The Lothians MSP says such a move is not “within the spirit” of ministerial rules which state that all “important announcements” should be made to Parliament when it was sitting.
The Labour leader says taking advantage of a “short recess” is aimed at avoiding scrutiny of MSPs in a letter to Holyrood Presiding Officer Ken Macintosh.
“I would appreciate clarification from you about what your expectation is of Ministers making announcements to Parliament, and not purely in the media, particularly in short recesses,” Ms Dugdale states.
Ms Sturgeon revealed last Thursday at the SNP conference she would be publishing the referendum Bill this week.
It comes as Scotland’s Brexit minister Michael Russell today holds with MEPs in a bid to prevent a so-called “hard Brexit” for Scotland. He will be joined by External Affairs Secretary Fiona Hyslop at the European Parliament in Brussels as they call for Scotland to be allowed to stay in the European single market. They will also host a briefing session for more than 130 figures from Europe and further afield.