The Law on Labor Migration and Labor Mobility
The cornerstone of Bulgaria's legal framework for employing foreign workers is the Law on Labor Migration and Labor Mobility (Zakon za Trudovata Migratsiya i Trudovata Mobilnost, or ZLMTM). Adopted in 2016 and regularly updated to align with evolving EU directives and domestic labor market conditions, this law defines the conditions under which third-country nationals — citizens from outside the European Union and the European Economic Area — can legally work in Bulgaria.
The ZLMTM establishes the institutional framework for processing work permits, defines the roles and responsibilities of the Employment Agency (Agentsiya po Zaetostta) as the primary administrative body, and sets out the rights and obligations of both employers and foreign workers. It distinguishes between several categories of employment authorization, each designed for specific types of workers and employment situations.
In addition to the ZLMTM, several other pieces of legislation are relevant to the employment of foreign workers in Bulgaria. The Labor Code (Kodeks na Truda) governs all employment relationships, including those involving foreign nationals, ensuring equal treatment in terms of working conditions, pay, and social protections. The Law on Foreigners in the Republic of Bulgaria (Zakon za Chuzhdentzite v Republika Bulgaria) regulates residence permits and visa requirements. Together, these laws create a comprehensive legal environment that governs every aspect of foreign worker employment.
Understanding the legal framework is not optional — it is a prerequisite for any employer who wants to hire foreign workers legally, avoid penalties, and build a sustainable international workforce.
Types of Work Permits in Bulgaria
Bulgarian legislation provides several distinct types of work authorization for third-country nationals, each tailored to specific employment scenarios. Choosing the correct permit type is the first and most critical step in the hiring process.
Standard Single Permit
The Single Permit for work and residence is the most common authorization for hiring third-country nationals for permanent or long-term positions. It combines work authorization with the right to reside in Bulgaria, issued through a unified application procedure. The employer must conduct a labor market test, demonstrating that the position could not be filled by a Bulgarian or EU citizen by advertising the vacancy for at least 15 business days. The permit is typically valid for up to one year and is renewable.
EU Blue Card
The EU Blue Card is designed for highly qualified professionals from third countries. To qualify, the candidate must hold a higher education degree (minimum bachelor's level) or demonstrate at least five years of relevant professional experience. The offered gross salary must be at least 1.5 times the average gross annual salary in Bulgaria. The Blue Card provides enhanced mobility rights within the EU and can lead to long-term residence after five years. It is particularly relevant for technology, engineering, medical, and management positions.
Seasonal Work Permit
For employment tied to seasonal demand — primarily in tourism, agriculture, and food processing — two subcategories exist. Short-term seasonal work of up to 90 days within a 12-month period requires only a simplified registration with the Employment Agency. Longer seasonal work of 90 days to 9 months requires a formal seasonal worker permit, including a Type D visa. No labor market test is required for seasonal work, making the procedure faster than for standard permits.
Intra-Corporate Transfer Permit
This permit facilitates the temporary transfer of managers, specialists, and trainee employees from a company established outside the EU to its branch or subsidiary in Bulgaria. The transferred worker must have been employed by the company for at least 3 to 6 months prior to the transfer. The ICT permit is valid for up to three years for managers and specialists, and one year for trainees.
Freelance Permit (Self-Employment)
Third-country nationals who wish to work independently in Bulgaria — for example, as freelance consultants or sole traders — must obtain a permit for self-employed activity. This requires demonstrating that the proposed activity will benefit the Bulgarian economy, typically through a business plan, proof of funding, and evidence of relevant qualifications or experience.
The Application Process Step by Step
The work permit application process in Bulgaria follows a structured sequence of steps that must be completed in the correct order. Understanding each stage helps employers plan effectively and avoid common delays.
Step 1: Assess Your Needs and Choose the Permit Type
Before starting the application, the employer must clearly define the position to be filled, the required qualifications, the duration of employment, and the salary to be offered. Based on this assessment, the appropriate permit type is selected. Applying for the wrong permit category is a common mistake that results in rejection and wasted time.
Step 2: Conduct the Labor Market Test
For standard permits, the employer must demonstrate that no suitable Bulgarian or EU citizen is available for the position. This involves registering the vacancy with the Employment Agency and publishing it for at least 15 business days. The job posting must include realistic requirements and a competitive salary. The Employment Agency monitors for attempts to manipulate the test by inflating requirements or offering below-market pay.
Step 3: Prepare and Submit Documentation
The documentation package submitted to the Employment Agency typically includes the completed application form, the signed employment contract (in Bulgarian), results of the labor market test, copies of the worker's passport and qualification documents, proof of the employer's legal registration and financial standing, evidence of arranged accommodation, and a health insurance certificate. All foreign documents must be properly apostilled or legalized and translated into Bulgarian by a certified translator.
