What you will learn
- The new minimum wage and which contracts need updating
- How the electronic employment record works and the recording deadlines
- When and how to finalise and return paper employment booklets
- What the Pay Transparency Directive requires and what obligations it will create
- The retirement requirements for 2026
- The current social security thresholds
- How eurozone accession affects employment relationships
Minimum Wage 2026 — EUR 620.20
By Council of Ministers Decree No. 243 of 13.11.2025, the minimum wage from 01.01.2026 is set at BGN 1,213, or EUR 620.20 at the fixed exchange rate of BGN 1.95583/EUR.
What this means for employers
- If you have employees with a basic monthly salary below EUR 620.20, you must immediately conclude a supplementary agreement under Art. 119 of the Labour Code for an increase effective 01.01.2026
- The minimum hourly rate is EUR 3.72 (based on an 8-hour working day and an average of 166.17 working hours per month)
- The increase also affects supplementary remuneration calculated on the basis of the basic salary — night work, overtime, and seniority pay
Context
The 2026 minimum wage represents an increase of approximately 8.7% over 2025 (BGN 1,077 / EUR 550.66). The trend of annual increases continues, and employers should factor this into medium-term personnel cost planning.
Important note: The average gross salary for Q4/2025 according to the NSI is BGN 2,678 (~EUR 1,369). This figure determines a number of thresholds — the minimum salary for an EU Blue Card, unemployment benefits, and others.
Electronic Employment Record
The electronic employment record is the central reform in employment law, aiming at full digitalisation of employment relationship documentation.
What it is
The electronic employment record is an entry in the Employment Register maintained by the NRA, replacing the paper employment booklet. Every employer records data on the conclusion, amendment, and termination of employment contracts, length of service, and professional experience.
Timeline
| Date | Event |
|---|---|
| 01.06.2025 | Electronic employment record takes effect for the private sector. The Art. 62 notification is replaced by a registration in the Employment Register |
| 01.06.2025 — 01.06.2026 | Transition period — employers finalise paper booklets and return them to employees |
| 01.06.2026 | Deadline for finalising paper booklets. System extends to civil servants |
Recording deadlines
| Event | Recording deadline |
|---|---|
| Conclusion of an employment contract | 3 days |
| Amendment of an employment contract | 3 days |
| Termination of the employment relationship | 7 days |
| Change of employer (Art. 123, 123a Labour Code) | 10 days |
What data is recorded
- Legal basis for the employment relationship
- Date of conclusion and date of commencement of work
- Job title and NKPD code (national classification of occupations)
- Basic remuneration and supplementary remuneration
- Working time (full or part-time)
- Contract duration (open-ended/fixed-term)
- Date and grounds for termination
- Length of service and professional experience
Access to data
- The employer — records and reviews data on its employees
- The employee — views their own employment record via PIC or QES
- NRA and supervisory authorities — official access
What you should do NOW
- Check whether your payroll/HR system supports electronic submissions to the Employment Register
- Train the responsible staff on the new procedure
- Draw up a schedule for finalising paper employment booklets (deadline — 01.06.2026)
- Inform employees about how to access their electronic employment record
Paper Employment Booklets — Deadline 01.06.2026
Between 01.06.2025 and 01.06.2026, employers must:
- Finalise the paper employment booklets — record length of service in words and figures, signature of the responsible officer, and company stamp
- Return the booklets to employees — in person against a signature or by registered post with return receipt
- Document the handover — protocol or other document confirming the return
What happens after 01.06.2026
- The paper employment booklet loses its legal significance as a document for establishing length of service for future periods
- It remains valid as evidence of service accrued before the electronic record took effect
- Employees should retain it — it will be needed for retirement to certify service before June 2025
Penalties for non-compliance
- An administrative fine under Art. 414 of the Labour Code — from EUR 767 to EUR 7,669 for the employer
- Employee claims for compensation under Art. 226(2) of the Labour Code — for the period during which the employee was unable to start new employment due to the employer retaining the booklet
Pay Transparency Directive — Deadline 7 June 2026
Directive (EU) 2023/970 on strengthening the application of the principle of equal pay between men and women for equal work or work of equal value is among the most significant European employment law initiatives.
Transposition deadline: 7 June 2026. As of March 2026, the Directive has not yet been transposed into Bulgarian law.
