As the deadline for transposition of the EU Pay Transparency Directive (Directive (EU) 2023/970) approaches, the topic of equal pay for equal work is becoming increasingly important for employers across Europe, including in Bulgaria.
Earlier this week, Bulgaria published for public consultation draft amendments to the Protection Against Discrimination Act and the Labor Code, through which the Ministry of Labour and Social Policy aims to implement the Directive requirements before the official deadline of 7 June 2026.
In this regard, Komarevski Dimitrov & Partners prepared a dedicated briefing for the members of the Hellenic Business Council in Bulgaria, outlining some of the key upcoming obligations and practical considerations for businesses operating in Bulgaria.
1. Hiring and Recruitment: Transparency and Non-Discrimination
The new rules extend the principles of transparency and non-discrimination to the recruitment process itself.
Employers are expected to review their hiring procedures, including:
- Using gender-neutral job titles and descriptions in job advertisements;
- Avoiding questions related to candidates’ previous remuneration during interviews;
- Providing information regarding salary levels or salary ranges during the recruitment process.
These requirements will likely require additional coordination between HR, recruitment and legal teams.
2. Transparency in Pay-Setting and Salary Increases
Under the draft legislation, employers will need to ensure that pay-setting systems are based on objective and gender-neutral criteria.
Indicative criteria include:
- Complexity of the role;
- Difficulty and effort required;
- Level of responsibility;
- Working conditions associated with the position.
Companies that already operate with structured compensation and bonus frameworks may still need to review their internal policies to ensure alignment with the new requirements.
3. Employee Access to Pay Information
One of the most discussed aspects of the Directive concerns employees’ rights to access information regarding average pay levels within the company, broken down by gender and by categories of equivalent work.
In addition, employers will no longer be allowed to impose contractual or internal restrictions preventing employees from discussing their remuneration.
This means that employment contracts and internal confidentiality provisions may need to be revised accordingly.
4. Reporting Obligations and Gender Pay Gap Monitoring
The Bulgarian draft legislation also envisages annual reporting obligations regarding gender pay gaps.
The first reports are expected to be submitted by 7 June 2027 and will initially apply to companies with 250 or more employees.
At this stage, smaller companies are not subject to reporting obligations, although they will still need to comply with the general pay transparency requirements.
Practical Business Preparation
Although the legislation is still in draft form and may undergo changes during the legislative process, employers are strongly encouraged to begin assessing their internal structures, policies and recruitment practices in advance.
Early preparation may help businesses avoid future compliance challenges and ensure smoother implementation once the new rules enter into force.
We would like to thank Komarevski Dimitrov & Partners for preparing this dedicated material for the HBCB community.
The full presentation prepared by the firm is available below.
