What are Internal Labour Regulations and why are they mandatory
Internal Labour Regulations are an internal normative act of the employer regulating the organisation of work and employment relations in the enterprise. They are mandatorily issued under Art. 181 LC: “The employer is obliged to issue internal labour regulations setting out in detail the rights and obligations of workers and employees and of the employer under the labour relationship and regulating the organisation of work in the enterprise in accordance with the specifics of its activity.”
No minimum workforce
Unlike other duties (e.g. establishing a Working Conditions Group at 5+ workers, or a Working Conditions Committee at 50+), the ПВТР is mandatory regardless of the number of workers. Even with 1 employment contract, the employer must issue them.
Functions
- Establishes the organisation of the work process — working time, shifts, breaks;
- Specifies rights and obligations of the parties;
- Sets the internal disciplinary regime — violations and sanctions;
- Serves as the basis for disciplinary measures — without ПВТР an imposed sanction may be annulled;
- Facilitates defence in court in labour disputes;
- Is a single document fulfilling the duty to acquaint workers with rules (Art. 403 LC).
Distinction from CBA and employment contract. The individual employment contract covers one worker. The collective bargaining agreement (CBA) governs employer–union relations. The ПВТР are generally applicable — valid for all workers, regardless of union membership.
Mandatory content
The LC does not prescribe a rigid structure, but practice and Labour Inspectorate guidance set out a stable core:
1. General provisions
- Employer name, UIC, seat;
- Scope of the ПВТР;
- Date of entry into force.
2. Work organisation
- Working-day start and end;
- Shifts, rotation and duration;
- Recording of working time (daily, weekly, monthly, cumulative);
- Flexible working time — core hours;
- Home-office rules — see our remote work article.
3. Breaks
- Daily rest (minimum 12 hours);
- Weekly rest (minimum 48 hours for a 5-day week);
- Lunch break — duration and timing;
- Meal time in continuous-process environments.
4. Leave
- Procedure for requesting and approving paid annual leave;
- Unpaid leave;
- Specific leaves (maternity, sickness, civic duty).
5. Labour-law discipline
- Worker duties (Art. 126 LC);
- Employer duties (Art. 127 LC);
- Specific disciplinary violations;
- Disciplinary sanctions (reprimand, warning, dismissal) — Art. 187–190 LC;
- Procedure for imposing sanctions.
6. Health and safety
- Obligations under the Health and Safety at Work Act;
- Induction and training;
- Risk assessment;
- Conduct in emergencies and accidents.
7. Information protection
- Trade-secret confidentiality;
- Personal-data protection (GDPR);
- Electronic communication and IT resource rules;
- Workplace video monitoring — see our separate article.
8. Final provisions
- Procedure for updating the ПВТР;
- References to other internal documents (job descriptions, policies);
- Date and employer’s signature.
Adoption and issuance procedure
Step 1: Drafting
The employer (or HR) prepares a draft ПВТР with all mandatory sections. Template use is advisable but must be adapted to the specific activity.
Step 2: Prior consultations
Art. 181(1) LC requires prior consultations with:
- Trade union representatives in the enterprise (if any);
- Workers’ and employees’ representatives — elected by a general meeting (Art. 7a LC).
Important: the law requires only consultation, not agreement. The employer may issue the ПВТР even without representatives’ consent, provided consultations took place. Absence of consultation, however, is a procedural violation sanctioned by the Labour Inspectorate.
Step 3: Issuance
The employer issues ПВТР in written form, with signature and date:
- Name and position of the issuer;
- Date of issue;
- Company stamp (recommended).
Step 4: Employee acknowledgement
Each worker must be acquainted against signature. Practical methods:
- Receipt for the ПВТР copy;
- Acknowledgement form (separate);
- Record in an HR system with electronic signature.
A copy must be permanently accessible at a visible location on site and/or the corporate intranet.
Step 5: Updating
When work organisation, hours or disciplinary rules change — the ПВТР are updated following the same procedure (consultation + renewed acknowledgement).
Legal limits on content
The ПВТР cannot contradict:
- Mandatory LC provisions — e.g. cannot extend normal working time beyond 8 hours, reduce minimum annual leave, or introduce bans beyond the law;
- Any Collective Bargaining Agreement (CBA) in the enterprise or sector — conditions cannot be less favourable than the CBA;
- Minimum health-and-safety requirements of the HSW Act;
- GDPR and the Personal Data Protection Act — video monitoring, worker-data processing;
- The principle of equality — non-discrimination by gender, age, ethnicity, health.
Common invalid clauses
- “The worker is liable for all damages in full salary” — contradicts Art. 203 et seq. LC;
- “The employer may retain the employment book on departure” — unlawful;
- “Annual leave cannot be carried over” — contradicts Art. 176 LC;
- “Automatic disciplinary dismissal after 2 delays” — contradicts proportionality under Art. 189 LC.
Sanctions — the Labour Inspectorate
Compliance with Art. 181 LC is enforced by the Labour Inspectorate (ИА ГИТ). During inspections it requests the ПВТР, consultation records and employee acknowledgements.
Sanctions under Art. 414 LC
| Violation | Sanction (BGN) | EUR equivalent |
|---|---|---|
| Missing ПВТР (employer) | 1,500–15,000 | EUR 767–7,669 |
| Missing ПВТР (officer) | 1,000–10,000 | EUR 511–5,113 |
| ПВТР without union/representative consultation | 1,500–15,000 | EUR 767–7,669 |
| No signed acknowledgement | 1,500–15,000 | EUR 767–7,669 |
| Clauses contradicting LC | 1,500–15,000 | EUR 767–7,669 |
| Repeat violation | Double | Up to EUR 15,338 |
Sanctions are imposed by АУАН and penalty order under the Administrative Violations and Sanctions Act. See our article on appealing АУАН and penalty orders.
Court consequences
Beyond administrative sanctions, missing or defective ПВТР may:
- Invalidate imposed disciplinary sanctions (no documented basis);
- Hamper defence in unfair dismissal claims — no documented disciplinary procedures;
- Trigger liability for damages to workers on identified irregularities.
Practical tips for employers
- Don’t use a template without adaptation. Typical drafts don’t reflect your specifics — schedules, roles, work processes.
- Document consultations. Prepare a protocol or written record of the consultation with unions and representatives — it’s the first thing the Labour Inspectorate asks for.
- Elect worker representatives. Without a union, hold a general meeting to elect representatives under Art. 7a LC — without them, no valid consultation.
- Signature is mandatory. Wet-ink or qualified electronic signature only — simple chat or email confirmations are not enough.
- Permanent accessibility. The ПВТР must be visible on site (board, intranet, HR system) — not only in HR’s file.
- Update on change. Introducing home office, new shifts, new rules — mandatory update with renewed acknowledgement.
- Align with the CBA. If a sectoral/company CBA exists, ensure ПВТР complies — otherwise the CBA prevails.
- Review every 1–2 years. Even absent formal changes — the law evolves (remote work, GDPR, AML). Specialist review recommended.
LC text at lex.bg. Labour Inspectorate guidance at gli.government.bg.
Drafting or revising the Internal Labour Regulations?
From preparing bespoke Internal Labour Regulations, through the consultation procedure with representatives, to defence during a Labour Inspectorate audit — the Innovires team supports employers through the full labour-law process. Tailored approach by sector and activity. Contact us for a diagnostic review of your current ПВТР or for drafting a new one.