What the Directive requires
1. Pre-hire pay transparency
- The employer must disclose the starting salary or salary range in the job posting or before the interview
- It is prohibited to ask the candidate about their current salary with a previous employer
2. Right to information for employees
- Every employee has the right to receive information on average pay levels by gender for comparable work or work of equal value
3. Mandatory gender pay gap reporting
| Company size | Reporting frequency |
|---|---|
| 250+ employees | Annually |
| 150–249 employees | Every 3 years |
| 100–149 employees | Every 3 years (with a possible grace period) |
4. Joint assessment — Where the pay gap between men and women exceeds 5% and cannot be explained by objective factors, the employer must conduct a joint assessment with employee representatives and take corrective measures.
What you should do NOW
- Conduct an internal pay audit — analyse gender pay gaps for comparable positions
- Create a job classification system — to determine which positions are of “equal value”
- Prepare an internal transparency policy — how you will provide information to candidates and employees
- Train your HR team — the prohibition on asking about current salary, the obligation to disclose a salary range
Retirement Requirements 2026
Old-age pension (Art. 68 Social Insurance Code)
| Gender | Required age | Required length of service |
|---|---|---|
| Women | 62 years and 6 months | 36 years and 10 months |
| Men | 64 years and 9 months | 39 years and 10 months |
Individuals who have reached 67 years of age may retire with a minimum of 15 years of actual insured service. The minimum old-age pension is EUR 322.37 (BGN 630.57) — at 2025 levels until the 2026 budget is adopted.
What employers need to know
- Upon reaching retirement age and service requirements, the employee does not automatically retire
- The employer may terminate the contract under Art. 328(1)(10), but only if this is the employee’s first pension
- Upon termination due to retirement, compensation is owed under Art. 222(3) of the Labour Code — 2 or 6 gross salaries
Social Security Thresholds and Contributions
| Parameter | EUR | BGN |
|---|---|---|
| Minimum wage | 620.20 | 1,213 |
| Minimum insurable income for the self-employed | 550.66* | 1,077* |
| Maximum insurable income | 2,111.64* | 4,130* |
| Poverty line | 390.63 | 764 |
| Average gross salary (Q4/2025) | ~1,369 | 2,678 |
*At 2025 levels until the 2026 budget is adopted.
Social security contributions — split
- Pension Fund: employer — 8.22% / employee — 5.58%
- General Sickness and Maternity Fund: employer — 2.10% / employee — 1.40%
- Unemployment Fund: employer — 0.60% / employee — 0.40%
- Supplementary Mandatory Pension Insurance (UPF): employer — 2.80% / employee — 2.20%
- Health Insurance: employer — 4.80% / employee — 3.20%
Note: As of March 2026, the 2026 state budget has not been adopted. After adoption, maximum insurable income, minimum insurable income for the self-employed, and certain contribution rates may change.
Eurozone — Impact on Employment Relationships
Bulgaria’s accession to the eurozone on 01.01.2026 at the fixed exchange rate of BGN 1.95583 = EUR 1 affects all aspects of employment relationships.
Salary recalculation
All employment remuneration is now paid in EUR. When rounding — always in favour of the employee (to the second decimal place, rounded up).
Example: salary BGN 2,500 → EUR 1,278.23 (not EUR 1,278.22)
Updating employment contracts
Concluding new employment contracts is not mandatory — it is sufficient for the employer to notify employees of the EUR equivalent. However, signing a brief supplementary agreement fixing the salary in EUR is recommended.
System updates
- Payroll software must operate in EUR
- Accounting systems — transition to EUR
- Cash registers — if used for salary payments in cash
- Internal policies and procedures — update all amounts
Dual display
During the transition period (01.01.2026 — 30.06.2027), dual display of prices and amounts in BGN and EUR is mandatory. This also applies to payslips — they must show amounts in both currencies.
Frequently asked questions
Conclusion
The first half of 2026 is packed with changes affecting every employer in Bulgaria. From the minimum wage increase to EUR 620.20, through the definitive transition to electronic employment records, to the upcoming transposition of the Pay Transparency Directive — the obligations are numerous and come with specific deadlines.
If you need assistance bringing employment contracts and internal policies into line with the new requirements, contact Innovires Legal. Our team will help you meet all deadlines and avoid administrative penalties.
This article is for informational purposes only and does not constitute legal advice. Certain parameters mentioned are subject to update upon adoption of the 2026 state budget. Information is current as of March 2026.
Need assistance?
The Innovires team can help you bring employment contracts and internal policies into line with the new 2026 requirements.