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Bulgaria Single Permit 2026: New Employer Rules, Not Law Yet

Yordan Cholakov Oct 16, 2026 13 min read

If you hold a Bulgarian single permit and plan to switch jobs under the new rules, wait: they are not law yet, and under the Foreigners in the Republic of Bulgaria Act (the Foreigners Act) as in force today, your right of residence ends on the date your employment ends. Bulgaria single permit 2026 coverage often blurs three layers: what EU Directive 2024/1233 requires, what Bulgaria's pending bill proposes, and what the law says today. Member States had until 21 May 2026 to transpose the directive. As of 16 October 2026, Bulgaria has not finished. The government bill that would let single permit holders change employer, and keep their status through a short spell of unemployment, sits between first and second reading in the National Assembly.

This guide is for non-EU workers who hold, or want, a Bulgarian single permit for residence and work, and for employers planning to hire them. We take the three layers one at a time, so you can see which rules you can rely on now and which ones to plan for. Each point is sourced to the directive on EUR-Lex, the European Parliament's procedure summary, the bill and its explanatory memorandum on parliament.bg, the State Gazette, or the government's public consultation portal (strategy.bg). Where we could not confirm a point, we say so rather than fill the gap.

Status as of 16 October 2026: Bill No. 52-602-01-29, which amends the Foreigners Act, passed first reading on 16 September 2026. The parliamentary record shows no second-reading vote and no publication in the State Gazette. Everything this article attributes to "the bill" is a proposal, not law in force.

90 days
Directive: maximum decision time on a complete application
6 months
Bill: minimum with the first employer before a switch
3 / 6 months
Directive and bill (not in force): unemployment tolerated 3 months, 6 after 2+ years as holder
21 May 2026
EU transposition deadline, now passed
Today
Foreigners Act in force: the residence right ends when the job ends (Art. 24i(19))

Where the reform stands as of October 2026

The EU directive is final and binding on Bulgaria. The Bulgarian text that implements it is not. The timeline below comes from EUR-Lex, from the bill record on parliament.bg and from the government's public consultation portal (strategy.bg).

DateStep
24 Apr 2024Directive (EU) 2024/1233 adopted as a recast of Directive 2011/98/EU, then published in the Official Journal on 30 April 2024
21 May 2026Deadline for Member States to bring national law into line (Art. 18(1))
22 May 2026Old Directive 2011/98/EU repealed (Art. 19)
1 Apr โ€“ 4 May 2026Ministry of Interior public consultation on the draft amendments, held on the government's consultation portal
28 Jul 2026Council of Ministers files bill No. 52-602-01-29 in the National Assembly
16 Sep 2026Bill passed at first reading in plenary
17โ€“23 Sep 2026MPs file proposals for second reading (per the parliament.bg record)
2 Oct 2026Internal Security and Public Order Committee: draft report for second reading (per the parliament.bg record)
16 Oct 2026No second-reading vote and no State Gazette publication on record

In practice, the Migration Directorate of the Ministry of Interior keeps applying the Foreigners Act as it stands until the amending act is adopted, promulgated and in force. MPs have filed second-reading amendments, so the final wording may differ from the government text described below. We also found no transitional provisions in the bill text we reviewed, meaning nothing yet says how the new rules would treat permits already issued or applications already filed. Watch the final text for both points.

Not sure how this applies to your permit or your hiring plan? Book an initial consultation to discuss your permit or hiring plan.

What Single Permit Directive 2024/1233 requires from Bulgaria

The 2024 directive replaces the 2011 one. It keeps the basic design, where one application leads to one decision that serves as both residence permit and work permit. On top of that, it adds rights that make the worker less dependent on a single employer. According to the European Parliament's procedure summary, the aim is to attract the skills the EU needs and fix gaps in legal migration.

A 90-day decision deadline

The competent authority must decide "in any event within 90 days of the date of submission of a complete application" (Art. 5(2)). In exceptional, duly justified cases linked to the complexity of the application, that limit can be extended by 30 days (Art. 8(3)). The Parliament's summary adds that where a labour-market check is carried out for the individual application, it falls inside those 90 days. If the file is incomplete, the authority must tell the applicant in writing what is missing, and it may reject the application if the documents do not arrive by the deadline it sets (Art. 5(4)).

