In connection with the extraordinary meeting of the National Council for Tripartite Cooperation (NCTC) convened for September 14, 2026, the Bulgarian Industrial Capital Association (BICA) presents its position on the draft acts included in the agenda, as follows:
1. Regarding the Bill to Amend and Supplement the Labour Code (No. 52-654-01-97), submitted by Svilen Trifonov and a group of Members of Parliament on July 16, 2026.
The Bulgarian Industrial Capital Association supports this bill.
We share the proponents' rationale and believe that the bill ensures a more adequate application of the legal possibility for minors to engage in employment—a measure beneficial to both parties in the employment relationship and to the development of a competitive economy driven by the dynamic needs of the labor market.
From the employers' perspective—given the established labor shortage and the consequent need to replenish the labor market by utilizing available opportunities—we believe that the proposed change streamlines the administrative process and establishes a more modern approach to safeguarding the parties' interests compared to the current regulations.
We emphasize that the proposed change does not eliminate the special protections afforded to minor workers and employees. Requirements regarding medical fitness, restrictions on the nature and conditions of work, special working-time arrangements, and the oversight powers of the Labour Inspectorate remain in place. The only change concerns the administrative mechanism, replacing the prior authorization regime with a notification-based regime. According to BICA, the protection of minors should be ensured through clear substantive requirements and effective oversight, rather than through an administrative authorization process for the commencement of each individual employment relationship.
We also endorse the proposed approach of regulating the details regarding the admission to employment of persons aged 16 to 18 via a joint ordinance issued by the Minister of Labour and Social Policy and the Minister of Health. The implementing regulation should provide for a fully electronic and maximally simplified notification process; it should not introduce waiting periods, additional approval steps, or excessive documentation requirements, as doing so would effectively transform the notification regime back into an authorization regime.
2. Regarding the Bill to Amend the Labour Code (No. 52-654-01-114), submitted by Galya Vasileva and a group of Members of Parliament.
The Bulgarian Industrial Capital Association does not support this bill.
While BICA shares the bill's objective of protecting maternity, paternity, and adoption, we do not agree with the proposed legislative method for achieving it. In our view, it violates the fundamental logic of fixed-term employment relationships and creates more problems than it solves.
A fixed-term employment contract differs from an open-ended contract precisely in that its termination is linked to the occurrence of a predetermined objective event—such as the expiration of the agreed term, the completion of specific work, or the return of the employee being replaced. The proposal that these objectively arisen grounds should not trigger the effect prescribed by law until the conclusion of the relevant leave blurs the fundamental distinction between fixed-term and open-ended employment relationships and alters the consequences of terms already agreed upon by the parties.
This inconsistency is particularly evident in contracts for substitution and contracts for the completion of specific work. If the employee being substituted has returned to work, or if the work for which the contract was concluded has been completed, the objective reason for the existence of the fixed-term relationship has ceased to exist. The law should not artificially maintain an employment relationship after the very ground for its inception has lapsed.
The forced continuation of a private-law contract beyond the agreed-upon ground for its termination is not an appropriate method for supporting a parent's income following the end of a fixed-term employment relationship. Social and demographic risks are societal risks; when additional income guarantees are necessary, they should be provided through the social security system and social policy, rather than by legislatively altering the pre-agreed term of a specific employment relationship.
An additional ground for objection arises from the provision applying the new rule to existing employment relationships as well. The parties concluded these contracts under the prevailing regulatory framework and with pre-determined conditions for their termination; the proposed legislative change would alter these conditions. This undoubtedly affects legal certainty and the predictability of employment relations.
3. Regarding the Draft Council of Ministers Decree on setting the national poverty line as of January 1, 2027, submitted by the Minister of Labour and Social Policy.
The Bulgarian Industrial Capital Association (BICA) supports the poverty line figure proposed by the Council of Ministers of the Republic of Bulgaria.
We believe that, given the clear regulations and the existence of a precise methodology for determining the poverty line, the only question that nationally representative social partner organizations need to address is whether the methodology was followed in formulating the proposal for the 2027 poverty line.
In our view, the methodology has been adhered to and aligns with the results of the harmonized European survey "Statistics on Income and Living Conditions" (EU-SILC), conducted in Bulgaria by the National Statistical Institute in accordance with European methodology.
We believe there are no legal grounds to determine the 2027 poverty line using any method other than the currently regulated and established methodology. We cannot accept changes being made to the methodology on the eve of setting the poverty line figure.
Read the full text of the position here.
