Employer of Record in Bulgaria

You can employ someone through a provider in Bulgaria if the arrangement meets the applicable employment rules; employer of record (EOR) is a commercial service label. A provider that employs someone to work under your direction and control must satisfy the registered temporary-work agency rules, including a permitted assignment purpose. You can also assess direct employment or independent contracting, with contracting suited to genuinely independent services.

4dev.com is a global contractor platform working with contractors in Bulgaria. This route applies to genuinely independent services.

What an employer of record is in Bulgaria

An employer of record employs a worker on a client company’s behalf and performs the employer duties agreed for that engagement. In Bulgarian temporary-work agency employment, the worker contracts with the agency, while the client, as user undertaking, signs a separate written agreement with it. That client agreement sets the assignment duration and the arrangements for exchanging working-time and remuneration information.

Employment administration and recruitment are separate services

Agree employment administration and candidate recruitment separately in the proposal. The agency’s employer duties include wages and social insurance; establish whether its service also includes candidate search, interviews or selection. The Bulgarian recruitment channels can help you plan that search, while optional benefits need their own agreed terms.

EOR, PEO and outsourced work

An EOR or PEO label does not identify the Bulgarian employment structure. Establish who signs the employment contract, gives daily instructions and supervises the worker, and whether the provider administers employment or delivers a service.

Kinstellar describes outsourced-service employees as hired and supervised solely by the outsourcing company, which is responsible for their overall work. A temporary agency worker instead operates under the user undertaking’s direction and control. Assess the proposal by how supervision and delivery will actually work.

Is an employer of record legal in Bulgaria?

An EOR offer must meet the rules governing the proposed work arrangement. Client-directed temporary work requires both a registered agency and an assignment that fits the statutory conditions.

Who directs the employee determines the structure

The Labour Code’s temporary-work provisions govern a provider that employs someone and sends them to work temporarily under the user undertaking’s direction and control. Identify who gives daily instructions and supervises performance before choosing the contracts. Employment administration alone does not establish that an assignment meets these provisions.

For an outsourced service, examine whether the provider will supervise its own employees and take responsibility for their overall work, as Kinstellar describes. Assess those responsibilities alongside the actual delivery arrangements. The outsourcing label cannot settle the result for a particular proposal.

In their March 2023 discussion of Bulgarian working arrangements, DGKV’s Viara M. Todorova and Ivan Punev drew attention to the agency-specific requirements:

The temporary work agency activities, however, are subject to a number of specific rules and requirements provided by Bulgarian law

— Viara M. Todorova, Partner, and Ivan Punev, Senior Associate, Djingov, Gouginski, Kyutchukov & Velichkov (roles at publication, March 2023)

The Bulgarian temporary-work fit check

A client-directed assignment must meet the conditions below and use a registered agency. Document the work and identify the actual user undertaking before applying them.

• Permitted purpose. The employment contract must be for completion of specified work or replacement of an absent employee. Identify the particular work whose completion ends the assignment, or the absent employee being replaced; a general description such as “temporary project” leaves that question unresolved.
• The user’s workforce. Agency-supplied employees must not exceed 30% of the actual user undertaking’s total workforce. Establish that undertaking and its workforce before assessing capacity; the provider’s staff or the foreign group’s global headcount cannot supply a substitute denominator.
• Prohibited work and contexts. Assignments cannot cover first- or second-category work, enterprises connected with national security or defence, or an undertaking where a strike is in progress. Check both the work category and the user’s circumstances.
• Collective redundancies. A user that has made collective redundancies may enter the agency contract only after six months from those redundancies. Review the user’s own redundancy history before agreeing the assignment.
• Current agency registration. The employing agency must be registered with the Employment Agency. Match the employing entity to its current registration and term; the next section explains the certificate and register checks.
• Basic conditions and equal treatment. The user must provide the same basic working and employment conditions as for its employees doing the same or similar work. Agency status alone cannot justify less favourable treatment, except where the law makes particular rights depend on qualifications or acquired skills. If the user has no employees doing the same or similar work, agency workers still cannot be placed in a less favourable position than the other employees working there.

If the Bulgarian user undertaking, workforce denominator or another condition is unknown, obtain a specific assessment before committing. A certificate confirms the agency’s registration status; the assignment’s purpose, capacity and other conditions need their own review.

The provider licence, and how to check registration

Temporary agency employment requires registration with Bulgaria’s Employment Agency. Open the temporary-work enterprise register under “Предприятие, осигуряващо временна работа” (temporary-work enterprise). Check the employing agency in that category, which is separate from private employment intermediaries.

Match the certificate to the contracting entity

Match the employer in the worker’s proposed contract to its registration record before signing the client agreement. Where a reseller or local partner is involved, identify which entity employs the person and holds the temporary-work registration. Compare the contract, certificate and register entry using these particulars:

• The employing entity’s exact legal name; request its identifier in the contract documents and match the name to the register.
• The certificate’s registration number and date.
• The registration term, including whether it covers the proposed assignment dates.
• The registered representative and the identity and authority of the proposed signatory.
• The management address and office addresses.
• Any displayed suspension status and any recorded withdrawal date or grounds.

Request current worker-claims insurance or bank-guarantee evidence and confirmation that the agency still meets the registration conditions. These include requirements concerning public liabilities, insolvency, liquidation and disqualifying offences, and must be maintained throughout registration. Review the supporting documents alongside the public entry and the assignment conditions.

Certificate validity and a new agency application

A registration certificate lasts five years, with separate deadlines for applying and maintaining registration. Those agency deadlines do not establish when your employee can start.

Certificate validity	Five years; electronic certificate issued and entered in the register after payment of the tariff fee	MLSP Employment Promotion Act
New application	Electronic application with the required insurance or banking documents and internal rules, including draft user and worker contracts; foreign-registered applicants also prove the specified legal-standing conditions under their home law	MLSP Employment Promotion Act
Registration decision	Within fourteen days after receipt of the complete application and attachments	MLSP Employment Promotion Act
Deficiency correction	Up to thirty days from receipt of the notification; the documents are treated as submitted on the date the deficiencies are corrected	MLSP Employment Promotion Act
Registered changes	Notify the Employment Agency within seven working days of the change	MLSP Employment Promotion Act
Annual maintenance	By 30 June each year, the agency submits insurance or banking proof through the register; the Employment Agency’s annual public-liability check has the same deadline	MLSP Employment Promotion Act
Worker-claims cover	Group insurance or an unconditional irrevocable bank guarantee of €102,258.38, the euro equivalent of the statutory BGN 200,000	MLSP Employment Promotion Act; LEX Employment Promotion Act; Euro Introduction Act

The cover secures claims of workers hired for temporary work; its €102,258.38 amount follows the Euro Introduction Act’s conversion and general rounding rules for the statutory BGN value. It is separate from fines, client deposits and compensation due to an individual employee. Obtain the cover document and check its current terms.