Directive: a right to change employer, with three optional conditions

The core sentence of the directive is short: "Member States shall allow a single permit holder to change employer" (Art. 11(2)). In Bulgaria this is not yet law; see What applies today. Each State may attach any of three conditions (Art. 11(3)):

Even inside that minimum period, States must allow a change in duly justified cases of a serious breach by the employer of the terms of the employment relationship.

Directive: unemployment is no longer an automatic ground for withdrawal

Under the directive, unemployment on its own is not a ground for withdrawing the permit, provided the total period of unemployment does not exceed three months during the permit's validity. In Bulgaria this is not yet law; see What applies today. The limit is six months where the worker has held a single permit for more than two years (Art. 11(4)). The start and end of any unemployment must be notified, and each State decides whether the worker or the employer does this. For periods longer than three months, States may ask for evidence of sufficient resources. Where there are reasonable grounds to believe the worker faced particularly exploitative working conditions, the directive adds three months to the permitted period (Art. 11(6)).

Other points that matter in practice

Fact vs our assessment: The transposition deadline passed on 21 May 2026, which is a fact. Whether a worker can rely directly on a particular provision of the directive against the Bulgarian authorities in the meantime is a legal question. The answer depends on the provision and the facts, so we assess it case by case and do not treat it as automatic.

What Bill No. 52-602-01-29 proposes for Bulgaria's single permit

The government bill rewrites much of Article 24i of the Foreigners Act, the article that governs the single permit for residence and work. Its explanatory memorandum says it transposes Directive 2024/1233 (it also covers EU border screening rules, which we leave aside here). Below is what the text filed on 28 July 2026 says. Read every "would" literally: second reading can still change it.

Changing employer after six months (proposed)

A single permit holder could change employer while the permit is valid, after working at least six months for the first employer. That is the longest minimum period the directive allows. An earlier change would be possible where the General Labour Inspectorate Executive Agency (the Labour Inspectorate) holds data on established breaches of labour legislation by the first employer during the worker's employment, and has passed that data to the Migration Directorate on request.

On procedure, the new employer, a person it authorises, or the worker would file an application for change of employer in person. The filing would go to the Migration Directorate or to a Migration unit at a regional directorate of the Ministry of Interior. It would include a defined subset of the documents required for a first application, and the review steps that apply to first applications would apply here as well.

Changing position with the same employer (proposed)

A separate rule would let the worker move to a different position with the same employer during the permit's validity, after at least six months in the current position. The application route and the document set would mirror the change-of-employer procedure.

A 90-day procedure, extendable by 30 days (proposed)

The bill would replace the current wording of Article 24i(18) with a procedure conducted within 90 days of the date the application is filed. Where the case is factually and legally complex, the period could exceptionally be extended by 30 days. The two texts count from different points: the directive runs from submission of a complete application, the bill from filing. Either way, the clock helps most when the file is complete on day one.

Unemployment: 3 or 6 months, with short notice deadlines (proposed)

The director of the Migration Directorate, or an authorised official, could not withdraw the permit because of unemployment as long as the total unemployment within the document's validity stays at or below three months. The limit would be six months for someone who has held a single permit for more than two years. If the bill is adopted as filed, the protection would come with tight duties:

  1. The worker would have to register with the Employment Agency within 7 working days after the employment ends.
  2. The worker would then have to notify the Migration Directorate (or the regional Migration unit) within 3 days of registering.

The explanatory memorandum adds that the permit can be withdrawn if an unemployed worker registered with the Employment Agency fails to notify the Migration Directorate in time. Two further rules help the worker. First, where a competent authority has established that the worker was subjected to particularly exploitative working conditions, the permitted unemployment period would be extended (the bill's wording is "up to three months"). Second, a worker who starts with a new employer within the permitted period could stay in Bulgaria until the new permit is issued or refused, even if that period runs out in the meantime.

