Starting an HR/Recruitment Agency in Bulgaria — Employment Intermediation Registration (2026)

Employment intermediation — scope of the activity

Employment intermediation is an activity in which a person (individual or legal entity) connects job seekers with employers and assists in the conclusion of an employment or other labour relationship. In practice, this is the classic field of HR agencies, recruitment firms and specialised headhunter boutiques.

Bulgarian legislation distinguishes this activity from several related but different regimes:

• HR consulting — training, staff assessment, organisational design — does not fall under this registration regime.
• Temporary work agency services — here the intermediary effectively becomes the employer of the assigned worker. This is a separate legal regime with its own registration and stricter requirements.
• Job board platforms — if they are limited to publishing ads without active matchmaking, they do not always fall within the scope, but practice shows that any shift toward active candidate screening triggers the registration requirement.

If your activity involves active sourcing, interviewing, recommending candidates and assisting with contract conclusion — that is intermediation and needs to be registered, regardless of what you call it commercially (recruitment, executive search, talent acquisition).

Legal framework

The regime is regulated at two main levels:

• Employment Promotion Act (EPA) — the framework law defining who may carry out intermediation activities and the core principles that apply.
• Ordinance on the Terms and Procedure for Carrying Out Employment Intermediation — which details the documentation, procedural steps, templates and oversight powers.

The competent authority is the Employment Agency (Agenciya po zaetostta, AZ), and licensed intermediaries are entered into the Unified Electronic Centralised Register of Natural and Legal Persons Carrying Out Intermediation Activities and/or Providing Temporary Work. The register is public and accessible online, which gives it a trust-signal function — any employer or job seeker can verify whether an agency is duly licensed.

The golden rule: services to job seekers must be free

Before diving into the procedure, we must underline one rule that is absolute and whose violation leads to immediate revocation of the registration: services provided to job seekers and to workers hired through the intermediary must be free of charge.

This means the following:

• No fees may be collected — whether fixed, percentage-based or disguised as “subscriptions”, “processing fees” or “CV editing” — from the candidate.
• No indirect schemes are permitted — for example, agreeing with the employer that the intermediary’s fee will be deducted from the first salary of the hired worker.
• No “penalties” or “reimbursement obligations” may be imposed on the candidate if they decline the offer or leave soon after being hired.

Where a violation is found — whether by an oversight body or on the basis of a complaint — a monetary sanction is imposed under the EPA and, in the event of repetition (or a more serious breach), the registration is cancelled. For this reason, the entire financial logic of an HR agency must be designed so that revenue comes exclusively from employers.

Types of registration

When filing the application, you must select the scope in which you will operate. The possible options are:

• Intermediation for work in the Republic of Bulgaria — for connecting candidates with Bulgarian employers inside the country. The most common option for domestic HR agencies.
• Intermediation for work in other countries — covers both EU/EEA and third countries. Aimed at agencies that source Bulgarian talent for foreign employers, or vice versa.
• Intermediation for seamen employment — a special regime with additional requirements linked to the international MLC 2006 convention and a minimum of three years’ maritime experience.

A single trader may apply for one or multiple scopes at the same time — the fee is payable for each of them separately.

Who can register

The regime is open to a wide range of legal forms:

• Bulgarian commercial companies — EOOD, OOD, AD, EAD. In practice, the most common choice is the EOOD (single-member limited liability company) due to ease of management and simple reporting.
• Sole proprietors (ET) — a possible form, especially for small boutique practices, though it offers no personal asset protection.
• Individuals — under certain conditions and for a more limited activity format.
• EU/EEA and Swiss companies — may operate in Bulgaria through a branch or representation, relying on their home jurisdiction documents.

For aspiring HR entrepreneurs, the practical advice is to start with an EOOD — registration is quick (around 3–5 business days in the Commercial Register), the capital requirement is symbolic (around EUR 1) and accounting is straightforward.

Premises and technical requirements

The Ordinance requires the applicant to have an appropriate material and technical base for carrying out intermediation activities. In practice, this includes:

• Suitable premises for service delivery and candidate meetings — it cannot be a virtual office without real meeting capability. A lease is allowed, but the agreement must be valid and cover the activity.
• Office furniture — desks, chairs, filing cabinets.
• Computer and printing/copying equipment — for document processing and data storage.
• Telephone line — fixed or mobile, serving as a contact channel.

In modern practice, most recruitment work is carried out remotely, but the regulator retains the requirement for a real office as a means of ensuring accountability and enabling inspections.

Eligibility requirements

Successful registration depends on meeting several conditions, most of which are verified ex officio by the Employment Agency:

1. No outstanding liabilities toward the state or municipalities for taxes and mandatory social security contributions, unless rescheduled or deferred.
2. Not in insolvency proceedings.
3. Not in liquidation proceedings.
4. No enforceable EPA sanctions in the previous 3 years.
5. Members of the management and control bodies — must also have no EPA sanctions in the previous 3 years, nor have been part of the management of other entities sanctioned during that same period.