If the proposal includes a registration-related charge, ask what it covers, its amount and its charging basis. For an agency still applying, review application completeness, any notified deficiencies and certificate issuance separately from the employee’s contract and pre-start documents. The five-year registration term does not determine the employee’s permitted assignment duration.

Who signs what, and who directs the work

The agency employs the worker and the user undertaking directs the assignment, with separate duties for each. The client agreement, employment contract and assignment act document those relationships. Daily instructions cannot replace the written employment contract.

Party	Agreement or document	Responsibility
Client/user and agency	Written commercial agreement for the assignment	Agree the roles, nature and duration of work, worker obligations, leave arrangements, information exchange, initial training and liability terms
Agency and employee	Written employment contract	Establish the employment relationship and required particulars, including the role, workplace, start arrangements and remuneration
Agency issuing to employee	Written assignment act, delivered at least one working day before the scheduled start at the user	Specify the user, reporting date, workplace, role and work, person to report to and initial training; the employee acknowledges delivery by signature

The user retains workplace duties

The user must provide the workplace and job description before work begins, ensure safety and instruction, record time and determine the basic and additional remuneration due. It notifies the agency and worker of that remuneration and provides the required workplace training and information about conditions for employees doing the same or similar work. Allocate those tasks to the client’s managers alongside the agency’s employer duties.

The agency pays wages and social-insurance contributions and performs the prescribed employment-record duties. If the worker requests documents certifying the creation, performance or termination of employment in writing, the agency must supply them within fourteen days. Name the contact who receives these requests and delivers the documents.

The written user–agency agreement must specify leave arrangements, procedures and deadlines for time and remuneration information, initial training and liability for non-performance. Agree the worker’s terms using the basic-conditions and equal-treatment comparison above. Record any optional benefits separately in the employee’s terms rather than relying on a provider brochure.

Joint liability has two different legal bases

The agency and user are jointly and severally liable to the worker for obligations arising from performance of the employment contract, including in a registered-agency arrangement. Commercial cost allocation does not remove those worker-facing obligations. Any indemnity or reimbursement claim depends on its terms and the circumstances.

Since 1 January 2025, a separate rule applies to a user contracting with an unregistered temporary-work agency. The user is jointly liable for the agency’s unpaid taxes and compulsory contributions for the supplied employees, together with VAT due on the supply. The exposure is limited to the unpaid obligation for the relevant period, so it must be distinguished from the employment obligations owed to the worker and from the commercial contract’s total value.

Hiring step by step, with legal start conditions

The employee can start only after receiving the contract signed by both parties and the National Revenue Agency (NRA)-certified employment-entry record, with the assignment act also delivered on time. Set the date around these handovers, the assignment assessment and any required permission. Agree the provider’s preparation schedule for the hire separately.

Step	Owner and deliverable	Timing
Check the proposed assignment	Client and agency identify the user undertaking, permitted temporary purpose, applicable restrictions and current registration	Before committing to the arrangement; agree the assessment schedule
Agree scope and employee-specific checks	Client and agency settle the commercial terms, review the required rights in the work and establish any applicable work-permission route	Before confirming the employment and assignment terms; agree the preparation schedule
Conclude the employment contract	Agency and employee sign the written contract with the required particulars	Before work starts
Enter employment data	Agency or its authorised representative completes the Employment Register entry	Within three days of concluding or modifying the contract
Deliver the pre-start employment documents	Agency gives the employee the contract signed by both parties and the NRA-certified record of the employment entry	Before admission to work
Deliver the assignment act	Agency gives the employee the written act specifying the user assignment, against signature	At least one working day before the scheduled start at the user
Arrange recurring contribution compliance	Agency handles the employee’s state social-insurance contributions	Due by the 25th of the month following the work month

The three-day entry deadline does not allow work to begin before the signed contract and NRA-certified record are delivered. The employee must ordinarily begin within one week of receiving those documents unless the parties agree another period. That employee start obligation begins after document delivery and is separate from the provider’s preparation time.

A new agency’s fourteen-day registration decision period and thirty-day deficiency-correction period do not measure the hire’s turnaround. Request an end-to-end schedule naming the owner of each contract, permission check and delivery. Resolve outstanding steps before agreeing the first working day.

A ready-to-start handover

Before admitting the worker, the client’s manager needs confirmation that the agency completed the employment-document handover. Assign the user’s workplace preparation at the same time:

• Name the agency contact responsible for sending the contract, certified entry record and assignment act, and confirm delivery to the employee.
• Check that the employee has the employment contract signed by both parties and the NRA-certified employment-entry record.
• Confirm signed receipt of the assignment act and that its delivery meets the one-working-day requirement.
• Identify the user’s owner for the job description, safety instruction, initial training and time records.
• Confirm the actual workplace and agreed remote-working terms, and raise equipment or reimbursement arrangements as contract questions where relevant.
• Where permission is required, check the proposed employer or host, workplace, role and work period against the applicable authorisation.

Ask the provider which signature method, medical documentation or other preparation is required for the particular hire, rather than assuming a universal package. Agree these items before the handover so the client and agency are working to the same start conditions.

History and rejected entries

Ask how the agency will receive and use the employee’s paper employment book for service before 1 June 2025. It remains an official certificate of the recorded circumstances: private employers had to complete it by 1 June 2026, or on termination during the specified transition period, recording service with that employer to 1 June 2025 and returning it immediately. Follow up outstanding completion or return using the country guide’s service-history explanation.

If an entry is rejected or the certified record is still unavailable, the required pre-start document delivery is incomplete. An entry made after the statutory deadline needs a mandatory Labour Inspectorate instruction that has taken effect; this overdue-entry rule does not apply to every routine correction. Ask the agency to resolve the actual entry problem and provide the required record before admitting the worker.

The agency can access prescribed previous-employer data for employees it has hired, but that access excludes earlier salary and compensation except the specified Article 222(2) and (3) compensation. Separate the service-history evidence from the information accessible through the register. Establish the proposed salary independently.

