Social Security (Minimum Standards) Convention, 1952 (No. 102) - Bulgaria (Ratification: 2008)

Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on social security, the Committee considers it appropriate to examine Conventions Nos 12 (workers’ compensation, agriculture), 44 (unemployment benefit), and 102 (minimum standards) together.

The Committee notes the observations of the Confederation of Independent Trade Unions in Bulgaria (CITUB), received on 19 September 2025. The Committee requests the Government to provide its comments in this respect.

Article 1 of Convention No. 12. Seasonal agricultural workers. The Committee notes the Government’s indication in its report that the duration of cash benefits for temporary incapacity for work due to employment injury provided to persons engaged in short-term seasonal agricultural work has been extended from 90 to 120 calendar days (section 42(4) of the Social Insurance Code). The Committee further notes that cash benefits for temporary incapacity for work due to employment injury are provided to other insured persons until the restoration of working capacity or until the establishment of disability (section 42(1) of the Social Insurance Code). The Committee recalls that Article 1 of the Convention requires the extension to all agricultural wage earners of all legal provisions for compensation for work injuries. The Committee therefore requests the Government to provide information on the measures taken or envisaged to ensure that short-term seasonal agricultural workers benefit from the same protection as other workers concerning the duration of cash benefits for temporary incapacity for work due to employment injury.

Part II (Medical care), in conjunction with Article 71(3), of Convention No. 102. General responsibility of the State for the due provision of benefits. The Committee notes that the Government does not provide specific information on the provision of medical care benefits. The Committee further notes that the 2025 European Commission Country Report on Bulgaria indicates significant challenges in accessing healthcare, including low health expenditure, high out-of-pocket payments, insurance coverage gaps, and persistent shortages of nurses and general practitioners (pp. 109–111). The Committee once again recalls that, in accordance with Article 71(3) of the Convention, a Member shall accept general responsibility for the due provision of the benefits and shall take all measures required for this purpose. The Committee therefore reiterates its request to the Government to provide information on the necessary measures taken or envisaged to improve access to medical care benefits for all persons protected.

Article 10(1)(b) of Convention No. 44 and Article 20, in conjunction with Article 69, of Convention No. 102. Concept of suitable employment. In its previous comments, the Committee noted that the wage rates offered to unemployed persons for a job could be lower than the wages or remuneration they previously received. The Government indicates that, under paragraph 1, item 4 of the Supplementary Provisions of the Employment Promotion Act, during the first 12 months after a person registers as unemployed at the Labour Office, "suitable work” means work that matches the person’s education, qualifications, or professional experience, health condition, and is located within the same settlement or up to 50 km away with appropriate public or employer-provided transportation. According to the Government, the wage rate offered for a job is not a legally established criterion for assessing whether the work is suitable. The Government further indicates that, since the beginning of 2025, the registration of 635 unemployed persons has been terminated because they refused to accept suitable work, accounting for 1.77 per cent of all terminations due to failure to meet obligations.

The Committee once again recalls that, according to Article 10(1)(b) of Convention No. 44, claimants may be disqualified for the receipt of benefits or of an allowance for an appropriate period if they refuse an offer of suitable employment and that employment shall not be deemed to be “suitable”, among others, if the rate of wages offered is: (i) lower than those which unemployed persons might reasonably have expected to obtain, having regard to those which they habitually obtained in their usual occupation in the district where they were last ordinarily employed or would have obtained if they had continued to be so employed (where the employment offered is employment in the claimants’ usual occupation and in that district); or (ii) in all other cases, lower than the standard generally observed at the time in the occupation and district in which the employment is offered. The Committee therefore requests the Government to provide information on the measures taken or envisaged to ensure that wage rates are considered in the definition of “suitable work”, particularly in cases where unemployment benefits are terminated due to refusal to accept suitable work.

Part V (Old-age benefit), Article 26(2), in conjunction with Article 29(1), of Convention No. 102. Pensionable age. The Committee notes from the Government’s report that the insurance period for the entitlement to an old-age pension is expected to increase to up to 37 years for women and 40 years for men by 2027. Furthermore, the pensionable age is set to increase to 65 years for women by 2037 and for men by 2029. The Government also indicates that, in cases of an insufficient insurance period, the right to an old-age pension is granted after completing 15 years of insurance upon reaching 67 years of age.

