What you will learn in this article
- The minimum working age and applicable exceptions
- The procedure for obtaining a Labour Inspectorate permit
- Which activities are prohibited for minors
- Working hour restrictions and why they are stricter
- When a medical examination is required and who issues it
- Special dismissal protection for minor employees
What the law says
The legal framework governing employment of minors is contained in several legislative acts that every employer must know and comply with before hiring a person under 18.
The Labour Code (LC) sets out the core rules in Articles 301–305. These provisions define the minimum employment age, the requirement for a prior permit from the Labour Inspectorate, and working hour limitations. Chapter XV, Section I of the LC is entirely dedicated to the special protection of minor workers.
Ordinance No. 6 of 24.07.2006 on the conditions and procedures for granting work permits to persons under 18 specifies the procedural requirements. It lists the required documents, deadlines, and catalogues of prohibited work.
The Child Protection Act additionally regulates the participation of children in certain activities — advertisements, film productions, cultural events, and sports competitions, for which specific conditions and permits apply.
Violations of the rules on employing minors result in significant administrative fines for the employer — from BGN 1,500 to BGN 15,000 (approximately EUR 750 to EUR 7,500) for a first offence, and from BGN 3,000 to BGN 20,000 (approximately EUR 1,500 to EUR 10,000) for repeat offences (Art. 414 LC).
Minimum age
General minimum age — 16 years
Under Art. 301(1) LC, the minimum age for employment is 16 years. This rule is mandatory — an employer who hires a person under 16 for a regular position violates labour legislation.
Exception — 15 years for light work
Exceptionally, persons who have turned 15 may be hired to perform light work (Art. 301(2) LC). Light work means an activity that is not dangerous or harmful to the person's health, physical, mental, or moral development, and whose performance does not prevent school attendance or participation in vocational orientation programmes.
Typical examples include: assistance in the family business, light clerical work, sorting and packaging of non-heavy products, distributing promotional materials, and similar.
Children under 15
Persons under 15 may only participate in filming, preparation and conduct of cultural and artistic events, sports competitions, and advertising activities (Art. 301(3) LC), provided this does not harm their health, development, and education.
| Age group | Permitted activities | Working hours |
|---|---|---|
| Under 15 | Cultural, artistic, sports events, advertising only | Individual schedule |
| 15–16 | Light work, not hazardous | Max 24 h/week, 5 h/day |
| 16–18 | General rule for permissible activities | Max 35 h/week, 7 h/day |
Labour Inspectorate permit
An employment contract with a minor may be concluded only after obtaining a prior permit from the Labour Inspectorate. This applies to all persons under 18, without exception (Art. 302–303 LC).
Who submits the application
The application is submitted by the employer to the Labour Inspectorate in whose territory the workplace is located (not the employer's registered office). This distinction is significant, particularly when the employer's seat is in Sofia but the workplace is in another city.
Required documents
- Application for a permit — using the official template published on the General Labour Inspectorate website.
- Job description for the position.
- Risk assessment card or list of identified risks at the workplace, together with measurement protocols for work environment factors.
- Description of health and safety measures for the minor.
- Medical fitness certificate — certified copy.
- Working time distribution — only for persons aged 15–16.
- Individual daily schedule for studies — only for persons under 15.
Submission channels
- In person at the relevant Labour Inspectorate.
- Via the GIT electronic portal — requires a qualified electronic signature (QES).
- Via the Secure Electronic Delivery System (SEDS).
- By post or licensed postal operator.
Deadline and fees
The Labour Inspectorate decides within 7 days of document submission (or from the date irregularities are corrected). No state fee is charged. If documents are incomplete, the employer is given at least 5 days to correct them.
Validity of the permit
The permit remains valid until:
- Termination of the employment contract for which it was issued.
- The worker turning 18.
- Revocation of the permit by the Labour Inspectorate.
A refusal to issue a permit may be appealed in court.
Prohibited activities
The law categorically prohibits certain types of work for persons under 18. These prohibitions derive from Art. 304 LC and are specified in Ordinance No. 6/2006, noting that the lists in the ordinance are not exhaustive.
Absolute prohibitions
Night work. Minors may not perform night work (Art. 140(4)(2) LC). For this category, “night” is the period from 20:00 to 06:00 — two hours earlier than the standard 22:00 to 06:00 for adults.