Working time, leave and benefits through an EOR

The agency administers employment protections using time, remuneration and absence information supplied under the user–agency agreement. Your managers must plan compliant schedules and absences and send the data needed for remuneration calculations and leave administration.

Contract, probation and remuneration

The agency’s employment contract must specify the workplace, role and work, conclusion and start dates, and duration. It must also specify leave, equal notice for both parties, basic and fixed additional remuneration, payment frequency and working time. Check these against the client assignment and request a breakdown of the fixed amounts and any separately agreed bonuses.

Probation can last up to six months, but a fixed term shorter than one year has a maximum of one month. The contract must name the party benefiting from probation; if it does not, both parties benefit. Before probation expires, the beneficiary may terminate without notice, so a client manager should check the clause with the agency before requesting that route.

Statutory leave and other justified periods when the employee does not perform the contracted work are excluded from the probation period. The same employee can have probation for the same work in the same enterprise only once. Ending the client’s commercial service arrangement is a separate decision from ending the agency’s employment contract.

Ask which remuneration additions apply to the employee and how they will be documented. Use the employment contract and applicable rules to establish the amounts and dates for administration.

Work schedules and overtime approval

Plan normal five-day schedules within the limits of eight hours per day and 40 hours per week. Additional hours require a statutory basis because overtime is generally prohibited. The user records the actual hours and determines the remuneration due, then supplies that information to the agency under the agreed procedures and deadlines.

The ordinary annual overtime ceiling is 150 hours per employee; a qualifying industry or sector collective agreement may raise it to 300 hours. Separate day/night limits are 30/20 hours per calendar month, 6/4 per calendar week and 3/2 over two consecutive working days. The specified Article 144, points 1–4 exceptions are excluded from the ordinary annual and shorter-period ceilings, so identify the precise legal basis before applying an exception to a roster.

Minimum overtime supplements are 50% on working days, 75% on rest days and 100% on official holidays; summed working-time accounting has a 50% minimum overtime supplement. Holiday work attracts at least double remuneration whether scheduled or overtime. Where holiday work is also overtime, assess its overtime payment rule alongside the holiday entitlement; payment of either amount does not authorise prohibited hours.

Preserve at least twelve uninterrupted hours of daily rest and, for a normal five-day week, at least 48 uninterrupted hours of weekly rest. Summed working-time accounting normally requires at least 36 weekly hours; a shift change may reduce this to at least 24 only where the enterprise’s actual and technical work organisation requires it. Under daily accounting, overtime on both weekly rest days also gives the employee at least 24 uninterrupted hours of rest during the following working week, alongside increased pay.

Leave and who funds absence

Employment leave and insurance benefits have separate conditions, so the agency needs the employee’s leave and insurance history before confirming who pays. Use the statutory reference points below for planning, while keeping employer remuneration separate from National Social Security Institute (NSSI) benefits.

Basic paid annual leave	At least 20 working days	Justice Labour Code
Public-holiday reference	14 + 1 day in 2026: fourteen general statutory calendar dates plus exceptional 2 January	Justice Labour Code; Euro-transition holiday decision
Employer-funded temporary incapacity	Initial two working days of eligible incapacity: 70% of average daily gross remuneration in the month incapacity begins; payment must also reach at least 70% of the agreed average daily remuneration. Pregnancy and childbirth are excluded	NSSI temporary-incapacity guidance
Ordinary sickness insurance benefit	NSSI pays 80% of average daily gross remuneration or insurable income for the eighteen calendar months preceding the incapacity month, capped at the reference period’s average daily net remuneration	Social Insurance Code
Occupational accident or disease benefit	NSSI pays 90% of the corresponding eighteen-month average; insured entitlement does not depend on length of insurance service	Social Insurance Code
Maternity leave and insured cash	Leave: 410 days per child, including 45 before birth. Benefit: 90% of average daily gross remuneration or insurable income for the 24 calendar months before the month pregnancy/childbirth incapacity begins, subject to the average-net ceiling and national minimum daily-wage floor; requires twelve months insured for general sickness and maternity	Justice Labour Code; Social Insurance Code
Father’s leave at birth	Fifteen days from the child’s hospital discharge, where the father and mother are married or live in one household	Justice Labour Code

For a person entering employment for the first time, use of annual leave requires at least four months of employment service; termination before that point still gives a right to compensation for unused accrued leave. At least five additional working days apply to qualifying work with specific health or life risks that cannot be removed, limited or reduced despite protective measures, and to an irregular working-day arrangement. Establish the applicable entitlement before the user and agency approve the absence.

The holiday reference counts calendar dates, including weekends, rather than weekdays lost to holidays. National Awakeners Day on 1 November is non-working for educational institutions only. When a statutory holiday other than the Easter holidays falls on Saturday or Sunday, the first one or two working days afterwards become non-working; apply that rule to the actual work calendar and keep Easter’s separate dates distinct.

Ordinary sickness cash generally requires six months of insurance for general sickness and maternity, including for the employer-funded initial days. That service requirement does not apply to employees under eighteen, while occupational accident and disease have their separate insured entitlement. Confirm eligibility for cash separately from the medically authorised absence and send the agency the information needed for the applicable claim.

With the mother’s consent, an employed father or qualifying employed grandparent may take the remaining maternity leave after the child reaches six months. Subsequent childcare leave until age two depends on the child not being placed in a childcare institution and the other statutory conditions; an employed father or grandparent may take it with the mother’s consent. The agency must assess leave and insurance benefit entitlement separately rather than treat the whole absence as ordinary salary.

Before the child turns eight, a father or adoptive father can have up to two months’ childcare leave, reduced by prior use of the specified transferred maternity, adoption or childcare leave; exclusions concerning the child’s death, parental-rights restrictions, adoption changes and specified child placements also apply. After the specified childcare or adoption leave, each qualifying employed parent can request six months of unpaid leave before age eight, provided the child is not in an institution fully funded by the state, and can use up to five months of the other parent’s entitlement with consent. Use the Bulgarian employment guide for the full leave, holiday and overtime tables, and confirm any applicable childcare cash benefit separately with the agency.

Optional benefits need their own terms

Agree the actual optional benefits package in the proposal and employee documents. Ask which cover is included, who qualifies, whether family members can enrol, what limits or exclusions apply and how its cost is allocated. Assess the required basic-conditions and equal-treatment comparison alongside those terms; it does not establish entitlement to every voluntary package in a provider’s catalogue.