Other changes employers will notice

Directive vs bill vs the law today

IssueDirective 2024/1233Bill 52-602-01-29 (proposed)Foreigners Act on 16 Oct 2026
Decision time90 days from a complete application; +30 days in exceptional, complex cases90 days from filing; +30 days for factual and legal complexityArt. 24i(18) does not set a 90-day period; the bill would replace its current wording
Change of employerMust be allowed; optional notification, labour-market check, and a first-employer minimum of up to 6 monthsAfter 6 months; earlier where the Labour Inspectorate holds data on breaches; application to the Migration DirectorateNo change-of-employer paragraph for single permit holders; the residence right ends when the employment ends (Art. 24i(19))
UnemploymentUp to 3 months in total (6 after 2+ years) is not a ground for withdrawalSame 3/6 months; register within 7 working days, notify Migration within 3 daysThe residence right ends on the date the employment ends
Exploitation+3 months of permitted unemploymentExtension where a competent authority has established particularly exploitative conditionsWould be a new rule added by the bill
Applying from insideAllowed for people who already hold a residence permitFirst-time applicants without a right of residence must be abroad, save for listed casesWould be a new sentence added by the bill

Hiring, or Switching Jobs, While the Rules Change?

Tell us whether you are the employer or the worker and where the permit stands. We'll map which steps apply today and which change if the bill is adopted. Regulated Bulgarian law firm.

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What applies today, before the law changes

Until the amendments take effect, the Foreigners Act as last amended governs. A second sentence added to Article 24i(19) by the amending act published in State Gazette No. 52 of 27 June 2025 provides that the right of residence ends on the date the employment relationship ends. The current Article 24i(18) does not set the 90-day decision period discussed above; that period comes from the directive and the bill. The paragraphs on changing employer, changing position and permitted unemployment are new paragraphs the bill would create, so none of them is in the Foreigners Act as of 16 October 2026.

Do not act on the bill yet. A worker who resigns after six months expecting the new procedure could find that it does not exist yet. Until the State Gazette publishes the final act and it enters into force, plan on the basis of the current text.

That's the legal map. Not sure which rules apply to you? Book a free consultation.

Bulgaria work permit processing time: what the proposed 90 days does and does not mean

Under Directive 2024/1233 and the pending bill, 90 days is the maximum decision time; the Foreigners Act in force on 16 October 2026 still applies the current wording of Art. 24i(18). Once the new rules apply, the 90 days is a ceiling, not an estimate of the usual time, and nobody can lawfully promise a faster result. Three practical points follow:

Applying for a Bulgarian single permit in 2026 under current law

Until the bill is in force, a new application follows the Foreigners Act as it stands, not the proposed rules described above. For the permit types and fees under the current regime, see our main-site guide to work permits in Bulgaria, which covers the basics. This article is limited to the reform.

Changing employer on a Bulgarian single permit: a checklist for workers

  1. Note two dates: your permit's expiry date and the day you started with your first employer. Under the bill, the six-month count runs from your work for the first employer.
  2. Do not resign on the strength of the bill. Under the Foreigners Act in force on 16 October 2026, the residence right ends with the employment.
  3. If the bill passes as filed and your job ends, register with the Employment Agency within 7 working days, then notify the Migration Directorate within 3 days of registering. Keep proof of both.
  4. Keep records of your contract, payslips and any written complaints. The bill ties an early change of employer to data held by the Labour Inspectorate, so a recorded complaint can matter.
  5. Count your years. If you have held a single permit for more than two years, the bill would allow six months of unemployment instead of three.
  6. Renewing? Under the bill, you could stay while a renewal decision is pending, even if your card expires in the meantime.

Hiring non-EU workers in Bulgaria: what employers should plan for

Once the bill is in force, an employer's position changes. After six months, a single permit holder could move to another employer through an application filed by that new employer. In our view, retention will depend more on pay and conditions and less on the permit itself. The directive's equal-treatment rule points the same way. Practical planning points:

For the cost side of a hire, see our breakdown of what it costs to employ someone in Bulgaria. For highly qualified roles, the EU Blue Card is a separate route with its own rules.

Questions about your sector or your team's nationalities? Ask us in a free consultation.

Common questions before booking:

What does it cost? The first consultation is free.