The Committee recalls that, in accordance with Articles 26(2) and 29(1) of the Convention, an old-age pension at the rate guaranteed by the Convention shall be provided to persons protected at age 65 after completing 30 years of contribution or employment. The Committee further recalls that, under Article 26(2) of the Convention, the pensionable age may be fixed higher than 65 years by the competent authority with due regard to the working ability of elderly persons in the country concerned. The Committee further observes that in Bulgaria, persons with 15 to 30 years of insurance period are entitled to an old-age pension at age 67. The Committee therefore requests the Government to provide information on the working ability of older persons, including, for example, data on healthy life expectancy, disability-free life expectancy, and the employment rate among persons older than 65 years in Bulgaria.

Part VI (Employment injury benefit), Article 34, and Part VIII (Maternity benefit), Article 49of Convention No. 102. Cost-sharing. The Committee notes with regret the absence of information in the Government’s report concerning the cost-sharing rules. The Committee reiterates its requests to the Government to confirm that cost-sharing for medical care is not required for the contingencies of (i) employment injury and (ii) pregnancy, confinement, and their consequences, and to supply the corresponding legal provisions.

Article 37of Convention No. 102. Benefits in case of temporary incapacity for work. The Committee notes the Government’s indication that there is currently no coverage by benefits for temporary incapacity for work in respect of persons whose occupational diseases appear one month after the termination of their employment contract. The Government further indicates that, if an occupational disease occurred before the termination of the legal relationship, there is no restriction in Bulgarian social security legislation on the payment of benefits. The Committee requests the Government to indicate whether a worker is entitled to benefits for temporary incapacity due to an occupational disease contracted in a previous job if its symptoms appear while employed in a new job.

Part VII (Family benefit), Article 44 of Convention No. 102. Total value of family benefits. The Committee takes note of the information provided by the Government concerning the total value of family benefits.

Part XI (Standards to be complied with by periodical payments) of Convention No. 102. The Committee notes the calculations of the benefits replacement rates provided by the Government. However, it observes that these calculations are based on a comparison of average benefit amounts and average insured income. The Committee recalls that replacement rates shall be determined by comparing the benefit amount provided to a standard beneficiary with the reference wage, in line with the requirements of Articles 65 or 66 of the Convention. The Committee therefore requests the Government to recalculate the replacement rates of old-age, employment injury, and survivors’ benefits, in accordance with Titles I-IV of the report form for Articles 65 or 66 of the Convention. Additionally, the Committee requests the Government to provide data on the adjustment of benefits in accordance with Title VI of the report form. The Committee recalls that the Government can avail itself of the technical assistance of the ILO in this regard.

Part XII (Equality of treatment of non-national residents), Article 68, in conjunction with Article 1(1)(b), of Convention No. 102. The Government indicates that a permanent residence permit is provided to foreigners who have legally and continuously resided in Bulgaria for five years before applying for permanent residence status and have not been absent for more than 30 months during this period (section 25 of the Act on Foreigners). The Committee further observes that foreign workers can apply for a single permit for residence and work, which is issued for a three-year period or less if the employment duration is shorter (section 24i of the Act on Foreigners). The Committee requests the Government to indicate whether social insurance benefits provided under the Social Insurance Code cover foreigners holding a single permit for residence and work.

Part XIII (Common provisions), Article 69 of Convention No. 102. Suspension of benefits. The Committee takes note of the Government’s indication that, under section 46 of the Social Insurance Code, the suspension of benefits for temporary incapacity for work resulting from hooliganism or other anti-social acts is based on law enforcement procedures involving an established violation under the Administrative Offences and Penalties Act and a court ruling imposing a coercive administrative measure.

Article 71(3) of Convention No. 102. General responsibility of the State. The Committee takes note of the Government’s indication that the National Social Security Institute produces actuarial reports every three years, which contain forecasts and analyses of the long-term financial state and sustainability of the mandatory social security system.

Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Part VI (Employment injury benefit), Article 36of the Convention. Benefits in case of permanent incapacity for work below 50 per cent. The Committee notes the Government’s indication in its report that, pursuant to section 25 of the Ordinance on Medical Expertise, when the permanently reduced work capacity is below 50 per cent, but the health condition of insured persons requires them to work under alleviated conditions, including a reduced working day, they can be reassigned to work with the possibility of taking sick leave for up to two years. The Committee further notes the Government’s indication in its 2024 report, submitted under article 19 of the ILO Constitution, that in cases where the permanently reduced work capacity is below 50 per cent, the disability pension due to employment injury is terminated.

The Committee recalls that, according to Article 36 of the Convention, periodic cash benefits shall be provided in respect of partial permanent incapacity for work due to employment injury. The Committee further recalls that periodic cash benefits may be converted into a lump sum where the degree of incapacity is slight, which has been previously considered by the Committee as a degree of disability up to 30 per cent (see the Committee’s 2025 General Survey, Achieving comprehensive employment injury protection, paragraph 245). The Committee, however, observes that in Bulgaria, no cash benefits are provided for permanent incapacity for work below 50 per cent for the entire period of such incapacity. The Committee therefore requests the Government to take measures to ensure the provision of periodic cash benefits in respect of permanent incapacity for work below 50 per cent due to employment injury.

The Committee is raising other matters in a request addressed directly to the Government.

Direct Request (CEACR) - adopted 2019, published 109th ILC session (2021)

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on social security, the Committee considers it appropriate to examine Conventions Nos 44 (unemployment benefit) and 102 (minimum standards) together.

Part II (Medical care), in conjunction with Article 71(3) of Convention No. 102. General responsibility for the due provision of the benefits. In its previous comments, the Committee referred to the 2010 conclusions of the European Committee of Social Rights (ECSR) on article 11 of the European Social Charter (ESC) indicating that the medical services available in Bulgaria for poor or socially vulnerable persons who lost entitlement to social assistance were not sufficient and requested the Government to provide information on the application of this Part of the Convention by the national social assistance and social insurance schemes. The Committee notes the information submitted by the Government in its report regarding the provision of medical care benefits under the Health Insurance Act of 1998 and the indication that, within the framework of the medical services package guaranteed by the National Health Insurance Fund (NHIF), all citizens have equal rights of access to medical aid. The Committee also notes the information provided by the Government in its report submitted under article 19 of the ILO Constitution in 2018, indicating that the Ministry of Health grants subsidies to hospitals and medical treatment facilities located in regions difficult to access across the country. On this issue, the Committee notes the observations of the Confederation of Independent Trade Unions in Bulgaria (CITUB) communicated with the Government’s report under article 19 of the ILO Constitution in 2018, which point out the insufficient funding of healthcare institutions at the municipal level. In addition, the Committee observes that the 2017 conclusions of the ECSR, state that “it has not been established that sufficient measures have been taken to effectively guarantee the right of access to health care”. In particular, the ESCR refers to the 2015 European Commission Country Report Bulgaria, which indicates that “the healthcare system faces major challenges, including limited accessibility, low funding, and poor health outcomes”. The 2017 conclusions of the ECSR further point out that “limited access to healthcare is illustrated by the high share of reported unmet medical needs, mainly due to costs”. Recalling that, in accordance with Article 71(3) of the Convention, a Member shall accept general responsibility for the due provision of the benefits provided in compliance with the Convention, and shall take all measures required for this purpose, the Committee requests the Government to provide information on the measures taken or envisaged to improve the access to medical care benefits for all persons protected.

