Annual leave in Bulgaria: twenty days and beyond

Working life · Last reviewed: 2026-08-24

The minimum measure: 20 working days, not calendar days

The unit the law uses is the WORKING DAY. The distinction matters more than it seems: 20 working days correspond to roughly four calendar weeks, because weekends and public holidays are not counted. Someone used to counting in calendar days looks at „20“ and concludes it is stingy; translated into the calendar, the same measure comes close to 28 days. Leave requests use the same unit — a person asking for five working days is away for nine days once the weekend is included.

Twenty working days is a FLOOR, not a ceiling. An individual or collective agreement may provide more; in Bulgaria 22 to 25 working days are common in IT, outsourcing and large manufacturing. Conversely, no contractual clause below the statutory floor is valid — and the employee's consent does not make it valid either, because minimum leave is not a right a person can waive.

When the right arises: the four-month rule

A worker starting employment for the first time may take paid annual leave once they have acquired at least four months of length of service. When those four months are completed during the first year of work, the person is entitled to paid annual leave for that same year in full — there is no proportion along the lines of „I worked four months, so I get a third“. For someone arriving in Bulgaria mid-year this has an immediate practical consequence: a person who starts in September completes four months in January, and the whole entitlement for that calendar year stands ahead of them.

The four months are counted not only from time with the current employer but from all periods the law recognises as length of service. Someone who has previously worked in Bulgaria under an employment contract may therefore already satisfy the condition on their first day in a new job. How employment abroad is counted is a separate question and depends on documents; handing your previous insurance records — especially periods within the EU — to payroll when you start heads off the later argument.

Additional annual leave: what the law adds on top of the twenty

Article 156 of the Labour Code provides ADDITIONAL paid annual leave in two situations. The first is work under specific conditions and risks to life and health that cannot be removed, limited or reduced regardless of the measures taken: here the additional leave is not less than 5 working days. The second is work with non-standard working hours (ненормиран работен ден) — roles where the working day may be extended when the job requires it: here too the additional leave is not less than 5 working days.

Which jobs fall into the first group is fixed by a Council of Ministers ordinance; the list is not discretionary and an employer cannot escape it by asserting „we have no heavy work here“. The second group depends on an employer's order setting out the positions placed on non-standard hours; that list must be published in writing. If your contract carries the phrase „ненормиран работен ден“, the corresponding additional leave days must be written down as well.

Article 156a states that larger amounts of the leave under Art. 156 may be agreed by collective or individual agreement. In practice that makes additional leave a negotiable item: asking for extra days in exchange for seniority, shift patterns or on-call load is both lawful and common. How much the additional leave is and on what ground it is owed should sit in a separate clause of the contract — the phrase „company policy“ creates no right.

How leave is planned: the mandatory annual schedule

In Bulgaria annual leave is not something you request whenever the mood strikes, but something planned in advance. Under Art. 173(1) of the Labour Code, by 31 December of the preceding calendar year the employer approves a schedule for the use of paid annual leave by workers for the following calendar year, after consulting trade union representatives and employee representatives. In other words, a schedule should already be in force in January.

The schedule binds both sides and provides two-way protection. For the worker: a period entered in the schedule cannot be refused arbitrarily. For the employer: busy periods are visible in advance and leave can be distributed. The most common problem in practice is that the schedule is never drawn up, or is drawn up once and never looked at again; that is a quiet breach which weakens the worker's position whenever they ask for time off.

1. 1

   In December, ask whether the schedule has been prepared

   The absence of a schedule is a gap. In most workplaces the question alone brings the schedule to light.
2. 2

   State your preferences in writing

   The consultation stage comes before approval. A written statement closes off the later argument that you never said anything.
3. 3

   Still file a request when you actually take leave

   The schedule shows the plan; actual use starts with a written request and the employer's approval. Keep a copy of the approval.
4. 4

   Check your remaining days once mid-year

   The payroll count and yours differ by a day or two more often than not. Noticing that in June is easier to fix than noticing it in late December.
5. 5

   At year end, plan the remaining days against the deferral rules

   Deferred leave does not live for ever; the two-year limitation described below comes into play here.

Unused leave: the two-year limitation period

This is the most widely misunderstood rule in the Bulgarian leave regime. In the Labour Inspectorate's own words: when paid annual leave has not been used by the end of two years from the end of the year for which it accrues, regardless of the reasons, the right to use it expires by limitation. Limitation starts running from the year following the one for which the leave accrues. So leave accrued for 2024 can be used until the end of 2026; it does not carry into 2027.

The second detail matters just as much: that two-year window does not care whether the leave was formally DEFERRED. The Inspectorate's guidance says so plainly — all days may be used until the end of their two-year limitation period, whether or not they were deferred into the following calendar year. So the argument „it was not deferred, therefore it lapsed“ is wrong; but so is the complacency of „it is still sitting there“, because the window really does close.

