Bulgaria Employment Guide · Reviewed 18 August 2026

Employer of Record vs Staff Leasing in Bulgaria: What’s the Difference?

The terms are often used as if they describe two completely different legal models. In Bulgaria, the distinction is more nuanced. Employer of Record is an international commercial description, while temporary-work and staff-leasing arrangements are specifically regulated under Bulgarian labour law.


Employer of Record


Staff Leasing

Quick answer

In Bulgaria, Employer of Record and staff leasing should not automatically be treated as two separate legal categories.
EOR describes the commercial service a client is buying. Staff leasing, or temporary work, describes a regulated Bulgarian employment structure in which a registered provider employs a worker and sends that worker to perform temporary work for a user undertaking.

EOR vs staff leasing at a glance

The terminology can overlap commercially, but the underlying legal relationship matters more than the name used on a website or proposal.

Question Employer of Record Staff leasing / temporary work
What is it? An international commercial term describing a service where a local provider handles the employment relationship and related administration. A specifically regulated Bulgarian temporary-work arrangement.
A separate Bulgarian legal category? Not by that English commercial name. Yes. Bulgarian labour legislation contains specific provisions for enterprises providing temporary work.
Who employs the worker? Depends on the legal structure used to deliver the EOR service. The registered temporary-work undertaking concludes the employment contract.
Who directs the day-to-day work? Depends on the underlying arrangement. The employee performs the assigned work at the user undertaking under its direction and control.
Provider registration Check the Bulgarian structure actually being used. The temporary-work provider must be registered with the Bulgarian Employment Agency.
Typical buyer International employer looking for a local employment solution without immediately building its own Bulgarian infrastructure. Company using workers supplied through a registered Bulgarian temporary-work provider.

Why the terminology causes confusion

Employer of Record has become a standard international term used by global employment providers. A foreign company may therefore search specifically for an “EOR in Bulgaria” because that is the service category it already understands.

Bulgarian law, however, is concerned with the actual employment relationship rather than the marketing terminology. Where a Bulgarian provider hires an employee in order to send that employee to perform temporary work for another undertaking under that undertaking’s direction and control, Bulgaria’s rules governing enterprises that provide temporary work become relevant.

That is why a buyer should ask an EOR provider how the proposed employment relationship will actually be structured in Bulgaria.

How staff leasing works in Bulgaria

Under the Bulgarian temporary-work framework, there are three important parties.

The employment provider

The registered Bulgarian undertaking concludes the employment contract and performs the employer obligations assigned to it by law.
The employee

The employee has a labour relationship with the employment provider and is assigned to perform work at the user undertaking.
The user undertaking

The user undertaking directs and controls the immediate performance of the assigned work and also has statutory responsibilities under the arrangement.

How an EOR service can fit into this

A company outside Bulgaria may simply want one outcome: employ a person locally without first building its own Bulgarian payroll, HR and employment infrastructure.

Commercially, that service may be described as Employer of Record. The provider can handle the local employment contract, payroll administration, statutory employer processes and related HR administration according to the structure agreed for the assignment.

The important point is that the EOR label itself does not replace Bulgarian labour law. The actual working arrangement must fit an appropriate Bulgarian structure.


What should an international employer ask?

Ask the provider: Who will sign the Bulgarian employment contract? What legal structure will be used? Who will direct the employee’s work? Is the provider registered for the activity it proposes to perform? Those answers matter more than whether the proposal is labelled “EOR”, “staff leasing” or “employment outsourcing”.

Which option should you use?

Start with the business situation, not the terminology.

You want to hire your first person in Bulgaria

An EOR-style local employment solution may be worth considering if you are not ready to establish your own Bulgarian company. Read our guide to hiring employees in Bulgaria without opening a Bulgarian company.

You need temporary or flexible staffing

A properly structured staff leasing arrangement may be appropriate when workers will be employed by a registered provider and assigned to your business.

You are building a permanent Bulgarian operation

As the team becomes larger or more permanent, establishing your own Bulgarian entity and employment infrastructure may become commercially preferable.

You still need to find the candidate

Employment structure and candidate sourcing are separate questions. IC Recruiting can combine local employment support with recruitment in Bulgaria.

Frequently asked questions

Is EOR the same thing as staff leasing in Bulgaria?

Not necessarily. EOR is a commercial term. Staff leasing or temporary work is a regulated Bulgarian employment arrangement. An EOR service may use a Bulgarian employment structure that overlaps with temporary-work rules, depending on how the employee will actually work.

Who is the legal employer under staff leasing?

The registered temporary-work undertaking concludes the employment contract with the worker. The employee is then sent to perform the assigned temporary work at the user undertaking.

Does the client manage the employee?

Under the Bulgarian temporary-work framework, the employee performs the assigned work at the user undertaking under its direction and control. Employer obligations are allocated between the parties according to Bulgarian law and the agreed arrangement.

Does a Bulgarian staff-leasing provider need to be registered?

Yes. The Bulgarian Employment Agency maintains a public register of enterprises that provide temporary work.

Can IC Recruiting provide both recruitment and employment support?

Yes. We can recruit candidates and separately discuss the appropriate local employment structure where the client does not intend to employ the successful candidate through its own Bulgarian entity.

Which is better, EOR or staff leasing?

Neither term is automatically better. The correct structure depends on the role, duration, working relationship, employer location and how the employee will be managed. The legal structure should be selected first and the commercial service label second.

Registered Bulgarian Provider

IC Recruiting

IC Recruiting is a Sofia-based recruitment and employment-services provider supporting Bulgarian and international employers.

Temporary employment registration No. 453 / 02.10.2023. Recruitment registration No. 2087 / 22.07.2016. Registration information can be verified through the Bulgarian Employment Agency.

Sources checked for this guide

This page provides general commercial information and is not individualized legal, tax or immigration advice. The appropriate structure should be assessed using the facts of the specific employment arrangement.

Not sure which Bulgarian employment structure fits?

Tell us where your company is established, what position you need, how the employee will work and whether you already have a Bulgarian entity. We can discuss the recruitment and employment options relevant to the assignment.


Discuss Hiring in Bulgaria