EU Pay Transparency Directive in Bulgaria: what will change by 2026

To start a company in Bulgaria today requires not only managing tax and administrative aspects, but also paying increasing attention to governance and regulatory compliance. Among these, the EU Pay Transparency Directive in Bulgaria (2023/970) plays a central role, introducing new obligations for employers regarding pay equity and gender pay gap reporting.

Bulgaria is required to transpose the directive by 7 June 2026. However, as of March 2026, no national implementing legislation has yet been adopted. This means that the obligations are not yet in force, but companies are strongly encouraged to prepare in advance.

EU Pay Transparency Directive in Bulgaria: Current legal framework and implementation status 

The Bulgarian legal system already ensures the principle of equal pay through provisions such as Article 243 of the Labour Code and Article 14 of the Anti-Discrimination Act. However, these rules are mainly reactive, applying after discrimination claims are raised.

Currently, there are no:

• structured gender pay gap reporting obligations
  
• salary transparency requirements during recruitment
  
• formal employee rights to access comparative salary data
  
• automatic thresholds triggering mandatory internal reviews
  

The EU directive introduces a more structured and proactive system.

As of now:

• no official measures have been notified in EUR-Lex
  
• no implementing law has been published
  
• a governmental working group has been established
  
• no draft law is publicly available

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Key obligations under EU Pay Transparency Directive in Bulgaria

The directive introduces a system based on transparency, accountability and control.

During recruitment, employers will be required to disclose salary levels or ranges before the interview and will be prohibited from asking candidates about their salary history.

Employees will have the right to request information on their pay and compare it with colleagues performing equivalent work, broken down by gender. Employers must respond within two months.

Reporting obligations depend on company size:

• 250+ employees → annual reporting
  
• 100–249 employees → reporting every three years
  

The first reports are expected from 2027 (based on 2026 data).

Reports must include:

• average and median gender pay gap
  
• gender distribution across pay levels
  
• access to bonuses and variable pay
  
• disparities in additional remuneration
  

If an unjustified pay gap of at least 5% persists for six months, companies must conduct a joint assessment with employee representatives and implement corrective measures.

The directive also strengthens sanctions and shifts the burden of proof to the employer.

EU Pay Transparency Directive in Bulgaria: which companies are affected

A key distinction must be made between transparency and reporting obligations.

Transparency rules (salary disclosure, employee rights) apply to all employers, regardless of size.

Reporting obligations apply only to companies with more than 100 employees. However, national law may extend these requirements further.

How to prepare for the new rules

Even before formal transposition, early preparation is a strategic choice.

Companies should review compensation policies, ensuring objective and documented criteria. Bonus systems and variable pay require particular attention.

Payroll systems must be adapted to generate gender-based analytics, including averages and medians. Job classification systems must be consistent.

Recruitment processes must also be updated, including salary disclosure in job postings.

Internal risk assessments are essential to identify unjustified pay gaps and document the reasons behind salary differences.

Pay transparency is increasingly part of ESG frameworks and corporate governance practices, representing both a compliance requirement and a competitive advantage.

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Impact on multinational groups

For companies operating across multiple EU countries, implementation may vary significantly between jurisdictions.

This creates differences in timelines, enforcement mechanisms and penalties. Multinational companies must therefore adopt a coordinated approach across markets.

Directive (EU) 2023/970 represents a major shift in the European regulatory landscape, introducing a structured approach to pay transparency and corporate accountability.

Although Bulgaria has not yet completed its implementation, companies — especially those with more than 100 employees — should begin preparing now.

Accountancy Bulgaria, Tax Advisor in Bulgaria, supports companies in adapting to regulatory changes, reviewing compensation policies and ensuring full compliance with EU requirements.