Occupational Health Service (OHS) in Bulgaria — How to Register and Operate (2026)

What an Occupational Health Service is and why it matters

An Occupational Health Service is a specialised organisation that delivers to employers a set of services related to protecting and promoting workers’ health, assessing occupational risk and assisting the employer in discharging its duties under the Health and Safety at Work Act (HSWA). Every employer in Bulgaria is legally required to secure OHS coverage — either by contracting an external service or by establishing an in-house structure.

That mandatory nature is exactly what makes OHS an attractive business niche. The market has several distinguishing features:

• A wide client base — in practice, every employer with at least one employee falls within the scope of the HSWA.
• Annual contracts — the typical model is a retainer-style subscription, generating predictable recurring revenue.
• Low regional concentration — most OHS providers operate locally, leaving room for new entrants outside Sofia.
• Mixed delivery models — some large industrial enterprises build their own in-house OHS, while SMEs almost always rely on external providers.

For employers, an OHS is far more than a formality — it is a key partner in workplace risk assessment, accident analysis, preparing documentation for the National Social Security Institute (NSSI) and limiting exposure to fines from the Labour Inspectorate.

Legal framework

The activity of OHS providers in Bulgaria is governed primarily by two instruments:

• Health and Safety at Work Act (HSWA) — Article 25b sets out the status of OHS providers, who may establish one, the minimum staff composition and their obligations.
• Ordinance No. 3 of 25 January 2008 on the conditions and procedure for carrying out the activity of occupational health services — this specifies the registration procedure, document flows, rules for keeping health files and reporting duties.

The registering authority is the Ministry of Health, which also maintains the public Register of Occupational Health Services on its official website (mh.government.bg). Entry in this register is the only legal basis for operating as an OHS.

Who may establish an OHS

The range of entities entitled to establish an OHS is relatively broad:

1. Employers — either alone (an in-house OHS for a single company) or jointly with other employers (a shared in-house OHS for a group of companies).
2. Commercial companies and cooperatives — legal or natural persons registered under the Commerce Act, the Cooperatives Act or the Non-Profit Legal Entities Act. This is the most common setup when launching an OHS as a standalone business.
3. Healthcare establishments — hospitals, medical centres and other licensed facilities for which OHS activity is a natural extension of their profile.

Companies from other EU/EEA Member States may also act as founders, subject to the general rules on freedom of establishment and the Bulgarian licensing framework.

Choosing a legal form — first steps

When the OHS is launched as an independent business, the most common choice is a single-member or multi-member limited liability company (EOOD / OOD). Since 2024, the minimum share capital for an OOD/EOOD is symbolic — just EUR 1 — which effectively removes the capital barrier to entry.

Special care should be taken with the scope of business (subject of activity) entered in the articles of association. It must explicitly cover occupational health services, occupational risk assessment, advice on occupational safety and health (OSH) and related activities. An incomplete scope of business may require an amendment in the Commercial Register before filing with the Ministry of Health, which unnecessarily extends the timeline.

Alternative forms — joint-stock company, cooperative or non-profit entity — are all permissible but rarely offer practical advantages over an EOOD/OOD for this type of activity.

Mandatory minimum staff composition

The single biggest regulatory hurdle when setting up an OHS is the requirement for a qualified team. Without a complete minimum staff composition, the application to the Ministry of Health cannot be approved. The statutory minimum is:

Important: missing even one of these profiles leads to refusal of registration. If the physician leaves after registration, the OHS has only a short window to secure a replacement — otherwise it risks deletion from the register.

In practice, the main bottleneck is finding a physician with the “Occupational Medicine” specialisation, as the number of such specialists in Bulgaria is limited. It is strongly advisable to secure the contract with the physician before filing the application with the Ministry of Health.

Who may NOT be part of an OHS team

To safeguard the independence of occupational health services, the law excludes certain categories of persons from being part of the team:

1. Employees of the Ministry of Health and the Ministry of Labour and Social Policy, as well as of their supervisory bodies — including the General Labour Inspectorate, the Regional Health Inspectorates (RHI) and similar authorities.
2. Medical professionals who have lost their licence or right to practise medicine.
3. Persons holding contracts with the National Health Insurance Fund (NHIF) who are registered with the relevant RHI as providers of primary or specialised outpatient care.

The last restriction is particularly important in practice: general practitioners with NHIF contracts cannot simultaneously appear in the staff list of an OHS.

