Electronic Employment Record Bulgaria 2025-2026 | What Changed

Q: What is the Unified Electronic Employment Record (EETZ)?

The EETZ is an electronic register maintained by the National Social Security Institute (NSSI) that replaces the traditional paper employment book. It contains data on all employment relationships of the employee: employer, position, start and end dates, grounds for termination, length of service, and more.

Q: Do I need to return my paper employment book?

No. The paper employment book remains with the employee. The NSSI recommends keeping it until retirement because it may serve as evidence for length of service acquired before the introduction of the EETZ, particularly for periods before 2003.

Q: What penalties does the employer face for non-compliance?

For failure to submit or late submission of data to the EETZ, the employer faces a property sanction of BGN 1,500 to BGN 15,000 (approximately EUR 767 to EUR 7,669). For a repeated violation, the sanction is doubled.

Q: How is pre-2003 employment data handled?

For periods before 2003, when mandatory electronic registration of employment contracts did not exist, the EETZ data may be incomplete. This is why it is essential to keep the paper employment book and any other documents evidencing length of service from that period.

What you will learn

What the Unified Electronic Employment Record (EETZ) is and its legal framework.
What data the electronic record contains.
Who has access to the data and how your personal information is protected.
Key dates and deadlines for the transition.
A complete employer compliance checklist.
What happens to the paper employment book.
How to check your own electronic record.
The penalties employers face for non-compliance.

What is the EETZ

The Unified Electronic Employment Record (EETZ) is an electronic register maintained by the National Social Security Institute (NSSI) that replaces the traditional paper employment book. The legal basis for the EETZ is the new Article 128b of the Labour Code, introduced by the amendments published in the State Gazette, issue 27 of 2025.

The EETZ is part of the broader initiative to digitise employment relations in Bulgaria, following the example of other European countries that have already transitioned to electronic registers. The goal is to ensure greater transparency, accessibility, and security of employment history data for every employee.

Unlike the paper employment book, which was physically held by the employee and could be lost, damaged, or destroyed, the EETZ is a centralised database with backups and a high level of data protection. Data is submitted by the employer electronically, and the employee can review it at any time.

The EETZ system builds on the NSSI’s existing infrastructure for registering employment contracts (notifications under Article 62(5) of the Labour Code), expanding it significantly. In addition to the existing data on concluding and terminating employment contracts, new fields have been added for position, base salary amount, professional experience, compensation payments, and more.

What data does it contain

The EETZ contains the following categories of data for each employment relationship:

Core employment contract data

Date the employment contract was concluded.
Legal basis for the contract (indefinite-term, fixed-term, replacement, etc. under Articles 67–68 of the Labour Code).
Job title and code under the National Classification of Professions and Positions (NKPD).
Place of work (city and address).
Agreed working time (full-time, part-time, number of hours).
Base salary amount.
Probation period (if agreed, under Article 70 of the Labour Code).

Data on changes to the employment relationship

Changes in position, workplace, or salary.
Conversion from fixed-term to indefinite-term contract.
Changes in working time.
Data from supplementary agreements under Article 119 of the Labour Code.

Data on termination

Date of termination of the employment relationship.
Grounds for termination (specific article and paragraph of the Labour Code).
Amount of termination compensation.
Unused paid annual leave for which compensation is owed under Article 224 of the Labour Code.

Data on length of service and professional experience

Total length of service.
Professional experience within the meaning of the Ordinance on the Structure and Organisation of Wages.
Data on recognised length of service from other legal relationships (e.g., military service, doctoral studies).

Data on leave and specific circumstances

Unpaid leave that counts towards length of service (up to 30 working days per year under Article 160(3) of the Labour Code).
Data on maternity/paternity leave taken.
Data on disciplinary sanctions (reprimand, warning of dismissal, dismissal).

Who has access

Access to the EETZ data is strictly regulated with a view to protecting personal data in compliance with the General Data Protection Regulation (GDPR / Regulation (EU) 2016/679).

The employee has full access to all their data in the EETZ. Access is through the electronic services of the NSSI or the NRA using a personal identification code (PIC) or a qualified electronic signature (QES). The employee can review their data, print reports, and submit alerts if discrepancies are found.

The employer has access only to the data they themselves submitted for their current and former employees. The employer cannot see data submitted by the employee’s previous employers. This is an important safeguard for confidentiality: your new employer will not know how much you earned at your previous job unless you provide that information yourself.