Work permits depend on the employee and legal employer

The candidate’s status and proposed employment or host arrangement determine whether the provider can employ them. EU, EEA and Swiss nationals have free-movement rights to work in Bulgaria, with residence-document requirements to check separately. For a third-country national, identify the labour-market access and residence route before confirming the provider’s role.

Check the actual permit scope before onboarding

Bulgarian labour-access routes distinguish local employment, posting within a service, intra-corporate transfer and self-employed activity. Ask which route fits the candidate and the proposed employer, work and assignment. Agency registration does not establish eligibility to sponsor the person.

For authorised employees and posted or sent workers within Article 7(2), the permission specifies the local employer or host, workplace, position and work period. Obtain confirmation of those particulars and compare them with the employment contract and assignment act. Neither an agency certificate nor a signed employment agreement supplies immigration permission.

Before a provider, client, workplace or role changes, check whether the existing authorisation covers the change and what further action is required. The permission should not be assumed to move automatically with the worker. Agree who handles the documents and review, together with route-specific costs and timing.

The country guide’s foreign-worker overview covers the broader routes. For this proposal, retain the candidate’s status documents and the confirmation that the actual employer, host and assignment fit the applicable permission.

The general workforce test is a separate question

The general Article 7 condition uses the local employer’s workforce, separately from the user undertaking’s temporary-agency capacity. Third-country employees hired by that employer during the preceding twelve months must not exceed 20% of its average total employment headcount, or 35% for qualifying small and medium enterprises. Ask the provider to identify the actual employing entity, applicable enterprise status and headcount records before applying the test.

Ask whether an Article 8 exemption or a special-route rule applies to the candidate before using those percentages. Assess an EU Blue Card or other status under its applicable route rather than applying the general percentages identically to every case. The 30% temporary-agency limit concerns supplied workers at the user undertaking; it answers a different question with a different workforce denominator.

What it costs, line by line

Budget for gross salary, applicable employer contributions and separately agreed provider services and extras. Calculate the statutory employee subtotal first, then request prices and terms for the commercial components.

Salary, capped contributions and income tax

Employer contributions depend on the employee’s insurance category, the applicable contribution base and the employer’s economic activity. The fixed 18.52% share below applies to an ordinary third-category employee born after 1959 who remains in universal pension insurance. The wholly employer-funded accident and occupational-disease contribution is additional and activity-dependent.

Full-month wage floor	€620.20 / month from 1 January 2026, under the normal eight-hour day and five-day week	Council of Ministers — Decree 243
Hourly wage floor	€3.74/hour under the same normal working-time assumptions	Council of Ministers — Decree 243
Employment personal income tax	10% of the statutory taxable base	EURES — taxation; Personal Income Tax Act
Fixed employer contribution share	18.52%, for the ordinary employee category described above; excludes accident and occupational-disease insurance	Social Insurance Code; Health budget Act; Health Insurance Act
Employer accident and occupational-disease insurance	0.4%–1.1%, determined by principal economic activity	Social Insurance Code
Monthly insurance ceiling	€2,300 for 1 August–31 December 2026	NSSI cap update

Check the minimum insurance-income floor for the agency’s actual economic activity and the employee’s occupational group before applying the ceiling. Calculate the applicable contributions separately for the person and each fund, rounding to cents with a third digit of five or more increasing the second decimal digit. The employee’s state social-insurance contributions are due by the 25th of the month after the work month.

The employer deducts and remits employment income tax from the employee’s remuneration; the 10% rate is applied to the taxable base. It is not an additional employer contribution or a complete deduction percentage from gross salary. Ask for the employee’s separate net-pay calculation, including the applicable deductions and reliefs, rather than infer take-home pay from this employer-cost illustration.

Statutory cost examples and provider charges

These examples use the National Statistical Institute’s (NSI) preliminary second-quarter 2026 national and sector averages: gross monthly arithmetic means for employees under labour contracts. They combine those earlier wage observations with August–December 2026 contribution rules for the ordinary third-category employee born after 1959 who remains in universal pension insurance. The model uses the €2,300 ceiling, rounds contributions separately for each person and fund, and assumes an illustrative 0.4% accident rate, rather than a verified rate for any named sector. Benefits and provider services are excluded.

National mean used as an input	Salary €1,444; employer contributions €273.20; statutory subtotal €1,717.20 / month	NSI wages; Social Insurance Code; Health budget Act; Health Insurance Act; NSSI cap update; Employee insurance bases; Contribution rounding
Financial and insurance activities mean used as an input	Salary €2,140; employer contributions €404.89; statutory subtotal €2,544.89 / month	NSI wages; Social Insurance Code; Health budget Act; Health Insurance Act; NSSI cap update; Employee insurance bases; Contribution rounding
Information and communication mean used as an input	Salary €3,079; employer contributions €435.16; statutory subtotal €3,514.16 / month	NSI wages; Social Insurance Code; Health budget Act; Health Insurance Act; NSSI cap update; Employee insurance bases; Contribution rounding

At the €3,079 input, the €3,514.16 subtotal already includes €435.16 of contributions. Request separate prices for provider services and benefits before completing the commercial quote.

The model assumes gross pay is the applicable insurance base before the ceiling; a real hire still needs its actual occupational-floor and activity-specific accident-rate checks. Contributions equal 18.92% of gross in the under-cap examples and an effective 14.13% in the capped information and communication example, with both distinct from the fixed 18.52% share. These illustrations are neither observed payroll bills nor offers for a role, seniority or city. The country guide’s salary references explain the underlying benchmarks and methodology.

Item	Included in statutory illustration?	What to obtain in proposal
Gross salary	Yes, at the specified reference input	The actual agreed salary and fixed or variable additions
Employer contributions	Yes, under the stated category, cap and illustrative accident-rate assumptions	The actual insurance category, occupational floor, activity rate and calculation
Optional benefits or insurance	No	Coverage, eligibility, exclusions and separately stated price
Provider service fee	No	Amount, charging basis, included work and the entity delivering it
Recruitment, if requested	No	Candidate-search or selection scope and price
Equipment or remote-work arrangements, where applicable	No	Required items, responsibility and agreed cost treatment
Contractual onboarding, offboarding or transition charges	No	Applicable events, amounts and terms
Cash-flow and tax terms	No commercial assumptions included	Any deposit or advance, invoicing dates, tax/VAT treatment and reconciliation or return terms

Identify the employer and any subcontractors delivering each item, and ask which costs change with the employee’s circumstances or the law. Compare prices for the same scope and exclusions. A comparison with your own entity also needs your actual employment-administration costs.

