In Bulgaria, the engagement of third-country nationals (non-EU citizens) through civil contracts is permitted—but only under strict conditions. Employers must understand the legal boundaries under Bulgarian labour migration law to avoid missteps. This article outlines the key rules, risks, and compliance essentials when considering civil contracts with foreign nationals.
Legal Insights
The employment of third-country nationals is regulated by the Law on Labour Migration and Labour Mobility (LLMLM) and the Law on Foreigners in the Republic of Bulgaria (LFRB). A valid work permit is typically required unless the individual falls under exempt categories (e.g. EU Blue Card holders or refugees).
Civil contracts, governed by the Law on Obligations and Contracts (LOC), are designed for independent tasks—not traditional employment. They exclude features like fixed hours, a defined workplace, or supervision.
Labour inspectors can reclassify a civil contract as an employment contract if it mirrors employment in practice—resulting in penalties.
Key points for employers:
- Only individuals with valid work permits may work under civil contracts;
- Civil contracts cannot be used to mask actual employment;
- Employment without a permit—under any contract type—is illegal.
Eurofast's Take – action points and impact for your clients
To stay compliant, employers in Bulgaria should:
- Confirm the work authorisation status of third-country nationals;
- Avoid using civil contracts to bypass employment rules;
- Consult with experts to mitigate legal exposure.
Eurofast supports companies with tailored labour migration guidance and EOR solutions in Bulgaria and across the region.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