Can you make the Migration Directorate decide faster? No one can lawfully promise that. What we control is a complete, consistent file from the start.

Frequently Asked Questions

Can I change employer on a Bulgarian single permit in 2026? +
Not yet under a dedicated procedure. As of 16 October 2026, the change-of-employer rules sit in bill No. 52-602-01-29, which has passed first reading only. Under the text filed, you could switch after at least six months with your first employer, or earlier where the Labour Inspectorate holds data on labour-law breaches by that employer. Under the Foreigners Act in force today, the right of residence ends on the date your employment ends. The right route depends on your dates and permit; book an initial consultation to discuss it.
How long does a Bulgarian single permit take to process? +
Directive 2024/1233 requires a decision within 90 days of a complete application, extendable by 30 days only in exceptional, complex cases. Bulgaria's pending bill would set a 90-day procedure counted from filing, with a possible 30-day extension for factual and legal complexity. As of 16 October 2026 that bill is not law, and document preparation before filing is not covered by either clock.
What happens to my single permit if I lose my job? +
Under the Foreigners Act as in force on 16 October 2026, the right of residence ends on the date the employment ends. If the bill is adopted as filed, unemployment would not be a ground for withdrawing the permit for up to three months in total, or six months if you have held a single permit for more than two years. You would have to register with the Employment Agency within 7 working days after the job ends and notify the Migration Directorate within 3 days of registering.
Has Bulgaria transposed Directive 2024/1233? +
Not as of 16 October 2026. The transposition deadline was 21 May 2026. The Council of Ministers filed the transposing bill on 28 July 2026, Parliament passed it at first reading on 16 September 2026, and the parliamentary record shows no second-reading vote or State Gazette publication yet.
Can I apply for a Bulgarian single permit while I am in Bulgaria? +
The directive allows applications from abroad, or from inside the Member State by people who already hold a residence permit there. Bulgaria's bill would require a first-time applicant who has no right of residence in Bulgaria to be outside the country when applying, except in cases the Foreigners Act lists. Which case you fall into depends on your current status, so check it before you travel or file. Ask us to check your route.
Does the new employer have to start a whole new procedure? +
Under the bill, the change would go through a separate change-of-employer application, filed in person by the new employer, a person it authorises, or the worker at the Migration Directorate or a regional Migration unit, with a defined subset of the first-application documents and the same review steps. The Foreigners Act in force on 16 October 2026 has no such procedure for single permit holders.
What if my employer breaks labour law or exploits me? +
The directive requires Member States to allow a change of employer before the minimum period ends in duly justified cases of a serious breach by the employer, and adds three months to the permitted unemployment period where there are reasonable grounds to believe the worker faced particularly exploitative working conditions. Bulgaria's bill links an early change to data held by the Labour Inspectorate, and extends the unemployment period where a competent authority has established particularly exploitative conditions.
Will the six-month rule apply to permits issued before the law changes? +
We cannot say yet. We did not find transitional rules on existing permits or pending applications in the bill text we reviewed, and the parliament.bg record lists second-reading proposals by MPs filed in September 2026, so the final wording may differ. Once the law is published, the answer will depend on its transitional provisions. Book a free consultation and we will check your permit against the final text.

The bottom line on the Bulgaria single permit 2026 reform

The Bulgaria single permit 2026 reform is real but unfinished. The directive already fixes the direction: decisions within 90 days of a complete application, a right to change employer, and three months of tolerated unemployment, or six after two years. Bulgaria's bill would use the full six-month first-employer period the directive allows and set short national notice deadlines for unemployed workers. As of 16 October 2026, though, it is still a bill, and the Foreigners Act in force ends the residence right when the job ends. Workers should not resign on the strength of the bill. Employers should build its 90-day clock, plus the 30-day extension, into their plans and watch the second reading closely.

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Dimitrova, Cholakov & Partners (Innovires Legal), a regulated Bulgarian law firm.

Legal notice: This article is for general information only and is not individual legal advice. It reflects the directive, the bill filed on 28 July 2026 and the parliamentary record as of 16 October 2026. The bill may be amended before adoption. For your situation, please consult a qualified lawyer.