Step 4: Employment Agency Decision
The Employment Agency reviews the application and issues its decision within 30 days for standard permits or 15 days for seasonal permits. During this period, the agency may request additional documents or clarifications. A positive decision authorizes the employer to proceed with the visa application.
Step 5: Visa and Entry
After receiving the Employment Agency's positive decision, the worker applies for a Type D (long-stay) visa at the Bulgarian embassy or consulate in their country of residence. The visa is typically processed within 30 to 45 days. Upon arrival in Bulgaria, the worker must register with the Migration Directorate within 14 days to obtain a residence permit.
Step 6: Registration and Employment Start
The employer registers the employment contract with the National Revenue Agency (NAP) within three days of the worker's start date, begins paying social and health insurance contributions, and notifies the Employment Agency of the actual start date. These post-arrival steps are legally mandated and essential for maintaining compliance.
EU Directives and Their Impact on Bulgarian Law
Bulgaria's labor migration legislation does not exist in isolation. As an EU member state, Bulgaria is required to transpose and implement European directives that govern the employment of third-country nationals. These directives set minimum standards that all member states must follow, while allowing some flexibility in implementation.
The Single Permit Directive (2011/98/EU)
This directive introduced a unified application procedure for issuing a combined work and residence permit, reducing the administrative burden on both employers and workers. Bulgaria fully transposed this directive through the ZLMTM, and the Single Permit is now the standard pathway for most non-seasonal foreign worker employment.
The EU Blue Card Directive (2009/50/EC, revised 2021/1883)
The Blue Card Directive establishes a common framework for attracting highly qualified workers to the EU. The revised directive, adopted in 2021, broadened eligibility criteria and strengthened intra-EU mobility rights for Blue Card holders. Bulgaria is implementing the revised provisions, making the Blue Card increasingly attractive for skilled professionals from outside Europe.
The Seasonal Workers Directive (2014/36/EU)
This directive specifically addresses seasonal employment, establishing conditions for entry and stay of third-country nationals for seasonal work lasting up to 9 months. It ensures equal treatment for seasonal workers in terms of pay, working conditions, health and safety, and access to social services. Bulgaria's seasonal work permit framework directly implements this directive.
The Intra-Corporate Transfer Directive (2014/66/EU)
For multinational companies, this directive provides a streamlined pathway to transfer key personnel from entities outside the EU to operations within member states. Bulgaria's ICT permit implements this directive, facilitating international mobility for managers, specialists, and trainees.
The Temporary Protection Directive (2001/55/EC)
Activated for the first time in 2022 in response to the conflict in Ukraine, this directive granted Ukrainian citizens the right to reside and work in EU member states without standard work permit procedures. In Bulgaria, it was implemented through a Council of Ministers decision and has significantly simplified the employment of Ukrainian nationals.
Employer Obligations and Compliance
Employers who hire foreign workers in Bulgaria bear significant legal responsibilities. Understanding and fulfilling these obligations is essential not only for legal compliance but also for building a sustainable and ethical employment practice.
Equal Treatment and Non-Discrimination
Foreign workers must receive the same pay and working conditions as Bulgarian workers in equivalent positions. This includes base salary, overtime compensation, bonuses, paid leave, working hours, and occupational health and safety protections. Any form of discrimination based on nationality is prohibited and punishable by law.
Social Security and Health Insurance
The employer must register the foreign worker with the National Revenue Agency and pay all mandatory social and health insurance contributions — pension, general illness and maternity, unemployment, and health insurance — at the same rates and under the same conditions as for Bulgarian employees. Failure to make these contributions constitutes a serious legal violation.
Accommodation Requirements
For certain permit categories, particularly seasonal work, the employer is required to provide or arrange suitable accommodation that meets sanitary and safety standards. The rent charged to the worker, if any, must be reasonable and cannot be automatically deducted from wages without the worker's written consent. Accommodation conditions are subject to inspection by authorities.
Record-Keeping and Reporting
Employers must maintain comprehensive records of the employment relationship, including copies of all permits and authorizations, the employment contract and amendments, payroll records, working hours documentation, and health and safety training records. These records must be available for inspection by the Employment Agency, the General Labour Inspectorate, and the National Revenue Agency.
Penalties for Non-Compliance
The consequences of violating labor migration laws in Bulgaria are significant and escalating. Employers face fines ranging from BGN 2,000 to BGN 20,000 for each illegally employed foreign worker. Repeat offenders may be prohibited from hiring foreign workers for a specified period. In cases of systematic abuse or exploitation, criminal prosecution is possible. Additionally, the foreign worker may face deportation, creating both humanitarian and operational complications.
Compliance is not a burden — it is the foundation of a successful international recruitment strategy. Employers who invest in proper legal procedures protect their businesses, their workers, and their reputations.
If you need expert guidance on navigating the legal framework for hiring foreign workers in Bulgaria and the EU, contact Eurasia Consult today. Our team of specialists will ensure that your recruitment process is fully compliant with all applicable laws and regulations, from the initial application through to the worker's successful integration into your business.