Bulgaria: Several EU Blue Card Rules Relaxed

February 28, 2023

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Country / Territory

At a Glance

The Bulgarian government has relaxed several rules related to EU Blue Card eligibility requirements and processes. Key changes include:

  • EU Blue Card applicants may be able to provide a certificate to prove their experience, instead of the current three-year university degree requirement;
  • The minimum employment agreement term to qualify for an EU Blue Card has been reduced to six months;
  • The maximum term of validity of the EU Blue Card was extended to five years; and
  • EU Blue Card holders must now be covered under the national health insurance system.

Many of these changes will expand the eligibility pool for EU Blue Card applicants.

The situation

Bulgaria’s government has implemented several changes to the EU Blue Card rules, mostly related to qualification criteria, validity, processing time, and activities allowed under the permit.

Change Current/previous related rule Impact
Eligibility criteria. For some positions, EU Blue Card applicants will be able to provide a 'knowledge, skills and competence' certificate, issued by a competent authority, evidencing professional experience to a level comparable to higher education that is relevant to the profession or sector as specified in the employment agreement, instead of the current stricter degree requirement.
 Applicants must hold a university degree from an education program of at least three years duration directly relevant to the position.
    • The Bulgarian Ministry of Labor and Social Policy must first approve a list of positions eligible for this exemption. The authorities are also expected to clarify what type of document would qualify to demonstrate the new eligibility criteria.
    • For positions not in the list, the minimum number of years of experience is five years.
    • If the Bulgarian authorities recognize documents proving the new eligibility criteria, this would expand the eligibility pool for EU Blue Card holders in Bulgaria.
Minimum term of employment agreement. The minimum employment agreement term to qualify for an EU Blue Card has been reduced to six months. The minimum term of a qualifying employment agreement was 12 months. This expands the pool of applicants eligible for an EU Blue Card to those with shorter employment agreements.
Online application process.  EU Blue Card applications are expected to be available on an online platform in the future.
Employer representatives and EU Blue Card applicants must visit the Migration Office to file EU Blue Card applications.

Once the online process is fully implemented, it will streamline the application steps for EU Blue Card applicants.

Some personal visits will still be required during the process.
Centralized filing. All EU Blue Card applications can now be filed centrally at the Headquarters of the Migration office in the capital city of Sofia, including if the applicant’s place of work and residence of the employee is in another city. EU Blue Card applications must have been filed at the Migration office in the area where the employee will work and live. The provision facilitates the employers in the EU Blue Card application process, as they no longer need to travel to other cities to file applications for employees not located in the capital city of Sofia.
Change of employer. After one year of employment, EU Blue Card holders are expected to be able to change their employer in Bulgaria under a simple procedure.
 EU Blue Card holders could change their employer in Bulgaria only after a new work and residence permit application was approved. Once authorities publish the steps of the simplified process, the change of employer process will be easier and more streamlined.
Reduced standard government processing times. The processing time for the first step of the EU Blue Card application process (in-country steps) has been reduced to approximately three weeks.
 The processing time was previously approximately one month for the in-country processing steps. The entire process for the EU Blue card application (which is approximately three to four months) will be reduced.

Work permit-exempt activities clarified. The government has clarified that holders of EU Blue Cards issued in another EU Member State can perform limited and temporary activities directly related with the business interests of their employer and with the professional obligations of employee under their employment contract, including:

      • participation in internal or external business meetings;
      • participation in conferences or seminars;
      • conducting negotiations for business deals;
      • making sales or performing marketing activities;
      • exploring business opportunities; and
      • participating in and undergoing training. 
 There were no explicit provisions regarding the scope of business activities which do did not require a work permit in Bulgaria. The new provisions give more clarity regarding the scope of work permit exempt business activities.
Public health insurance. EU Blue Card holders, even those with EU Blue Cards issued before January 29, 2023, must now be covered under the national health insurance system. EU Blue Card holders were not eligible or required to enroll in the national health insurance system, and were instead required to have private insurance policies. EU Blue Card holders can now benefit from the offerings of the national health insurance system.
Duration. The EU Blue Card is now valid for five years.
 The EU Blue Card was valid for four years. EU Blue Card holders now benefit from a longer validity period of their permit, allowing them to stay in Bulgaria without renewal, for a longer period of time.
Remote work. Remote work in Bulgaria is now allowed for EU Blue Card holders.           
Work was only permitted at the premises of the employer. The government has made it possible for Bulgarian EU Blue Card holders to work in any location in Bulgaria.

These changes were implemented to account for the labor and skills shortage in Bulgaria and to implement the EU Blue Card Directive.

We will report on related developments regarding the implementation of the above rules.

There are no further immigration-related changes expected in the near future since Bulgaria currently does not have an operating legislative body and may not have one for months.

This alert is for informational purposes only. If you h ave any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].

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