This comparative legal study on national implementations of copyright exceptions and limitations in EU 27 was initiated and coordinated by DIGITAL REPUBLIC in the beginning of 2020.  

The goal of the research is to identify particularly restrictive national implementations to EU exceptions and limitations – ones that hinder the fulfillment of the very goal of the respective exception, frustrating the exercise of fundamental rights, such as freedom of expression, access to information, freedom of the arts, right to access to education, freedom of the press, etc.

The study is based on the analysis of primary sources (the copyright legislation of the respective jurisdictions) in EU 27, as well as on the more in-depth analysis of national regulations and case law for five Member States – Bulgaria, Greece, Poland, Portugal, and Romania.

The research for these jurisdictions was conducted by the following national experts: Ana Lazarova and Siyanna Lilova from Digital Republic – for Bulgaria; Alexandra Giannopoulou from Homo Digitalis – for Greece; Natalia Mileszyk, former Centrum Cyfrowe – for Poland; Eduardo Santos from Associação D3 – for Portugal and Bogdan Manolea from ApTI – for Romania.

This work was supported with a pre-litigation research grant from the Digital Freedom Fund. The results of this research have been used as one of the main sources concerning the national implementation of the InfoSoc Directive for the update of the project.


DIGITAL REPUBLIC, together with COMMUNIA Association for the Public Domain and Open Future is at the heart of the update of is a collaborative effort to map the fragmented landscape of user rights in the European Union’s copyright framework in a comprehensive way. It provides information on the national implementations of the various exceptions and limitations to copyright and related rights foreseen in the following EU copyright directives.

Our own Ana Lazarova is one of the initial contributors to the updated platform.

If interested to contribute to, detailed instructions can be found on the project’s contribute page.


On 15 July 2019, several Bulgarian media received an email containing 11 gigabytes of Excel spreadsheets. The email was released by a Russian mail server and eventually it was found to contain 57 folders of tax-relevant data of predominantly Bulgarian citizens. The National Revenue Agency (NRA) data breach led to the publication of personal data of more than 6 M natural persons and disclosed allegedly illegal processing of categorised information on judges, prosecutors, investigators, senior civil servants, football players, physicians, and others. 

It was disclosed that the Agency had failed to implement the legal requirements with respect to the protection of the information entrusted to it, including the personal data of the Bulgarian citizens. The International Tax Forum withdrew its trust from Bulgaria and ceased the automated exchange of tax information. 

Following the breach, around 100 individual civil claims for damages were brought before the court. The Bulgarian Data Protection Body imposed a fine and ordered the NRA to comply with certain injunction measures but the Agency appealed.

Digital Republic is part of an informal group of people and institutions that are bringing a class action against the NRA. More information about the initiative and the case development can be found at the  intiative’s website.


The law surrounding digital technologies is starting to shape as a legal and regulatory field in its own right. Digital Republic follows closely the developments pertaining to the Platform to Business Regulation, the digital finance package, the artificial intelligence bill, the blockchain bill, the drafts of the Digital Services Act and the Digital Markets Act.

The domination of technologies in our daily life accelerated by the pandemic makes the vigilant protection and promotion of digital rights ever more important.


Digital Republic advocates that copyright protection should support, not hinder, educational activities. We believe that both open access to educational resources and robust and broad educational copyright exceptions are equally important to achieving this goal.

We actively support and advise both individual educational institutions and other cultural organizations on the creation and development of modern policies that combine open access to educational resources and the principles set forth in the Cape Town Declaration and the Open Education Movement.