An Occupational Health Service (OHS) in Bulgaria is a registered preventive service that helps employers protect workers' health and meet their workplace health-and-safety duties. In Bulgarian, it is known as a sluzhba po trudova meditsina (STM).

For founders, establishing an OHS is not simply a matter of incorporating a company. The service may operate only after registration with the Bulgarian Ministry of Health, and the applicant must demonstrate the required specialist team, qualifications, and supporting documentation.

This guide explains who may establish an OHS, the minimum staffing rules, the registration file, the Ministry of Health procedure, and the main obligations that continue after registration.

Occupational-health legislation, administrative practice, and official fees can change. Confirm the current requirements with the Ministry of Health before filing. This guide provides general information and does not replace advice on a specific application.

Occupational Health Service in Bulgaria at a Glance

What Is an Occupational Health Service?

An OHS is a unit with primarily preventive functions. It advises and assists employers, workplace health-and-safety committees, and working conditions groups with:

• maintaining healthy and safe working conditions
• protecting workers' health and capacity for work
• adapting work to workers' physical and mental capabilities
• identifying and reducing occupational risks
• monitoring health in relation to workplace conditions
• developing workplace health-and-safety measures and training

The service supports the employer, but it does not take over the employer's legal responsibility for workplace health and safety.

Bulgarian employers must arrange occupational-health coverage for their workers through a registered OHS. An employer can create an internal service where the statutory conditions are satisfied, establish a shared service with other employers, or contract an external registered provider.

The Ministry of Labour and Social Policy provides an official overview of occupational-health services for workers and employees.

Legal Framework and Registering Authority

The principal rules are found in:

1. The Health and Safety at Work Act, particularly the provisions on the creation, registration, staffing, and functions of occupational health services.
2. Ordinance No. 3 of 25 January 2008 on the conditions and procedure for carrying out the activities of occupational health services.

The Minister of Health issues the registration certificate. Registered providers are included in the Ministry's public Register of Occupational Health Services, which employers can use to verify a provider's status.

Commercial Register entry alone does not authorise a business to provide OHS services. The entity must complete the separate Ministry of Health registration before operating as an OHS.

Who May Establish an OHS?

The Ministry of Health identifies the following categories of eligible applicants:

• legal entities or natural persons registered under the Bulgarian Commerce Act
• cooperatives registered under the Cooperatives Act
• entities registered under the Non-Profit Legal Entities Act
• companies established under the law of another EU Member State or a state in the European Economic Area
• employers establishing a service individually or jointly, subject to the statutory rules

Healthcare establishments may also create an OHS, but it must be formed as a separate legal entity.

For an independent commercial provider, an EOOD or OOD limited-liability company is often considered. The structure depends on ownership, management, financing, tax, liability, and the planned scope of services.

Our company registration guide explains the main Bulgarian legal forms and incorporation process. The company's registered activities should accurately cover the services it will provide, but a broad object clause cannot replace the required OHS registration.

Mandatory Minimum Specialist Team

Staffing is one of the most important parts of the application. The minimum team must include:

The Ministry requires notarised copies of the relevant diplomas, specialty certificates, and professional-experience records. For the technical specialist, evidence can include employment, civil-service, or social-insurance records, work performed abroad, job descriptions, orders, and other official documents demonstrating the required experience.

The names on identity and qualification documents must be consistent. If they differ, the Ministry's guidance calls for a municipal identity certificate establishing that the records concern the same person.

The minimum-team members must submit declarations under Article 25b(3). Neither the OHS team nor specialists engaged for particular tasks may include:

• staff of the Ministry of Health, the Ministry of Labour and Social Policy, or their control authorities
• a medical professional who has lost the right to practise under the Health Act
• a person who both holds a National Health Insurance Fund contract and is registered with a Regional Health Inspectorate

These restrictions apply beyond the three-person minimum team, so they should also be checked before any additional specialist is engaged.

