BIA OPINION ON ORDINANCE OF AMENDMENT AND SUPPLEMENT OF REGULATION № 5 FROM 2002 ABOUT THE CONTENT AND TIMING OF THE NOTIFICATION ON ART. 62, PARA 5 OF THE LABOUR

BIA opinion on Ordinance of amendment and supplement of Regulation № 5 from 2002 about the content and timing of the notification on Art. 62, para 5 of the Labour code

The BIA has sent to the Minister of Labour and Social Policy Mrs. Zornitsa Roussinova its opinion on the Ordinance of amendment and supplement of Regulation № 5 from 2002 concerning the content and timing of the notification on Art. 62, para 5 of the Labour code. The BIA has made suggestions about the content of the Ordinance in order to achieve precision of the newly adopted changes.

By the submission of notification for changes in an already concluded employment contract more data would be required, including the amount of the employee’s remuneration at the date of the contract’s conclusion. The BIA suggests the amount stated in the notification to be at the date of the notification’s submission, in order to trace back the actual amount of remuneration that the employee receives.

Another suggestion of the BIA is directed at the employee’s position designation in the electronic application. There should be a field, in which the employee can write the name of the position that he takes if it is not fully corresponding to the National Classification of Professions and Positions (NCPP).

The BIA suggests also to reduce the time limit of the notification from 30.10.2017 to 30.06.2017, which would allow earlier data introduction for localization of job positions and other characteristics of individual employment contracts, including implementation by the end of the year of a new mechanism for determination of the minimum wage based on objective criteria and up-to-date information.

In conclusion, the BIA expresses its satisfaction with the initiation of changes by which long-standing suggestions of the BIA are implemented such as identifying employment based on a local criteria.