Actions taken by Sb Accounting & Consulting

Bulgaria declared a State of Emergency over COVID-19 on 13th of March 2020.

Regarding the serious measures taken by the Government, we would like to let You know that our main priorities are to ensure the health of Team members, Partners and their families, as well as to provide the continuity of our business processes that support Your corporate activity.

Sb maintains a stable business continuity management program. The company designed its strategy and response plans that ensures the availability of our workforce, technologies and workplaces.

Our Contingency plan provides 95% of the Team working home office in order to #StaySafe and to protect their health, but on the other hand to continue the service to our clients smoothly and provide the same level of support.

Sb Team will keep all agreed deadlines and timelines as per the calendar events!

Actions taken by the Government and the State

60% compensations for companies that have terminated the work of the enterprise or have transferred to part-time work during the State of Emergency.

New list of activities:

  • Retail trade (except of motor vehicles and motorcycles)
  • Different types of passenger transport and air transport
  • Hotels and other similar accommodation
  • Restaurants, fast food and drinking establishments, Cinemas
  • Travel agency and operator activity; other travel and booking activities
  • Artistic, creative activity and other cultural activities
  • Pre-school activity
  • Sports and other activities related to leisure and recreation, maintaining good physical condition
  • Congresses and trade fairs organization
  • Companies from different sectors, which prove that the revenue fell more than 20% in March 2020 compared to March last year

Full list of activities and code under the Classification of economic activities.

List of activities that are NOT included:

  • Agriculture, forestry and fisheries
  • Financial and insurance activities
  • Government sector
  • Human health and social activities
  • Education sector (excluding private kindergartens)

During the State of Emergency, different measures were adopted and enhanced, including closing of schools and universities, closure of restaurants and shopping centers (except those for food delivery and pharmacy), cancellation of all public and group events. Currently the measures are even tighter and including travel restrictions within Bulgaria and abroad.

Changes in the tax accounting periods and deadlines:

  • Extending the terms for 2019’s Annual Accounting Closure – by 30th June for filling the Annual Tax Returns, Reports to the Statistics and Non Activity Declarations for dormant companies
  • Extending deadline for publishing the Annual Financial Statements until 30th of September 2020
  • Extended deadlines for publishing the Audit Transparency Report until 31st of July 2020
  • Extended deadlines for the Audit committee to prepare and present the Annual activity report until 30th of September 2020

Advanced installments for Profit Tax under the Corporate Income Tax Act (CITA) shall be made as follows:

  • When the Annual Tax Return for 2019 is submitted before the entry into force of the “Measures and Actions during a State of Emergency Act”, the advance installments shall be made in the amount as declared. If it is necessary, a correction could be done.
  • When the Annual Tax Return for 2019 is filed by 15 April 2020, the advance installments shall be made as the amount is declared
  • When the Annual Tax Return for 2019 has not been submitted by 15 April 2020, the advance installments shall be declared in accordance with the previous model of the Annual Tax Return.

Changes concerning Labour and Social Security Law, giving more flexibility to the Employers during the State of Emergency:

  • Option for unilaterally assigning of home office for the Employees
  • Option for reducing the working time schedule from full time to part time
  • Option for unilaterally assigning half of the annual paid leave entitlement
  • Temporary suspension of work due to the State of Emergency
  • Compensation in amount of 60% from the Employees’ social insurance income for January 2020 for certain business entities, defined by the Council of Ministers (such as hotels, restaurants, travel agencies, passenger transport providers and other defined as most affected by the crisis)

Important changes tailored to the individuals and work of the institutions:

New distrains over bank accounts of individuals, medical establishments and over labor remuneration and pension payments should not be imposed. The law regulates exceptions and the above restrictions do not apply to child support claims, tort claims and claims for labor remuneration.

All distrains imposed up to March 24, 2020, shall remain in force and continue to be executed in accordance with the instructions specified in the respective letters of notice.

Other measures:

  • Temporary suspension of sales held by judicial officers
  • Postponement of court cases scheduled to open hearings (excluding those for bankruptcy, child support, child adoption etc.)

The validity of personal documents  expiring from 13 March 2020 to 31 October 2020 is extended by 6 months.

For the period of extension all documents above are considered valid documents only on the territory of the Republic of Bulgaria.

Long-term resident alien in Bulgaria:

  • for whom the term of residence expires within the declared state of emergency, may apply for extension of residence within 14 days after the cancellation of the state of emergency. The period of the declared state of emergency shall not be considered as an interruption when the foreign citizen applies for a long-term or permanent residence
  • of whom the permitted long-term residence expires within the declared state of emergency, may enter the territory of the country without a visa within 14 days after the cancellation of the state of emergency

Notaries and their activities during the declared state of emergency are limited to an urgent only and the Notary Chamber provides notaries on duty.

List of Notaries

Urgent are all cases:

  • In which the parties would suffer from damages, if the notary authentication is not performed in time (for example notary authentication of a power of attorney, which is needed to be released a goods, detained by the National Customs Agency)
  • When there is a risk if the notary authentication is not executed now, it cannot be done at all in the future (for example a testament)
  • Circumstances of a purely life character, and the client as a consequence to have the need to access a notary service, otherwise the client would suffer from property or other damages (for example in case of illness, need of funds, etc.)

Call us for assistance upon necessity of urgent notary certifications with our partner notary!

National Insurance Institute allows submitting a request for Personal Identification Code (PIC) electronically.

Questions and Answers

If the corporate tax return has already been filed, will there be a deferral for tax payment?

Yes, it is extended until 30.06.2020.

