New NRA e-service: employers can now see their employees’ full employment record
Until now, employers in Bulgaria could see in the employment register (регистър на заетостта) only the data they had filed themselves. With the new e-service of the National Revenue Agency (НАП), the employer also sees the entries made by previous employers of its staff, but without their pay. Here is what the service shows, how to use it and what to watch out for.
Checked on against the official sources cited in the text. Reviewed by Rumyana Radoslavova, certified public accountant and managing director of Avia Invest EOOD. This article is not individual advice.
What is new
Employers and appointing authorities now have full access to the electronic employment record of their employees, not only to the data they filed themselves. The service is called „Достъп на работодател/орган по назначаване до данните от Регистъра на заетостта за служител/работник“ (employer/appointing authority access to the employment register data of an employee). It is in the „Справки“ (Enquiries) section of the NRA e-services portal and is used with a qualified electronic signature (КЕП) (source: NRA).
The right is set out in the Labour Code: employers are entitled to information about their employees entered by previous employers, except the amount of pay and compensation the employee received there (source: Labour Code, Art. 347a(4)). The NRA provides this access for the persons with whom the employer has an employment or civil service relationship (source: Ordinance on Entries in the Employment Register, Art. 15(1)(4)).
What you see and what you don’t
- You see the single electronic employment record of the people who work for you now, including the entries filed by their previous employers (source: NRA).
- The employment record contains, for example, the legal basis and term of the contract, the date it was signed and the start of work, the dates of supplementary agreements, the date and reason for termination, the position code and the working hours (source: Labour Code, Art. 349(1)).
- You do not see the amount of pay and compensation the employee received from previous employers (source: Labour Code, Art. 347a(4)).
- The Code also entitles the employer to information about compensation paid on termination due to illness and on retirement, for example to check whether the employee has already received compensation on the same ground (source: Labour Code, Art. 347a(4) and Art. 222(2) and (3)). The NRA does not say whether the new service shows this as well.
- You do not see former employees. When the relationship ends, access to their employment record is terminated automatically (source: NRA).
- You cannot check a candidate who has not been hired yet. The exception is a competition for a position that requires work experience (source: Labour Code, Art. 347a(5)): then the experience can be certified from the employment record with the candidate’s consent (source: Ordinance on Entries in the Employment Register, Art. 15(1)(5)).
How to use it
- Log in to the NRA e-services portal with a qualified electronic signature.
- Open the „Справки“ (Enquiries) section and choose „Достъп на работодател/орган по назначаване до данните от Регистъра на заетостта за служител/работник“ (source: NRA).
- Run the enquiry for the employee. The service covers only people with whom you have an employment or civil service relationship (source: Ordinance on Entries in the Employment Register, Art. 15(1)(4)).
An employer with up to 5 employees can also request access at the NRA territorial directorate with a standard form. The data is then provided on paper at the directorate or to an email address you give, within 7 days. For employers with more than 5 employees this access is electronic only (source: Ordinance on Entries in the Employment Register, Art. 15(3) and (4)).
If your accountant runs the enquiries
An authorised person, for example your accounting firm, can use the service once an application or notice for filing documents electronically and using the NRA e-services with the qualified electronic signature of an authorised person has been submitted (in Bulgarian: „Заявление за подаване на документи по електронен път и ползване на електронните административни услуги, предоставяни от НАП с КЕП на упълномощено лице“ or the notice with the same title) (source: NRA).
If we are already your authorised representative before the NRA, we will check whether our access also covers the new service. If not, we will tell you exactly what to file.
What to watch out for
- The employee can see who opened their employment record. They are entitled to information about the history of access, which shows at least the employer, the public authority or the third party that ran the enquiry. The only exceptions are enquiries by pre-trial investigation authorities under the Criminal Procedure Code and by the State Agency for National Security (source: Labour Code, Art. 347a(3)). Run enquiries only when you need them for work.
- The data in the employment record is personal data. Keep printouts and files the way you keep the employee’s personnel file.
- An employment record book (трудова книжка) issued before the Labour Code changes introducing the electronic employment record remains an official certifying document for what is entered in it (source: Labour Code, § 22 of the transitional provisions of the amending act, State Gazette No. 85 of 2023).
How we handle it
Avia Invest takes over your company’s payroll and HR administration. As an authorised person, we file the electronic employment records, check the NRA reports and run enquiries in the employment register when needed, for example after a new employee is hired.
Payroll for 1–3 employees is included in the “Business” package from €150 a month, and for up to 5 employees in “Premium” from €250 a month, excluding VAT. The first consultation is free, at our office in Sofia or online.
Frequently asked questions
Can I see the employee’s pay from their previous job?
No. The employer receives the data from previous employers without the amount of pay and compensation (source: Labour Code, Art. 347a(4)).
Can I check a job candidate before hiring them?
No. Access covers only persons with whom you have an employment or civil service relationship (source: Ordinance on Entries in the Employment Register, Art. 15(1)(4)). In a competition for a position that requires work experience, the experience can be certified with the candidate’s consent (source: Labour Code, Art. 347a(5)).
Do I need a qualified electronic signature?
The NRA says the e-service is used with a qualified electronic signature (source: NRA). An employer with up to 5 employees can also request access at the NRA territorial directorate with a standard form (source: Ordinance on Entries in the Employment Register, Art. 15(3)).
Can my accountant run the enquiry for me?
Yes, once an application or notice for using the NRA e-services with the qualified electronic signature of an authorised person has been submitted (source: NRA).
Will the employee know that I looked at their record?
They may. The employee is entitled to information about the history of access to their employment record, which shows which employer opened it (source: Labour Code, Art. 347a(3)).