Euro and contribution changes affect the proposal

The currency and insurance period determine which amounts and reporting rules belong in the proposal. Bulgaria adopted the euro on 1 January 2026 at EUR 1 = BGN 1.95583. Existing BGN values in legal instruments follow the statutory conversion and rounding rules; euro adoption itself does not release obligations, change deadlines or give a party a unilateral right to alter or terminate a contract, without prejudice to the parties’ agreement.

The earlier insurance ceiling was €2,111.64 for January–July 2026. Holding the €3,079 gross input and contribution shares constant, the two cap assumptions give employer contributions of €399.53 and €435.16 respectively, a €35.63 monthly difference. This comparison isolates the cap’s effect at an unchanged input; it does not reconstruct the employee’s actual earlier-period bill or measure wage growth.

For completed tax or insurance periods, reporting documents use the currency official at period end; a period ending in or including dual circulation uses euros. A declaration for a future tax period instead follows the currency official when it is filed. Ask the agency to identify the reporting period before preparing older-period documents.

The wage-setting amendment promulgated on 29 September 2026 introduced criteria involving purchasing power and living costs, wage levels and distribution, wage growth and long-term productivity, with a separate periodic adequacy assessment. It does not supply an adopted minimum-wage amount for 2027. Request the applicable wage decree and the proposal’s process for statutory updates when agreeing a future budget, keeping promulgation separate from the amendment’s commencement.

Assignment, IP and termination limits

A provider agreement cannot override assignment conditions, supply missing rights in the work or replace a lawful employment exit. Resolve these questions before the employee starts and revisit them when the role, client operation or intended use of the work changes.

Temporary purpose, user workforce and business presence

Tie the proposed employment term to the specified work being completed or the absent employee’s replacement, and agree what happens when that purpose ends. Check capacity against the actual user’s total workforce: temporary agency employees cannot exceed 30%, using neither provider staff nor the group’s worldwide headcount as the denominator. An unidentified Bulgarian user or workforce needs an assessment before capacity can be calculated. The five-year agency certificate concerns registration validity.

Changing or expanding an assignment requires another review of its purpose and user conditions. First- and second-category work, national-security or defence enterprises, and an undertaking with a strike in progress are prohibited contexts. A user that made collective redundancies must wait six months before contracting with an agency; a current registration entry cannot resolve those conditions.

Assess the client’s Bulgarian business presence separately. Aidos identifies local client-facing work, negotiation on the employer’s behalf and plans for a branch or local entity as reasons to review permanent establishment. Give the adviser the premises, local decision-making and contracting authority, activities and applicable treaty position. Provider registration cannot settle that tax assessment.

Employee software rights must reach the client

Trace the rights in the work from the employee through the employing provider to the client. Bulgarian copyright defaults distinguish employee software and databases from other employee works, so review any promise of ownership against the deliverables and actual agreements.

Employee computer programs and databases	The employer owns the copyright unless otherwise agreed. Where the agency employs the author, the client must establish the rights it receives from that agency.	Copyright and Related Rights Act
Other works created in employment or public service	Copyright belongs to the author unless the Act provides otherwise. The client cannot infer ownership merely because it commissioned the employee’s work through a provider.	Copyright and Related Rights Act
Employer use of those other employee works	Unless the employment agreement provides otherwise, the employer has exclusive use for its own purposes within its usual activity, without further author permission or remuneration. That employer-use entitlement does not itself describe the client’s onward rights.	Copyright and Related Rights Act

Kinstellar warns that software copyright may stay with the employing EOR because the end user is not party to the employment agreement, and recommends careful drafting across the three-party arrangement. Identify the author, work or version, employee agreement and provider-to-client grant before work begins. Check the intended uses, onward grants, territory, duration and exclusivity across that chain; the client service agreement alone cannot establish every upstream right.

Where the arrangement uses a copyright use-right grant, exclusivity must be expressly agreed in writing; otherwise the grant is treated as non-exclusive. An exclusive grant operates within the agreed manner of use, term and territory, while a non-exclusive grant leaves the author able to use the work and grant non-exclusive rights to others. If the grant sets no term, it defaults to three years, or five for architectural works; an omitted territory defaults to the user’s country of citizenship or registered office, as applicable.

The former Article 37(2) licence-duration provision was repealed from 1 December 2023 and cannot be used as a current limit. The prohibition on granting use rights over all works an author might create throughout their lifetime remains. Genuine independent commissions have different defaults, covered in the Bulgaria contractor guide.

Post-employment non-competes need separate scrutiny

DGKV’s 2026 Global Legal Insights chapter describes employee post-employment non-competes as unenforceable under the Supreme Court of Cassation’s interpretation, including restrictions offered for monetary consideration. The stated reason is the constitutional freedom to choose an occupation and employment. The chapter describes the decisions as strongly persuasive and routinely followed by lower courts, rather than binding precedent in the common-law sense.

Review an employee restriction on that basis before relying on it for the client’s business. Assess confidentiality, rights in the work and other intended obligations separately. This employment interpretation does not determine a genuine business-to-business covenant’s enforceability or dispose of every confidentiality and intellectual-property protection.

Ending the client service does not dismiss the employee

A client service cancellation needs a separate employment decision. Send the agency the requested change, operational reason, proposed date and supporting records so it can identify the employment ground and procedure. A provider exit charge does not establish a lawful dismissal ground.

Probation can permit termination without notice by the party for whose benefit it was agreed, before the period expires. Outside that route, notice and payments depend on the contract and termination ground. For an indefinite contract, notice is ordinarily 30 days unless a longer period has been agreed, up to three months; a fixed-term contract has three months’ notice capped by its remaining term. Ending before the applicable notice expires can require gross remuneration for the unserved portion.

Specified business-dismissal grounds can also require compensation for actual unemployment, ordinarily up to one month unless a more favourable law, collective agreement or employment term applies; lower-paid subsequent employment can give rise to the corresponding remuneration difference. Compensation is also due for unused annual leave whose entitlement has not expired. Have the agency separate final wages, notice compensation, applicable dismissal compensation and leave compensation in its calculation, with the ground and supporting records for each item.

