Employment Brief: Introduction of a unified electronic employment record in Bulgaria

Following an amendment in the Bulgarian Labour Code in late 2023 which will enter into force on 1 June 2025, Bulgaria is moving towards the introduction of a unified electronic employment record. This change will affect all Bulgarian employers and their employees and bring an end to the issuance and maintenance of paper-based labour books. 

What are the upcoming changes and what will each employer need to do?

• Up to and including 31.05.2025, the handling of labour books will remain unchanged.
• As of 01.06.2025, all entries relating to the conclusion, amendment and termination of employment relationships – which are currently recorded in the labour book – will instead constitute electronic employment records (i.e. the current notifications to the NRA under Art. 62, para. 5 of the Labour Code). These records will be submitted using a qualified electronic signature (“QES“) in a fully digital environment, via an employment register to be established by the National Revenue Agency (“NRA“) by that date. Paper submission of this information will no longer be possible. However, in the absence of a QES, employers will be able to submit the information on digital medium (CD/USB) at the NRA office, accompanied by a covering letter.
  Please note that, with the introduction of the unified electronic employment record, circumstances that are currently not declared will also become subject to declaration to the NRA, including. the commencement of the employment relationship (not only the conclusion of the contract), the number of days of paid annual leave, as well as any leave taken in the year of termination, etc. We are available to provide more detailed information.
  The current deadlines for declaring the relevant circumstances will remain in place – three days from the conclusion or amendment of the employment relationship or seven days from its termination.  
  
• Between 01.06.2025 and 01.06.2026, employers will be obliged to request the labour books of their employees (unless they are held by the employer). It is recommended that each employer make this request in writing, so they can demonstrate compliance with the obligation and give employees sufficient time to provide their labour books. Depending on the number of employees and the organisational structure of the company, employers may wish to plan the collection of  labour books in stages, by department,  to avoid creating a backlog of documents for the responsible officers.
  
• Labour books should be completed by recording all service accrued with the employer up to and including 31.05.2025. The length of service must be entered in figures and words, signed by the chief accountant and the employer, as well as stamped with the company seal (if applicable). Unless the employment relationship has been terminated, the relevant fields for this (such as date and grounds for termination) should remain blank. We also recommend that the return of employees’ labour books be documented in writing, by means of a declaration signed by the employee and attached to their personnel file.
  It is important not to complete the labour books before 01.06.2025, in order to avoid situations where an employee leaves in the meantime and their length of service would need to be entered prematurely (and subsequently corrected as of 31.05.2025).
  
• Apart from entering the length of service as at 31.05.2025 in the labour books, no further action will be required from employers, as the length of service of all employees since 2003 should already be entered ex officio in the NRA system, which will be upgraded to the new employment register. In this regard, employees should retain their paper labour books, which will remain official certifying documents, particularly important for those with employment history prior to 2003.

Submission of data and access to the employment register

• Electronic employment records will be submitted by the employer or a person authorised by the employer (with an explicit power of attorney), as well as ex officio by the Labour Inspectorate (e.g. when a relationship is deemed to be an employment relationship) and by the NRA.
• Access to the employment register will be granted to:
  
  (1) Employees – each employee will have full access to their unified electronic employment record, including a history of access to their record.
  (2) Parents/guardians/custodians – in relation to records for persons under 18 years of age.
  (3) Employers – only in respect of employees they have hired.
  
  Access to the employment register may be requested using a QES, a Personal Identification Number (PIN) issued by the NRA, or via a paper application to the NRA. The data itself will be provided through the NRA portal, to a specified email address or on paper, as applicable.