AmCham Bulgaria Position on the Bill for Amendments and Supplements of the Labor Code

AmCham Bulgaria sent on Friday, July 17th, 2020, a Position on the Amendments and Supplements Act of the Labor Code. The position was prepared by the HR and Education Committee incorporating input from members.

The chamber emphasized the fact the dialog with the Ministry of Labor and Social Policy is fruitful. Also, it reminded some of the main elements of the AmCham Bulgaria White Paper 2017 where some of the newly proposed amendments of the Labor Code were expressed by our members then.

There are three main sections of the positoins.

Support to the Amendment proposals
  • Elimination of the legal and technical discrepancies in the Labor Code and various related acts
  • Constructive labor dialog and bargaining with regard the overtime and working hours calculations in various branches
  • Work at international organizations (expanding the existing scope)
  • Temporary work
  • Short-term contracts at the tobacco sector
  • One-day contracts to the tobacco workers
  • Extension of the overtime inline with the Collective Bargaining Agreement
  • Labor Code Compliance and penalties for second or consecutive violations
  • Paid-leave threshold decrease to 4 months
  • Labor Rules compliance
Disagreements with the Amendment proposals
  • Expanding of the scope of the compentences of the National Tripartite Cooperation Council
  • Not supporting the automatic expansion of the coverage of the Collective Bargaining Agreements by institutional decree
  • Not supporting the adjoining fee to those workers that are automatically joined to a CBA
  • The minimal period of working time calculation to be a month
  • Vagueness at Art. 121a, para 6
  • Not supporting the workers on duty or on stand-by amendement
Additional recommendations from AmCham Bulgaria
  • Removing the hurdles before temporary employment
  • Protection of the temporary workers
  • Removing the barriers before lease employees processes
  • Protection of lease employees by their hired employer for temporary work
  • Relief of the administrative burden
  • Digitalization of the labor relations and processes
  • Removing of the additional payments related to work and professional experience
  • Explicit conditions for labor contract termination
  • Work permits to Non-EU member states workers (Moldova, Serbia, Ukraine, etc.)
  • Work accidents and Professional Disease events
  • Transition from telework to work at the employer’s premises.

AmCham Bulgaria Position on the Amendments and Supplements Act of the Labor Code, July 17th, 2020

AmCham Position on Labor Code Amendments on the Public Consultations Website (