Protection and selection must be checked before issuing the dismissal. Depending on the ground and employee category, prior Labour Inspectorate permission or other consent may be needed, with additional restrictions for pregnancy and maternity leave. DGKV describes a structured comparison of qualifications and work performance where a redundancy exercise affects employees in identical or comparable positions. Ask who will prepare those records and seek any required permission, rather than assuming the client’s choice of the person determines the lawful outcome.

The exit handover should include the employer’s decision, final remuneration and compensation calculations, and confirmation of the employment-register entry, which is due within seven days of termination. The country guide’s termination rules provide the full general notice and payment tables. Agree the client’s reimbursement obligations separately: commercial allocation between agency and user does not replace obligations owed to the worker.

Employer-proposed compensated termination

Article 331 provides a specific employer-initiated compensated termination route. The employee must accept the proposal in writing within seven days; without that response, it is treated as unaccepted. If accepted, compensation must be at least four times the last received monthly gross remuneration, unless a higher amount is agreed.

Payment must be made within one month of termination, or the termination basis lapses. The agency therefore needs to manage the proposal, written acceptance and payment together, while the client arranges any agreed commercial funding. These conditions belong to this particular route and should not be applied to every ordinary mutual termination agreement.

What a mistake costs and who pays

Penalties depend on the statutory actor and breach, with worker claims and unpaid-tax exposure governed separately. The fines below convert the provisions’ nominal lev amounts under the Euro Introduction Act, using the full official rate and general cent rounding. Public liabilities are paid and collected in euros after adoption; the lev amounts retained in the provisions are not the payment denomination.

Party	Risk	Amount
Temporary-work agency	Providing temporary work without registration	€2,556.46; repeat breach €2,556.46–€5,112.92; each subsequent breach €5,112.92–€10,225.84
Temporary-work agency	Breaching chapter eight-a requirements of the Employment Promotion Act	€511.29–€1,278.23; repeat breach €1,278.23–€2,556.46
Employer	Breaching the specified written-contract, register-entry or pre-start duties	€766.94–€7,669.38 for each separate violation
Culpable official	The specified written-contract, register-entry or pre-start violation	€511.29–€5,112.92 for each separate violation
Agency and user	Worker obligations arising from performance of the assigned employment	Joint and several liability for the obligation owed; registration does not remove this basis
User contracting with an unregistered agency	Unpaid employee taxes and compulsory contributions, and VAT on the supply	Joint liability limited to the unpaid obligation for the relevant period
Employer	Unlawful dismissal	Gross remuneration for actual unemployment caused by the dismissal, up to six months; the statutory remedy can instead cover the remuneration difference for lower-paid work during that period

The employer and culpable-official rows show ordinary Article 414(3) penalties; Article 414(4) has a separate repeat schedule. The specified written-contract, register and pre-start offences are excluded from the minor-infringement route. Agency registration and chapter eight-a offences have their own repeat categories, so these ranges cannot be combined into one maximum bill.

A commercial indemnity may allocate recovery between client and provider, subject to its terms and circumstances; it does not erase a fine or worker claim. The agency’s worker-claims insurance or guarantee and any client deposit serve different purposes. Ask who is responsible for each exposure and what contractual recourse applies.

Direct hiring without an EOR or Bulgarian subsidiary

Assess direct-employer registration before deciding that the hire requires an EOR or subsidiary. Your activity in Bulgaria determines the registrations and employment, social-insurance and tax duties to review. Establish who performs those duties and what administration direct hiring would require.

A foreign employer can need registration without a subsidiary

BULSTAT registration can apply to a foreign company without the creation of a Bulgarian subsidiary. Its statutory scope includes foreign legal persons carrying on economic activity in Bulgaria and non-natural persons acting as social insurers that lack another qualifying registration. The Act also excludes EU and EEA foreign persons whose Bulgarian economic activity consists solely of exercising the freedom to provide services; that specific scope should be assessed against the company’s activity, rather than inferred from the employee’s nationality.

Where BULSTAT registration applies, an application is due within seven days of the obligation arising; changes to circumstances subject to entry have the same deadline. Identify the registration category, triggering event, documents and applicant. The filing deadline does not establish the complete employer-setup timetable.

Aidos describes limited remote hiring without a broader Bulgarian operational footprint as suitable for foreign-employer registration. Test that practitioner scenario against the role: home working, business premises, client-contract negotiation, management authority and support for a wider local operation need consideration. Obtain the footprint assessment before relying on this route.

Assess cross-border social-security law and social-insurer registration alongside the business footprint. Identify which country’s insurance rules apply and how the employer will meet them. Insurer registration cannot settle corporate permanent establishment or the personal-income-tax employer definition.

The PIT employer definition is a separate check

The Personal Income Tax Act uses a specific employer definition for employment-income tax duties. Under Additional Provisions §1, point 27(a), it includes a domestic person, a foreign person operating through a Bulgarian permanent establishment or fixed base, or an investment-law trade representation, where the person employs individuals or is party to a foreign personnel-supply agreement. The analysis must therefore identify the actual establishment and arrangement, rather than treating social-insurer registration as the answer.

Article 42 assigns monthly calculation of employment-income advance tax to the statutory employer using the monthly tax base. Under Article 42(5), that employer withholds tax on the final payment of taxable income accrued for the month. Identify the statutory employer before allocating calculation and withholding.

The Act separately recognises employment relationships involving labour hired by a foreign person for work in Bulgaria, and labour of a resident individual hired by a foreign person for work abroad, under §1, point 26(e). Article 50(3) requires resident and foreign individuals receiving the specified employment income under point 26(e) or (i) to file an annual declaration for that income. The employee’s declaration obligation is a separate check from employer withholding; the foreign payer’s name or registration cannot settle both questions.

Have the adviser document the statutory-employer analysis, employee income category and reporting duties alongside the establishment and treaty facts. These determine the applicable withholding and declaration duties; a general foreign-employer payroll description cannot supply a universal rule or exemption. Request the NRA services and forms, identifiers, electronic-access sequence, fees and case-specific preparation time. The BULSTAT deadline is not a setup estimate.

Existing employment administration or real independent services

An existing employer can contract for payroll or HR administration of its own employment relationship. Set the scope, responsible people and employment and tax-record handover against its duties. The direct-registration workflow explains the first-contract steps; specify who performs them in the support agreement.

