Business trips abroad from Bulgaria: rules and per diems 2026

The Ordinance on Official Business Trips and Specialisations Abroad (НСКСЧ) is one of the most frequently applied but rarely analysed pieces of secondary legislation. Every government body, municipality and enterprise that sends employees abroad works under it, and after a series of amendments (the latest in State Gazette (ДВ) No. 8 of 28 January 2025) and the adoption of the euro on 1 January 2026, applying it in practice raises new questions for human resources departments, payroll (ТРЗ) specialists and administrative lawyers.

This analysis sets out the current version of the ordinance from the order to the financial report, with precise references to the applicable provisions and to the related rules of the Labour Code (КТ). The aim is practical: to outline the framework within which a business trip abroad is documented correctly and defensible for tax purposes.

Legal framework: what the НСКСЧ regulates

The ordinance was adopted by Council of Ministers Decree No. 115 of 3 June 2004, promulgated in ДВ No. 50 of 11 June 2004 and in force from 1 July 2004. As of June 2026 the latest amendment and supplement was promulgated in ДВ No. 8 of 28 January 2025. It is important to stress that the so-called euro omnibus (Council of Ministers Decree (ПМС) No. 354/2025, ДВ No. 115 of 30 December 2025) amended the Ordinance on Business Trips within the Country (НКС), not the НСКСЧ, so the adoption of the euro in itself has not changed the currency amounts in Annex 2 of the regime for trips abroad.

The basis for sending someone on a business trip and the right to travel allowances are found in the Labour Code. Posting an employee within the country is governed by Art. 121 of the КТ (for no more than 30 calendar days without interruption), while posting in the context of providing services in another EU Member State, which transposes Directive 96/71/EC, is the subject of Art. 121а of the КТ. The right to travel, per diem and accommodation allowances derives from Art. 215 of the КТ.

Business trip and specialisation: scope and definitions

The ordinance distinguishes two institutions. A business trip abroad is sending people to carry out specific official work abroad, while a specialisation is sending them to acquire or improve qualifications and to study foreign experience. The distinction is not a formality: it determines the purpose, the typical duration and the financial conditions of the stay.

The scope of the ordinance is broad. It covers government bodies, municipalities and enterprises, and for each category the ordinance names the authority that issues the order for the trip (Art. 3). That is why, to determine the competent issuer, you first need to establish which category the sending body belongs to.

The business trip order: required elements and electronic form

The order is the central document of the regime. Art. 5(2) of the НСКСЧ lists exhaustively twelve mandatory elements, among them the name of the body, the legal basis, the person and position, the date and duration, the country and place, the financial conditions, the official task, the mode of travel and the route, and the signature and stamp. A missing element can compromise the trip both in terms of employment law and in terms of accounting.

Since the 2023 supplement, the order may also exist as an electronic document under Regulation (EU) No. 910/2014 (eIDAS) and the Electronic Document and Electronic Trust Services Act (ЗЕДЕУУ). Art. 4 covers the case where the order is issued by one body and the costs are borne by another, after prior written agreement, and in urgent cases a simplified procedure is allowed. Art. 6 determines who issues the orders for the heads of government bodies and enterprises themselves.

Travel allowances: per diems, accommodation and travel

Per diems and accommodation allowances are set by Annex 2 to the ordinance, which contains a table of amounts differentiated by country. Since the 2023 amendments the table has been denominated in euro. This analysis deliberately does not reproduce specific amounts by country: they change often, so every practitioner should check them in the current version of Annex 2 as at the date of the trip.

There are three separate grounds for reducing per diems under the НСКСЧ, and they should not be confused with the regime for trips within the country. Where full board is provided, per diems are 30 per cent (Art. 20). For a stay in a neighbouring country of less than 24 hours but more than 4 hours, 35 per cent is due (Art. 21). For a business trip lasting more than 30 days, per diems are reduced by 25 per cent (Art. 22).

Accommodation allowances are due against a document (an invoice), and the ordinance provides that, where necessary, the head of the body or enterprise may allow payment of the actual amount. Travel allowances are recognised on the documented costs and in the manner laid down in the ordinance.

Reporting on the trip and returning funds

Reporting rests on several separate documents, which in practice are often confused. The funds for the trip are approved by an account in a form approved by the Minister of Finance, and a copy of the account is given to the person sent (Art. 35). It is worth clarifying here that Art. 35 does not describe the internal breakdown of per diems, travel and accommodation, but regulates the approval of the funds through the Ministry of Finance form.

The two time-limited documents after the return should be clearly distinguished. The report on the work done is submitted within 10 days of the return (Art. 38(1)), while the financial report on the foreign currency spent is a separate document with a 14-day limit (Art. 39). Mixing up the two time limits and the two documents is a frequent source of remarks in later audits.

Posting within the EU, exceptions and tax treatment

When services are provided in another Member State, the regime differs from an ordinary business trip. Under Art. 121а of the КТ, which transposes Directive 96/71/EC, the posted worker is covered by the minimum working conditions of the host country. This is a separate institution that should not be equated with posting under Art. 121 of the КТ.

Annex 2 also provides for exceptions from the general regime for certain categories of staff: land transport staff, aircraft crews and ship crews, including on the River Danube. Specific rules apply to them, so the general table should not be carried over automatically.

Practical guidance for employers and HR

Correct handling of business trips abroad is built in advance, through an internal policy on travel expenses and approved limits. Such a policy is a practical defence in tax inspections, because it makes both the basis and the amount of the sums paid traceable.

The topic attracts steady informational interest, but quality content in the Bulgarian online space is fragmented and often mixes up the two regimes. A systematic reading of the НСКСЧ in force, accompanied by precise references, remains the surest basis for sending people on trips correctly.

For related questions on employment documentation, see the analysis of § 24 of the Transitional and Final Provisions of the Act Amending the КТ, and for checking tax liabilities, the article on checking your liabilities to the National Revenue Agency (НАП).