On 19 May 2026, Bulgaria’s Ministry of Labour and Social Policy published a draft law — the Law on Amendment and Supplement to the Protection against Discrimination Act — for public consultation, with the consultation period running through 18 June 2026, extended from 2 June 2026.
The short draft law includes an already-passed entry into force date of 7 June 2026 and pursues a targeted transposition strategy, incorporating the EU Pay Transparency Directive’s requirements primarily through amendments to the Protection against Discrimination Act and the Labour Code.
What Is the Current Status of Bulgaria’s EU Pay Transparency Transposition?
Bulgaria’s draft entered public consultation with an original end date of 2 June 2026, but the path from the close of consultation to enacted legislation raised immediate and serious timing questions with the proposed entry into force of 7 June 2026.
The consultation period was then extended to 18 June 2026, an implicit acknowledgement that Bulgaria would miss the 7 June 2026 deadline. After the consultation period the remaining legislative steps include:
- The Ministry of Labour reviews all consultation feedback, documents its justifications for accepting or rejecting each submission, and finalizes revised legislative text.
- The Council of Ministers formally votes to approve the finalized text and transmits it to Parliament.
- Parliament completes the required readings, committee review, amendments, and floor votes.
- The President signs the legislation into law.
- The legislation is printed in the State Gazette, which generally publishes only on Tuesdays and Fridays.
Each of these steps carries its own procedural requirements and minimum timelines. Completing all of them in three working days would not have been feasible. However, employers with Bulgarian operations should begin to prepare against the compliance framework set forth in the draft’s substantive provisions as the draft begins to move through this legislative process on a delayed track.
How Does Bulgaria’s Draft Define Right to Information Obligations?
Bulgaria’s draft implements a standard two-month deadline for employers to respond to initial RTI requests, consistent with the Directive’s baseline requirement.
For clarification requests — where a worker follows up on a response that is incomplete or inaccurate — the draft sets a notably tight 14-day response deadline. This is shorter than the approach taken by most Member States and will require employers to maintain readily accessible pay data to support rapid follow-up responses.
Annual Reminder Requirement
Employers must issue an annual reminder to workers about their RTI rights by January 31 of each calendar year. This is a tighter deadline than the Directive’s open-ended annual notification obligation, and earlier in the calendar year than comparable deadlines in other Member States — Romania, for example, sets a March 31 deadline.
Privacy and Restricted Disclosure
Where an employer determines that fulfilling an RTI request would risk disclosing the pay of an identifiable worker, it has the right to restrict direct access by the employee. In those cases, the information is instead made available to the trade union at the organization and/or the Commission for Protection against Discrimination.
This approach implements the optional limitation in Article 12(3) of the Directive, consistent with the majority of Member States that have published drafts to date. As with other jurisdictions, Bulgaria’s draft does not define a specific threshold for determining when a worker category is too small to safely disclose comparative pay data — leaving that determination to employer judgment.
An employer may also require employees not to use RTI information for purposes other than the exercise of their right to equal pay.
What Are Bulgaria’s Pay Reporting Requirements?
Bulgaria’s draft aligns with the Directive’s standard reporting cadence:
- Employers with 150 or more employees must submit their first pay gap report by 7 June 2027.
- Employers with 100 to 149 employees must submit their first report by 7 June 2031.
Where a pay gap of at least 5% is reported within any worker category, the employer must prepare and submit a written justification to the Commission for Protection against Discrimination.
Employers are also required to respond to requests for additional information about reported pay differences — from workers, trade unions, the labour inspectorate, or the Commission — within one month of the request.
Where pay differences remain unjustified after six months, the employer must take corrective measures in consultation with trade unions and/or the Commission.
What Are Bulgaria’s Joint Pay Assessment Requirements?
Bulgaria’s draft applies the Directive’s standard Joint Pay Assessment triggers. Where a pay gap of 5% or more is reported in a worker category and it is not justified or remediated within six months, employers are required to prepare a joint pay assessment after consultation with worker representatives and/or the trade union at the organization. The employer then has one year to correct unjustified pay differences.
What Is the Additional Information Right Under Bulgaria’s Draft?
Bulgaria’s draft introduces a discrete additional information right in the Labour Code that goes beyond the Directive’s standard RTI framework.
Upon written request, an employer must provide a worker with information on the average level of salaries within the organization at the same job level. This response must be provided within 14 days of the request.
This provision supplements the standard RTI framework and creates a standalone disclosure obligation tied to an individual worker’s position — rather than the broader comparative pay data covered by Article 7. Employers should ensure their compensation data infrastructure can generate both types of responses within the applicable deadlines.
What Does Bulgaria’s Draft Mean for Employers?
Bulgaria’s draft is brief and structurally aligned with the Directive, but several provisions warrant attention:
The 14-day response deadline for both RTI clarification requests and the additional information right is among the tightest compliance windows seen in any Member State draft to date. Employers accustomed to planning for the Directive’s two-month baseline will need to build faster internal workflows for these specific obligations.
The January 31 annual reminder deadline is also earlier in the calendar year than comparable requirements in other Member States, creating a compressed window at the start of each year.
Employers should also monitor the legislation’s progress. While Bulgaria missed the deadline the original, ambitious proposal to enter into force by 7 June 2026 could signal an intention to fast track this legislation to limit the delay. Public employers in Bulgaria should also keep in mind the potential vertical effect of sufficiently clear and unconditional Directive requirements now that the transposition deadline has passed.
How Trusaic Can Help
At Trusaic, we provide employers across the EU with solutions to comply confidently with the Directive.
Our Complete EU Pay Transparency Solution enables compliant pay systems, ensures gender-neutral job evaluations, and automates complex reporting obligations to keep you one step ahead of EU pay transparency enforcement.
- PayParity® analyzes your rewards data (compensation/benefits in kind) and quickly identifies any potential unjustified inequities. It enables you to more easily comply with Article 7 (right to information) and Article 6 requirements (pay setting and progression policy).
- Our Remediation Optimization Spend Analysis (R.O.S.A.) works as PayParity’s remediation engine to find the most cost-effective way to close nominal pay gaps to ensure compliance.
- Automated RTI workflows: Our bi-directional integrations with global HCM platforms allow pay equity data to flow securely from the Trusaic platform back into the HCM. Employees can then access their RTI reports directly within their existing HR systems. This eliminates manual report generation and reduces compliance risk.
- For organizations that prefer platform-based access, RTI reports can also be generated and delivered securely through the PayParity platform, with role-based permissions and full auditability.
- Salary Range Finder® ensures equitable pay at the point of hire to prevent any increases in pay gap and enables you to easily comply with the Directive’s salary range disclosure and salary history ban requirements.
- Pay Decisions: Generate fair, competitive offers instantly from Workday.
- Regulatory and Pay Transparency Reporting™ captures your pay equity findings and generates compliant reports.
Trusaic is GDPR compliant and can assist any organization in any EU state in meeting its obligations under both the EU Corporate Sustainability Reporting Directive and the EU Pay Transparency Directive.
Visit our always updated Member State Transposition Monitor to stay on top of the latest EU Pay Transparency Directive developments.
