in which it was carried out, and not take into consideration the subjective elements such as the perception of the hearer.

Any limitation on speech may not include the vague concepts of “incitement to discrimination or hatred.” So called “offensive” and “disturbing speech” should not be banned but allowed for a meaningful public debate and to engage citizens in the democratic process.

For similar reasons, as per the arguments listed above about “hate speech” the idea of elevating the status of so-called “hate crimes” must be abandoned.


In general, the Road Map poses a threat to individual freedoms as it aims to criminalize free speech beyond any tradition and principle of democratic societies and impose control on free thought by using the fluid and vaguely defined category of “hate speech.” Any regulations based on the ideas in the document will be in contrast and in possible violation of already adopted laws and treaties.

In regards to “hate crimes” the inclusion of the worldview (bias of motive) of the perpetrator of these crimes will further and unnecessarily deprive the judiciary of objective criteria on which to establish the extent of the crime, its effect on the victim and society, and a proportionate punishment. The rule that in a democratic society the state punishes actions, not thoughts, will be abandoned as a solid legal principle.

Thus, the Road Map paves the way to establishing harmful laws and regulations that will further erode essential individual freedoms which are the pillars of a free and democratic society. The Road Map, if implemented, will inevitably propel the EU toward becoming a massive totalitarian super-bureaucracy police state which eventually will lead to its rejection by the peoples of Europe.

Viktor Kostov, Ph.D.
lawyer, missiologist
Freedom for All


(Correction: A previous version stated "Council of Europe" in paragraph 3. It was corrected to read "Council of the European Union." This correction should be kept in mind when accessing the PDF report submitted to the EC.)


[1] See Hate speech & hate crime – inclusion on list of EU crimes (

[2] Hate speech and hate crime in the EU and the evaluation of online content regulation approaches, a Study requested by LIBE, July 2020, p. 22, Access at:

[3] An example of the fluidity of thought behind the term “hate speech” is this attempt at a definition in the study requested by LIBE committee of the EP: “The term "hate speech" is used inclusively according to its everyday meaning, covering all expressions and manifestations of racism, xenophobia, homophobia, etc., and for distinction of the legal category "criminal hate speech" or specifically "incitement to hatred" is used.” See Hate speech and hate crime in the EU and the evaluation of online content regulation approaches, a Study requested by LIBE, July 2020, p. 20, Access at:

Advocate Dr. Viktor Kostov's speech,
presented at a discussion held on February 14, 2020, 11:00,
at the 44th National Assembly, East Hall


Ladies and Gentlemen, Honorable Members of Parliament,

Freedom for All (FFA) is a human rights and publishing group, active since 2004. We work to protect basic human rights and the traditional family.

Here is a brief summary of our joint opinion submitted to the National Assembly in November 2019 on the issue with ROD. Our position is completely critical of the letter and spirit of the Social Services Act (SSA), which has been delayed until 1 July 2020.

We draw attention to the fact that there is still no satisfactory legally reasoned response to our extensive criticisms of the Social Services Law.

The new SSA is tyrannical and anti-democratic legislation of philosophy and concept. The Social Services Act is contrary to the European Convention on Human Rights (ECHR) and the Constitution (CRB).

As a matter of principle, the SSA (ZSU -- abbreviation in Bulgarian) is a total law which, instead of the “social assistance” referred to in the CRB, introduces a “social service” that is universal and comprehensive, and in many cases obligatory, that is, provided against the will of the beneficiary. ZSU threatens the right to privacy and family life, the right and obligation of parents to raise their children, the right to a fair trial, etc. fundamental rights - ECHR - Art. 8, Art. 6 - and of the Constitution - Art. 32, para. 1, and Art. 47;

ZSU puts in opposition to each other parents and children, introducing and further perverting the idea of ​​children's rights as opposed to those of their parents. In this way, millennial legal principles and the natural bond between parents and children are being violated and the traditional family is being deconstructed.

The law privatizes and makes a commercial profit of the idea of ​​human mutual assistance and virtue.

It enables foreign traders and legal entities to act on the territory of the country, including without a license, and in violation of national sovereignty. The law virtually deprives Bulgarian citizens living in Bulgarian territory of the protection of the Bulgarian Constitution and the European Convention.

Under ZSU complete and centralized databases with personal information of parents and their children are formed, with full access to those by local and foreign actors and organizations.

ZSU extends the powers of social services and providers of social services excessively and in violation of a number of laws, turning them into coercive bodies without adequate judicial control and supervision, and without adequate protection of the rights of parents and children.

In general, the ideological charge behind the SSA and related child protection legislation contains elements of social engineering and does not respect the millennial traditions of the Bulgarian people, religious customs and practices, as well as the fundamental essence of the natural family unit.

The shortcomings of the SSA are so significant and numerous that no attempts and draft amendments can correct the radical ideological and anti-democratic nature of the law.

The Social Services Act should be repealed in its entirety.



A view of one of the parental protests in 2019 against the anti-family policies and laws


2019 was marked by the emergence of a wide family rights movement in Bulgaria. Parents, distraught at the total neglect of their rights, and at the clear putting in opposition to each other their parental privileges and duties, on one side, and the "right of the child," on the other, pushed back against the government policies and new laws.

A brief chronology of the events in 2019: 

  • a homeschooling organization and our own Freedom for All publish statements and petitions critiquing the new National Strategy for the Child 2019-2030 and its anti-family ideology, Jan 2019;
  • a petition is added, it reaches over 30,000 signatures, Feb 2019;
  • A Facebook group is started by two concerned mothers, Feb 2019;
  • the Strategy is withdrawn by the government but applied in the newly adopted Social Services Act, March 2019;
  • the FB group grows exponentially to over 100,000 members, May 2019;
  • Street rallies and protests are held in various cities in the nation, May-June 2019;
  • First attempt at addressing the issues with members of Bulgarian parliament, July-Aug 2019;
  • A first international conference on child kidnapping by Social Services is held in Sofia, with guests from the UK, Austria, and most notably from Norway, whose notorious Barenevernet (Child Protection Services) is being sued in the European Court of Human Rights for parental rights and human rights violations on more than 30 cases, Sept. 29, 2019;
  • Generally, central media continuously ignore the serious arguments against the new SSA and its anti-family and totalitarian essence, depicting the family-rights groups as "extremist," "right-wing," and "religious sects," May-Oct 2019.
  • a non-profit organization is formed, Parents United for Children (ROD), to express the views of the movement and give it public legitimacy, the Facebook group grows to over 210,000 members, Oct. 2019;
  • Protests, meetings with representatives of parties in parliament, sympathetic to the cause continue. FFA and ROD submit a brief legal analysis (see below) insisting that SSA should be entirely revoked as totalitarian and anti-family and anti- basic human rights, to the National Assembly. One of the political parties in parliament introduces a law with a single provision: the revocation of SSA, Nov. 2019;
  • Dec. 2019 - parent' group's protests and critical publications continue media debates and conversations with politicians. The National Assembly postpones the enactment of SSA, due to become active on Jan. 1, 2020, for 6 months.

It remains to be seen if the government will honor parental rights and concern or will yield to the pressure from the EU, Norway and big donors who insist on changing societal mores and values in small Eastern European nations, including Bulgaria.


Here you can download the full critical analysis of the Social Services Act of 2020, 8 pp., in English.