New Challenges in Labour Relations in the Digital Era

The labour market in Bulgaria is evolving rapidly – from remote work and hybrid schedules to the gig economy and freelancing. But is labour legislation keeping up? In this article, we explore the new forms of employment in 2025 and the main legal challenges that accompany them, including the most recent legislative amendments from 2024–2025.

New Forms of Employment in Bulgaria in 2025

• Remote and Hybrid Work:
  After the pandemic, remote work has become a lasting model, especially in sectors like IT and services. While some employers are bringing staff back to the office, many employees – particularly younger professionals – continue to prefer flexibility and the “office–work-from-home” balance. In 2024, lawmakers finally regulated this type of work in detail, introducing comprehensive provisions on “remote work” into the Bulgarian Labour Code. For instance, employment contracts may now include multiple places of work for remote work arrangements, including locations in different settlements, thereby legalizing hybrid work across multiple locations. A new rule allows employees, upon written request, to work from a different place of work for up to 30 working days per year under certain conditions. These changes aim to provide more flexibility while ensuring clarity regarding the place of work.
• Gig Economy and Freelance Work:
  Alongside remote employment, the so-called gig economy has gained momentum in 2025 – involving piecework through platforms or civil contracts. Flexible hourly engagements and short-term projects are increasingly popular, particularly among professionals seeking autonomy or supplemental income. Sectors such as IT, digital services, marketing, and design increasingly rely on freelancers and project-based contracts. Although there is still no specific legal status for platform workers in Bulgaria, the new EU Directive on Platform Work (adopted in October 2024) will soon trigger changes. It introduces a presumption of employment under certain conditions and aims to ensure proper classification of the status (employee vs. self-employed) of individuals working via online platforms. This means Bulgarian legislation will soon need to provide better protection for so-called “platform workers” – such as drivers, couriers, freelance IT specialists, etc.
• Digital Nomads:
  A modern feature of today’s labour landscape is the digital nomad – individuals who work online from any location. All they need is a laptop and internet access. In Bulgaria, this phenomenon has two dimensions: (a) Bulgarian citizens working for a domestic or foreign employer while temporarily residing abroad; (b) Foreigners who choose to live in Bulgaria while working remotely for a foreign company. In June 2025, Bulgaria took a major step to attract the second group: a “digital nomad visa” was introduced through amendments to the Foreigners in the Republic of Bulgaria Act. This is essentially a long-term residence permit that allows non-EU foreign workers to stay in Bulgaria for up to one year (with a one-time extension for another year). Generally, to qualify, they must prove that they work online –  either as employees of a foreign employer or as entrepreneurs or freelancers with sufficient income. With this “visa”, Bulgaria joins many other countries offering similar incentives to digital nomads – recognizing that the globalization of labour has created a new category of mobile workers that traditional borders no longer constrain.

