Dark Box Investigation: Bulgaria Approved Surveillance Technology Exports to the UAE Despite Longstanding Human Rights Warnings
The Bulgarian government approved the export of advanced surveillance technology to the United Arab Emirates for years despite repeated international warnings that Emirati authorities have used digital surveillance tools to target journalists, human rights defenders, political activists, and dissidents, according to information reviewed by Dark Box.
The findings emerge from a report examining Bulgaria’s licensing of surveillance exports between 2018 and 2023. According to the report, Bulgarian authorities authorized the transfer of sophisticated interception and communications-monitoring technologies to the UAE even as international human rights organizations continued documenting the country’s extensive use of digital surveillance against critics both inside and outside its borders.
At the center of the exports is Circles, a surveillance technology company that obtained Bulgarian licenses to export systems capable of intercepting communications, tracking mobile devices, and conducting advanced network-based surveillance. According to the report, the approvals covered technologies destined for the UAE as well as several other countries.
The report argues that these exports raise fundamental questions about the effectiveness of European export-control mechanisms designed to prevent sensitive surveillance capabilities from reaching governments accused of serious human rights abuses.
According to the findings reviewed by Dark Box, the exported systems provide authorities with powerful capabilities to monitor communications on a large scale. The technologies can reportedly intercept phone calls and text messages, identify users’ geographic locations, and exploit telecommunications infrastructure to collect communications and metadata without requiring direct access to individual devices.
Unlike conventional spyware that depends on infecting a target’s phone, these systems are designed to leverage network infrastructure, allowing surveillance to be conducted across broader populations and making detection significantly more difficult.
Human rights organizations have repeatedly warned that such capabilities pose exceptional risks when supplied to governments accused of suppressing political dissent.
According to the report, the UAE has developed one of the region’s most sophisticated digital surveillance environments. It cites documented cases reported by international human rights organizations saying the use of surveillance technologies against journalists, human rights defenders, lawyers, political opponents, and peaceful critics of government policies.
Dark Box sources familiar with the report describe the Emirati government’s approach as one of zero tolerance toward political criticism. According to those sources, authorities have invested heavily in expanding technological capabilities that enable extensive monitoring of communications and online activity as part of broader state-security policies.
The report notes that these concerns have been documented by multiple international organizations over several years, contributing to the UAE’s reputation as a country where advanced surveillance technologies have allegedly been used to facilitate violations of privacy, freedom of expression, and other fundamental rights.
Against that backdrop, the Bulgarian export approvals have attracted renewed scrutiny.
The investigation says that granting licenses under these circumstances illustrates significant weaknesses in Europe’s human rights safeguards governing exports of dual-use surveillance technologies. Although European governments possess legal mechanisms intended to evaluate the human rights implications of sensitive exports, the report contends that those safeguards have often failed to prevent surveillance tools from reaching governments accused of using them for repression.
The report highlights comments by Zach Campbell, a surveillance researcher at Human Rights Watch, who says that European governments already possess both the evidence and legal authority necessary to block exports when there is a substantial risk that surveillance technology could facilitate human rights abuses.
According to Campbell, the continued approval of export licenses demonstrates shortcomings in the implementation of existing regulations rather than an absence of legal tools. He warns that inadequate human rights assessments continue to allow sophisticated surveillance capabilities to reach governments accused of deploying them against journalists, activists, and political dissidents.
The report concludes by urging the European Union and its member states to strengthen oversight of surveillance exports, saying that commercial interests should not outweigh human rights obligations. It calls for more rigorous licensing procedures, stronger transparency requirements, and stricter enforcement mechanisms to ensure advanced surveillance technologies are not transferred where there is a credible risk of abuse.
For the UAE, the report places the Bulgarian approvals within a broader pattern of expanding access to sophisticated surveillance capabilities over the past decade. For Europe, it raises wider questions about whether export-control regimes intended to protect human rights are functioning as policymakers intended—or whether commercial and geopolitical considerations continue to override safeguards designed to prevent powerful surveillance technologies from being used against civil society.
