The hiring and posting of third-country nationals to Bulgaria involve specific requirements regarding access to the labor market, the right of residence, and the documentation that must be submitted by the employer or the host company. Third-country nationals are individuals who are not citizens of a member state of the European Union, the European Economic Area, or Switzerland.
When determining the applicable regulatory framework, it is important to distinguish between two fundamental scenarios: the hiring of a third-country national by a Bulgarian employer, and the posting of such an individual to Bulgaria by an employer based in another country. The requirements vary depending on the reason for the work activity, the duration of the stay, and the individual's status.
I. Hiring of Third-Country Nationals by a Bulgarian Employer
When a Bulgarian company wishes to hire a third-country national under an employment contract, it must first be determined on what legal basis the individual is authorized to work in Bulgaria. The mere possession of a visa or a residence permit does not automatically grant the right to engage in any form of gainful employment.
Depending on the specific case, an authorization for access to the labor market, a combined residence and work permit, or another document—as required under the Law on Labor Migration and Labor Mobility and the Foreigners in the Republic of Bulgaria Act—may be necessary.
The procedure generally involves the employer submitting an application along with the required documentation, followed by a review by the competent authorities. If applicable, further steps may be required to obtain a long-stay visa and a residence permit. The exact sequence of steps depends on the type of permit, the individual’s nationality, and whether the person is already legally residing in Bulgaria.
Furthermore, the employer should verify that the position meets the applicable requirements regarding qualifications and professional experience. If the role requires specific education, professional licensure, or particular vocational qualifications, the relevant documentation must satisfy both the requirements for the specific position and the applicable regulations concerning the classification of professions and occupations.
Once the requirements for labor market access and legal residence have been met, the employer may conclude an employment contract and fulfill their obligations under labor and social security law. Before the individual begins work, all applicable permits and registration requirements—as well as their respective validity periods—must be verified.
II. Secondment of Third-Country Nationals to Bulgaria
A secondment differs from direct employment. In this scenario, the third-country national generally remains in an employment relationship with an employer based outside of Bulgaria, who temporarily assigns them to perform work within Bulgarian territory. Depending on the specific nature of the activity, this may involve the provision of services, the fulfillment of a contract with a Bulgarian client, or work performed within the framework of a company belonging to the same corporate group.
Prior to the secondment, the applicable regulatory framework—governed by the Law on the Posting of Workers Abroad and its subordinate legislation—must be determined. Key factors include the duration of the activity, the reason for the stay, the individual’s status, and whether the person remains an employee of the sending company or is hired by a Bulgarian employer.
Unlike EU citizens, third-country nationals cannot rely solely on the provisions regarding the free movement of workers within the Union. Even if they are legally employed in another Member State, it must be assessed whether the secondment procedure, a registration process, or some other form of authorization is required for their work in Bulgaria.
1. Long-term Secondment
If the activity in Bulgaria falls under a regulatory framework that requires a work permit—or a combined residence and work permit—the sending employer or the host company must prepare the documentation stipulated for the relevant procedure.
Depending on the specific case, this may include an application, identification documents, proof of an existing employment relationship, details regarding the nature and duration of the activity, documentation of the employee’s qualifications, and records pertaining to the operations of both the sending employer and the host company. It should be noted that the same set of documents is not required for every instance of an employee being posted abroad. Therefore, the list of required documentation must be tailored to the specific legal basis applicable under the Act on the Posting of Workers Abroad and its implementing regulation; a one-size-fits-all list should not be used.
Where the procedure involves a long-stay visa or a residence permit, these steps must be carried out in accordance with the regulations applicable to foreign nationals. While work authorization and the right of residence are interconnected, they involve distinct legal issues and should be assessed separately.
2. Short-term posting
For certain short-term assignments, the legislation provides for a registration procedure as an alternative to the standard process for obtaining a work permit. Depending on the applicable legal basis, this may allow for the temporary performance of work in Bulgaria for a period of up to three months within a specified timeframe.
The employer or the host entity must verify whether the specific posting meets the criteria for this arrangement and submit the required declaration or notification within the prescribed deadline. Furthermore, it must be ensured that the conditions for the individual’s lawful entry into and residence in Bulgaria are met.
The framework for short-term postings should not be construed as a general exemption from labor market access requirements. It applies only when the specific legal conditions are satisfied. If these conditions are not met, or if the planned activity exceeds the permitted duration, it should be determined whether an alternative regulatory framework might apply.
III. Submission of Documents and Changes to Administrative Procedures in 2026
Council of Ministers Decree No. 85 of July 16, 2026, published in the "State Gazette" (No. 66, July 21, 2026), introduced amendments to the implementing regulation for the Law on Labor Migration and Labor Mobility.
A key change is the transition to the electronic submission of applications and declarations for procedures covered by the relevant provisions of the implementing regulation. Documents must be submitted via designated electronic channels—such as a secure electronic delivery system, a specific electronic portal, or a channel indicated by the Employment Agency. It is necessary to verify in advance which channel applies to the specific procedure in question.
As of July 21, 2026, the Employment Agency will no longer accept paper-based documents for procedures subject to the mandatory electronic submission requirement. Consequently, employers and authorized representatives must ensure they are equipped for electronic submission and must comply with all requirements regarding document format and electronic signatures.
When documents are submitted on behalf of an employer, they must bear a qualified electronic signature from the legal representative or a duly authorized individual. If a submission is made by an authorized representative, the relevant power of attorney must be included, where required.
The regulation also modifies the list of required documents for certain procedures. In some cases, copies of residence documents are no longer necessary; however, a copy of the passport page containing personal data remains mandatory. As requirements vary depending on the specific basis for the application, the same list of documents should not be applied to all types of applications. If a position requires specific training or professional qualifications, the submitted documentation must align with the requirements of the role and the applicable classification of professions and activities. Employers should verify these prerequisites before submitting the documents to avoid procedural delays.
Under the special procedure for individuals of Bulgarian origin—as stipulated in Section 30a of the implementing regulations for the Law on the Employment of Foreigners—the requirements for proving one’s origin have been modified. Provided that the legal criteria are met, the Employment Agency will verify the relevant information ex officio by consulting available administrative registers, eliminating the need for the applicant to provide the previously required documentation. Current regulations stipulate a 10-day period for the issuance of a confirmation under this procedure.
Any applicable fees must be paid in the prescribed manner—for instance, via bank transfer, where this is an accepted payment method for the specific service. Please note that fees paid are generally non-refundable, and documents will not be returned if an application is withdrawn. Before submission, it is advisable to confirm the current fee amount and the correct bank account details for the specific procedure.
IV. What must the employer verify before work begins?
Regardless of whether the situation involves direct employment or a secondment, the employer or the host company must—before a third-country national begins working in Bulgaria—determine the legal basis upon which the individual will work in the country. This includes verifying whether a work permit, registration, or other documentation is required. Furthermore, it is necessary to examine the applicable residence and visa regulations, identify the documents that must be prepared and the procedures for their submission, ascertain the validity period of any work permit or registration (and whether an extension might be needed), and clarify the obligations arising under labor, social security, and tax law.
It is particularly important to distinguish between a work permit, the right of residence, and registration requirements. Possessing one of these documents does not automatically mean that all other requirements have been met.