EU Pay Transparency Directive Status Bulgaria: Draft Published, Deadline Missed
Bulgaria published a draft transposition of Directive 2023/970 on 19 May 2026, proposing to implement it through targeted amendments to the Protection Against Discrimination Act and the Labour Code rather than a standalone statute. The draft nominally listed 7 June 2026 as its intended entry into force, but public consultation on the draft was still open past that date, originally scheduled to close 2 June 2026 and then extended to 18 June 2026, meaning Bulgaria effectively acknowledged it would miss the EU deadline before it even arrived. As of early August 2026, the draft remains in a post-consultation review stage, still needing sign-off from the responsible ministry, approval by the Council of Ministers, two readings and a vote in the National Assembly, and presidential signature and publication in the State Gazette before it takes legal effect; no enacted date has been set. The draft's proposed obligations, including specific reporting thresholds and a 5% unjustified pay gap trigger for corrective action, are consistent with the Directive's own default framework, but none of this is binding Bulgarian law until the legislative process concludes.
What is Pay Transparency, and who does it apply to?
The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law requiring pay equity for equal work between women and men. It introduces mandatory rules around salary disclosure, pay gap reporting, and worker rights.
Bulgaria's existing protection against pay discrimination comes from the Labour Code together with the Protection Against Discrimination Act of 2003, in force since 2004 and enforced by the Commission for Protection Against Discrimination, but Bulgaria has never had a standalone gender pay gap reporting requirement for private employers. Bulgaria also had to transpose the EU Pay Transparency Directive by 7 June 2026, a deadline it missed, though unlike some member states it has at least published a concrete draft law.
Bulgaria currently has no gender pay gap reporting threshold at all for private employers; under the draft transposition, reporting obligations would apply first to Bulgarian employers with 150 or more employees from 2027 and then to those with 100 to 149 employees from 2031, while pay information and salary history rules would apply to all employers regardless of size once enacted.
What employers must do in Bulgaria
All employers (current law)
- Comply with the general equal pay principle under the Labour Code and the Protection Against Discrimination Act
- No obligation exists today to publish or report gender pay gap data
Proposed under the draft transposition, not yet in force
- Respond to employee requests for pay information within two months, and to clarification requests within 14 days
- Refrain from asking candidates about salary history and disclose starting pay information
- Employers with 150 or more employees would submit an initial gender pay gap report by 7 June 2027, then report periodically
- Employers with 100 to 149 employees would submit an initial report by 7 June 2031
- Justify in writing to the Commission for Protection Against Discrimination any unjustified pay gap of 5% or more, and run a joint pay assessment with worker representatives if it persists after six months
Key deadlines
Penalties for non-compliance in Bulgaria
Under the current Protection Against Discrimination Act, fines for discrimination, including pay discrimination, generally range from roughly 250 to 2,000 euro for the employing entity and up to about 2,500 euro for a manager who allows a breach, figures that were redenominated from Bulgarian lev into euro alongside Bulgaria's 2026 currency changeover and increased somewhat in the process. The pending pay transparency draft would need to add its own specific, dissuasive penalty scale, which has not yet been published in detail.
The Commission for Protection Against Discrimination, Bulgaria's national equality body, investigates complaints and can issue binding decisions and administrative fines.
How TalentUp can help you with Pay Transparency Compliance
Below you can see a preview of our platform, where we help you stay compliant with Pay Transparency by spotting pay inconsistencies and structural risks in your compensation strategy, analysing data from your company.
Book a demo| Name | Level | Location | Salary | Labels | Actions |
|---|---|---|---|---|---|
|
John Doe
Software Developer
|
Mid
|
Sofia
Bulgaria
|
32500 EUR
Above market
|
Unbalanced
|
|
|
Jane Smith
Project Manager
|
Senior
|
Sofia
Bulgaria
|
45000 EUR
Above market
|
In Market
|
|
|
Michael Brown
Data Analyst
|
Mid
|
Plovdiv
Bulgaria
|
39000 EUR
Above market
|
In Market
|
|
|
Emily Johnson
QA Engineer
|
Mid
|
Plovdiv
Bulgaria
|
36000 EUR
Above market
|
In Market
|
|
|
Robert Wilson
HR Manager
|
Senior
|
Varna
Bulgaria
|
50000 EUR
Above market
|
Above Market
|
|
|
Sarah Davis
Marketing Specialist
|
Junior
|
Varna
Bulgaria
|
34000 EUR
In market
|
In Market
|
MEAN PAY
39.4K EUR
MEDIAN PAY
37.5K EUR
MEAN FEMALE PAY
38.3K EUR
MEDIAN FEMALE PAY
36K EUR
MEAN MALE PAY
40.5K EUR
MEDIAN MALE PAY
39K EUR
Gender gap
Variable pay by gender
General gender pay gap
Pay gap insights
Add employee data to see pay gap insights
Tenure distribution
Pay gap per level (quartiles)
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Frequently asked questions about pay transparency in Bulgaria
Yes. Bulgaria was due to transpose the Directive by 7 June 2026, but its own draft law was still in public consultation past that date, so Bulgaria missed the deadline without an enacted law.