Bulgaria's pay-transparency implementation bill is still pending. This guide explains the EU requirements and what employers can prepare now without treating the proposal as enacted law.
Vassilev & Chisuse Law Firm · 2026-10-11 · Legal review: 12 October 2026
Bulgaria has not yet completed the national implementation of Directive (EU) 2023/970 on pay transparency. As of 12 October 2026, the Government bill amending the Protection from Discrimination Act has been submitted to the National Assembly under No. 52-602-01-42 but has not yet become law. Employers should therefore distinguish between the Directive's requirements and the current Bulgarian legislative proposal.
The missed transposition deadline does not make it sensible to postpone preparation. The Directive sets concrete future reporting dates, and the Bulgarian bill is intended to introduce recruitment transparency, worker information rights, objective pay criteria and enforcement mechanisms. The final Bulgarian wording may still change during the parliamentary process.
Directive (EU) 2023/970 required Member States to transpose its rules by 7 June 2026. Bulgaria published a draft amendment to the Protection from Discrimination Act for public consultation in May 2026 and the Council of Ministers later approved a revised bill. The bill was submitted to the National Assembly on 11 September 2026.
As of 12 October 2026, the parliamentary file lists the proposal as a bill. It should therefore not be described as an enacted Bulgarian pay-transparency law. Businesses can prepare against the Directive and the filed proposal, but final policies and reporting processes should be checked again when the Bulgarian legislation is adopted and promulgated.
The Directive requires applicants to receive information about the initial pay or its range for the position, based on objective and gender-neutral criteria. The information must be provided in a manner that enables an informed and transparent negotiation, for example in the vacancy notice, before the interview or by another appropriate method before the employment terms are agreed.
Employers may not ask applicants about their pay history during current or previous employment relationships. Recruitment notices and job titles must also be gender neutral and recruitment processes must be conducted in a non-discriminatory manner.
An employer cannot provide meaningful pay-range information if it has no coherent internal approach to the value of roles. Preparation therefore starts with job architecture, salary bands and objective criteria for setting and progressing pay rather than with changing the wording of vacancy advertisements.
The Directive requires pay structures to enable an assessment of whether workers are in a comparable situation with regard to the value of work, based on objective and gender-neutral criteria. Skills, effort, responsibility and working conditions are expressly relevant factors, while other criteria may be used where appropriate to the position.
The Directive gives workers the right to request and receive written information on their individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work as them or work of equal value.
Employers must make workers aware of this right annually and explain how it can be exercised. The information must be provided within the period set by the Directive, which is no later than two months from the request. The Bulgarian implementation bill is designed to incorporate this information-right framework into national law.
The Directive requires Member States to ensure that workers are not prevented from disclosing their pay for the purpose of enforcing the principle of equal pay. Contractual confidentiality provisions and internal policies therefore need to be reviewed carefully where they could prevent a worker from exercising rights connected with equal pay.
This does not mean that every type of payroll or personal information becomes public. Employers must still protect personal data and confidential information, and disclosure rules must be applied consistently with data-protection requirements.
The Directive introduces staged reporting obligations based on workforce size. Employers with at least 250 workers must report annually, with the first report due by 7 June 2027 for the preceding calendar year. Employers with 150 to 249 workers report every three years, also beginning by 7 June 2027. Employers with 100 to 149 workers report every three years beginning by 7 June 2031.
Member States may impose reporting duties on smaller employers as well. The final Bulgarian law should therefore be checked before an employer relies only on the minimum thresholds in the Directive.
The Directive requires reporting on the gender pay gap, the gender pay gap in complementary or variable components, median pay gaps, the proportion of female and male workers receiving complementary or variable components, the proportion of workers in each pay quartile and pay gaps between workers by categories of workers, broken down by ordinary basic salary and complementary or variable components.
Producing reliable figures requires consistent payroll data and defensible worker categories. Employers should test data quality, treatment of bonuses and benefits, working-time adjustments and the methodology used to group employees performing the same work or work of equal value.
Under the Directive, a joint pay assessment is required where pay reporting reveals a difference in the average pay level between female and male workers of at least 5 percent in a category of workers, the employer cannot justify the difference on objective gender-neutral criteria, and the unjustified difference is not remedied within six months after submission of the pay report.
This threshold should not be read as permission for smaller unjustified differences. Equal-pay obligations apply independently of the reporting trigger. The 5 percent test determines when the specific joint-assessment mechanism is required.
Preparation should begin with data and decision-making. Employers should identify who decides starting salaries, how salary increases and bonuses are determined, whether job families are consistently defined and whether the organisation can explain differences using documented objective criteria.
Recruitment teams should be prepared for salary-range disclosure and the prohibition on pay-history questions. Human resources and payroll teams should be able to answer worker information requests, while management should understand the potential legal and financial consequences of unexplained pay disparities.
Multinational groups should also avoid assuming that a single global job-grading model automatically satisfies Bulgarian requirements. Local employment terms, benefits, working time and the final Bulgarian implementing rules must be reflected in the analysis.
Pay transparency requires more access to information, but it does not remove data-protection obligations. Reports and worker responses should be structured so that employees can exercise their rights without unnecessarily disclosing identifiable remuneration data of individual colleagues.
Small comparison groups can create particular re-identification risks. Employers should therefore design their information and reporting processes together with their data-protection framework. VC Law's Data Protection practice can assist with this interaction.
Employers should not present the pending Bulgarian bill as if it were already enacted, and they should not lock internal procedures to provisions that may still change in Parliament. At the same time, delaying all preparation creates unnecessary implementation risk because the core Directive requirements are already known and the first EU reporting dates are fixed.
A sensible approach is to build the underlying pay architecture, data quality and governance now, while keeping legal documents and final reporting workflows flexible until the Bulgarian legislation and any implementing rules are published.
Vassilev & Chisuse Law Firm advises employers on Bulgarian employment law, equal-pay requirements and preparation for the EU pay-transparency framework. Assistance can include review of pay structures, recruitment documentation, worker information procedures, internal policies and the legal aspects of pay-gap analysis.
For broader employment matters, see our Employment and Social Security Law practice.
This article reflects the legislative position reviewed as of 12 October 2026. The Bulgarian implementation bill has not yet been enacted and may change during the parliamentary process. This material is for general information only and does not constitute individual legal advice.