Employer Documents
Job descriptions, orders, certificates, statements, notices and other unilateral employer documents connected with the employment relationship.
Horizons® Bulgaria · HR Compliance & Administration
Electronic Employment File in Bulgaria
Digitise employment documentation with a compliant, traceable and employee-accessible process. Horizons Bulgaria supports employers with the legal framework, HR workflows and administration needed for electronic documents in personnel files.
2018 frameworkSpecific Bulgarian ordinance
2-factor accessRequired system protection
Audit trailTimestamped document history
Free accessContinuous employee access
What it is
Electronic documents in the employee’s personnel file
Under Article 128b of the Bulgarian Labour Code, an employee’s employment file may contain paper and electronic documents relating to the creation, existence, amendment and termination of the employment relationship.
Important distinction
Personnel file and electronic employment record are not the same
The employer’s personnel file contains the underlying HR documents. The Unified Electronic Employment Record is held in the Employment Register administered by the National Revenue Agency and replaced the paper employment booklet for employment relationships from 1 June 2025.
Employer personnel fileContracts, orders, applications and other employment documents maintained by the employer.
Employment RegisterStatutory employment data submitted to the National Revenue Agency by employers.
Electronic documents are optionalThe 2018 ordinance permits a compliant electronic process; it does not impose a universal paperless-file requirement.
Paper remains possibleAn employer may not refuse a document submitted by an employee on paper.
Contents
What the electronic file may contain
The employer defines in its Internal Labour Rules which document categories will be created or stored electronically, subject to the applicable legal requirements and retention rules.
Employee Documents
Applications, declarations, notifications, consents, reports and requests submitted by the employee.
Documents Signed by Both Parties
Employment contracts, additional agreements, qualification agreements and other documents requiring the agreement of employer and employee.
Leave & Absence Documents
Leave requests, approvals and relevant absence documentation maintained according to the applicable HR process.
Documents Issued by Third Parties
Medical, educational, official and other third-party documents evidencing facts relevant to the employment relationship.
Termination & Related Records
Notices, orders, employee statements and other documents connected with the termination and final administration of employment.
How it works
Requirements for a compliant electronic process
The process requires more than scanning paper. The information system, document exchange, signatures, access and history must meet the ordinance and other applicable Bulgarian and EU rules.
Internal rules and employee notice
The employer identifies the electronic document types in its Internal Labour Rules and informs employees that electronic documents will be created or stored.
Electronic statements
The parties may expressly agree to receive electronic statements concerning the employment relationship. Either party may subsequently withdraw that consent.
Appropriate electronic signature
Employer-created documents must be signed with a qualified electronic signature. Employee signatures follow the legal requirements and the agreed process; if the employer requires QES, it provides the signing mechanism at its expense.
Traceable electronic exchange
Electronic statements are served through a qualified electronic registered delivery service, with receipt and document registration evidenced in the system.
Protected storage and audit trail
The system must support two-factor authentication, qualified electronic timestamps, action history and protection against unauthorised access, alteration or destruction.
Employee access and copies
Employees receive continuous, free access to their electronic documents and may request electronic documents or paper copies, which the employer must provide within 14 days.
Benefits
Better administration without losing legal control
A properly implemented electronic file can simplify HR operations while strengthening accessibility, traceability and document control.
Faster HR Workflows
Coordinate onboarding, amendments, employee requests and offboarding across office, remote and hybrid teams.
Clearer Compliance Control
Track document status, access, delivery, signatures and time-sensitive actions through one structured workflow.
Employee Transparency
Give employees direct access to their electronic documents and a clear history of relevant HR records.
Audit Readiness
Retrieve relevant documents and system history efficiently when required for an internal review or lawful authority inspection.
Reduced Paper Administration
Lower printing, courier and physical-archive requirements for the document categories included in the electronic process.
Information Security
Use controlled access, immutable history and technical safeguards instead of unstructured document exchange and storage.
Employer checklist
What to define before implementation
Document categories have different legal, operational and retention requirements. A compliant implementation starts with a documented scope rather than a blanket “scan everything” approach.
Document mapDefine which HR documents are created electronically, scanned or retained on paper.
Signature matrixMatch each document type with the correct author, signature and delivery method.
Retention scheduleApply the specific statutory and operational retention period for each document category rather than one universal period.
GDPR safeguardsControl access, purpose, data minimisation, security and deletion in line with applicable data-protection duties.
Need help with HR compliance?
Structure your electronic HR administration
Horizons Bulgaria can support your employment-document workflow, HR administration and payroll processes with a practical, compliance-focused approach.