New employee and the employment register: what happens if you miss the deadline
Hiring someone? The employment contract must be entered in the employment register (регистър на заетостта), kept by the National Revenue Agency (НАП), before the employee starts work. If you miss the deadline, the entry has to go through the Labour Inspectorate, and the fine applies to each separate violation. Here is what the law says and how to get it right.
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.
The problem: the contract is signed but not registered
The Labour Inspectorate keeps finding people who work without an employment contract. In the first six months of 2026, inspectors found 1,774 such workers, and after the inspections employers hired 2,196 people on employment contracts (source: General Labour Inspectorate Executive Agency (ИА „Главна инспекция по труда“), 17 July 2026). During the campaign in the seaside resorts from May to September 2026, 142 people were found working without an employment contract (source: General Labour Inspectorate Executive Agency, 15 October 2026).
You don't have to be hiding anyone to have a problem. It is enough to leave the entry for later and let the 3-day deadline run out (source: Labour Code (Кодекс на труда), Art. 62(3)). Or the person starts work on a Friday and the entry is filed on Monday. The deadline may still be running, but the employee has been allowed to work without a copy of the entry, and that is prohibited (source: Labour Code, Art. 63(2)). The entry for the start of work must be filed before the first working day (source: Ordinance on Entries in the Employment Register (Наредба за вписване в регистъра на заетостта), Art. 10(3)).
If you are used to the “notification to the NRA”: since 1 June 2025, the Labour Code requires an entry in the employment register, and notifications under the old Ordinance No. 5 (Наредба № 5) cover the period up to that date (source: Ordinance on Entries in the Employment Register, § 1a).
What the law says
- The employment contract is concluded in writing and before the employee starts work (source: Labour Code, Art. 61(1) and Art. 62(1)).
- The data is entered in the employment register within 3 days of the conclusion or amendment of the contract and within 7 days of its termination. The entry is made by the employer or by a person authorised by the employer (source: Labour Code, Art. 62(3)).
- The entry with the start date of work is filed before the employee starts (source: Ordinance on Entries in the Employment Register, Art. 10(3)).
- Before the first working day, the employee receives a copy of the signed contract and a copy of the entry. Without them, the employer may not allow the employee to start work (source: Labour Code, Art. 63(1) and (2)).
- The register is kept by the NRA. It holds the single electronic employment record of each employee, which is an official certifying document (source: Labour Code, Art. 347(1) and Art. 347a(1)).
What happens if the deadline is missed
After the 3-day deadline, an entry can be made only after a mandatory instruction from the Labour Inspectorate has entered into force (source: Labour Code, Art. 62(4)). Inspectors can issue such an instruction when they find that the deadline was not met (source: Labour Code, Art. 404(1)(10)). After the deadline, the date of conclusion of the contract can also be corrected only following an instruction (source: Ordinance, Art. 13(2)).
If someone works without a contract, the inspectorate can issue a formal decision declaring that an employment relationship exists between you, and set the date from which it arose. It then instructs you to offer the employee an employment contract from that date (source: Labour Code, Art. 405a(1) and (4)).
| Violation | Employer | Official at fault |
|---|---|---|
| Work without a written contract, failure to register on time, or allowing work without the documents, for each separate violation | BGN 1,500–15,000 (€766.94–7,669.38) | BGN 1,000–10,000 (€511.29–5,112.92) |
| Repeat violation | BGN 15,000–20,000 (€7,669.38–10,225.84) | BGN 5,000–10,000 (€2,556.46–5,112.92) |
| Systematic violations | BGN 20,000–30,000 (€10,225.84–15,338.76) | BGN 10,000–20,000 (€5,112.92–10,225.84) |
The amounts are set by Art. 414(3), (4) and (7) of the Labour Code (source: Labour Code). The Code still states them in leva (BGN), and they continue to apply: the amount in leva is divided by the fixed rate of 1.95583 and rounded to the cent (source: Euro Introduction Act (Закон за въвеждане на еврото), Art. 12, Art. 13 and § 5(1) of the Transitional and Final Provisions).
