I decided to conduct an online search for the latest news regarding the 2025 ZBDOO using ChatGPT with the "ChatGPT 03-mini-high" and "Deep research" settings. After about 5 minutes of thorough research across more than 10 sources, I received the following analysis, which I decided to publish.

Delay of the 2025 State Social Security Budget Act and the Reasons Behind It

The State Social Security Budget Act (ZBDOO) for 2025 had not yet been adopted at the beginning of the year​ tita.bg. Typically, the ZBDOO is voted on together with the national budget, but this year there has been a delay due to political reasons. The 2025 draft budget, prepared by the caretaker government at the end of 2024, was withdrawn at the end of January 2025 , which further delayed its adoption​ knsb-bg.org. This delay keeps the previous year’s parameters in effect until the new law is adopted. In practice, the social security system is currently operating under the 2024 framework, in accordance with a special temporary law​ knsb-bg.org.

The reason for the delay is primarily political—the new government believes it must make adjustments to the budget rather than proceed with the version proposed by the caretaker cabinet​ knsb-bg.org. This led to the need for more time to revise and coordinate the state budget, and, along with it, the budget of the National Health Insurance Fund. As a result, all related legislative acts (including the budget of the National Health Insurance Fund) are being delayed​ tita.bg.

The new minimum wage (MW) – 1,077 BGN starting in 2025.

Despite the lack of an approved budget, as of January 1, 2025, the national minimum monthly wage has been raised to 1,077 BGN (6.49 BGN per hour) dv.parliament.bg. This was established by Decree No. 359 of the Council of Ministers dated October 23, 2024, published in the State Gazette. Employers are required under the Labor Code to provide at least this amount of gross pay for a full month of work dv.parliament.bg.

It is important to note that the new minimum wage of 1,077 BGN applies regardless of the delay in the budget laws. Accountants should update the salaries of employees earning the minimum wage, effective January. All social security contributions on income (salaries) must be calculated based on no less than 1,077 BGN where the employee works full-time and the previous salary was below this amount.

Minimum social security thresholds for 2025 – current status

Minimum social security income by major economic activities and occupational qualification groups (the so-called minimum social security thresholds) for 2025 has not yet been updated by a new law. Until the Social Insurance Budget Act (ZBDOO) for 2025 is adopted, the minimum thresholds specified in Annex No. 1 to the ZBDOO for 2024 remain in effect. tita.bg. This means that, for now, the social security thresholds remain at their 2024 levels. tita.bg.

Since the national minimum wage was 933 BGN in 2024, the lowest thresholds were set equal to that amount tita.bg. However, the minimum wage is now higher (1,077 BGN), while the thresholds remain temporarily at their previous levels. In practice, in some sectors, the minimum social security threshold for unskilled positions remains at 933 BGN, which is below the new minimum wage tita.bg. In these cases, this discrepancy does not exempt the employer—the employer must still calculate social security contributions based on at least 1,077 BGN (since the actual salary cannot be below the minimum wage). For positions and sectors with higher minimum thresholds (above 1,077 BGN), the higher threshold naturally applies until the new values take effect.

The minimum social security income for self-employed individuals also remains temporarily at 933 BGN (the 2024 amount) tita.bg. The new Social Security and Health Insurance Act 2025 is expected to raise this amount (likely to the minimum wage level of 1,077 BGN), but until that happens, the self-employed can legally pay social security contributions based on a minimum of 933 BGN per month. Please note that this temporary exception will result in the need to make retroactive social security contributions, if the new law raises the minimum effective from the beginning of the year. Accountants should monitor this change and inform self-employed individuals that they may need to make additional social security contributions for the first months of 2025 (on the amount exceeding 933 BGN).

The maximum monthly insured income currently remains at the 2024 level—3,750 BGNtita.bg. This is the ceiling above which no social security contributions are due for the time being. It is possible that this maximum will be updated with the 2025 Social Security Budget Act (there are proposals to increase it, e.g., to approximately 4,130 BGN starting in 2025​ mediapool.bg), but until a law is passed, amounts exceeding 3,750 BGN are not subject to tax. If the maximum income is subsequently increased retroactively as of January 1, employers with highly paid employees must be prepared to calculate additional social security contributions on the amount exceeding 3,750 BGN (up to the new ceiling).

Differentiated contributions for work-related accidents and occupational diseases—no change for now

The Social Insurance Budget also sets annually the amounts of social security contributions to the “Work-Related Accidents and Occupational Diseases” fund by groups of primary economic activities (differentiated rates based on risk). Since the 2025 Social Insurance Code has not yet entered into force, the 2024 rates continue to apply under this heading​ tita.bg. For each company, the contribution rate for this fund remains the same as it was last year—between 0.4% and 1.1%, depending on the economic activity, as specified in Appendix No. 2 to Article 14 of the 2024 Social Security Code tita.bg. Accountants must use the current rates when calculating social security contributions due for January and subsequent months until a new decree or law is issued with updated rates.

