Social Insurance on Multiple Grounds in Bulgaria — Rules, Examples and Common Mistakes (2026)

Legal Framework

The primary legislation governing social insurance in Bulgaria is the Social Insurance Code (KSO). It defines which persons are subject to mandatory insurance, for which risks, and under what conditions. Additional rules are contained in:

• The Ordinance on the Elements of Remuneration and Income Subject to Insurance Contributions — specifies the concrete elements of insurable income.
• The State Social Insurance Budget Act for the respective year — annually sets the minimum and maximum insurable income, and the minimum insurance thresholds by economic activity and professional qualification group.
• Ordinance No. N-13 of the NRA — regulates the submission of data for insured persons (Declaration Form 1 and Declaration Form 6).

A key principle of the KSO is that insurance contributions are due on all income from employment activity, but the total amount on which contributions are calculated cannot exceed the maximum insurable income — for 2026 this is approximately EUR 2,112 per month.

Who Is Fully Insured and Who Is Partially Insured?

The KSO distinguishes two main groups of insured persons depending on the scope of covered insurance risks:

Full insurance (all social insurance risks)

Partial insurance (disability, old age and death only)

This distinction matters because when multiple grounds are combined, the scope of risks under each ground is determined independently, and contributions accumulate up to the maximum insurable income ceiling.

Two Employment Contracts Simultaneously

A person working under two or more employment contracts is insured under each of them separately. Each employer calculates and pays insurance contributions on the remuneration it pays. However, the total insurable income cannot exceed the maximum insurable income.

Employee's obligation

The employee is required to notify the second employer of the insurable income on which contributions are already being paid by the first. This is done through a declaration under Art. 4(1) of the Ordinance on the Elements of Remuneration. Based on this declaration, the second employer determines the insurable income ceiling up to which it must pay contributions.

Example with EUR figures (2026)

Maria works under two employment contracts. Her insurable income with the first employer is EUR 1,500. With the second — EUR 900. The total is EUR 2,400, but the maximum insurable income is EUR 2,112.

• First employer: contributions on EUR 1,500 (the full amount).
• Second employer: contributions on EUR 612 (EUR 2,112 − EUR 1,500), not the full EUR 900.
• The remaining EUR 288 (EUR 900 − EUR 612) is not subject to contributions.

If Maria fails to submit the declaration to her second employer and the employer pays contributions on the full remuneration, the overpaid amounts are subject to refund, but the process is administratively burdensome.

Employment Contract and Management Contract

A common scenario is a person employed under an employment contract in one company who also serves as a manager (under a management and control agreement) in another. Both relationships result in full insurance for all risks.

The rules are analogous to two employment contracts — contributions are paid under both grounds, with total insurable income capped at EUR 2,112. The order matters: income from the employment contract is counted first, then income from the management contract.

Example

Petar has an employment contract with insurable income of EUR 1,800 and is a manager of an OOD with monthly remuneration of EUR 600. Contributions:

• Under the employment contract: on EUR 1,800.
• Under the management contract: on EUR 312 (EUR 2,112 − EUR 1,800).

Self-Insured Persons — The One-Ground Rule

When a person has multiple grounds for self-insurance, they are insured on only one of them — by their own choice. This is expressly provided for in Art. 2(3) of the Ordinance on Social Insurance of Self-Insured Persons.

Typical scenarios

• Freelancer + EOOD owner: the person chooses whether to insure as a freelancer or as an EOOD owner working in the company. Contributions are not due on both grounds.
• OOD partner + sole trader: again — insurance on only one ground.
• Farmer + freelancer: by choice on one ground.

The minimum monthly insurable income for self-insured persons in 2026 is approximately EUR 275. Advance contributions are calculated on the chosen insurable income (between the minimum and maximum), and the final amount is determined through annual equalization.

Self-Insured and Employment Contract Simultaneously

If a person works under an employment contract and simultaneously carries out activity as a self-insured person, insurance contributions are due on both grounds, but the total insurable income again cannot exceed EUR 2,112.

Order of insurance

1. First, the insurable income from the employment contract is counted.
2. Then — the advance insurance contributions from self-insurance, on the difference up to the maximum income.

Example

Ivana works under an employment contract with insurable income of EUR 1,400 and is registered as a freelancer. She self-insures on the minimum income of EUR 275.

• Under the employment contract: contributions on EUR 1,400.
• As a self-insured person: advance contributions on EUR 275.
• Total: EUR 1,675 — does not exceed the ceiling of EUR 2,112, so she is insured on the full amount.

