The recast single permit directive and what changes for employers in Bulgaria
Directive (EU) 2024/1233 applies from 22 May 2026, cuts the decision to 90 days and grants a right to change employer that Bulgaria must transpose by 21 May.
Directive (EU) 2024/1233 of 24 April 2024 recasts the single permit regime. Member states must transpose it by 21 May 2026, its provisions apply from 22 May 2026, and Directive 2011/98/EU is repealed from the same date. Three changes reach employers in Bulgaria: a shorter decision period, a right to change employer, and a protected period during unemployment.
The recast does not create a new document. The single permit remains one application and one card, issued in Bulgaria by the Migration Directorate under Article 24i of the Aliens Act. What changes is what the worker can do once the card is in hand.
The three substantive changes
| Element | Under Directive 2011/98/EU | Under Directive (EU) 2024/1233 |
|---|---|---|
| Decision period | up to 4 months in national transpositions | 90 days, plus 30 in complex cases |
| Change of employer | national rules, often a new permit | a right within validity, subject to conditions |
| Suspension on notification | not regulated | up to 45 days from the notification |
| Unemployment | ground for withdrawal under national law | 3 months not in itself a ground |
| Longer period | none | 6 months where the permit was held for at least 2 years |
The 90 day period runs from a complete application and covers both the residence permit and labour market access. Bulgaria's general period under Article 24i is already two months, extendable by a further two, so on paper Bulgaria is not far from the new frame. The practical difference sits in the other two points.
The right to change employer is the real novelty. Member states may require a notification and may check the labour market situation, and the right to change may be suspended for up to 45 days from the date the notification is made. After that period the worker can start with the new employer.
On unemployment, a period of three months is not in itself a ground to withdraw the single permit. The period is at least six months for a holder who has held a valid permit for at least two years. For longer unemployment, member states may require evidence of sufficient resources without recourse to the social assistance system.
The 90 day period is procedural discipline as much as a shorter calendar. It covers the whole chain of authorities rather than the last one to decide, and it runs from a complete application. That leaves the incomplete file as the only lawful way the clock does not start, and it pushes the burden of assembling documents further onto the employer.
What this means for a Bulgarian employer
Today the single permit ties the worker to one employer and one position, and every change goes through the Migration Directorate. The enforcement side of that tie is covered in labour inspections of foreign workers, and the procedure itself in the single permit procedure.
After transposition the picture shifts in three ways. The investment in selection becomes more mobile, because a worker trained and relocated by one employer will be able to move to another on a lighter route. Retention planning stops leaning on administrative attachment and starts leaning on pay, housing and schedule. And notifications become more frequent and more consequential, because the suspension of up to 45 days runs from the notification, not from the intention.
The calendar caveat matters. Until the changes are promulgated in the State Gazette and enter into force, the existing national rules apply in full. An employer building a 2026 plan on the right to change employer before it is transposed is planning on a directive rather than on applicable law.
The failure mode
A company relocates 14 workers in February on the assumption that from May they can move to an affiliated company in the group under the new rules without a fresh procedure. The changes are transposed later than expected, and even under the new regime a change requires notification and allows suspension of up to 45 days. Fourteen people stay on the old permit, moving them turns out to be a new Migration Directorate procedure, and the production schedule at the receiving company slips by a full quarter.
The practical rule is to track legal change by the date of promulgation, not by the date of the directive. How one directive produces different national documents and different authorities is covered in the single permit explained, and the chain of obligations that stays with the employer whatever the regime in the sponsorship compliance chain. The terms on which Werklist tracks transposition across corridors are set out on the employers page.
The direction of travel is clear and it favours the worker. Employers who already compete on conditions rather than on paperwork will feel the change least.
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