The good news is that there is no change in the contribution to the “Guaranteed Receivables of Workers and Employees” Fund —it remains at 0%, as it was in 2024. tita.bg. This means that employers will not make separate contributions to this fund in 2025 either, unless a new law stipulates otherwise (which is unlikely at this stage).

What accountants should (and should not) do while waiting for the changes

Do not make sudden changes based on unofficial information. During periods of regulatory uncertainty, the best approach is to comply with the rules and laws currently in effect, without speculating on what might be enacted. Follow the current legislation as of today, namely: apply the 2024 thresholds and percentages, along with the new minimum wage for 2025 that has already taken effect. Avoid entering projected values into software or spreadsheets—wait for the official changes.

Do not delay current obligations and reports. In other words, do not postpone the filing of returns and reports (such as Form No. 1 and No. 6 for social security contributions) in the hope that the new law will be enacted soon so you can file them directly with the new data. The law may be delayed further, and in the meantime, missing deadlines will result in violations. It is better to file your returns on time according to the current rules than to risk fines for late filing. If a correction is subsequently required (for example, to the declared social security income), it can be made via an amended return on radiovelikotarnovo.com. Experience shows that tax authorities and regulators are prepared to accept such corrections in the event of legislative changes​ radiovelikotarnovo.com.

Plan ahead, but remain flexible. You can inform your management or clients about which parameters are expected to change (e.g., higher maximum social security income thresholds) and how this would affect them financially. Prepare for various scenarios, but do not take action until the changes become official. For example, if you expect a certain social security threshold to increase, you can set aside a reserve for additional social security contributions instead of treating these amounts as other expenses.

Follow official sources – Ministry of Finance, the National Social Security Institute (NOI), and the National Revenue Agency (NRA). Pay attention to the transitional and final provisions of the law when it is enacted, as they often specify how to handle matters retroactively. There may be guidelines or instructions from the NRA regarding adjustments without penalties, as well as extended deadlines for certain reports. Your role is to stay informed and be ready to act as soon as the regulatory changes take effect.

Patience and a pragmatic approach—key qualities at this time

In times of regulatory uncertainty patience is especially important. For accountants, this means staying calm and continuing their routine work under the current rules, without succumbing to stress over the expected changes. Panicor hasty actions can lead to mistakes—such as incorrectly calculated contributions or missed deadlines. Instead, with a pragmatic approach, focus on what can be done now (based on current regulations), and prepare a plan for what will need to be done once the changes take effect.

A pragmatic approach to your work also helps when communicating with managers and employees. Explain the situation to them: that the rules are temporarily the same as last year’s, but changes are expected. Reassure them that you are monitoring developments and will make the necessary adjustments in a timely manner. This demonstrates professionalism and builds trust.

Last but not least, patience will protect you from unnecessary stress. Instead of repeatedly changing salaries, advance payments, or documents, wait for the final decisions. This saves you from having to do the same work twice—entering data now and then having to correct it later. A calm approach and sensible actions will save you effort and potential penalties in the future.

Will the National Revenue Agency (NRA) impose fines for delays caused by the changes?

Many accountants are concerned that delayed or corrected tax returns—submitted for objective reasons (due to the late adoption of the law)—will result in penalties from the National Revenue Agency. Historically, the National Revenue Agency has shown understanding in situations involving regulatory changes. In similar cases in the past, when social security thresholds or income levels were changed retroactively, the agency provided guidance on how to make corrections, without penalizing payers acting in good faith who made the necessary corrections in a timely manner​ radiovelikotarnovo.com.

It is important to make a distinction: there will be no fines if you meet the current deadlines and then make corrections as necessary. However, if you decide on your own to delay filing returns or paying contributions without an official extension of the deadline, then you are subject to penalties under the current rules. In other words, the National Revenue Agency (NRA) will not fine you for submitting accurate information under the old rules and then correcting it under the new ones—this is expected behavior. However, the National Revenue Agency (NRA) could impose a fine if you fail to file any information at all or file it after the statutory deadline without justification.

Upon the adoption of the Social Security and Health Insurance Act 2025, there may be explicit instructions from the NRA or statutory provisions addressing the period prior to its adoption. Keep an eye out for such guidance. For example, a grace period might be granted for the payment of social security contributions, without interest, if they are paid by a certain date after the law is promulgated—similar measures have been taken in the past. If no such guidelines are provided, the standard rules for late-payment interest will apply automatically.

Summary: If you comply with the current law and then, in good faith, bring your reports and payments into line with the new requirements, the risk of fines is minimal. The National Revenue Agency is primarily concerned with ensuring that the required social security contributions are collected correctly, rather than punishing businesses in a situation that is exceptional for everyone. Your task is to fulfill your current obligations and be prepared to respond to changes—as professionalism demands.

In conclusion, the waiting period for the 2025 Social Security and Health Insurance Act requires accountants to be extra vigilant, but it should not cause unnecessary stress. Adhere to the current rules, monitor official sources for updates, and be prepared to adapt your work. With the right balance between patience and proactivity, you will ensure the compliance of your financial statements and peace of mind for your organization and clients.