Genuine independent services require a different relationship. Under a contract for work, the contractor undertakes the ordered result at their own risk and ordinarily uses their own means unless otherwise agreed. A working arrangement that supplies labour under employee-like direction cannot become independent merely through invoicing: the Labour Inspectorate identifies fixed workplace and working time, monthly remuneration and hierarchical subordination as signs of employment being unlawfully regulated through a civil contract.

If the Inspectorate establishes labour provision contrary to the employment rule, it can declare an employment relationship and its start date. The Bulgaria contractor guide explains classification and available forms. Choose between employing directly, appointing a third-party employer and buying an independent result by the actual work and responsibilities.

Alternatives, and when each fits

Choose the route by who will employ the person, direct the work and take responsibility for the result. A plan to test the market or make a first hire still needs to satisfy the chosen route’s conditions, while a lasting operation needs an assessment of its actual Bulgarian footprint. Headcount alone cannot decide either question.

Model	Who employs or contracts	When it fits	What to check
Direct employment through your Bulgarian entity	Your entity signs the employment contract and acts as employer	You want to employ and manage the person within your own local operation	Employment terms, registrations, operating responsibilities and the administration your entity will perform or contract out
Foreign direct-employer registration	The foreign company remains the proposed employer, subject to the applicable registration and tax analysis	The company’s actual Bulgarian activity and hiring arrangement support this route without a subsidiary	BULSTAT scope, social-insurance rules, PIT statutory-employer status and business presence; registration is not universal eligibility
Registered temporary work	The agency employs the worker; the user directs and controls the assigned work	Completion of specified work or replacement of an absent employee, within the user and assignment conditions	Actual agency registration, user workforce capacity, prohibited contexts, post-redundancy timing and the relevant basic-conditions comparison
Provider-controlled outsourced service	The service provider employs and supervises its own employees	You buy delivery for which the provider is responsible, with the provider retaining direction and supervision	Who actually instructs the employees, controls delivery and carries responsibility for the overall work; a service-contract label cannot answer this
Genuine independent services, directly or through a contractor-platform or Contractor of Record proposal	An independent contractor undertakes the result; establish the contracting role of any intermediary	The work is an independent undertaking at the contractor’s risk	Actual control, result and contractor form, plus the parties and rights in every contract; invoicing does not settle classification

If you will direct the individual as part of your workforce, assess the employment routes against that plan. If you will buy an outsourced result, establish how the provider supervises its employees and takes responsibility for delivery, following Kinstellar’s distinction above.

Contractor of Record appears as a commercial label in contractor-service offers. For such an offer, establish who contracts with the independent professional and client, and assess the real service relationship under the same classification rules. For a PEO or co-employment proposal, ask which entity would legally employ the person and what Bulgarian structure supports the arrangement before treating the name as a separate legal route.

Moving to your own employer or another provider

A change of employer needs both employment and commercial handovers. The agency employment contract cannot prohibit or make employment with the user impossible during or after the assignment, and the agency cannot charge the worker for obtaining that job or entering user employment. These worker protections do not establish that every commercial agency-client conversion charge is prohibited.

Review the agency-client agreement’s notice, records and any claimed transfer charge. Have the employers establish the lawful end and new-start basis, including employee agreement where needed. If an automatic transfer is proposed, establish its legal basis and effect on employee rights before scheduling the move.

The handover should cover:

• Existing employment close: the responsible employer, lawful ground and procedure, required notice or compensation, outstanding remuneration and compensation for unused annual leave whose entitlement has not expired.
• New employment start: the new employing entity, agreed terms and start date, employment-register entry and delivery of both the contract signed by the parties and the NRA-certified entry record before the employee is admitted to work.
• Permission and work scope: whether a third-country worker’s current authorisation covers the new employer or host, workplace, role and work period, and what action is required before starting under changed circumstances.
• Work and rights records: relevant employment-service evidence, deliverables and the continuing employee-to-provider-to-client rights chain, including any new employer’s role in later software or database work.

Where the move involves termination and a new contract, the old employer must enter termination within seven days and the new employer must enter the contract within three days of conclusion. The new employer still has to deliver the signed contract and NRA-certified record before work starts. Set the handover dates around both filing and delivery duties.

Keep service-history evidence distinct from the new employer’s promised package. The pre-reform paper employment book remains official proof of its recorded circumstances, with completion and return covered above. Ask which prior service the new employer recognises for each purpose and how it handles leave, remuneration additions and optional benefits. A company change should not be assumed to preserve every benefit or tenure credit.

Record any obligations still owed under the previous arrangement. A provider change does not erase agency and user obligations arising from the assigned employment. Name who supplies the records, completes remaining payments and answers later questions.

How to choose a provider for the Bulgarian arrangement

Choose a proposal that identifies the employer, establishes assignment fit and explains how each party fulfils its duties. Request the underlying documents before comparing commercial terms. Local, global, owned-entity and partner offers all need to answer the employer and responsibility questions below.

