Bulgaria Pay Transparency Law: EUPTD Transposition Status
Local term: прозрачност на заплащането
As of 28 September 2026: Bulgaria has a transposition bill before the National Assembly. The Council of Ministers submitted it in September 2026 after a public consultation that closed on 18 June 2026.
Status snapshot
| Status | Draft published |
|---|---|
| National instrument | Bill amending the Protection Against Discrimination Act and the Labour Code. |
| Official source | Draft law on the public consultation portal (strategy.bg) |
Pay gap reporting required before the Directive
No national gender pay gap reporting obligation before the Directive.
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
| Employees | First report | Frequency |
|---|---|---|
| 250+ | 7 June 2027 (2026 data) | Annually |
| 150–249 | 7 June 2027 (2026 data) | Every three years |
| 100–149 | 7 June 2031 (2030 data) | Every three years |
| Under 100 | No obligation | Voluntary |
As set out in the draft bill. The employee's right to request pay information, and other general duties such as the pay secrecy ban, are dated from 7 June 2026. That date has already passed, so there is the potential that employees get these rights immediately once the bill is enacted, rather than from a future date. The reporting duty above is separate and later: first reports would be due by 7 June 2027 for employers with 150 or more employees, and by 7 June 2031 for those with 100 to 149.
What remains unclear
Information is unclear on sanctions, on the anonymity threshold for small worker categories, and on the methodology for job evaluation. The draft's 2-month deadline to answer employee pay information requests also conflicts with an existing 14-day deadline under the Labour Code. These points were raised in the public consultation and may change before the bill is enacted.
Things to work on now
- Priority for Bulgaria. The general duties (including the employee right to request pay information) are dated from 7 June 2026, which has already passed. There is the potential that employees get that right immediately once the bill is enacted, rather than after a lead-in period, so be ready before it passes, not after.
- Priority for Bulgaria. The draft gives employers one year to remedy confirmed unjustified pay differences and involves the equality body in joint assessments. Plan remediation budgets accordingly.
- Map the draft. Compare the published draft with your current practice and note where it goes further than the Directive.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.
- Pay ranges. Agree pay ranges for roles so you are ready for pre-employment disclosure (Article 5).
- Shadow reporting. Run a trial gender pay gap calculation on 2026 data using the Directive's Article 9 indicators, including by category of workers.
- Remediation budget. Model the cost of closing unexplained gaps of 5% or more, which would trigger a joint pay assessment (Article 10).
Legislative timeline
- 19 May 2026Draft published for public consultation
- 18 June 2026Consultation closes
- September 2026Government submits the bill to the National Assembly
Frequently asked questions
Has Bulgaria transposed the EU Pay Transparency Directive?
Bulgaria has a transposition bill before the National Assembly. The Council of Ministers submitted it in September 2026 after a public consultation that closed on 18 June 2026.
When does gender pay gap reporting start in Bulgaria?
Under Bulgaria's law, Directive (Article 9) reporting, including gaps by category of workers, applies as follows: employers with 250+ employees: 7 June 2027 (2026 data); employers with 150–249 employees: 7 June 2027 (2026 data); employers with 100–149 employees: 7 June 2031 (2030 data).
What should employers in Bulgaria do now?
The general duties (including the employee right to request pay information) are dated from 7 June 2026, which has already passed. There is the potential that employees get that right immediately once the bill is enacted, rather than after a lead-in period, so be ready before it passes, not after. The draft gives employers one year to remedy confirmed unjustified pay differences and involves the equality body in joint assessments. Plan remediation budgets accordingly. Compare the published draft with your current practice and note where it goes further than the Directive.