Important obligations of the employers by the end of January 2026

Employers that are obligated entities under the Whistleblowing Law are required to submit to the Commission for Personal Data Protection (the “Commission”), by 31 January 2026, statistical information for the previous year regarding the number of reports received, the unique identification numbers (UICs) of the reports, their subject matter, the number of inspections carried out, and the results thereof.

According to the Methodological Guidelines of the Commission, the obligated entities that have not received any reports during the reporting period are not required to submit statistical information to the Commission.

Pursuant to Art. 149, Para. 2 of the Labour Code, employers are required to report the overtime work accumulated during the calendar year 2025 to the Labour Inspectorate by 31 January 2026.

Pursuant to Art. 37a of the Ordinance on Working Hours, Holidays and Leaves, the employers are required to notify each employee in writing, by 31 January 2026, of the amount of paid annual leave which the employee is entitled to use during the calendar year 2026, including any leave deferred or unused from previous calendar years.

Pursuant to Art. 315 of the Labour Code, an employer with more than 50 employees is required to determine annually job positions suitable for placement of persons with disabilities, in an amount ranging from 4 to 10 percent of the total number of employees, depending on the employer’s economic activity. The identification of such suitable job positions shall take place no later than 31 January 2026.

Employers with 50 or more employees are required to prepare annually, no later than the end of January, a list certifying the designated job positions for the fulfilment of the quota under Art. 38, Para. 1 of the Persons with Disabilities Act. The list shall be kept by the employer and shall be presented upon request to the supervisory authorities.

Additionally, please note that, pursuant to Art. 38 of the Persons with Disabilities Act, employers are required to employ persons with permanent disabilities. This obligation shall be fulfilled within the period from 1 January to 31 March 2026. The obligation applies to employers with 50 or more employees, who are required to employ under an employment contract a certain number of persons with permanent disabilities in accordance with a statutory quota, as follows:

—  for employers with 50 to 99 employees – one person;

—  for employers with 100 or more employees – two percent of the average number of employees in the enterprise for the preceding calendar year.

KPMG team is available to assist you in preparing the necessary documents to fulfil the above obligations within the statutory deadline.

Emil Evtimov
Director
Legal Advisory Services
Tel.: +359 2 9697 300

Dilyana Dimitrova
Associate Director
Legal Advisory Services
Tel.: +359 2 9697 300