Bulgaria has moved employment paperwork into a fully digital environment. Since 1 June 2025, electronic employment records have replaced the paper labour book, and employers can also keep the rest of an employee’s file in digital form. For foreign-owned businesses, this means less paperwork, but also new duties and deadlines that are easy to miss.
This guide explains the two frameworks that now govern electronic employment documents in Bulgaria: the Unified Electronic Employment Record, maintained by the state, and the Ordinance that lets employers keep the employee’s own file electronically.
The Unified Electronic Employment Record
Following amendments to the Labour Code, the paper labour book that certified each employee’s work history has been replaced by the Unified Electronic Employment Record. It is held in a national employment register maintained by the National Revenue Agency (NRA). The system applies to private-sector employment from 1 June 2025, and to civil servants from 1 June 2026.
What employers must do
Employers no longer submit the old notifications on hiring, changes, and termination. Instead, they enter this data directly into the electronic register, using a qualified electronic signature (QES). The deadlines are unchanged: three days for the conclusion or amendment of a contract, and seven days for its termination. A few details that were not declared before must now be recorded, such as the start of actual work and paid annual leave. A business without a QES can still submit the data on electronic media at an NRA office, with a covering letter.
What happened to paper labour books
The law set a transition period from 1 June 2025 to 1 June 2026. During that year, employers had to complete each employee’s paper labour book, recording the length of service up to 1 June 2025 in words and figures, sign and stamp it, and return it to the employee. Employees should keep these books safely. They remain official proof of service before 1 June 2025, which matters most for service accrued before 2003.
Who can access the record
Each employee has full access to their own record, including a history of who has viewed it. Employers can see the data they entered and data from previous employers, but not past salary amounts or most termination payments. The NRA and, where the law allows, control bodies such as the General Labour Inspectorate also have access.
Electronic Documents in the Employee’s File
Alongside the state register, employers may keep the employee’s own file in digital form. This is governed by an Ordinance adopted under Article 128b of the Labour Code (Council of Ministers Decree No. 71 of 10 May 2018). Going digital here is an option, not an obligation, and paper files remain allowed.
If an employer chooses the electronic route, it must set out in its Internal Rules which documents will be kept electronically and which electronic signature employees will use. The employee’s clear, written consent is required, and the employer covers all the costs of the system.
At a minimum, the system must offer:
- a secure, encrypted environment with multi-factor authentication;
- remote electronic identification of the employer and employees;
- signing by the employer with a QES, and by the employee with the signature type set in the Internal Rules;
- certified electronic delivery in line with the EU eIDAS Regulation;
- ongoing access for each employee to their file, including after they leave.
Penalties for Non-Compliance
Missing these duties carries real risk. For example, failing to complete and return a labour book on time can lead to an administrative fine under Article 414 of the Labour Code of between EUR 767 and EUR 7,669, plus possible compensation claims from employees.
How Leinonen Bulgaria Can Help
Digital records cut paperwork, but they add strict deadlines and new declaration duties. Leinonen’s payroll and legal specialists can set up compliant Internal Rules, manage your electronic employment records, and keep you on the right side of every NRA deadline. Get in touch to keep your business fully compliant with Bulgaria’s latest employment requirements.