Documents Required for OHS Registration

According to the Ministry of Health's current registration procedure and document list, the application file includes:

1. An application to the Minister of Health, signed by the person establishing the service.
2. The applicant's name, registered office, address, and telephone details.
3. A copy of the act or other document establishing the applicant, where applicable.
4. An agreement between the employers when several employers create a shared service.
5. Commercial Register identification data or the applicable current registration evidence for non-profit or EU/EEA applicants.
6. An approved list of the minimum OHS specialist team.
7. Notarised copies of each specialist's education, qualification, and professional-experience documents.
8. Declarations from the minimum-team members under Article 25b(3) of the Health and Safety at Work Act.
9. Proof that the state fee has been paid.

The Ministry currently states that it does not provide a standard form for this procedure. The applicant must therefore ensure that its own application and supporting schedule contain all required information.

Documents issued outside Bulgaria may require Bulgarian translation and appropriate authentication. The exact treatment depends on the issuing country, the document, and any applicable EU rules or international treaty.

Registration Process Step by Step

1. Choose and Establish the Applicant

Decide whether the OHS will be an internal employer service, a shared service, or an independent provider. Establish the appropriate entity and complete any required Commercial Register filings.

2. Secure the Minimum Specialist Team

Confirm the occupational-medicine physician, technical specialist, and technical officer before filing. Review their qualifications, professional experience, and statutory eligibility, then prepare the appropriate contractual arrangements.

3. Collect and Certify the Evidence

Obtain the diplomas, specialty documents, experience records, declarations, and any identity certificate required because of different names. Complete notarisation, translation, or authentication before assembling the final file.

4. Prepare the Application Package

Prepare the application, applicant data, specialist list, registration evidence, declarations, and payment document. Use a document index and check names, dates, qualification descriptions, and signatures across the entire file.

5. Pay the State Fee

The Ministry of Health currently publishes a registration fee of EUR 187.64. Confirm the amount, payment account, reference, and accepted proof of payment immediately before filing.

6. Submit to the Ministry of Health

File the complete package through an accepted Ministry channel. Keep copies of the application, all enclosures, payment evidence, and proof of submission.

7. Respond to Instructions

Within 30 days of filing, the Ministry either handles the complete file or gives written notice of missing or irregular documents. That notice must allow at least 14 days for correction. The Ministry then has 30 days from correction to issue the certificate or a reasoned refusal. A refusal may be appealed under the Administrative Procedure Code.

8. Verify Registration Before Operating

After approval, verify the certificate and the service's entry in the public OHS register. The business should begin providing regulated OHS services only after registration is effective.

How Long Does OHS Registration Take?

The 30-day review period does not include the preparation phase. Recruiting the physician, proving technical experience, notarising qualifications, aligning names, and preparing foreign documents can take longer. A Ministry correction notice also restarts the 30-day decision period once the deficiencies are remedied.

Registration Validity and Changes

OHS registration has no periodic renewal date, but its validity depends on preserving the registered conditions and specialist team. A change to a circumstance registered under Article 25g(1), including identifying details, legal status, shared-employer arrangements, or the minimum team, must be notified in writing to the Minister of Health within seven days, with documents proving the change.

The Ministry's current change-registration procedure publishes a fee of EUR 116.06. The Ministry records the change within 20 days and, for changes to the service's identifying data, shared-employer agreement, or minimum team, also issues a replacement certificate or a reasoned refusal. Loss of the minimum team can lead to deletion from the register; the Act does not provide a grace period in which the service may continue without the required composition.

What Does an OHS Do After Registration?

Registration starts the regulated activity; it does not complete the compliance work. A registered OHS performs preventive and advisory functions that can include:

• participating in workplace health-and-safety risk assessments
• proposing measures to prevent, eliminate, or reduce identified risks
• helping develop workplace health-and-safety rules and instructions
• organising first-aid, self-help, and mutual-aid training appropriate to workplace risks
• monitoring, analysing, and evaluating health in relation to working conditions
• preparing fitness-for-work conclusions within the applicable rules

Contracts should define precisely which services are included, which party performs each task, how information is exchanged, and how urgent events or regulatory requests are handled.

Records, Confidentiality, and Data Protection

An OHS must adopt internal rules covering its structure, procedures, quality controls, document flow, archives, and working time. For each employer served under contract, it keeps a separate file containing the contract and evidence of the work performed.

