In Bulgaria's irrigation sector, collective action solutions have been propagated by the Bulgarian Government and the World Bank in recent years. However, the introduction of a World Bank Project, the enforcement of the Bulgarian Water Law in 2000 and the Water User Association Act in 2001 find no common ground where collective action can grow. Given that villagers often hardly know anything about the water user associations that had been established on paper, the local situation is closer to one of open access, with efforts by some powerful individuals to exert some authority.

This paper will show that what formally gives the impression of being a devolution-oriented policy reform by turning over decision power in resource management to local communities is, in fact, a further concentration of power in the irrigation sector. Empirical evidence is provided for pseudo devolution which is due to the actual implementation process of Bulgaria's recent legislation in the irrigation sector, which results in a concentration of property rights with state authorities. Likewise, individual actors who are capable of achieving short-term access to and management rights for the resource system are able to take advantage of the actual ambiguous local assignments of property rights and gain private benefits.