Bulgaria’s Labour Migration Act Amendments: Higher Quotas and Employer Mobility for Third-Country Nationals
3 February 2026The Bulgarian Ministry of Labour and Social Policy has published a draft Bill amending the Labour Migration and Labour Mobility Act (Закон за трудовата миграция и трудовата мобилност, “LMLMA”). The public consultation ran from 8 to 22 January 2026 on the Council of Ministers’ public consultation portal. Below we outline the two changes most relevant to employers and foreign workers.
Five-Percentage-Point Increase in Employment Quotas
Under the current framework, employers in Bulgaria are subject to caps on the number of third-country nationals they may hire under a Unified Residence and Work Permit (Единно разрешение за пребиваване и работа, “URWP”). The draft Bill raises those caps by 5 percentage points for both small-and-medium enterprises and large enterprises alike.
The quota increase is designed to address what the Ministry describes as the “ever-growing needs of Bulgarian employers for labour force.” It applies specifically to workers employed under an employment relationship with a local employer holding an URWP and not to EU Blue Card Holders.
In addition to the general quota expansion, the Bill introduces an extra-quota mechanism allowing employers to hire third-country nationals outside the standard caps for the execution of projects and activities of national significance.
Practical impact: Employers who have been constrained by the existing quotas will gain additional headroom to recruit third-country workers. Companies engaged in nationally significant projects will benefit from the possibility of hiring foreign workers without being limited by the standard numerical caps.
Right to Change Employer
One of the most significant novelties in the draft Bill is the introduction of an explicit right for third-country workers to change their place of work — a provision that did not previously exist in the LMLMA.
Under the current regime, a third-country worker’s UWRP is tied to a specific employer and position. This has long been criticised as limiting the worker’s ability to respond to abusive employment conditions or simply to pursue better opportunities. The proposed amendment would allow such workers to switch employers, subject to conditions yet to be detailed in the implementing regulations.
Practical impact: This change will bring Bulgaria closer to the requirements of EU Directive 2014/36/EU on seasonal workers and broader EU policy trends favouring labour mobility. Employers should be aware that the retention of third-country nationals may become more competitive, as workers gain the legal ability to move between employers.
Background and EU Context
The amendments are driven primarily by the need to align Bulgarian legislation with EU Directive 2014/36/EU on conditions of entry and stay of third-country nationals for the purpose of employment as seasonal workers. The European Commission opened infringement proceedings (No. 2023/2017) against Bulgaria for incorrect transposition of the Directive. The compressed 14-day public consultation period reflects Bulgaria’s commitment to the Commission to resolve the identified discrepancies.
Beyond EU compliance, the Bill also introduces a regulatory framework for intermediary services in the recruitment of third-country nationals and establishes sanctions against employers who hire third-country nationals who are residing illegally in Bulgaria.
What to Watch
The draft legislation attracted considerable public attention during the consultation period, with stakeholders expressing a range of views — from employer associations welcoming the increased flexibility to commentators raising concerns about the impact on the domestic labour market. The Bill’s progress through the legislative process and the specific implementing rules (particularly concerning the conditions for changing employer) will be critical for employers relying on third-country labour.