Bulgaria is progressing legislation to implement the EU Pay Transparency Directive, with proposed requirements covering recruitment, employee access to pay information, gender pay reporting and the way organisations assess remuneration.
The Ministry of Labour and Social Policy published draft amendments to the Protection Against Discrimination Act in May 2026. The proposals are intended to transpose the Directive into Bulgarian law, although the country's 7 June 2026 implementation deadline has now passed without the legislation being finalised.
For organisations operating in Bulgaria, the direction is nevertheless becoming clearer. Greater visibility of pay will need to be supported by objective remuneration structures, reliable workforce data and processes capable of explaining how pay decisions are reached.
Salary Information Before the Interview
Recruitment is one of the areas expected to see a significant shift. Under the Bulgarian proposals, job advertisements would need to provide information about the basic salary or salary range, together with applicable permanent additional remuneration. Businesses would also be prevented from asking applicants about their previous salary.
These measures are designed to give candidates greater visibility over remuneration before entering salary negotiations and reduce the potential for previous pay inequalities to influence future earnings.
Recruitment and HR teams should therefore consider whether existing job advertising, interview and salary setting processes will be able to meet the proposed requirements.
Giving Employees Greater Visibility
The reforms would extend transparency beyond recruitment and into the employment relationship.
Employees would gain stronger rights to access information about remuneration, including average pay levels by gender for workers performing the same work or work of equal value. The proposals would also restrict confidentiality arrangements that prevent employees from discussing their remuneration.
This means organisations will increasingly need to be able to answer three important questions:
Having clear answers will be an important part of demonstrating that remuneration practices are applied consistently.
Building Objective Pay Structures
A central principle behind the reforms is that remuneration should be determined using objective criteria that apply equally to employees.
This goes beyond simply identifying whether a gender pay gap exists. Businesses may need to demonstrate how roles are evaluated, how remuneration levels are established and why differences between comparable workers are justified.
Areas likely to become increasingly important include:
For organisations with less formal remuneration structures, establishing these foundations may require significant preparation.
Reporting Will Bring Greater Scrutiny
The Bulgarian draft also introduces gender pay gap reporting obligations for organisations meeting the relevant workforce thresholds. The information is expected to cover differences in remuneration between women and men, including basic and additional remuneration, with further analysis across categories of workers.
The wider EU framework phases reporting according to workforce size, with the first reporting deadline for organisations with 150 or more workers falling in 2027 and reporting for those with 100 to 149 workers beginning in 2031.
The Significance of the 5% Pay Gap
Greater transparency will also bring additional responsibilities where significant differences cannot be explained.
Under the proposals, an unjustified gender pay gap of at least 5% within a category of workers can trigger further action. The wider Directive requires a joint pay assessment where the difference cannot be justified using objective, gender neutral criteria and has not been remedied within the prescribed period.
This makes the reasons behind a pay gap just as important as the headline percentage. Businesses should be able to demonstrate where legitimate differences arise from factors such as skills, responsibilities, experience or working conditions, rather than gender.
A Greater Focus on Legal Risk
One aspect particularly relevant to Bulgaria is the potential for greater scrutiny of pay decisions once employees have increased access to remuneration information.
The EU framework strengthens enforcement of equal pay rights, including access to compensation and changes to the burden of proof in pay discrimination proceedings. Bulgaria's draft is still progressing, and legal analysis has identified enforcement provisions as one area where further development or clarification may be required before the legislation is finalised.
Clear documentation will therefore become increasingly valuable. Being able to show how remuneration decisions were reached can help organisations demonstrate that differences are based on legitimate, gender-neutral factors.
Bulgaria – Global Insights
For further guidance on Bulgarian payroll, employment legislation, workforce compliance and global mobility, visit the Bulgaria Global Insights section on the activpayroll website.
Building Readiness for Bulgaria's New Framework
Bulgaria's legislation is still progressing, but the proposed direction is clear. Greater transparency during recruitment, stronger employee information rights and future gender pay reporting will place increased expectations on how organisations determine, document and analyse remuneration.
If you would like to understand how Bulgaria's developing pay transparency requirements could affect your organisation, speak to our experts today.
With thanks to our Bulgaria in-country experts at Eurofast for their valuable insight and contribution to this article.