Bulgaria intra corporate transfer permit: moving a group employee into a local entity

The intra corporate transfer permit is a separate route under Article 33p of the Bulgarian Aliens Act. It lets a company in Bulgaria host a manager, specialist or trainee employed by a group undertaking outside the European Union. The Employment Agency issues it. The employee stays on the sending company's contract, and the Bulgarian host entity is the party that files.

The legal base is Chapter Two, Sections I and V of the Labour Migration and Labour Mobility Act, which transposes Directive 2014/66/EU. This is not a variant of the single permit and it is not filed on that track. An employer who starts down the wrong procedure loses weeks before collecting a refusal on formal grounds.

Who qualifies, and for how long

The Employment Agency recognises three categories: managers, specialists and trainees. For managers and specialists the transfer runs for a maximum of 3 years. For trainees the ceiling is 1 year. The first permit is issued for 1 year and is extended inside those ceilings while the transfer lasts.

Prior employment inside the group is the condition that fails most often on review. The Employment Agency requires 12 months of continuous employment with the group undertaking for managers and specialists, and 6 months for trainees, immediately before the transfer. If the employee moved between group companies during that year, the period breaks and the application falls, even when total service with the group is long.

What the host entity files

The application uses the form set out in Annex 3a to the implementing rules of the Labour Migration and Labour Mobility Act. With it, the Bulgarian host entity files evidence that it belongs to the same group, the assignment letter stating the post, the place of work and the pay, and evidence of the employee's professional qualification or experience for the post.

Evidence of prior employment inside the group must be legalised and translated. That is the Employment Agency's position, and it covers the employment contract and the certificate of service from the sending company. Employers underrate this step because the document exists and looks sufficient in the original. Legalisation in the country of origin takes its own weeks and belongs in the plan before filing, not after.

A separate declaration states that the pay and working conditions of the transferred employee are no less favourable than those of Bulgarian workers in the same or comparable posts. That declaration is what the Labour Inspectorate checks later, so the figure in it has to match the figure in the personnel file.

Deadlines, cost, and where the schedule breaks

The executive director of the Employment Agency issues a written opinion within 14 days. The whole procedure by law does not exceed 3 months from a complete application, extended by a further 1 month where the case is factually and legally complex. The state fee for examining the application is set by the tariff under the Labour Migration and Labour Mobility Act and is payable on filing, whatever the outcome.

The clock starts on a complete file. A missing legalised proof of prior employment does not pause the 14 day opinion period, it postpones it, because the file is not treated as opened. A host entity that promised the group a start date eight weeks out usually discovers this in week five, once the flights are booked.

Once the permit is issued, the employee applies for a type D visa at the Bulgarian consulate covering their residence, and collects the residence document from the Migration Directorate after entry. The visa leg is set out in Bulgaria's type D visa timings and fees. Where the prior employment condition is not met, the alternative is usually the single permit for residence and work, which in turn runs through the labour market test and the employer's justification.

The intra corporate transfer is a narrow procedure with plain numbers: 12 months back, 3 years forward, 14 days for the opinion. Companies that assemble the legalised evidence before filing keep their schedule. If you are planning transfers into a Bulgarian entity over the coming year, our employer team can read the profiles against these conditions.