under open-type prison regime and four under closed-type prison regime. Such a distinction between open-type and closed-type prison regime does not affect the detainees’ status since they serve their time under equal conditions and organisation. The Implementing Rules do not distinguish between the regimes under which minors serve their time; the only difference being strict and general regime, on the one hand, and light regime on the other hand is whether minors move accompanied or unaccompanied. Bedrooms are locked for the night regardless of the different regimes. The building architecture allows for locking separate sections versus corridors. Thus, these 23 persons are grouped in several small groups, in accordance with the capacity of the premises. Pursuant to Article 194 Execution of Punishments and Remand in Custody Act (EPRCA) persons of age serve their time in open-type prison hostels, while those sentenced to a strict regime or with five years remaining of their time – in closed-type prison hostels. This leads to a paradox since a person of age serving his time under a general regime in an opentype prison hostel moves unaccompanied, while a minor serving under a general regime moves accompanied in the territory of the Correctional Home. The reason for this paradox lies in the notion of the general regime, which has different meanings in relation to closed and open type facilities for deprivation of liberty, i.e. corridor type of locking during the day in the closedtype facilities and free movement in the territory of the prison hostel for the open-type facilities. In the case at hand apparently the notion of general regime for minors is rendered identical to the general regime for persons of age serving in closed-type facilities. The NPM notes that when future amendments of the Implementing Rules are considered, this issue should be put to a public discussion with a view to making this particular regime identical to the open-type regime, i.e. free unaccompanied movement of minors serving under a light and general regime in the territory of the Correctional Home. Until then the NPM recommends to the head of the Vratsa Prison, pursuant to Article 190, para 2 EPRCA, to increase the time in the open above the minimum two hours during the summer period and place benches and sheds for outdoor activities. As regards Keramichna fabrika closed-type prison hostel, in 2019 the NPM reminded once again that the hostel is privately owned. The Ministry of Justice has no legal grounds to incur public costs for this property, which is why the building has been left unattended for more than 20 years now. These are in fact two two-floor buildings, with external corridors and staircases. The bathroom and toilet are shared, without any heating in winter and in a very poor condition. Inmates prefer to use the summer fountain in the yard during summer for their morning toilet. Inmates serve their time in extremely unfavourable conditions which may affect negatively their health. In 2019 the NPM established no changes in the conditions in the prison hostel. Taking account of the poor hygiene and material conditions in this prison hostel, the NPM recommends to the Minister of Justice, pursuant to Article 46 EPRCA, to close it down and transfer it elsewhere. Boychinovtsi closed-type prison hostel was opened in 2018 in the territory of the former Correctional Home in Boychinovtsi. During the inspection conducted in 2019 the second floor of the building was used. A total of 53 persons were placed there. Five persons were serving their time in an open-type facility and were working as janitors. The facility was not overcrowded and the material conditions were good. The premises and the surrounding area allow for further development of this prison hostel. The issues raised by the inmates concerned the irregular supplies in the prison shop and the lack of opportunities for work. The NPM is of the opinion that “Prison Production” State-owned enterprise should act proactively to create opportunities for work in this hostel and thus recommends to the executive director 11