OHS documentation

A registered OHS must maintain an internal organisation built on several mandatory layers of documentation:

• Internal rules on organisation and activity — an internal act describing the organisational structure of the service, the allocation of duties among specialists, client-servicing procedures and the rules for protecting medical confidentiality.
• Dossier for each employer contract — for every employer served, the OHS maintains a separate dossier containing a workplace map, risk assessment, lists of employees and correspondence.
• Individual health files for workers — personal records with results from prophylactic medical check-ups and other medical information linked to occupational risk. These files are strictly confidential and subject to medical secrecy.

Failure to keep this documentation in order is one of the most frequent findings during inspections by the Ministry of Health or the Labour Inspectorate.

Registration procedure (step by step)

The full path from idea to registered OHS can be summarised in seven steps:

1. Incorporate the EOOD/OOD in the Commercial Register — with a scope of business covering occupational health services.
2. Prepare the documentation — sign contracts with the minimum required specialists, collect notarised copies of diplomas and qualification certificates, draft lists and declarations.
3. File the application together with the full set of documents at the Ministry of Health.
4. Review within 30 days — the ministry’s administration checks the completeness and compliance of the file.
5. Remedying deficiencies — if shortcomings are identified, the applicant is given at least 14 days to correct them.
6. Issuance of the registration certificate — upon positive outcome, the Minister of Health (or an authorised deputy) issues the registration act.
7. Entry in the Register of OHS providers — the service is listed on mh.government.bg and may start operating.

Required documents for the application

The standard file submitted to the Ministry of Health includes:

1. Core data — name, registered seat, management address and contact phone of the company applying to register the OHS.
2. Copy of the court registration / certificate from the Commercial Register — proving the legal status of the applicant, together with a current status certificate.
3. Agreement between the employers — only where the OHS is established jointly by several employers as an in-house service.
4. List of the minimum required staff — signed and stamped, indicating positions, names and qualifications of the specialists.
5. Notarised copies of the education, qualification and professional experience documents for each specialist.
6. Declarations under Art. 25b(3) HSWA from each specialist confirming that they do not fall within any of the prohibited categories (see section above).
7. Proof of payment of the state fee — a payment order or bank statement.

Practical tip: it helps to organise the file in the order in which it is described in the application form — this makes life easier for the official reviewing the case.

State fees (2026)

As of 1 January 2026, all Bulgarian state fees are paid directly in euro at the fixed conversion rate of EUR 1 = BGN 1.95583:

Validity. OHS registration is indefinite — it is not subject to periodic renewal. However, keeping it alive depends on continuously maintaining the minimum staff composition and complying with the legal framework.

Change notifications. In the event of changes affecting the composition of the service (e.g. departure or replacement of the physician), the OHS must notify the Ministry of Health within 7 days and file an application for registration of the change, together with the applicable state fee of EUR 116.06.

What services an OHS provides to employers

The scope of a typical retainer contract between an employer and an OHS includes:

• Annual prophylactic medical check-ups — organising and conducting the mandatory examinations of workers based on the nature of their duties.
• Occupational risk assessment — preparing and updating risk assessments for each workplace.
• Analysis of work accidents and occupational diseases — assistance with investigation and documentation.
• Training on occupational safety and health for management, OSH officers and workers.
• Ergonomics and workplace design advice — including for office and remote work setups.
• Medical documentation for NSSI — preparing files for recognition of occupational diseases or workplace accidents.

This core package can be extended with add-ons such as psychosocial assessments, corporate wellness programmes and vaccinations.

How employers should choose the right OHS

For employers looking for a contractual partner rather than an in-house service, the key selection criteria are:

• Listing in the official OHS register on mh.government.bg — a mandatory first check that takes less than a minute.
• Staff qualifications — a team beyond the statutory minimum (e.g. more physicians, ergonomists, psychologists) signals a serious provider.
• Industry experience — an OHS that already serves clients in your sector understands the specific risks and regulatory expectations.
• Scope of services — compare exactly what the retainer covers (check-ups, risk assessment, training, NSSI documentation) versus what is billed separately.
• Price per employee — the typical pricing is annual per worker, depending on sector and headcount.
• References — from clients of similar profile and size.

Do not rush to accept the cheapest quote. In the event of a Labour Inspectorate audit or a workplace accident, the quality of the documentation produced by your OHS is often decisive.

Frequently asked questions