BULGARIA Trends and Developments Contributed by: Diana Milkova and Victoria Penkova, Penkova & Partners Law Firm
pensions shall be paid in euros and shall be recalcu - lated in accordance with the rule under the preceding sentence. That rule also applies to labour remunera - tion, compensation, cash and social benefits, and pensions, which are determined in levs, but have not been paid by 1 January 2026. Employment agreements and any employment-relat - ed documents prepared and concluded after 1 Janu - ary 2026 shall include labour remuneration calculated in euros. Changes in the Labour Migration and Labour Mobility Act and the Regulations for its implementation The changes provide that in all cases of change of the employer by an EU Blue Card holder, the new employ - er or its representative shall submit the application for change of employment. When the change of employer is carried out after the first 12 months of employment on the grounds of the issued EU Blue Card, the appli - cable procedure is significantly simplified, requiring submission by the new employer of a certified copy of the employment agreement and declaration from the new employer that the conditions for work and labour remuneration are fulfilled and that those are not infe - rior to the ones of Bulgarian employees in the same labour category. If in such case the new employer is in the same industry sector, the required documents are certified by the new employer – a copy of the employ - ment agreement and document ascertaining that the conditions of performance of a profession, included in the List of Regulated Professions in the Republic of Bulgaria under Article 3 of the Recognition of Profes - sional Qualifications Act. Applicants for EU Blue Cards are not required to be out of Bulgaria when they are subject to application for an EU Blue Card. In case applicants for EU Blue Cards are already holders of a prolonged residence permit on other grounds, the application has to be submitted at least two months before expiration of the term of the previous prolonged residence permit. In case the applicant does not comply with this term, he or she is subject to administrative penalty from BGN100 to BGN500 and from BGN200 to BGN1,000 in case of repeated violation. Employers are subject to pecuni -
ary sanctions from BGN200 to BGN1,000 and from BGN400 to BGN2,000 in case of repeated violation. With the changes in the Foreigners in the Republic of Bulgaria Act and the Labour Mobility and Labour Migration Act, if the applicant is in the IT field, he or she is required to establish, via official documents, professional experience, relevant to the position under the employment agreement, which requires higher education of at least three years in the seven years prior to applying for an EU Blue Card. The position under the employment agreement is required to be in group 133 “Managers in the field of IT”, subclass 25 “IT Specialists” as per the National Classifier of Professional Positions. In case the applicant is not in the IT field, he or she is required to prove via an official document at least five years of professional experi - ence, which requires higher education and is relevant to the position under the employment agreement. As per the latest changes in the Foreigners in the Republic of Bulgaria Act, in force as of 1 July 2025, a new ground for granting of a permit for prolonged residence has been introduced for individuals referred to as “digital nomads”. A digital nomad is a foreigner who: • is employed under an employment contract by an employer registered/established outside a member state of the European Union, or a state that is party to the Agreement on the European Economic Area, or the Swiss Confederation, and who provides remote services through the use of information technology – in case the employment contract is concluded for a fixed term, the remaining term of the contract must be no less than the term of valid - ity of the long-term residence permit issued on this basis; • is a legal representative, member of the manage - ment body, owner of a company, partner or share - holder owning more than 25% of the capital of a company registered/established outside a member state of the European Union, or a state that is party to the Agreement on the European Economic Area, or the Swiss Confederation, through which it pro - vides remote services through the use of informa - tion technologies and does not perform work and/
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