Seasonal Workers in Bulgaria for 2027: New Insurance, 3-Day Confirmation and the 10-Day Start

Seasonal workers in Bulgaria: what changed on 21 July 2026?

The new rules sit in the Regulations for the Implementation of the Labour Migration and Labour Mobility Act (the Implementing Regulations). They were amended by Council of Ministers Decree No. 85 of 16 July 2026, promulgated in State Gazette No. 66 of 21 July 2026. The Decree took effect on the day of promulgation, except for § 26, which has its own date (see the last section).

Three points matter for employers, as of November 2026:

• Two processing periods instead of one — under Art. 32(3) of the Implementing Regulations, the registration is confirmed within 10 days of filing the declaration, and within 3 working days for a worker covered by Art. 24(3) of the Labour Migration and Labour Mobility Act (LMLMA).
• A new document in the file — a scanned copy of mandatory medical insurance valid in Bulgaria for at least three months. This is a new item 4 in Art. 32(1). Some secondary sources call it “paragraph 4”; in the promulgated text it is an item within paragraph 1.
• Transitional rule — the insurance is required for applications filed from 21 July 2026. Procedures still pending on that date continue under the rules in force when they were filed. For the 2027 season, every new file follows the new rules.

Volume explains why the timing matters. In 2025 alone, the Employment Agency recorded 19,057 registrations of seasonal work of up to 90 days, according to the Ministry of Labour and Social Policy report on the draft (in Bulgarian).

Which workers get 3 working days and which stay on the 10-day track?

What decides it is the individual worker's history, not your sector or the worker's nationality. The fast track under Art. 24(3) LMLMA (a new paragraph added by State Gazette No. 52 of 2025) applies to a foreign national who has performed seasonal work of up to 90 days in Bulgaria at least once in the past 5 years. A first season in Bulgaria, or such work only more than 5 years ago, means the 10-day period.

However, the agency's page states that employment may start no earlier than 10 days after filing, so the faster confirmation does not bring the start date forward.

The rule comes from EU law. According to the impact assessment for the draft, it implements Art. 16 of Directive 2014/36/EU: a facilitated procedure for third-country nationals admitted as seasonal workers at least once within the previous five years. The ministry's report adds that the amendments also aim to close infringement procedure No. 2023/2017 against Bulgaria.

From our practice: split your workforce into two columns now — “returning” and “new”. For the first column, gather the registration documents from earlier seasons. Without them it is hard to show that a worker meets the condition.

Hotels and farms yes, construction no: is your sector on the list?

Registration of seasonal work of up to 90 days is tied to the list of sectors for seasonal work. As of November 2026, according to the Employment Agency (in Bulgarian), the list covers only two sectors:

• agriculture, forestry and fishing;
• hotels and restaurants.

Construction is not on the list. A construction company planning non-EU workers for 2027 needs a different route — the general regime is covered in our guide to the Bulgarian work permit.

Two limits apply in every listed sector:

• Duration — seasonal work registered with the Employment Agency lasts up to 90 days without interruption within any 12-month period.
• One employer — a change of employer is not allowed, nor is work for another employer under a second employment contract.

In practice: if one owner runs the hotel and the restaurant through separate companies, each company is a separate employer. The worker cannot move between them on the same registration.

The 90-day seasonal work file after Decree No. 85

Decree No. 85 added the insurance to the file. These are the items we check for each worker, as of November 2026:

We add the entry-into-force clause to the contract expressly; general content requirements are in our article on employment contracts in Bulgaria.

Which copies were dropped and which were not

According to the ministry's report, Decree No. 85 removes the requirement for a copy of the worker's residence document in the procedures under Art. 26, 29, 33, 34, 34a and 36 of the Implementing Regulations, in line with Art. 3(5) of the Bulgarian Personal Documents Act. Art. 32 — the 90-day seasonal declaration — is not on that list. Our assessment is that you should not expect a lighter 90-day file from this change; follow the Employment Agency's current checklist.

2027 season calendar: when to file so the worker arrives on time

The 3 working days speed up confirmation, but they do not move the start date. This is the order in which we plan a season, as of November 2026:

1. List and check (winter) — split workers into returning and new. Plan 3 working days for returning workers who meet the Art. 24(3) LMLMA condition; where the earlier season was under a permit of more than 90 days, we check eligibility case by case. Plan the 10-day period for others. Employment Agency guidance sets the start for both groups no earlier than 10 days after filing (see step 3).
2. Insurance and contract — prepare insurance of at least three months and the contract with the required clause for each person before filing.
3. File with the Employment Agency — registration must be completed before employment begins. The agency's page states that employment may start no earlier than 10 days after the employer files the documents. That guidance remains in place after the 3-day period was introduced, so plan the start date with at least that buffer — for returning workers too. This is guidance on the agency's page, not a requirement of Art. 32(3) of the Implementing Regulations.
4. Visa, where required — the worker must hold a valid visa for the purpose of seasonal work where one is required for nationals of their country. Leave a separate margin for this stage.
5. Start and Labour Inspectorate — within 7 days of the actual start of work, notify the competent regional directorate of the General Labour Inspectorate.
6. Early termination — notify the Employment Agency in writing within 3 days of the termination date.

Seasons longer than 90 days: when registration is not enough

Seasonal work of up to 90 days is a registration procedure: the Employment Agency does not issue an express permit, and the maximum duration is 90 days. If your season is longer — say a seaside hotel that opens in spring and closes in autumn — you need a separate procedure, planned separately and earlier. We outline it in the seasonal work section of our work permit guide.

Will you be able to file at the local labour office?

Not reliably yet: the declaration under Art. 32(1)(1) of the Implementing Regulations is filed electronically, so do not plan on paper filing at a counter until the agency publishes express guidance. According to the ministry's report on the draft, § 26 of Decree No. 85 (amending the Employment Agency's Organisational Rules) aims to have 90-day seasonal procedures handled also by the local “Labour Office” directorates; that part takes effect one month after the Decree was promulgated in State Gazette No. 66 of 21 July 2026.

Frequently asked questions

Conclusion

For the 2027 season, seasonal workers in Bulgaria fall into two tracks: 3 working days for a worker who has done seasonal work of up to 90 days in Bulgaria at least once in the past 5 years, and the 10-day period for others. Whether an earlier season under a permit of more than 90 days also qualifies is an open question that we assess case by case. Both groups need the new insurance, the agency's 10-day gap between filing and start, and a sector on the list. The real decision point is therefore the winter: that is when you settle who you invite back, which sector applies and how long your season is.