Overtime. Overtime work by minors is prohibited (Art. 147(1)(2) LC). This rule admits no exceptions, even in force majeure circumstances.
Prohibited types of work
- Work with loads exceeding age and gender-based limits (Ordinance No. 16/1999).
- Work with chemical agents, carcinogenic, and mutagenic substances.
- Work involving ionising radiation.
- Underground work (mines, tunnels, sewers).
- Work in temperature conditions exceeding permissible limits.
- Work with machinery and equipment posing increased risk.
- Work involving noise, vibrations, or electromagnetic fields above permissible levels.
- Work in establishments serving alcoholic beverages and tobacco (for persons under 16).
The employer must conduct a risk assessment specifically for the minor's workplace and document protective measures.
Working hours
Reduced working hours are one of the main safeguards for minor employees. The rules in Art. 305(3) LC are mandatory — the employer may not derogate from them even with the minor's or parent's consent.
Maximum duration
| Age group | Daily working hours | Weekly working hours |
|---|---|---|
| 15–16 years | not more than 5 hours | not more than 24 hours |
| 16–18 years | not more than 7 hours | not more than 35 hours |
For comparison, the standard working time for adults is 8 hours per day and 40 hours per week.
Leave entitlement
Minor employees are entitled to:
- Extended paid annual leave — not less than 26 working days (Art. 305(4) LC), compared to 20 working days for adults.
- Leave at preferred times — minors may take their paid annual leave during summer and at any other time they choose (Art. 305(5) LC).
- Rest break — for working days of 4.5 to 7 hours, the minor worker has the right to a break of at least 30 minutes.
Medical examinations
A medical examination is a mandatory prerequisite for a minor to commence work. Without a medical fitness certificate, the Labour Inspectorate will not issue a work permit.
For persons aged 15–18
The medical fitness certificate is issued by the employer's Occupational Health Service (OHS). The minor must first present to the OHS a medical certificate for commencing work from their general practitioner.
For persons under 15
Children under 15 participating in cultural, artistic, or sports events require a medical certificate from a Medical Advisory Commission (LKK), confirming the activity will not harm the child's health or interfere with their development.
Periodic examinations
Minor employees are subject to annual periodic medical examinations organised by the employer. If deterioration in health or unfitness for the work is identified, the employer must immediately take measures — transfer to another suitable position or terminate the employment contract.
Special dismissal protection
Minor employees enjoy special dismissal protection under Art. 333(2) LC. This protection is broader than the general protection under Art. 333(1) — it applies to every ground for dismissal, not only specific ones.
The employer may terminate a minor's employment contract only with a prior permit from the Labour Inspectorate for each specific case. Dismissal without such permit is unlawful and subject to court annulment.
This protection is additional and cumulative — if the minor also falls within another protected category (e.g., a rehabilitated worker or a worker with a condition listed in Ordinance No. 5), both protections apply simultaneously.
The only exception is complete closure of the enterprise (Art. 328(1)(1) LC), where the special protection does not apply.
Practical guidance for employers
Before hiring a minor, follow this sequence:
- Verify the position is permissible. Check whether the work is on the prohibited activities list in Ordinance No. 6/2006.
- Conduct a risk assessment specifically for the minor's workplace.
- Obtain a medical certificate from the person's general practitioner and submit it to your Occupational Health Service for a fitness assessment.
- Prepare the Labour Inspectorate documents — application form, job description, risk card, medical certificate.
- Submit the application to the Labour Inspectorate at the workplace location.
- Await the permit — 7 working days.
- Conclude the employment contract only after receiving the permit.
- Register the contract with the NRA within the standard 3-day deadline.
- Observe the reduced working hours — organise the schedule accordingly.
- Arrange periodic medical examinations — annually.
Frequently asked questions
Conclusion
Employing minors in Bulgaria is subject to strict legal requirements designed to protect the health, development, and education of young workers. Employers must obtain a Labour Inspectorate permit before concluding an employment contract, ensure compliance with reduced working hours, and refrain from assigning prohibited activities. Failure to comply carries significant fines.
If you need assistance with hiring minor employees or have questions regarding the legal protection of persons under 18, the team at Innovires Legal can provide guidance. Contact us for a consultation.
This article is prepared for informational purposes only and does not constitute legal advice. For a specific legal question related to your situation, please consult a qualified lawyer.
Need assistance?
The Innovires team can assist you with employment law questions — from Labour Inspectorate permits to compliance with working hour restrictions.