Employment of Third-Country Nationals in Bulgaria

The shortage of skilled and seasonal workers has become a lasting risk to the growth of the Bulgarian economy. In 2024 alone, the Employment Agency approved 10,403 applications for labour market access by third-country nationals, with one in four applicants coming from Kyrgyzstan, followed by Uzbekistan and Nepal. In an effort to meet these needs, the legislator and the executive amend the migration framework almost every year, and in June 2025 the National Assembly even created an entirely new category, the long-stay visa for digital nomads.

1. The Legal Structure – Four Main Sources

• The Foreigners in the Republic of Bulgaria Act governs the types of visas and residence permits.
• The Labour Migration and Labour Mobility Act sets out the conditions for access to the labour market.
• The Labour Code contains special rules on remote work, which also apply to foreign nationals.
• Secondary legislation specifies the documents, time limits and fees.

These instruments operate together and define different “routes”, from the highly qualified EU Blue Card to simplified seasonal registration.

2. EU Blue Card – the Premium Route for Highly Qualified Workers

Highly qualified specialists, such as software engineers, doctors and architects, most often enter through the EU Blue Card. Bulgarian law restricts labour mobility during the first two years.

“During the first two years of highly qualified employment, the holder of an EU Blue Card may carry out activities meeting the conditions under which the card was issued only in the territory of the Republic of Bulgaria. During the period under paragraph 1, the holder … may change employer only under the conditions of Art. 33k.” Art. 33n(1)–(2) of the Foreigners in the Republic of Bulgaria Act, as amended by State Gazette No. 21/2021, in force from 1 June 2021

After the two-year period, changing employer becomes considerably easier, requiring only a notification rather than a new full procedure. The salary threshold remains 1.5 times the average gross salary (BGN 2,609 for 2023, with an update expected for 2024). The card is issued for up to four years and leads to long-term residence after the fifth year.

3. The “Classic” Single Work Permit

Where the position is medium-skilled but no local candidates are available, an application is made for a single permit. The law is clear.

“The work permit for persons under Art. 40(2)(1) shall be issued for a period of up to 12 months.” Art. 41(1) of the Labour Migration and Labour Mobility Act

On renewal, the Employment Agency checks whether the position, place of work and remuneration remain unchanged, and any “silent” change leads to revocation.

“The permit under Art. 40(1) shall be revoked by decision of the Executive Director of the Employment Agency where … the control authorities of the Ministry of Labour and Social Policy establish that the employment of the third-country national does not correspond to the position, place of work, employer or person receiving a posted or seconded third-country worker stated in the permit.” Art. 43(1)(2) of the Labour Migration and Labour Mobility Act

4. Intra-Corporate Transfer (ICT)

Multinational companies often transfer managers or key experts to their Bulgarian office. The Foreigners in the Republic of Bulgaria Act provides that the permit may be “extended to a maximum of three years” for managers and specialists.

5. The Digital Nomad Visa – a Brand-New Addition

On 19 June 2025, Parliament finally adopted amendments introducing “long-term residence for remote workers employed by a foreign employer”. The expected secondary legislation will require income equal to 200% of the minimum wage, health insurance and a lease or ownership of accommodation. The visa will allow residence of up to 24 months but will not permit an employment contract with a Bulgarian employer.

6. Remote Work – Obligations under the Labour Code

The April 2024 amendments to the Labour Code require genuine protection for remote employees.

“The employer shall take measures to ensure, as at the date on which the employment relationship arises or is amended, that the workplaces for remote work meet the minimum requirements for healthy and safe working conditions laid down in the Health and Safety at Work Act and its implementing instruments.” Art. 107k(3) of the Labour Code

The address of the foreign national's home office must be declared to the Ministry of Interior together with the residence documents.

7. Seasonal Employment – the Fastest Route for Tourism and Agriculture

Bulgarian law offers two “routes” for the short-term hiring of third-country nationals during peak months. Both are designed for sectors where demand for labour rises sharply, namely agriculture, forestry and fishing and accommodation and food services. The law defines seasonal work as work that “depends on the change of seasons and is linked to a certain time of year when the need for labour is significantly greater”.

