Employment books in Bulgaria 2026: § 24 finalising rules
How employers finalise paper employment books under § 24 of the ЗИД на КТ by 1 June 2026: procedure, columns 7 and 8, unclaimed books, penalties.
From 1 June 2025 Bulgaria moved to the Employment Register (Регистър на заетостта) and the unified electronic employment record (единен електронен трудов запис). With § 24 of the Transitional and Final Provisions (ПЗР) of the Act Amending and Supplementing the Labour Code (ЗИД на КТ, State Gazette No. 85 of 2023), the legislator gave employers a one-year period to finalise the paper employment record books (трудови книжки). The period expires on 1 June 2026, that is, in a matter of days, and in practice some questions remain open: are columns 7 and 8 filled in, is a stamp applied, what is done with unclaimed books and what is the penalty for doing nothing.
This analysis brings together the exact text of the law, the competent position of the Ministry of Labour and Social Policy (МТСП) and the scholarly view on the storage of employment record books into one practical guide for lawyers, payroll specialists (ТРЗ) and HR officers.
❓What does § 24 of the ЗИД на КТ require from employers?
Source: ЗИД на КТ, § 24(1) of the Transitional and Final Provisions (State Gazette No. 85 of 2023)
What § 24 of the Transitional and Final Provisions of the ЗИД на КТ says
The provision provides for a one-off technical closing of the paper employment record books in connection with the move to the electronic employment record. The basis for finalising the book is § 24 itself, not the termination of the employment relationship, which matters directly for how it is filled in (see the section on columns 7 and 8 below).
Transitional and Final Provisions of the Act Amending the Labour Code (State Gazette No. 85 of 2023)
§ 24(1)
Official Bulgarian text
„В срок до 1 юни 2026 г. или при прекратяване на трудовото правоотношение в периода от 1 юни 2025 г. до 1 юни 2026 г. работодателите оформят трудовите книжки, като с цифри и думи се записва продължителността на трудовия стаж към 1 юни 2025 г., подписва се от главния счетоводител и от работодателя, като се подпечатва с печата му, ако разполага с такъв. След оформянето й трудовата книжка се връща незабавно на работника или служителя.“
Two scenarios as to the due date exist side by side. While the relationship continues, the final deadline is 1 June 2026. If it is terminated in the period from 1 June 2025 to 1 June 2026, the book is finalised at the time of termination. In both cases the book records the length of service (трудов стаж) as at the reference date of 1 June 2025, because after that date length of service is kept electronically in the Employment Register.
Context: the move to the Employment Register
The legal framework of the Employment Register was introduced by the Ordinance on Entry in the Employment Register, adopted by Council of Ministers Decree No. 267 of 29 July 2024 (promulgated in State Gazette No. 65 of 2024). The ordinance enters into force in stages: from 1 June 2025 for employment relationships and from 1 June 2026 for service relationships under the Civil Servants Act (Закона за държавния служител).
Ordinance on Entry in the Employment Register (Council of Ministers Decree No. 267 of 29 July 2024)
Final Provisions
Official Bulgarian text
„Наредбата влиза в сила от 1 юни 2025 г. за трудовите правоотношения и от 1 юни 2026 г. за служебните правоотношения по Закона за държавния служител.“
With the same amendment (State Gazette No. 65 of 2024, in force from 1 June 2025), Section I “Employment Book” (Раздел I „Трудова книжка“) of the previous ordinance was dropped, and the ordinance itself was renamed the “Ordinance on Length of Service” (Наредба за трудовия стаж). This is important for citing correctly in practice: the ordinance in force is no longer called the Ordinance on the Employment Book and Length of Service (НТКТС). The paper employment record book, however, does not lose its significance for the circumstances already entered in it, as § 22 of the Transitional and Final Provisions shows.
Transitional and Final Provisions of the Act Amending the Labour Code (State Gazette No. 85 of 2023)
§ 22
Official Bulgarian text
„Трудовата книжка, издадена преди влизането в сила на този закон, е официален удостоверителен документ за вписаните в нея обстоятелства, свързани с трудовата дейност на работника или служителя.“
| Criterion | Paper employment record book | Electronic employment record |
|---|---|---|
| Who keeps the record | The employer (until 1 June 2025) | The Employment Register (НАП/НОИ) |
| Period covered | Length of service up to 1 June 2025 | Length of service from 1 June 2025 onwards |
| Evidentiary force | Kept for the circumstances entered in it (§ 22) | Official electronic record |
| Access | A physical document held by the employee | Electronically, through the register |
| Effect after the move | Finalised once under § 24 | Updated on an ongoing basis by the insurer (осигурител, the employer who pays the insurance contributions) |
Paper employment record book compared with the electronic employment record after 1 June 2025
The finalising procedure step by step
Finalising under § 24 is a relatively simple technical act, but it requires precision, because the book remains an official certifying document. The following steps should be observed.
Finalising a paper employment record book under § 24
Calculating the length of service
Determine the length of service with the employer as at the reference date of 1 June 2025.
Entry in figures and in words
Enter the length of service both in figures and in words in the relevant field of the book.