However, if her employment contract income were EUR 2,000, the maximum she could self-insure on would be EUR 112 (EUR 2,112 − EUR 2,000), even though the minimum self-insurance income is EUR 275. In that case, advance contributions are paid on EUR 112.

Civil Contracts — Different Scenarios

Insurance for work under civil contracts depends on whether the person is also insured on another ground:

Scenario 1: Civil contract + employment contract

When a person employed under an employment contract also receives income under a civil contract, insurance contributions are due on the sum of both incomes, but not exceeding EUR 2,112. Contributions under the civil contract are for disability, old age and death, split between the principal and the contractor.

Scenario 2: Civil contract without other insurance

If the person is not insured on another ground and the monthly remuneration under the civil contract (after deducting statutory recognized expenses) equals or exceeds the minimum wage, they are subject to insurance for disability, old age and death. The principal withholds and pays the contributions.

Scenario 3: Civil contract with low remuneration, no other insurance

If the monthly remuneration (after deducting expenses) is below the minimum wage and the person is not insured on another ground, no insurance contributions are due. The person remains uninsured for that month.

Example

Georgi works under an employment contract with insurable income of EUR 1,200. He also receives EUR 500 under a civil contract (statutory recognized expenses 25%, i.e. insurable income EUR 375).

• Under the employment contract: contributions on EUR 1,200.
• Under the civil contract: contributions on EUR 375.
• Total: EUR 1,575 — below the ceiling of EUR 2,112.

Priority Order of Income for Multiple Grounds

When a person is subject to insurance on multiple grounds, the KSO defines a priority order in which incomes are taken into account to reach the maximum insurable income. This order is regulated by Art. 6(11) of the KSO:

1. Income from employment and equivalent relationships (employment contracts, civil service).
2. Income from management and control agreements (managers, board members, procurists).
3. Income from self-insured activity (freelancers, sole traders, owners/partners in OOD/EOOD).
4. Income from civil contracts (contracts for work, mandate contracts, etc.).
5. Income from other activities subject to insurance.

This priority order means that if the sum of incomes from the higher-ranked sources already reaches the maximum insurable income, no contributions are due on the lower-ranked sources. In practice, the person (and the respective insurers) must correctly determine which portion of income falls within the ceiling and which falls outside it.

Annual Equalization of Insurable Income

Self-insured persons pay insurance contributions in advance on the monthly insurable income they have chosen. At year-end, however, they are required to perform annual equalization based on the actual income declared in the annual tax return under Art. 50 of the Personal Income Tax Act (PITA).

How does equalization work?

• The annual insurable income is determined as the sum of all insurable incomes for the year (from employment, self-insurance, civil contracts), but not more than 12 times the maximum monthly insurable income (12 × EUR 2,112 = EUR 25,344 for 2026).
• If actual self-insurance income is higher than the advance-declared amount — additional contributions are due.
• If actual income is lower — overpaid contributions are offset or refunded.
• Equalization is performed when filing the tax return — deadline 30 April of the following year.

Annual equalization is mandatory for all self-insured persons. Failure to complete it can result in NRA penalties and incorrect determination of insurance service record and income for pension purposes.

Common Mistakes with Insurance on Multiple Grounds

In our practice, we most frequently encounter the following problems:

1. Failure to submit a declaration to the second employer

   The employee does not notify the second employer of the insurable income with the first. Result: overpaid contributions, need for declaration corrections, and administrative burden.

2. Double self-insurance

   A person who is both a freelancer and an OOD partner pays insurance contributions on both grounds instead of just one. The excess payments are difficult to recover.

3. Failure to account for the civil contract

   A person working under an employment contract receives income under a civil contract, and neither the person nor the principal pays insurance contributions. Upon NRA inspection, contributions are assessed together with interest and penalties.

4. Incorrect priority order of incomes

   When filing the annual return, the person or accountant does not follow the statutory priority order of incomes. This leads to incorrect equalization and potential discrepancies with NRA records.

5. Failure to complete annual equalization

   Self-insured persons who also have income from other sources fail to perform annual equalization. Beyond the penalty, this also results in an incorrect insurance service record.

6. Incorrect determination of insurable income on civil contracts

   The principal does not deduct statutory recognized expenses (25%) and calculates contributions on the gross amount, or conversely deducts a higher percentage of expenses than allowed.

Frequently Asked Questions