Advisory opinion on the draft Government Decision “on the approval of the Sanitary Regulation for pre-school educational institutions”

The regulation would apply uniformly to state, private and NGO-run institutions, which is important for children's rights and wellbeing. However, the document should first be simplified by removing excessive requirements, and possibly made more concise, including the informative note. It also lacks an assessment of the impact on the private and non-governmental sector, and the claim that no additional public money is needed is unrealistic. The budget impact should be assessed only after simplification.

The opinion calls for repeated public hearings (an attempt was made in 2012) involving private and non-governmental representatives, including APSCF members. It suggests splitting the text into mandatory minimum standards and good-practice recommendations, and phasing implementation, as the proposed six months is too short and some points need 2-3 years with sufficient state funding. Finally, each kindergarten should produce a self-assessment, an action plan and individual costs.