Key Labour Law Risks Related to Remote Work

• Working Hours and Overtime Control:
  Remote work makes it more difficult for employers to monitor compliance with working hours, breaks, and overtime. The lack of physical supervision creates risks – for example, employees may work longer hours than agreed or feel expected to be constantly available. This increases the risk of overwork, burnout, and disputes about unpaid overtime. To address this, recent legal amendments introduced the right to “uninterrupted rest” – the employee is not obliged to respond to work calls or emails outside regular working hours. Although the Labour Code does not use the explicit term “right to disconnect,” a rule has been adopted prohibiting employers from contacting employees during rest periods – effectively shielding them from penalties for not responding outside work hours. Employers should clearly define contact hours for remote workers to ensure compliance.
• Health and Safety in Remote Work Environments:
  The law now explicitly extends the employer’s responsibility for health and safety conditions to cases where the employee works remotely. This poses a challenge – how can safety be ensured when the workplace is beyond direct control? The new rules require that, upon signing a remote work contract, the exact workplace must be specified. The employee must provide written information about their remote work environment –  e.g., a designated desk or room at home. The employer must ensure that the remote work location complies with minimum health and safety standards and provide the necessary tools and equipment if needed. This framework allows for work-related incidents that occur at home to be classified as occupational accidents rather than domestic ones – resolving a previously unclear issue.
• Confidentiality and Cybersecurity:
  A dispersed workforce increases the risk of compromising company information. When working outside the office, employees often use home Wi-Fi, personal devices, or share space with others – increasing the risk of data breaches or cyberattacks. The employer is obligated to implement adequate security measures, including compliance with the GDPR and the Personal Data Protection Act, such as: Secure connections (VPN); Antivirus software; Rules for using work devices, etc. A cybersecurity incident during remote work could result in serious consequences for the company, including fines under GDPR.
• Labour Discipline and Workplace Incidents:
  The absence of direct supervision in remote settings also complicates enforcing labour discipline. If a remote employee fails to meet deadlines or complete tasks, documenting the breach requires clear reporting procedures. Therefore, the latest amendments provide that the work mode be specified in the employment contract – indicating periods when the employee works remotely or from the office, as well as the method for tracking work (e.g., daily reports, time-tracking software, output-based reporting). With well-defined procedures and the use of electronic documents, employers can impose disciplinary actions even remotely. Since 2018, a Regulation has been in force in Bulgaria that allows the use of electronic employment records, including electronic signing and delivery of documents. In practice, however, the requirements are strict – for example, the employer must use a qualified electronic signature for all electronic documents, and delivery must be carried out via a specialized electronic registered mail service. These are technical barriers due to which many companies still prefer the traditional approach – serving important documents (such as termination notices) in person or via courier. Employees working remotely are expected to provide a current mailing address for correspondence or, alternatively, to cooperate in the process of electronic signing, in order to avoid becoming “difficult to reach” in the event of disciplinary procedures.
• Legal Issues in Cross-Border Work:
  The global nature of the digital era enables many people to work for a Bulgarian employer while physically residing in another country – or vice versa, a foreigner working from Bulgaria for a foreign employer. Such cross-border employment raises complex legal questions: Which labour law applies? Where are social security contributions and taxes due? As a general rule, if a Bulgarian employer hires someone under an employment contract, the Bulgarian Labour Code applies – even if the work is performed abroad (subject to mandatory local provisions). But if the employee permanently works from another country, local legal requirements may apply. For example, if the employee resides in another country for more than 183 days per year, they may become a tax resident or person liable for social security contributions there under certain conditions. Within the EU, coordination rules apply – typically, social security contributions are paid in only one country. If the employee works mainly from their home country (different from the employer’s), the employer may be required to pay contributions under that country’s laws (via A1 form or local registration) – a complex process requiring expert advice. Bulgarian employers are often unprepared for these issues. Thus, many opt for alternatives: short-term secondments; hiring via a local partner; or using an Employer of Record (EOR) service in the relevant country. Lack of clarity poses risks for both parties: the employee may end up uninsured or doubly taxed; the employer may face sanctions for violating local laws. It is now mandatory to explicitly state in the employment contract if the work will be performed from abroad – to address these circumstances. Likewise, upon termination of a remote employment contract, delivering termination documents to an employee abroad can be a challenge. Bulgarian law allows electronic delivery, but only if specific conditions are met (e.g., regarding the electronic signatures and registered electronic mail). Otherwise, the employer must send a hard copy by registered mail with return receipt to the employee’s permanent address. All of this shows that international remote employment is an area where labour and tax and social security law cross borders – and employers must be mindful of many regulations beyond national law.

Flexible work models undoubtedly offer benefits – freedom, balance, and access to global opportunities. But they also present new challenges for labour law. Between 2023 and 2025, Bulgarian legislation began to adapt: it regulated remote work, introduced a form of the “right to disconnect,” provided a definition for digital nomads, and is even considering reforms related to fee-based contracts. Employers in the IT sector and other innovative industries should closely follow these changes and align their internal policies accordingly. For their part, individuals working flexibly – whether as employees or freelancers – should be familiar not only with the technologies, but also with their rights and obligations. Only then can the new digital era of work be sustainable and fair for both parties in the employment relationship.

Disclaimer: The analysis and information provided in this article are for general informational purposes only and should not be considered legal advice. If you require legal assistance in relation to a specific case, we recommend consulting a competent attorney. The author assumes no liability for actions taken based on the content of this publication.