State authorities (Labour Inspectorate, NSSI, NRA, courts) have access to the data within the scope of their statutory powers.

GDPR considerations: The data in the EETZ is processed on the basis of a legal obligation (Article 6(1)(c) of the GDPR). The employer, acting as a data controller, is required to inform employees about the processing of their data in the EETZ. It is recommended that this information be included in the company’s data protection policy.

Key dates and deadlines

Date / Deadline	Event
1 June 2025	The EETZ becomes operational. Employers are required to submit data electronically for all new employment contracts and changes
3 business days	Deadline for submitting data when concluding a new employment contract or amending its terms
7 business days	Deadline for submitting data upon termination of the employment relationship
10 business days	Deadline for submitting data in the event of a change of employer (e.g., transfer of undertaking under Article 123 of the Labour Code)
1 June 2026	Final deadline for full transition. By this date, employers must have transferred all historical data for existing employment relationships

Important note on deadlines: The 3, 7, and 10-day periods are counted in business days, not calendar days. They run from the occurrence of the relevant event. Late submission exposes the employer to a penalty.

The transitional period until 1 June 2026 is intended for employers to bring their systems and processes into compliance with the new requirements, train staff, and transfer historical data for existing employment relationships.

Employer compliance checklist

To ensure full compliance with the new requirements, the following checklist is recommended:

Technical preparations

Verify that your payroll system (or accounting software) supports submitting data in the EETZ format.
Update your software to a version compatible with the new requirements.
Obtain a QES for the persons who will be submitting the data.
Test the connection with the NSSI electronic system.

Organisational measures

Designate a responsible person (or persons) for submitting data to the EETZ.
Develop an internal procedure to ensure compliance with the 3, 7, and 10 business-day deadlines.
Train HR and accounting staff on the new requirements.
Update the job descriptions of responsible persons if necessary.

Legal obligations

Update internal personal data processing rules to include information about the EETZ.
Inform employees about the processing of their data in the EETZ (obligation under Article 13 of the GDPR).
Review contracts with external payroll providers and ensure a data processing agreement is in place (Article 28 of the GDPR) if they submit data on your behalf.
Review and, if necessary, update the Record of Processing Activities (Article 30 of the GDPR).

Transitional actions (by 1 June 2026)

Carry out an inventory of all current employment relationships.
Cross-check data in paper employment books against the electronic data already in the NSSI system.
Submit correcting data where discrepancies are found.
Transfer all required historical data for existing employment relationships.

What happens to the paper employment book

One of the most common questions is whether the paper employment book must be destroyed or returned. The answer is clear: no, the paper employment book remains with the employee.

The NSSI specifically recommends that employees keep the paper employment book at least until retirement. The reason is practical: for periods before 2003 (when mandatory electronic registration of employment contracts was introduced), the EETZ data may be incomplete or entirely absent. The paper employment book remains the only evidence of length of service from those earlier periods.

Legal status of the paper employment book after 1 June 2025:

From 1 June 2025, employers are no longer required to make entries in the paper employment book for newly created employment relationships. For existing (ongoing) relationships, however, employers must continue to maintain both the paper book and the electronic record in parallel until 1 June 2026.

The paper employment book retains its evidentiary value for the entire period for which it contains entries. In a dispute about length of service, it can be presented before a court, the NSSI, or another authority as written evidence.

If the paper employment book is lost or destroyed, data for periods after 1 June 2025 can be recovered from the EETZ. For earlier periods, however, recovery can be significantly more difficult.

Practical tip: Scan your paper employment book and store a digital copy in a secure location.

How to check your record

Every employee can verify their data in the EETZ electronically. Here are the two main methods:

Option 1: Through the NRA portal (portal.nap.bg)

Log in to the NRA portal with your PIC or QES.
Navigate to the “Insurance” or “Employment Contracts” section.
Review the data on registered employment contracts and insurance history.
If you find discrepancies, submit a report through the portal or contact your employer.

Option 2: Through the NSSI portal (noi.bg)

Log in to the NSSI electronic services with your PIC or QES.
Select the Unified Electronic Employment Record inquiry service.
You can print a report covering your full employment history or a specific period.

How to obtain a PIC

The personal identification code (PIC) is issued free of charge by any NRA office. You need to appear in person with an identity document. The PIC is issued on the spot within minutes. Alternatively, you can use a QES if you have one.