This last condition is important — it aims to prevent the “transfer” of a licence by incorporating a new company controlled by individuals previously penalised for violations in intermediation activities.

Required documents

The document set is relatively concise but must be precise:

1. List of data on the applicant — the manager of the legal entity or the individual themselves, plus every employee who will carry out intermediation activities. For each person, the list must include the personal ID number, the number, date and issuer of the education diploma (Bulgarian) or the recognition document (for foreign qualifications).
2. Copy of the diploma for secondary or higher education of the applicant — for older diplomas (secondary before 2007, higher education before 2012), which are not checked ex officio through the diploma register.
3. Diplomas of the employees who will work as intermediaries — same rule for older diplomas.
4. For seamen intermediation — documents proving at least 3 years’ experience in maritime transport.
5. Power of attorney where the application is filed through an authorised representative (for example, a lawyer).

One operational detail deserves attention: the list of employees must be updated on every change — departure, new hire, change of duties. Missing this update is among the most frequently observed violations during inspections.

Procedure — electronic only

The procedure has been fully digitised for several years now. The application and all supporting documents are submitted exclusively electronically through the Unified Electronic Centralised Register of the Employment Agency (chtp-povr.az.government.bg/employment-register). Paper documents are not accepted.

Procedural steps

1. Document preparation in electronic format (PDF, with qualified electronic signature where required).
2. Filing via the Employment Agency portal using the qualified electronic signature (KEP) of the manager or authorised representative.
3. Admissibility check — the Employment Agency reviews the documents within 14 days of submission.
4. Check for violations — the Employment Agency obtains a reference from the General Labour Inspectorate (GIT) regarding any EPA sanctions.
5. Remedying deficiencies — where gaps are identified, a 14-day deadline is granted for correction.
6. Decision — where the conditions are met, a registration certificate is issued; otherwise, a reasoned refusal is issued and may be appealed.

The fee is paid after the documents are approved, which is a user-friendly approach — you do not pay for a procedure before it is clear it will end successfully.

State fees (2026)

The fees for 2026 are payable in euros and depend on the scope of the registration:

Important: fees are paid after documents are approved, not at submission. If you apply for multiple scopes at the same time, fees are cumulative — for example, registration for Bulgaria plus other countries would come to around EUR 857.44 in total.

Certificate and validity

Upon successful completion of the procedure, the Employment Agency issues a registration certificate in the form of an electronic document. This is a meaningful advantage of the regime compared to a number of other licensing procedures — you do not have to wait for a paper original with a seal or travel to collect it.

The certificate has indefinite validity. No renewal, re-certification or annual maintenance fee is required — the registration remains active until:

• a change of circumstances occurs that requires an update (new manager, new employees, new address); or
• it is revoked by decision due to violations.

The certificate — printed or in electronic form — must be displayed in a visible place in the office so that every visitor, including oversight bodies, may review it.

Business model and pricing

Having covered the regulatory framework, let us look at the practical side — how an HR agency actually makes money within the bounds of the law. As already stressed, all revenue must come from employers.

Core fee models

• Percentage of annual gross salary — the most widespread model for permanent positions. It typically ranges between 15% and 25% for standard roles and can reach 30% or more in executive search.
• Flat fee — an agreed amount for successfully filling the position. Suitable for mass recruitment projects (call centres, retail networks).
• Retainer — an upfront payment covering part of the work, with the remainder payable upon successful placement. Typical for high-end executive search.
• Guarantee period — usually 3 months, during which, if the candidate leaves, the agency provides a replacement free of charge or refunds part of the fee. This is a critical contract element.

Types of recruitment activity

• Permanent placement — classic intermediation for permanent employment.
• Executive search — for senior executive roles, with a greater element of active sourcing and targeted selection.
• Mass recruitment — where large numbers of hires are needed in short timeframes.
• Temp/interim — requires a separate temporary work agency registration, but is often combined with recruitment activity.

Niches

Specialisation is often more profitable than a generalist approach. Common niches on the Bulgarian market are: IT and technology, medical and healthcare, tourism and hospitality, finance and accounting, industrial manufacturing and international sourcing for Germany, the Netherlands, the UK.

Common mistakes in practice

From our experience with HR clients, we have identified several typical pitfalls that cost agencies fines and even revoked registrations:

• “Consulting” or “administrative” fees from candidates — dressed up under another name, but essentially prohibited collection.
• Deduction from the first salary — agreed with the employer but economically borne by the worker. The regulator looks at the substance, not the form.
• Outdated list of employees — the register entry must be updated immediately upon any departure, new hire or change of duties.
• Missing mandatory clauses in the contract with the job seeker — the Ordinance requires certain standard clauses whose absence is a procedural violation.
• Certificate not displayed in the office — a minor but frequently identified failure during inspections.
• Insufficient GDPR protection for CVs — an HR agency is a personal data controller at scale and must have policies, storage rules, deletion timelines and consent mechanisms in place.
• Breaches of the Anti-Discrimination Act — job ads and selection processes cannot rely on criteria based on gender, age, ethnicity etc. without a legitimate basis.

Frequently asked questions