There is a third situation: where leave is deferred under Art. 176(4) of the Labour Code, the right to use it expires two years after the end of the year in which the reason for not using it ceased. That provision matters most to people returning after long-term sickness or maternity leave: their clock starts at the end of the year of return, not at the end of the year the leave belongs to.

Does the entitlement keep accruing during a long absence

The question is vital for anyone on long-term sick leave, maternity leave or child-care leave. The short answer: as long as the employment relationship stands, the leave entitlement does not vanish by itself; but which periods count as length of service is a separate question and varies by the type of absence. So the answer to „I was signed off for a year, did my leave burn?“ is not an automatic yes or no — the calculation looks at the legal basis of the absence.

In practice the most important protection is the deferral rule in Art. 176(4): the two-year period starts again from the end of the year in which the reason for non-use ceased. For someone returning from a long illness or from maternity leave that means the accumulated days will not burn the very next year. The first thing to do on returning is to obtain from payroll, in writing, the number of accumulated days and the limitation date for each year separately.

The money for leave days: how payment is calculated

Annual leave is paid leave: the worker is paid for the days spent on leave. The basis of that payment is the average daily gross remuneration for a period preceding the start of the leave. This detail has direct financial consequences for people on variable pay — commission-based sales, shift allowances, regular overtime. On a fixed salary the difference between a leave month and an ordinary month is imperceptible; where a substantial share of income is variable, the leave month can come out differently.

The practical conclusion is this: when choosing dates, look not only at the holiday calendar but at the structure of your own pay. Taking leave immediately after a period with strong variable components can mean better-paid leave. That is not a trick but an understanding of how the calculation works; and if a dispute arises, this base is precisely what will be argued about.

What to do if a leave request is refused

The right to leave and the DATE on which it is taken are not the same thing. The right comes from the law; the date depends on the schedule, the workload and the employer's approval. A single refusal is therefore not by itself a breach of the right — the breach is the worker being effectively prevented from taking leave across the whole year and the days being pushed towards the limitation date. The distinction turns on whether this is one refusal or a pattern.

Where refusal becomes a pattern, the route is written and sequential: put the request and the refusal in writing, refer to the schedule, state your remaining days and the limitation date, and if nothing changes, complain to the Labour Inspectorate. The point of that sequence is this: an inspection looks not at one refusal on one date but at the employer failing to allow leave across the year — and only correspondence can show that.

For workers posted to Bulgaria there is a separate track: paid annual leave forms part of the minimum set of conditions applicable to posted workers, and the Inspectorate publishes a dedicated information page about it. So even where your contract is governed by another country's law, you enjoy a minimum protection on leave for the duration of your posting in Bulgaria.

Splitting leave, recall and interruption

Leave may be taken in parts; the law does not require it to be taken in one block. That said, the purpose of leave is rest, and splitting it into single days in a way that defeats that purpose is problematic both for the worker and in an inspection. The common arrangement is to take part of the leave as a summer block and spread the remainder through the year.

Being recalled to work during leave is exceptional and does not happen automatically. If leave is interrupted, the remaining days are not lost; the unused portion stays available. Equally, the leave of someone who falls ill and produces a sick note is not treated as consumed for the days covered by that note. In both cases documentation is decisive: the recall must be in writing and the sick note must be in the system.

Leave under part-time and fixed-term contracts

A part-time worker's annual leave entitlement is not reduced in proportion to a full-time worker's: leave is counted in DAYS, and someone working three days a week earns the same number of working days of leave. What differs is the monetary value of those days, because payment is based on the person's own average daily pay. This is where part-time workers are most often misled, and the sentence „your leave is half as well“ is, as a rule, wrong.

Under fixed-term contracts the question is whether four months of service fit inside the term. On a six-month contract the four months are reached and the right to take leave arises; on a three-month contract they are not, and unused leave is paid as compensation when the contract ends. In tourism and agriculture, where seasonal work is the norm, this distinction recurs every year and is the most frequently skipped line in the end-of-season settlement.

The three commonest mistakes newcomers make

The first mistake is treating leave as calendar days — which leads to poor planning all year and the feeling in December that the days have run out. The second is reading the four-month condition as „no leave in the first year“; in fact, once four months are completed the full entitlement for that year arises. The third is hearing about the two-year limitation and planning to „wait two years and take them all at once“: the two years are a margin of flexibility, not a savings account, and when the window closes the right disappears.

The remedy for all three is a single habit: twice a year, ideally in June and November, ask payroll in writing for your remaining day count. The written answer is both your own record and, if needed, your evidence; verbal confirmation is worth nothing at the moment of separation.

How to verify this page today

Leave provisions change through amendments to the Labour Code and updates to secondary legislation, and the additional-leave lists live at ordinance level. The information here is tied to official sources as at 24 August 2026; before making a claim or accepting a settlement on departure, confirm the current value on the official page: the МТСП page „Отпуски“ for the general frame, the Labour Inspectorate's guidance „Ред за ползване и отлагане на платен годишен отпуск“ for procedure, the same agency's publication on limitation, and the relevant ordinance for additional-leave lists.

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