Bulgaria's pension ordinance (НПОС): insurance record rules

The Ordinance on Pensions and Insurance Record (Наредба за пенсиите и осигурителния стаж, НПОС) is the procedural backbone of the Bulgarian pension system. It turns the substantive rules of the Social Insurance Code (КСО) into a concrete administrative procedure: an application, documents, counting of insurance record (осигурителен стаж, your contribution history) and establishing of income. For social security lawyers, payroll and HR specialists (ТРЗ) and pension consultants, knowing the ordinance is often the difference between a pension right that is upheld and one that is refused.

In this analysis we set out the structure of the current НПОС, its key procedural provisions and the typical disputed situations in the practice of the National Social Security Institute (НОИ, the NSSI). The post reflects the version in force as of 2026; the exact consolidated text should be checked in the official source before it is applied in practice.

What the НПОС is and how it relates to the КСО

The НПОС was adopted as an annex to a secondary act of the Council of Ministers, not as a standalone law. This also determines its function: it details the procedure without creating new substantive law. The right to a pension and its amount are governed by the КСО; the way this right is proved and realised before the NSSI is governed by the ordinance.

The hierarchy of sources matters in practice. When the ordinance is silent or unclear, the answer is sought in the КСО, not the other way round. That is why any work with the НПОС means reading in parallel the corresponding provisions of the code, to which the ordinance constantly refers.

Structure of the ordinance

The current НПОС is organised in two main chapters. The first governs the granting of pensions and the establishing of insurance record and income, and the second is devoted entirely to payment.

For the practitioner this division is a handy map. Questions of granting and proof are in Chapter One, while the specific payment regimes, including an address abroad or payment through banks and payment institutions, are set out in Chapter Two.

Granting a pension: application, documents and file

The granting procedure starts with a written application. The ordinance regulates both the form of the application and the channels for submitting it, as well as the competent territorial office of the NSSI.

The actual decision on the file is an order issued by an official of the NSSI. The ordinance takes this link directly from the substantive law.

An important procedural guarantee in favour of the applicant is the collection of municipal documents by the authorities themselves. It shifts the burden of obtaining them from the citizen to the administration.

A pension file is opened for every applicant. The ordinance introduces a clear rule for identifying it, which makes it easier to track the case.

Counting and certifying insurance record (УП-3)

Establishing and counting insurance record and income is regulated in Section V of Chapter One (Art. 37 et seq.). Here the ordinance defines when a period counts as insurance record and by what documents it is proved.

Establishing insurance income (УП-2)

Determining the income from which the pension is calculated is regulated in Section VI of Chapter One (Art. 46 et seq.). Certificate УП-2 is the main document for gross pay and insurance income for a period chosen by the person.

The numerical thresholds for minimum and maximum insurance income are set every year by the State Social Security Budget Act (ЗБДОО) and change each year. For current values always check the ЗБДОО in force for the relevant year, not secondary sources, which often go out of date.

Administrative practice and disputes over pension rights

The НПОС is a heavily applied ordinance and gives rise to a considerable volume of administrative disputes. Review of NSSI orders follows a typical multi-instance logic that the practitioner must know.

Typical disputed situations concentrate around proof. Among them are establishing insurance record where payrolls and receipts have been erased or not preserved, determining the category of labour and recognising a specific insurance income. In all these cases the evidentiary value of УП-2 and УП-3, and their correctness, are decisive.

Practical guidance for lawyers and payroll specialists

Good knowledge of the ordinance saves time for both the consultant and the client. The following checklist summarises the most common factors that speed up or slow down the procedure.

For related material see our professional analysis of the Ordinance on Medical Expertise (ТЕЛК/НЕЛК), as well as the practical guides to the retirement table by ЕГН, the amount of a pension with 15 years of insurance record and the NSSI check with ЕГН and ПИК.