Article 10(1)(b) of Convention No. 44 and Article 20 of Convention No. 102, in conjunction with Article 69. Concept of suitable employment. In its previous comments on Convention No. 44, the Committee requested the Government to indicate whether, under the current definition of suitable employment established by the Supplementary provisions to the Employment Promotion Act of 2016, a beneficiary could be deprived of the right to unemployment benefit if he or she does not accept a job where the minimum wage would be less than the amount of the unemployment benefit otherwise due to this beneficiary. The Government indicates in its report that the amount of labour remuneration in relation to the unemployment cash benefit is not taken into account in the determination of what constitutes an “appropriate job”, according to subparagraph 4(1) of the Supplementary provisions to the Employment Promotion Act of 2016. It further indicates that in accordance with article 20(4) of the Employment Promotion Act of 2002, the registration of unemployed persons shall be terminated if they refuse to accept an appropriate job offered to them. The Committee notes that the amount of unemployment benefit, according to section 54(b) of the Social Insurance Code of 1999, is determined as a percentage of the unemployed person’s former wages (60 per cent). It noted subsequently that where the wages for a job offered to an unemployed person are lower than the amount of unemployment benefit this person is entitled to, these wages will necessarily be lower than the unemployed person’s previous wages or remuneration. In this regard, the Committee recalls that, according to Article 10(1)(b) of Convention No. 44, claimants may be disqualified for the receipt of benefit or of an allowance for an appropriate period if they refuse an offer of suitable employment and that employment shall not be deemed to be “suitable”, among other, if the rate of wages offered is lower than those which unemployed persons might reasonably have expected to obtain and where the employment offered is employment in the claimants’ usual occupation and in the district where they were last ordinarily employed, or in all other cases lower than the standard generally observed at the time in the occupation and district in which the employment is offered. In light of the above, the Committee requests the Government to take the necessary measures to ensure that the payment of unemployment benefits will not be suspended in case of refusal by an unemployed person to accept a job where the minimum wage is less than the amount of the unemployment benefit otherwise due. The Committee further requests the Government to provide statistical data on the number of cases where unemployment benefits were suspended as a result of refusal to accept a job where a salary is lower than the amount of received unemployment benefit.

Part V (Old-age benefit). Article 26(2) of Convention No. 102, in conjunction with Article 29(2). Pensionable age for reduced old-age pension. The Committee notes the Government’s indication that pursuant to section 68 of the Social Security Code of 1999, as of 31 December 2016, the insurance period required for receiving full old-age pension will be increased each year by two months until attainment of 37 years for women and 40 years for men by 2027. It further notes, as indicated by the Government, that the pensionable age will be also increased by two months every year until attainment of 65 years for women and men by 2037. The Government further points out that if a person has an insufficient period of insurance, the right to the old-age pension will be acquired after having completed 15 years upon reaching 66 years and four months for men and women in 2019 and 67 years by 2023. The Committee recalls that, in accordance with Articles 26 and 29(2) of the Convention, a reduced old-age pension shall be secured to persons protected who have completed a qualifying period of at least 15 years of contribution or employment upon reaching pensionable age, which shall be not more than 65 years or such higher age as may be fixed by the competent authority with due regard to the working ability of elderly persons. The Committee therefore requests the Government to indicate whether a reduced old-age pension is provided to persons protected who have completed a qualifying period of 15 years of insurance or employment upon reaching the normal statutory pensionable age.

Part VI (Employment injury benefit). Article 34 and Part VIII (Maternity benefit), Article 49. Cost-sharing. The Committee once again requests the Government to confirm that cost-sharing of medical services is not required for the contingencies of employment injury and pregnancy, confinement and their consequences in accordance with Articles 34 and 49 of the Convention, and to supply the corresponding legal provisions.

Part VI (Employment injury benefit). Article 36. Payment for permanent incapacity below 50 per cent. The Committee once again requests the Government to indicate what benefit is provided to the victims of employment injuries who have permanently lost less than 50 per cent of their working capacity.

Article 38. Duration of the benefit. The Committee once again requests the Government to explain what coverage exists for persons whose occupational diseases manifest themselves over a month after the termination of their employment contract or insurance coverage.

Part VII (Family benefit). Article 44. Total value of family benefits. The Committee requests the Government to provide statistical data on the total value of family benefits in accordance with the report form for the Convention.

Part XI (Standards to be complied with by periodical payments). The Committee reiterates its request to provide statistical information on the level of old-age, employment injury and survivors’ benefits and their substantial changes in the cost of living required by Titles I-VI of the report form under Articles 65 and 66 of the Convention.

Part XII (Equality of treatment of non-national residents). Article 68, in conjunction with Article 1(1)(b). The Committee reiterates its request to explain the qualifying conditions for achieving permanent residence in Bulgaria and supply the relevant legal provisions.