How to obtain a certificate that I do not owe taxes and compulsory social security contributions during the state of emergency?

You may request a certificate of existence or lack of public obligations online, by using the NRA’s e-services portal.

How to recover discontinued health insurance rights during the state of emergency?

If your health insurance rights have been discontinued due to unpaid contributions you may file a declaration and pay the health insurance contributions that are due online.

If you recover health insurance rights on another grounds (for example you are full-time student abroad, you have been insured in an EU member state, etc.) and you have to submit documents to the NRA, you can send them scanned via e-mail to the office of the revenue agency as per permanent address.

How to file an income declaration without visiting NRA office if I do not have PIC or electronic signature?

You can fill in the declaration with a barcodeprint it out and send it by registered letter to the NRA office as per your permanent address.

Can I obtain a PIC remotely, without visiting NRA office?

No, you cannot. Issuing a PIC requires a personal visit to the NRA office by the person or a person authorized by him/her with a notarized power of attorney. Until the state of emergency ceases, it is recommended that you do not visit NRA offices unless necessary. 

Can I refer to Article 218 of the Labor Code and pay half salaries for the period during which the facility is closed?

In the present case Art. 218 of the Labour Code is not applicable.
In the case of a declared state of emergency, the employer may, by order, suspend the work of the enterprise, part of the enterprise or individual employees for the whole period or part of it until the state of emergency is canceled. The employer is obliged to pay the gross salary to the employee for the duration of termination of employment.

Can I place employees on paid leave?

During the state of emergency, employers may unilaterally grant up to one-half of the paid annual leave to employees without their request or consent.

When an order of a public authority has terminated the work of the enterprise, part of the enterprise or individual employees, the employer shall be entitled to grant paid annual leave to the employee without his or her consent, including to an employee who has not acquired 8 months of service. In this case, the employer has the right to unilaterally order the use of paid annual leave, including paid annual leave which has been postponed, without the request or consent of the employee.

Can I place employees on unpaid leave?

Unpaid leave is allowed at the request of the employee, and the employer cannot unilaterally grant this type of leave without requesting it.

During the declared state of emergency in the Republic of Bulgaria, the employer is obliged to allow the use of unpaid leave at the request of:

  • Pregnant worker and an advanced worker in vitro
  • Mother or adoptive parent of a child up to 12 years of age or of a disabled child regardless of age
  • Worker or employee who is a single father or adoptive parent of a child up to 12 years of age or a disabled child, regardless of age
  • Worker or employee who is under 18 years of age
  • Employee with permanent disability of 50 and more than 50 percent
  • Employee with the right to protection upon dismissal under Art. 333, para. 1, items 2 and 3

Termination of employees due to reduced workload?

In case of reduction of the workload, the employer has the right to terminate the employment contract with an employee by sending a written notice to him within the statutory terms. Significant for the legality of the dismissal is the actual reduction in the workload (the amount of production, the volume of turnover, the amount of services rendered, etc.). The reduction in the volume of work should relate to the work functions performed by the worker.

Change of working hours from full to part time?

The employer may establish part-time employment for the whole or part of the period for the full-time workers. The length of working time may not be less than half the statutory one for the period of calculation of working time. 

For example, if the calculation of working time is daily, this means that part-time work cannot be entered in less than half of the statutory day. The establishment of part-time work shall be by written order of the employer on a case-by-case basis, specifying the term and the positions for which part-time work and working hours are entered.

Can I refer to Article 306 of the Commercial Code and not pay rent for the period of emergency?

Yes, you can refer to Art. 306 of the Commercial Act and you could not pay rental price during the period of state of emergency, but only if certain prerequisites are in place.

For example, if the order imposing the state of emergency should prohibit the hired by you unit from working – then the fulfillment of the obligations and the related to them counter-obligations is suspended, ie you may not pay rental price. In other words, the state of emergency must be the direct reason because of which the leased unit could not be used.

However, if there is an opportunity to use the rented commercial unit, but there are no customers due to the imposed restrictions with the state of emergency or any other reason, then the institute of economic intolerance could help – the court may, at the request of one of the parties, amend or terminate the contract in whole or partially.

If, despite the force majeure, both parties to the contract have an interest in executing the lease, it may be possible to modify the contract for the duration of the force majeure and to maintain the contract in such a way that it is acceptable to them. In each case, it should be taken into account whether all the prerequisites exist, as well as what are the interests of the parties and whether they are justified. In this regard, it is needed every case to be reviewed individually and a consultation by a specialist to be provided.

Will MultiSport cards subscription fees be deducted from the employee remuneration for March, provided that the service has been suspended since 13.03.2020?

Yes, all invoices for March are due within the deadlines set in the contractual relations, but any paid and unused subscription for March will be reactivated immediately after the service MultiSport has been restored.

In addition:

  • You will not be able to order, activate or deactivate any cards during the State of Emergency
  • You will not be invoiced for April and you don’t need to deduct any subscription fees from the employees’ remuneration for this month


Find useful templates that will help You organize the work processes faster in order to be in compliance with the “Measures and Actions during a State of Emergency Act”.

Traveling within Bulgaria

In order to pass through the checkpoints of regional cities in Bulgaria, each citizen must present:

  • Declaration for the purpose of the trip that shall be provided to each checkpoint, on each passing, so prepare enough number of Declarations for all checkpoints you will pass through!
    Use the Template – Regional City Cross Border Declaration
  • No need Employer authorization of the Declaration
  • ID card
  • Official note issued by the Employer – if the trip is labour related (only one) that is just displayed at each checkpoint

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