Bulgaria labour inspections of foreign workers: checks, notifications, penalties

The Executive Agency General Labour Inspectorate enforces Bulgaria's Labour Migration and Labour Mobility Act. Where a third country national is found working without the relevant permit or registration, the pecuniary sanction on a corporate employer is 2,000 to 20,000 leva under Article 75a(2) of the Act, imposed separately for each unlawfully employed worker.

At the official rate of 1.95583 leva to the euro, in force since Bulgaria adopted the euro on 1 January 2026, that is roughly 1,022 to 10,225 euro. For a group of eight, the upper end of the sanction passes 80,000 euro, and that is before social security and tax consequences are counted.

The two notifications employers miss most often

The permit is not the end of the administrative work. It is the beginning of it. Article 10 of the Labour Migration and Labour Mobility Act sets two periods, and both are counted in days rather than working days.

The employer notifies the Executive Agency General Labour Inspectorate within 7 days from the date the third country national actually starts work.

Where employment ends early, the employer notifies the Employment Agency within 3 days from the date of termination.

A missed notification is not a formality. It creates a gap between what was authorised and what is happening on site, and the gap is exactly what the inspector works with.

The 7 day period runs from the actual start of work, not from the date of the employment contract and not from the date of entry. For groups arriving on two flights in different weeks, that means two notifications with different start dates rather than one notification for the group. The same applies on seasonal permits, where notifying that work has started is again a 7 day obligation. Keep a register of each person's first working day and reconcile it against filed notifications once a month.

What the inspector looks at on site

The visit does not start with the permit. It starts with the people and with what they are doing. An employment relationship can be established without a written contract and is proved by any admissible evidence, including statements from those working, shift rosters, access control records and payroll.

That approach is why an otherwise orderly employer collects a finding. The inspector does not compare the folder with the folder. He compares the people with the folder. If someone on site appears on no list but does appear on the shift roster, the visit starts there.

From there the visit moves to documents: the permit or registration granting labour market access, the match between the position on the permit and the work actually performed, the Article 10 notifications, pay and working conditions against Bulgarian nationals in the same category of work, and accommodation where the route requires it. The housing component and the prohibition on deducting rent from pay are covered in accommodation for third country workers.

The Bulgarian regime sits on Directive 2009/52/EC on minimum standards for sanctions against employers of illegally staying third country nationals. That is why the penalty travels with other consequences: payment of outstanding wages and contributions, return costs, and exclusion from public procurement on repeat findings. How the right to work check looks in other member states is compared in right to work verification checks.

The failure mode

A manufacturer holds single permits for seven people as machine operators. In the second month the line is reconfigured and three of them start driving forklifts in the warehouse. The warehouse role requires a different qualification and is a different position on paper. The Migration Directorate is not notified, because the move looks internal.

At inspection the officer compares the permits with the work actually performed and finds a mismatch for three workers. An Article 75a(2) finding of unlawful employment follows, with a separate sanction for each, and the Migration Directorate is alerted to assess whether the ground for residence still holds. The company loses three positions, pays the sanction, and starts a new procedure that costs another two months.

Notifying before the change costs one email. The sanction after the change is measured in five figure sums and in lost workers. The place of the permit in the chain, and the way it binds one named position, is set out in the single permit procedure. The terms on which Werklist tracks Article 10 notifications after arrival are set out on the employers page.

Practice shows one durable pattern. Inspection problems almost never come from a missing permit. They come from a permit that no longer describes the work the person is doing. The document stays where it was, and the work moves.