Signatures
The book is signed by the chief accountant and by the employer.
Stamp
It is stamped with the employer’s stamp, if the employer has one.
Returning it to the employee
After finalising, the book is returned immediately to the employee against a signature.
1 June 2026
Final deadline for finalising the paper employment record books under § 24(1) for ongoing employment relationships.
If the relationship is terminated before this date, the book is finalised at the time of termination.
Ask Pravko and get an answer with citations from the law.
Columns 7 and 8: the position of the МТСП
The most common practical question when finalising is whether columns 7 and 8 of the employment record book are filled in, that is, the field for the ground and date of termination of the employment contract. The Ministry of Labour and Social Policy gives a clear answer in its Questions and Answers.
Columns 7 and 8 are not filled in
❓Are stamps affixed when finalising under § 24?
Source: ЗИД на КТ, § 24(1) of the Transitional and Final Provisions
A lost or destroyed employment record book after 1 June 2025
The legislator has also provided for the case of a lost or destroyed book after the reference date. The competent authority is the Labour Inspectorate directorate (дирекция „Инспекция по труда“), and the new book records only the data on length of service acquired before 1 June 2025.
Transitional and Final Provisions of the Act Amending the Labour Code (State Gazette No. 85 of 2023)
§ 24(2)
Official Bulgarian text
„Когато след 1 юни 2025 г. трудовата книжка е изгубена или унищожена, съответната дирекция „Инспекция по труда“ издава нова и вписва данни за трудовия стаж, придобит преди 1 юни 2025 г., въз основа на писмено заявление-декларация на работника или служителя, към което се прилагат удостоверения от работодателите.“
Issuing a new employment record book when one is lost or destroyed
Application-declaration
The employee submits a written application-declaration to the Labour Inspectorate directorate (дирекция „Инспекция по труда“).
Certificates from the employers
Certificates of length of service from previous employers are attached to the application.
Issuing the new book
The Labour Inspectorate directorate issues a new book and enters only length of service acquired before 1 June 2025.
The obligation to keep unclaimed employment record books
Because under § 22 of the Transitional and Final Provisions the paper book remains an official certifying document, books not claimed by employees cannot be destroyed. This is also the dominant scholarly position, expressed by Assoc. Prof. Dr Andrey Alexandrov (Institute of State and Law, ИДП-БАН) in the journal “Труд и право” (Labour and Law). The logic is tied to protecting people’s insurance rights in the long term.
Social Insurance Code (КСО)
Art. 5(10)
Official Bulgarian text
„При прекратяване на дейността на осигурителите, които нямат правоприемник, документите по ал. 7, т. 1, както и неполучените от осигурените лица трудови книжки се предават в съответното териториално поделение на Националния осигурителен институт.“
The reference to Art. 5(7), item 1 КСО sets the 50-year storage period for payroll sheets, employment contracts and related documents. The chain from Art. 5(7), item 1 (the storage obligation) to paragraph 10 (handing over to the territorial office, ТП, of the National Social Security Institute (НОИ) where there is no successor) outlines the lasting regime for documents certifying length of service and insurance record.
Do not destroy unclaimed books
Penalties and a practical checklist for the employer
The Labour Code has no special administrative-penal offence for violations concerning the employment record book. The general (residual) offence under Art. 414(1) КТ applies, which currently provides the following amounts.
Labour Code (КТ)
Art. 414(1)
Official Bulgarian text
„...се наказва с имуществена санкция или глоба в размер от 1500 до 15 000 лв., а виновното длъжностно лице, ако не подлежи на по-тежко наказание - с глоба в размер от 1000 до 10 000 лв.“
BGN 1,500 to 15,000
Property sanction for the employer under Art. 414(1) КТ (responsible official: BGN 1,000 to 10,000)
Source: Art. 414(1) КТ
The amounts of BGN 1,500 to 15,000 for the employer and BGN 1,000 to 10,000 for the responsible official are the current values. Some payroll (ТРЗ) materials still contain outdated figures (for example BGN 10,000 to 15,000), which do not match the wording in force and should not be used.
Employer’s checklist until 1 June 2026
Practical steps to comply with § 24 of the ЗИД на КТ.
The length of service of each employee as at 1 June 2025 has been calculated*
The length of service is entered in the book in figures and in words*
The signatures of the chief accountant and the employer have been added*
A stamp has been applied, if the employer has one
Columns 7 and 8 (ground and date of termination) have NOT been filled in*
The ground is § 24, not termination of the relationship.
The book has been returned to the employee immediately against a signature*
Unclaimed books are kept, not destroyed*
* Mandatory documents
Common mistakes in practice
The move to the electronic employment record changes how length of service is certified, but it does not remove the importance of a properly finalised paper book for the period up to 1 June 2025. For related topics see our article on the electronic employment record book and on the employment contract check by ЕГН.
Pravko provides legal information but does not replace consultation with a lawyer. For important legal matters, consult a licensed lawyer.
⚠️ Important
Pravko provides legal information, but it does not replace advice from a lawyer. For important legal matters, consult a licensed lawyer.
