New rules concerning the single application procedure for third-country nationals to apply for a single residence and work permit are currently being considered by parliamentary committees. The amendments relate to the full transposition into Bulgarian law of Directive (EU) 2024/1233 on a single application procedure for third-country nationals to obtain a single residence and work permit in a Member State and on a common set of rights for third-country workers lawfully residing in a Member State.

The draft Law amending and supplementing the Foreigners in the Republic of Bulgaria Act (“the Bill”) proposed by the Council of Ministers continues the trend towards a clearer and more predictable regulatory framework in the field of labour migration. We also highlighted similar changes in Issue 269 of 31 July 2025 of our Legal Digest, in which we analysed the status of digital nomads in Bulgaria.

At present, the legal framework does not allow foreign nationals holding a ‘Single Residence and Work Permit’ (“SRWP”) to take up employment with another employer on the basis of the SRWP already issued. When changing employers, these foreign nationals are required to apply for and obtain a new SRWP. Furthermore, the current legislation does not provide for the holder of a SRWP to retain their right of residence for a certain period following a period of unemployment.

These issues are expected to be addressed by the amendments, which provide for the legal possibility for holders of a SRWP to retain their right of residence whilst unemployed, provided that the specified conditions are met. The total period of unemployment must not exceed three months within the period of validity of the residence document, or six months where the third-country national has held a SRWP for more than two years.

Within 7 working days of the termination of the employment relationship, a foreign national holding a SRWP is required to register with the Employment Agency and to notify the Migration Directorate of this within 3 days of registration. The permit may be revoked if, following registration with the Employment Agency, the foreign national fails to notify the Migration Directorate within the prescribed time limit.

The draft Bill also provides for the possibility for a foreign national to change their employer during the period of validity of the permit, provided they have worked for their first employer for at least 6 months. Changing employer before the expiry of this period will be possible where the Executive Agency ‘General Labour Inspectorate’ has evidence of established breaches of labour legislation by the first employer. A change of employer must be reflected in the plastic card of the SRWP by the foreign national or the new employer with a submission of an application to the Migration Directorate.

The measures described above represent a significant step towards a clearer regulatory framework for labour migration; they simultaneously expand the options available to holders of a ‘Single Permit for Residence and Work’ in the event of unemployment or a change of employer, whilst introducing additional requirements and control mechanisms.

The proposed amendments are particularly important against the backdrop of the growing practical significance of labour migration and the increasingly frequent recruitment of workers from third countries by Bulgarian employers. In this context, clearer rules regarding changes of employer, periods of unemployment and notification obligations would contribute to a more predictable environment for both foreign workers and businesses. Of course, it remains to be seen what the final version of the amendments to the Foreigners in the Republic of Bulgaria Act will be, should they be adopted.

This article has been prepared for and is part of the Legal Digest issued by Penkov, Markov & Partners. The publications therein do not constitute legal advice and are not binding. Penkov, Markov & Partners reserves all rights to this material, and any distribution thereof is subject to the prior written consent of the law firm.