These violations cannot be treated as minor. So the lower fine of BGN 100 to 300 for a minor violation does not apply to them (source: Labour Code, Art. 415c).
The solution: steps for a new employee
- Sign a written employment contract before the person starts work.
- File an electronic employment record with the NRA through its e-services portal, using a qualified electronic signature or an NRA personal identification code (ПИК). An employer with up to 5 employees can also file it at the NRA territorial directorate on an electronic data carrier with a cover letter (source: Ordinance, Art. 9(2) and (3)).
- Do it within the 3-day deadline, but always before the first working day.
- Check the report the NRA issues. It shows which entries were made, which were not and why. If an entry was not made, fix the cause and file it again within 3 days of receiving the report (source: Ordinance, Art. 12(1) and (2)).
- Give the employee a copy of the contract and a copy of the report with the entered data before they start work (source: Ordinance, Art. 12(3)).
- The employee starts work within one week of receiving the documents, unless you have agreed on a different period. The start of work is confirmed in writing (source: Labour Code, Art. 63(3) and (4)).
- When the salary, position, working hours or place of work changes, file a new entry within 3 days. On termination, the deadline is 7 days (source: Ordinance, Art. 10(1) and (4)).
- For each month, file the Form 1 and Form 6 declarations (обр. 1 и обр. 6) by the 25th of the following month (source: NRA).
What to prepare. The electronic employment record contains the contract data (source: Labour Code, Art. 349(1)), so gather it in advance:
- the employee's full name and Bulgarian personal number (ЕГН) or foreigner's personal number (ЛНЧ);
- the legal basis and term of the contract, the date of conclusion and the start date;
- the basic salary and the length of the working hours;
- the position code under the National Classification of Occupations and Positions, and the economic activity code;
- the town or village where the work will be done, and the agreed paid annual leave.
If we file the entry for you, we will also need a power of attorney from the company.
If you are already late
Don't file anything blindly, and don't wait for an inspection. Contact us: we check when the contract was signed, since when the person has been working and what has been filed with the NRA. The way to fix it goes through the Labour Inspectorate, and the specific steps depend on the case.
How we handle it
Avia Invest takes over your company's payroll and HR administration. We prepare the employment contract and supplementary agreements, file the electronic employment record as an authorised person, check the NRA report and send you the copy for the employee before their first working day. We track the deadlines for changes and terminations and file the monthly declarations.
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, excl. VAT. The first consultation is free, at our office in Sofia or online. If you have already missed a deadline, tell us straight away.
Frequently asked questions
How soon must a new employee be registered?
Within 3 days of the conclusion of the contract (source: Labour Code, Art. 62(3)). However, the entry with the start date is filed before the first working day (source: Ordinance on Entries in the Employment Register, Art. 10(3)).
Can I register the contract myself if I am late?
No. After the deadline, an entry can be made only after a mandatory instruction from the Labour Inspectorate has entered into force (source: Labour Code, Art. 62(4)).
What is the fine if an employee works without a registered contract?
For the employer, it is BGN 1,500 to 15,000, i.e. €766.94 to €7,669.38, for each separate violation. For a repeat violation, it is BGN 15,000 to 20,000 (source: Labour Code, Art. 414(3) and (4)).
Do I need an electronic signature?
Not necessarily. The entry can be filed with a qualified electronic signature or with an NRA personal identification code (ПИК). An employer with up to 5 employees can also file it on an electronic data carrier at the NRA territorial directorate (source: Ordinance on Entries in the Employment Register, Art. 9(2) and (3)).
Is there still an employment record book?
The data is now kept in the single electronic employment record, which is an official certifying document (source: Labour Code, Art. 347a(1)). An employment record book (трудова книжка) issued before 1 June 2025 remains an official document for what is entered in it (source: Act Amending and Supplementing the Labour Code (ЗИД на КТ), Transitional and Final Provisions, § 22, State Gazette (Държавен вестник) No. 85 of 2023).