Part XIII (Common provisions). Article 69. Suspension of benefits. The Committee reiterates its request to explain how section 46 of the Social Insurance Code, according to which cash benefits for temporary incapacity for work are suspended where insured persons have lost their capacity for work due to “hooliganism and other anti-social behavior”, is applied in practice and provide examples of the types of activities that would lead to the suspension of benefits.

Article 71(3). General responsibility of the State. The Committee once again requests the Government to indicate whether actuarial studies and calculations concerning financial equilibrium are made periodically and, in any event, prior to any change in benefits, the rate of insurance contributions or the taxes allocated to covering the above contingencies.

Direct Request (CEACR) - adopted 2012, published 102nd ILC session (2013)

The Committee takes note of the Government’s first report received in July 2011 on the application of the accepted Parts II, III, V, VI, VII, VIII, and X of the Convention and would be grateful to receive additional information on the following points.

Part II (Medical care). The Committee notes that according to the 2010 conclusions of the European Committee of Social Rights on article 11 of the European Social Charter, the medical services available in Bulgaria for poor or socially vulnerable persons who have lost entitlement to social assistance are not sufficient. The Government is invited to explain with reference to the corresponding provisions of the national legislation, how and to what extent the social assistance scheme gives effect to Part II of the Convention in addition to the health insurance scheme.

Part VI (Employment injury), and Part VIII (Maternity benefit). Cost-sharing. According to section 37 of the Health Insurance Act, protected persons are required to participate in dentist and physician fees at a rate of 1 per cent of the national minimum monthly wage per visit, and 2 per cent of the national minimum wage for each day of hospital treatment for a maximum of ten days per year. The Committee notes that while this section exempts certain categories of persons from the payment of these fees, it does not include pregnant and confined women and persons suffering from an occupational accident or disease. The Government is requested therefore to confirm that cost-sharing of medical services is not required for the contingencies of employment injury and pregnancy, confinement and their consequences in accordance with Articles 34 and 49 of the Convention, and to supply the corresponding legal provisions.

Part VI (Employment injury). Article 36. Payment for permanent incapacity below 50 per cent. According to sections 41, 42 and 78 of the Social Insurance Code, insured persons receive a periodical payment for permanent invalidity where insured persons have lost 50 per cent or more of their working capacity. Please indicate what benefit is provided to the victims of employment injuries who have permanently lost less than 50 per cent of the working capacity.

Article 38. Duration of the benefit. According to section 42 of the Social Insurance Code, cash benefits in case of temporary disability caused by an occupational disease occurring 30 days after the termination of an employment contract or insurance coverage are paid for no more than 30 calendar days. Please explain what coverage exists for persons whose occupational diseases manifest themselves over a month after the termination of their employment contract or insurance coverage.

Part XI. Standards to be complied with by periodical payments. The Government is asked to provide in its next report statistical information required by the report form under Articles 65 and 66 of the Convention to enable the Committee to assess the level of benefits granted and to ensure that old age, employment injury and survivors’ benefits are reviewed following substantial changes in the cost of living.

Part XII. Article 68. Equality of treatment, in conjunction with Article 1(1)(b). The Committee notes that both under the compulsory insurance scheme and the social assistance scheme, access to benefits by foreign citizens is conditional on permanent residence. In this respect, the Committee also takes note that in its 2009 conclusions on article 13 of the European Social Charter, the European Committee on Social Rights determined that foreign nationals were subject to an excessively long condition of continuous presence in Bulgaria to be entitled to social assistance. The Committee recalls that for the purpose of social security coverage, Article 1(1)(b) defines residence as “ordinary residence in the territory of the Member and the term “resident” means a person ordinarily resident in the territory of the Member”. The Committee would invite the Government to explain the qualifying conditions for achieving permanent residence in Bulgaria and supply the relevant legal provisions.

Part XIII (Common Provisions). Article 69. Suspension of benefits. According to section 46 of the Social Insurance Code, cash benefits for temporary incapacity to work in case of sickness, employment injury and pregnancy and childbirth are suspended where insured persons have lost their capacity due to hooliganism and other anti-social behaviour which have been ascertained according to the relevant procedure. The Committee would like the Government to explain how this section is applied in practice and provide examples of the types of activities that would lead to the suspension of benefits.

Article 71(3). General responsibility of the State. Please indicate whether actuarial studies are performed periodically and under which legal provisions.