Transposition of the EU pay transparency directive into Bulgarian legislation
On 19 May 2026, the Ministry of Labour and Social Policy published for public consultation a draft law amending and supplementing the Protection Against Discrimination Act. The proposed amendments aim to transpose the requirements of Directive (EU) 2023/970 on pay transparency into Bulgarian legislation. The public consultation period is open until 2 June 2026, after which the draft is expected to be submitted to the National Assembly for consideration.
Key proposed amendments
The draft legislation provides for:
- job advertisements to include information on the amount or range of the basic salary, as well as any permanent additional remuneration;
- employers to be prohibited from requesting information about applicants’ previous remuneration;
- the determination and increase of remuneration to be based on objective criteria applied equally to all employees;
- employees to have the right to access information regarding average remuneration levels by gender for employees performing the same work or work of equal value;
- the abolition of confidentiality clauses relating to the amount of remuneration;
- employers with more than 100 employees to be subject to reporting obligations regarding equal pay between women and men.
The reports must include information on gender pay gaps, including differences in both basic and additional remuneration, as well as data broken down by employee categories. Where an unjustified pay gap exceeding 5% is identified, the employer will be required to take measures to eliminate the gap within the statutory time limits.
Recommended actions for employers
In view of the forthcoming legislative amendments, it is recommended that companies:
- review and update their HR and recruitment policies and procedures;
- align their internal mechanisms for setting and increasing remuneration with the new requirements;
- carry out an internal risk assessment regarding potential pay disparities;
- prepare the necessary information and internal processes for future reporting obligations.