Bulgaria's Ministry of Labor and Social Policy has published a draft Law on amendments and supplements to the Protection Against Discrimination Act (PADA) to transpose EU Pay Transparency Directive 2023/970. The transposition would amend several laws, most notably the PADA and the Labor Code. The draft law was submitted for public consultation on May 19, 2026, which is planned to conclude on June 18, 2026. This is later than the directive’s June 7, 2026 transposition deadline, and the date the amended law will enter into force (once approved) is currently unknown. (The deadlines noted below are subject to change, as they reflect those in the draft law, which were initially based on a June 7, 2026 effective date.)
Key provisions
From an employer’s perspective, key changes in the draft law include:
- All employers would be required to establish and apply objective criteria for determining and increasing remuneration. The criteria include job complexity, burden, responsibilities and working conditions in accordance with the adopted standards for the quantity and quality of the work and the duration of the work performed. Gender-neutral job grading would be required unless gender-based differences can be objectively justified
- Employers would be required to 1) disclose base salary (or salary range) as well as any other remuneration of a permanent nature for the role in job advertisements or before any interviews, 2) use gender-neutral job titles, 3) refrain from requesting candidates' prior salary history, and 4) disclose any applicable collective agreement pay conditions
- Companies with 150 or more employees would be subject to mandatory pay gap reporting by June 7, 2027 (every three years for companies with 150 to 249 employees; annually for larger employers). The mandate would expand to include companies with 100 to 149 employees by June 7, 2031 (required every three years). Smaller employers would be exempt
- Pay gap results would have to be submitted to employees and their representatives (requests for additional information could be made within one month of initial receipt) as well as the Commission for Protection against Discrimination. Workers, trade unions, the labor inspectorate and the Commission for Protection against Discrimination have the right to request additional information related to the gender pay gap results, which the employer would need to provide within one month after the request. Where results show a pay gap of at least 5% for any category of workers, employers would have to submit formal justification to the Commission for Protection against Discrimination. If the differences cannot be justified, employers would have six months to implement corrective measures developed jointly with employee representatives or labor unions. Corrective measures would need to be implemented within one year after consultation with workers’ representatives, employees and/or trade union organizations
- Under PADA, employers would be required to provide an employee's pay and the average pay for employees performing same or equivalent work, broken down by gender, within two months of a written request. If information is deemed inaccurate or incomplete, employees can request follow-up information or explanations, and the employer is obliged to provide a written response within 14 days. Employers would be required to notify employees annually of their right to request average pay level information (by January 31 each year). When provision may lead to disclosure of an individual's pay level, the employer has the right to restrict access to the information by providing it to the trade union organization or the Commission for Protection against Discrimination at their request
- Under the Labor Code, employees can also make requests for average pay level information for employees at the same job level (without breakdown by gender). This information would need to be provided within 14 days of the request, as would any follow-up questions (unless requests are made more than once a year)
Employers should monitor the final approval of the draft law, including when its mandates take effect. In the meantime, companies should begin reviewing pay criteria, recruitment practices and pay gap data infrastructure. Women's average gross hourly earnings in Bulgaria were 12.0% below men's in 2024, a larger gap than the EU average of 11.1% (Eurostat).
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