For every worker, the service maintains the prescribed health dossier on both paper and electronic media. It includes available pre-employment and periodic-examination records, fitness conclusions, TELK/NELK decisions, and National Social Security Institute decisions recognising an accident as occupational. The OHS also prepares an annual aggregate health analysis for each employer and supplies the prior year's analysis to the employer and competent Regional Health Inspectorate by 30 July.

Health dossiers pass directly between services when a worker changes employment and the new OHS requests them, or when an employer appoints a new OHS. If an enterprise closes, the last OHS retains the dossiers. If the OHS closes, it transfers them to the employer only for safekeeping until a new service is engaged; the employer may not access their content. The statutory retention period is 50 years.

Staff must protect the employer's trade secrets and handle medical data under the Health Act and the GDPR. Access controls, transfer protocols, privacy information, security measures, and documented staff duties should be in place before client records are accepted.

Common Registration Mistakes

Avoid these recurring problems:

1. Treating company incorporation as permission to operate an OHS.
2. Filing before every minimum-team role is covered.
3. Relying on job titles instead of official evidence of professional experience.
4. Submitting copies that are not notarised where notarisation is required.
5. Overlooking different names across identity, diploma, and employment records.
6. Using foreign documents without checking translation and authentication requirements.
7. Leaving declarations, signatures, applicant data, or payment evidence incomplete.
8. Failing to create operational, confidentiality, and data-protection procedures before serving employers.
9. Failing to monitor later staffing or registered-circumstance changes.

OHS Registration Checklist

Before filing:

1. Select the internal, shared, or independent-service model.
2. Establish and verify the eligible applicant.
3. Secure all three minimum-team profiles and verify their eligibility.
4. Obtain notarised, translated, and authenticated documents where required.
5. Prepare the application, declarations, specialist list, and document index.
6. Confirm the fee and complete a final consistency review before filing.

Before beginning operations:

Verify the certificate and register entry, adopt internal and data-control procedures, prepare employer contracts, and calendar staffing, change, and reporting obligations.

Our Bulgaria corporate tax guide provides a general overview of the tax and compliance environment for a Bulgarian business.

Register an Occupational Health Service with Lion Consult

Lion Consult assists founders with establishing the Bulgarian operating entity, preparing and coordinating the OHS registration file, organising supporting corporate documentation, and setting up the accounting, payroll, tax, and ongoing compliance processes required for the business.

Contact Lion Consult to discuss the proposed service, specialist team, documents, and registration timetable.

This guide provides general information and is not legal, medical, tax, accounting, or data-protection advice.

Frequently Asked Questions

Must every Bulgarian employer use an Occupational Health Service?

Bulgarian employers must arrange service by a registered Occupational Health Service for their workers. Depending on the circumstances, an employer may use an external registered provider or establish an eligible internal or shared service.

Who can register an Occupational Health Service in Bulgaria?

An employer may establish an internal OHS alone or jointly with other employers. Traders under the Commerce Act, cooperatives, non-profit legal entities, and companies formed under EU or EEA law may establish an external service. A healthcare establishment may do so only through a separate legal entity.

What specialists are required for OHS registration?

The minimum team includes a physician with an occupational-medicine specialty, a higher-educated technical-sciences specialist with at least three years of occupational health-and-safety experience, and a technical officer with at least secondary education.

What is the fee for registering an OHS in Bulgaria?

The Bulgarian Ministry of Health currently publishes a registration fee of EUR 187.64. Applicants should confirm the amount, payment details, and required payment reference immediately before filing.

How long does OHS registration take?

The Ministry has 30 days from filing a complete application, or from correction of an incomplete file, to issue the certificate or a reasoned refusal. It must notify irregularities within 30 days and allow at least 14 days to correct them.

Does an OHS registration need to be renewed?

There is no periodic renewal. Changes to registered circumstances, including the minimum team, must be notified in writing within seven days. The Ministry currently publishes a EUR 116.06 change fee and acts on the notification within 20 days.

How long must an OHS retain workers' health dossiers?

Workers' health dossiers must be maintained on paper and electronically and retained for 50 years. The rules require direct transfer between occupational health services in specified cases; an employer holding dossiers temporarily after an OHS closes may not access their contents.