How does Bulgaria's Ordinance No. 41 initial-qualification exam differ from Ordinance No. 38 category C or D licence theory?

1. They are the same paper; Code 95 is stamped automatically after any C or D theory pass
2. Ordinance 41 replaces the need to hold a C or D licence
3. Ordinance 38 is only for transport managers
4. Ordinance 38 is the C/D licence theory test; Ordinance 41 is the separate two-part professional-qualification exam for the driver qualification card