Given that the National Revenue Agency (NRA) will initially obtain data from the existing registered contracts concerning base salary, does this mean that, in practice, we must register the current base salaries (based on an annex/order) before June 1, 2025?

This is an important question that we have also identified and raised with the relevant authorities.

At this time, it is unclear whether, following the creation of the register, employers will be required to submit an electronic employment record to update information—such as salary—or to introduce data not previously included in the official notification, such as working hours, paid annual leave, or to reflect the new code for remote work (99999), for example.

There is currently no explicit legal obligation for employers to transfer data from paper employment record books into the new register.

It remains to be clarified.

Before June 1, 2025, employers are not required to submit a notification under Article 62, Paragraph 5 of the Labour Code for changes in the base salary.