Question	Evidence to request	Why it changes the decision
Which entity will employ the worker?	The employing entity and any local partner; matching temporary-work certificate, registration term, withdrawal or suspension status, and proposed signatories	The employer and its relevant registration must match the arrangement being offered
Who is the user, and what makes this assignment eligible?	Actual supervisor and user; specified-work completion or absent-worker replacement purpose; user total-workforce denominator and proposed agency staffing	The 30% capacity test belongs to the actual user, while a temporary purpose must be identifiable
Is the work or user context prohibited?	Work-category and undertaking assessment, strike status and dates of any user collective redundancies	First- or second-category work, national-security or defence enterprises, and undertakings with an ongoing strike are prohibited; the user must wait six months after its collective redundancies before contracting
What worker-claims cover is maintained?	Group insurance or unconditional irrevocable bank guarantee for €102,258.38, its applicable terms, validity and maintenance records	This is agency worker-claims cover, separate from a client deposit, fine or automatic individual compensation
How will operating information reach payroll?	Agreed time, basic/additional remuneration, leave and training records; same/similar-work comparator information and the responsible people on both sides	The user supplies operating data, while the agency performs employer duties; the basic-conditions comparison needs actual evidence
How does the proposal address liability?	Separate explanations of worker obligations, unregistered-agency exposure and contractual recovery terms	Agency and user joint worker liability differs from the relevant-period unpaid employee taxes, compulsory contributions and supply VAT exposure associated with an unregistered agency
What proves readiness to start?	Employment contract signed by both parties, process for entry within three days of contract conclusion or amendment, NRA-certified entry record and signed assignment-act delivery record	Employment documents must reach the worker before admission, and the agency assignment act must be delivered at least one working day before user start
Who handles an overdue register entry?	Escalation owner, response process and the effective mandatory Inspectorate instruction required for entry after the statutory deadline	The instruction requirement concerns overdue entry; ask separately how routine corrections are handled
How were statutory employer charges calculated?	Activity-specific accident rate, applicable occupation floor, August–December 2026 cap of €2,300 and itemised calculation for the actual hire	The earlier cost illustration cannot establish the named hire’s rate, floor or complete quote
How will the client receive rights in the work?	Relevant employee-provider agreement, provider-client grant and identified works, uses, duration, territory and exclusivity	Employer software/database rights and ordinary employee-work defaults differ; the client needs its actual onward-rights chain
Can this person work in this arrangement?	Candidate status, applicable permission route and comparison with the proposed employer or host, workplace, role and work period	Agency registration does not establish person-specific work permission or portability to a changed employer
Who manages an exit or direct hire?	Ground/procedure review, notice and compensation method, required permission and selection records, employee non-compete analysis, direct-hire terms and transition deliverables	Client cancellation requires a separate employment decision; worker direct-hire protections and commercial client conversion terms need separate treatment
What service is actually included?	Quoted fees and benefits, recruitment scope, support languages, employee contact and escalation, payroll/document cutoffs, reconciliation and transition responsibilities	These are commercial commitments to compare in the proposal, with named owners and measurable response terms
Can the proposed technology support the handover?	Demonstration of relevant record access, exports and any offered API or self-service function; proposed signature workflow and documented service limits	A demonstration can test the required tasks and access without assuming functionality from a product description

Match the certificate to the worker’s contractual employer, including where a reseller or partner participates. Agree who monitors continuing registration conditions and communicates changes or cover issues. The agency must report registered changes within seven working days and submit annual insurance or bank proof by 30 June.

Agree who sends working-time, remuneration, leave, training and comparator information, when it is due and how exceptions are resolved. Those records support the agency’s payroll and employment decisions. For any cutoff or response SLA, request its measured definition, exclusions and escalation procedure alongside the statutory filing and pre-start duties.

Test the digital workflow with the records you need to exchange and retain. Establish who can view, correct and export each record, how signatures are obtained and how records are handed over at exit. Demonstrate any offered support language, API, export format or self-service function and document the limits. Data handling also needs review against the actual arrangement.

Frequently asked questions

Are employer of record services legal in Bulgaria?

Legality depends on the actual arrangement behind the EOR label. Where a provider employs someone to work under the client’s direction and control, the temporary-work rules require agency registration and employment tied to completing specified work or replacing an absent employee. Check the actual user’s capacity against the 30% workforce limit and the prohibited work and undertaking contexts; registration alone does not establish that the proposed assignment qualifies.

How do I find a local employer of record?

Check the employing entity in the Employment Agency’s temporary-work register category, which is distinct from the private employment-intermediary category. Match the employer named in the proposed contract to the entity, certificate number and date, registration term and withdrawal or suspension status. A local brand or partner description should lead to those documents and the assignment assessment, rather than being treated as proof of the whole proposal’s suitability.

How much does an employer of record cost in Bulgaria?

Request an itemised quote for the provider fee and extras in addition to salary and employer contributions. For illustration, NSI’s preliminary second-quarter 2026 Information and communication gross monthly arithmetic mean for employees under labour contracts, €3,079, gives €435.16 of employer contributions and a €3,514.16 statutory subtotal. This model uses an ordinary post-1959 third-category employee remaining in universal pension insurance, gross pay as the applicable insurance base above the occupational floor, an illustrative 0.4% accident rate and the later August–December 2026 €2,300 cap, with contributions rounded separately by person and fund. The earlier observed sector mean plus those later assumptions does not establish a role offer, observed payroll bill or all-in provider price; price benefits and other commercial items separately.

How quickly can an EOR onboard an employee in Bulgaria?

Elapsed preparation time depends on the proposed employer, candidate documents and any permission requirements, so request a case-specific timetable. Employment-register entry is ordinarily due within three days of contract conclusion or amendment, but the worker must receive the contract signed by both parties and the NRA-certified entry record before admission to work. The agency must also deliver the written assignment act against signature at least one working day before the scheduled user start. These filing and delivery duties do not establish the provider’s total onboarding turnaround.

Can an EOR help with a Bulgaria work permit?

Ask the provider to establish whether the proposed employing entity and arrangement support the candidate’s actual permission route. For a third-country worker with authorised access, the permission’s specified employer or host, workplace, role and work period matter. Confirm the required documents and any action needed for changes before the person starts; agency registration and employment papers alone do not establish work permission or universal sponsor eligibility.

Can I hire someone in Bulgaria without a local office?

A foreign employer can assess direct registration before assuming it needs a Bulgarian office, subsidiary or third-party employer. The applicable BULSTAT and social-insurer registration scope must be established for the company and working arrangement. Aidos describes limited remote hiring without a broader Bulgarian footprint as a suitable foreign-registration scenario, which remains a practitioner assessment rather than a rule for every remote job. Review the actual business activity, establishment and treaty facts, together with the PIT statutory-employer definition; social-insurer registration alone cannot settle those tax questions or guarantee the absence of a permanent establishment.

How long can someone work through an EOR in Bulgaria?

For temporary-agency employment, the contract is tied to completing specified work or replacing an employee who is absent. The agency’s five-year registration certificate concerns its registration term, not a five-year assignment entitlement. Assess the actual purpose and employment ending conditions for the proposed work rather than relying on a universal month limit or an unlimited-service promise.

Can I move an EOR employee to my own Bulgarian entity?

You can assess a move to your own entity with a lawful employment handover. The agency employment contract cannot block employment with the user during or after the assignment, and the worker cannot be charged for obtaining that job or entering user employment; any claimed commercial client conversion charge needs separate review. Establish the lawful end/new-start or applicable transfer basis and arrange final remuneration, compensation for unexpired unused leave, employment records and new-employer pre-start documents. Resolve permission and IP handovers and ask which prior service and benefits the new employer will recognise, rather than assuming automatic transfer or complete continuity.

Sources

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