7.1 The “Up to 90 Days” Route – Registration and, Where Required, a Visa

• Two conditions. Art. 24l of the Foreigners in the Republic of Bulgaria Act requires, first, that the worker hold a short-stay type C visa for seasonal work where their nationality requires one and, second, that the employer file a declaration of registration of employment with the Employment Agency.
• Time limit and fee. The declaration is processed in about 10 calendar days, and no state fee is charged.
• Start of work. Employment may begin only once both conditions are met. For visa-exempt nationals, this means in practice immediately after the registration is approved. For all others, after the visa is obtained at the consulate.

A breach, such as starting work before the visa or registration, is punishable by a fine of up to BGN 10,000 and a temporary block on the company's access to new seasonal workers.

7.2 The “90 Days to 9 Months” Route – Seasonal Worker Permit

Where the season lasts longer, the employer moves to the regime under Art. 24k of the Foreigners in the Republic of Bulgaria Act. The employment contract must be for at least 90 days and at most nine months in any 12-month period.

The procedure is joint.

• First, the Employment Agency issues a decision under Art. 7(3) of the Labour Migration and Labour Mobility Act (within 15 days).
• The Ministry of Interior then finalises the permit and the type D visa (within a further 15 days).

The state fee is BGN 100, and on arrival the foreign national receives a biometric “seasonal worker” card. The permit may be extended once until the nine-month limit is reached.

7.3 Sectoral Restriction and Definition

The Labour Migration and Labour Mobility Act confines the seasonal scheme to “agriculture, forestry and fishing” and “accommodation and food services”. Outside these sectors, the Employment Agency does not accept declarations. The Additional Provisions (§ 1(18)) stress that the activity must be closely tied to the annual cycle.

7.4 The Employer's Obligations

• Social guarantees. The company bears the cost of the worker's return ticket, accommodation and health insurance, and these costs may not be deducted from pay.
• Quota. Seasonal hires count towards the overall quota of “20% (or 35% for SMEs) third-country nationals” under Art. 7(1) of the Labour Migration and Labour Mobility Act.
• Supervision. A change of position or place of work without new registration leads to loss of access and a fine of up to BGN 15,000.

7.5 Timeline of the Procedure

1. Contract – signed with a clause stating that it “enters into force after registration or permit”.
2. Filing – a declaration under the up-to-90-days route, or an application in the prescribed form under the 90-days-to-9-months route.
3. Decision – 10 days (short regime) or 15 + 15 days (long regime) for the Employment Agency and the Ministry of Interior together.
4. Visa – type C (short-stay) or type D (long-stay), depending on the regime.
5. Card – under the long regime, the Ministry of Interior issues a “seasonal worker” card after biometric data is taken.

With correct documents, the whole process is usually completed within one month. When the nine-month maximum expires, the worker leaves the country and may be hired again after a three-month break (Art. 5(2)(1) of the Labour Migration and Labour Mobility Act).

7.6 The Risks of “Skipping” the Rules

• Starting work without registration or a visa – a fine of up to BGN 10,000 (Art. 76 of the Foreigners in the Republic of Bulgaria Act) and a blocked quota.
• Deducting transport or rent from pay – a fine of up to BGN 15,000 and a 12-month ban on hiring foreign nationals (Art. 72 of the Labour Migration and Labour Mobility Act).

Following the procedure is not a formality. It is the price of lawful, predictable and repeatable access to labour in the busiest seasons.

8. Responsibilities Not to Be Overlooked

• Time limits – renewal begins 60 days before expiry, and missing it blocks access to the quota for new foreign workers for one year.
• Currency risk – a salary falling below the statutory threshold after exchange rate movements leads to refusal or revocation.
• Remote work address – failure to declare the address under Art. 107k of the Labour Code to the Ministry of Interior may cost BGN 15,000.

9. How We Can Assist

Our firm offers a full range of services, from a strategic assessment and the choice of a suitable route, through drafting contracts and applications, to representation before the Employment Agency and the Migration Directorate. For corporate clients, we can monitor legislative changes on a retainer basis and alert you to approaching deadlines.

Bulgaria now has a full range of instruments, the EU Blue Card for high salaries, the administratively “light” single permit, the ICT Card for transfers, an expanded framework for seasonal employment and the newly adopted digital nomad visa. Each regime offers specific opportunities but also specific obligations. With the right legal strategy, you can make use of them without risking penalties or loss of time. Our [employment law](/uslugi/trudovo-pravo) team assists employers at every stage of the process. [Contact us](/kontakti) and we will help you navigate the regulations.