The internal reporting channel duty in Bulgaria

2023-05-04 (three months after publication in State Gazette No. 11 of 2 February 2023)..

Private sector employers with 50 or more workers or employees ("работодателите в частния сектор с 50 и повече работници или служители", Art. 12(1)(2)). Public sector employers regardless of headcount, except municipalities under Art. 12(2). No threshold for private sector employers, whatever their headcount, whose activity falls within the scope of the EU acts listed in Part I, letter B and Part II of the Annex to Art. 3(1) and (3) - financial services, products and markets, AML/CFT, transport safety, environmental protection (Art. 12(1)(3)).

17 December 2023. Final provision §10: the Act entered into force three months after publication, but Chapter Two, Section I (Articles 12-18, i.e. the whole internal-channel regime) applies to private sector employers with between 50 and 249 workers or employees from 17 December 2023. Private employers with 250+ were covered from 4 May 2023.

Not accepted. Art. 9, as amended by SG 38/2025: "Не се образува производство по анонимни сигнали" - no proceedings are opened on anonymous reports. Reinforcing this, the mandatory report form approved by the national body must contain the reporter's three names, address and telephone plus a signature, electronic signature or other identification (Art. 15(2) and (3)). Art. 10 gives protection only to a person who reported anonymously outside the procedure of this Act, or made an anonymous public disclosure, and was subsequently identified and subjected to retaliation. Bulgaria is the clearest "no" of the six.

Комисия за защита на личните данни (КЗЛД) / Commission for Personal Data Protection - designated by Art. 19(1) as the central body for external reporting and for the protection of persons entitled to protection under the Act. It organises receipt of reports and routes them to the competent bodies, issues guidance to obliged entities, approves the report form and register model, and its chair issues the penal decrees (Arts. 19, 46, and §7 and §9 of the final provisions).

Out of date as currency. Bulgaria joined the euro area on 1 January 2026; the lev is no longer Bulgaria's currency and amounts in legislation apply redenominated at the irrevocable rate 1.95583 BGN = 1 EUR. Restate in euro: Art. 41(1) EUR 511.29-2,556.46 (natural person); Art. 41(2) EUR 2,556.46-10,225.84 (legal person / sole trader); Art. 41(3) EUR 2,556.46-5,112.92 or EUR 5,112.92-15,338.76 on repeat; Art. 42(1)(1) EUR 204.52-2,045.17; Art. 42(2) EUR 511.29-3,578.10; Art. 43 EUR 1,022.58-4,090.34. Drop the "about EUR 10,200 at the fixed rate" gloss, which reads as if the lev were still live.

Yes. Art. 14(5): obliged entities under Art. 12(1)(2) and (3) - i.e. private sector employers - "могат да възлагат функциите по приемане и регистриране на сигнали за нарушения и на друго физическо или юридическо лице извън своята структура", may assign the functions of receiving and registering reports to another natural or legal person outside their own structure, provided the requirements of the Act are met. Note the wording covers receipt and registration; the entity retains the substantive review and follow-up duties, and must still designate one or more employees responsible for examining reports (Art. 14(1)).