What to do if you find an error

If you discover an inaccuracy or missing data, the first step is to contact the employer (or former employer) who submitted the data, with a written request for correction. The employer is obliged to submit correcting data. If the employer refuses or no longer exists (liquidated or deregistered company), you can file a complaint with the Labour Inspectorate or the NSSI, presenting evidence (paper employment book, employment contract, payslips, etc.).

Penalties

The legislature has provided for significant penalties for employers that fail to comply with their EETZ obligations.

For failure to submit or late submission of data

Under the amended Article 414 of the Labour Code, an employer that fails to submit data to the EETZ within the prescribed deadlines or submits inaccurate data faces a property sanction of BGN 1,500 to BGN 15,000 (approximately EUR 767 to EUR 7,669). For a repeated violation, the sanction is doubled: BGN 3,000 to BGN 30,000 (approximately EUR 1,534 to EUR 15,339).

For refusing to provide data access to the employee

If the employer refuses to provide the employee with a report on the data submitted about them, or refuses to make a correction where an error has been proven, this also carries a penalty under Article 414 of the Labour Code.

Supervisory authority

Compliance with EETZ obligations is supervised by the Labour Inspectorate (General Labour Inspectorate Executive Agency). During inspections, inspectors can compare the data in the EETZ with the actual situation and establish violations.

Practical risks for employers beyond fines

Inaccurate data in the EETZ can lead to labour disputes with employees, problems during Labour Inspectorate inspections, difficulties when bidding for public procurement contracts (where proof of hired staff is required), and other adverse consequences.

Frequently asked questions

What is the Unified Electronic Employment Record (EETZ)?

The EETZ is an electronic register maintained by the NSSI that replaces the paper employment book. It contains data on all employment relationships of the employee: employer, position, start and end dates, grounds for termination, length of service, and more. Its legal basis is the new Article 128b of the Labour Code.

Do I need to return my paper employment book?

No. The paper employment book remains with you. The NSSI recommends keeping it at least until retirement, as it constitutes evidence for length of service from periods before the introduction of electronic registration, particularly for service before 2003.

How can I check my electronic employment record?

You can check your data through the electronic services of the NRA (portal.nap.bg) or the NSSI (noi.bg) using a PIC or QES. A PIC can be obtained free of charge from any NRA office by appearing in person with an identity document.

What are the deadlines for the employer to submit data?

The employer must submit data within: 3 business days of concluding an employment contract or amending its terms, 7 business days of termination of the employment relationship, and 10 business days in the event of a change of employer (transfer of undertaking under Article 123 of the Labour Code).

What penalties does the employer face for non-compliance?

For failure to submit or late submission of data, the employer faces a property sanction of BGN 1,500 to BGN 15,000 (approximately EUR 767 to EUR 7,669). For a repeated violation, the sanction is doubled.

When did the electronic employment record become mandatory?

The EETZ has been operational since 1 June 2025. From that date, employers are required to submit data electronically. The deadline for full transition, including the transfer of historical data for existing employment relationships, is 1 June 2026.

How is pre-2003 employment data handled?

For periods before 2003, the EETZ data may be incomplete because mandatory electronic registration of employment contracts did not exist at the time. It is therefore essential to keep the paper employment book and any other documents evidencing length of service from that period.

I work abroad. Does the EETZ apply to me?

The EETZ covers only employment relationships concluded under Bulgarian labour law. If you work abroad under an employment contract governed by the law of another country, that data will not appear in the EETZ. For recognition of foreign employment when claiming a pension, the EU social security coordination rules apply (Regulation (EC) No 883/2004 and Regulation (EC) No 987/2009). However, if you have an employment contract with a Bulgarian employer who posts you abroad, the posting data is recorded in the EETZ.

Conclusion

The transition to an electronic employment record is a significant change in Bulgarian labour law that affects all employers and employees. For employers, the key priority is to ensure timely and accurate submission of data within the prescribed deadlines, train staff, and update internal processes. For employees, the recommendation is straightforward: check your electronic employment record and make sure your data is correct.

The deadline for full transition is 1 June 2026. If you have not yet taken the necessary steps, do not delay. The penalties for non-compliance are substantial, and timely preparation will save you from problems down the line.

Contact Innovires Legal if you need assistance with compliance. We can help you prepare internal documents, train your staff, and navigate the complete legal framework of the transition.

This article was prepared by Innovires Legal and is for informational purposes only. The content does not constitute legal advice on any specific case. For legal advice tailored to your situation, please contact us or another qualified lawyer. The applicable legislation and case law may change after the date of publication.

Electronic Employment Record in Bulgaria — What Changed (2025–2026)