I decided to do an online survey for the latest news on the 2025 CEAA using ChatGPT with parameters "ChatGPT 03-mini-high" and "Deep research". After about 5 minutes of extensive searching of over 10 sources, I got the following analysis, which I decided to publish.

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Delays in the 2025 BAPA and the reasons for it

The State Social Insurance Budget Act (SSPBA) 2025 has not yet been passed as of the beginning of the year tita.bg. Normally, the BAPA is voted together with the state budget, but this year there is a delay due to political reasons. The draft budget for 2025 prepared by the caretaker government in late 2024 was withdrawn at the end of January 2025, further delaying its adoption knsb-bg.org. This delay leaves the previous year's parameters in place until the new law is passed. На практика, в момента социално-осигурителната система работи по рамката на 2024 г., съгласно специален временен закон​ knsb-bg.org.

The reason for the delay is mainly political - the new government judged it needed to make adjustments to the budget rather than proceed with the knsb-bg.org option proposed by the caretaker cabinet. This has led to the need for more time to revise and reconcile the state budget and, with it, the PSO budget. As a result, all related regulations (including the budget of the National Health Insurance Fund) are delayed tita.bg.

The new minimum wage (MWW) - BGN 1077 from 2025

Despite the lack of an adopted budget, from 1 January 2025 the minimum monthly wage for the country has been raised to 1077 BGN (6.49 BGN per hour) dv.parliament.bg. This was done by Decree No 359 of the Council of Ministers of 23 October 2024, published in the State Gazette. Employers are obliged by the Labour Code to provide at least this amount of gross remuneration for a full working month dv.parliament.bg.

It is important to note that the new minimum wage of £1,077 applies regardless of the delay in budget laws. Accountants are due to update the salaries of minimum wage employees from January. All earnings (wage) contributions must be calculated on no less than £1,077 where the worker is full-time and the previous salary was below this amount.

Minimum contribution thresholds for 2025 - current position

The minimum insurance income by main economic activities and qualification groups of professions (the so-called minimum insurance thresholds) for 2025 has not yet been updated by a new law. The minimum thresholds set out in Annex 1 to the 2024 tita.bg shall continue to apply until the adoption of the 2025 Act. This means that for the time being the insurance thresholds remain at their 2024 levelstita.bg.

As the national minimum wage was £933 in 2024, the lowest thresholds have been tita.bg aligned to this amount. Now, however, the minimum wage is higher (£1,077) and the thresholds are temporarily standing at their old levels. In practice, in some sectors the minimum social security threshold for unqualified positions remained at BGN 933, which is below the new minimum wagetita.bg. In these cases, this discrepancy does not exempt the employer - it still has to charge social security contributions on at least 1077 BGN (because the real salary cannot be below the minimum wage). For jobs and sectors with higher minimum thresholds (above £1,077), the higher defined threshold naturally applies until the new values come in.

The minimum insurable earnings for self-employed persons also remains temporarily at £933 (the rate from 2024) tita.bg. It is expected that the new LBIT 2025 will raise it (probably to the level of the minimum wage of £1,077), but until that happens, the self-employed can legally be insured at a minimum of £933 a month. Note that this temporary exception will result in the need to pay additional contributions retrospectively if the new law increases the minimum from the beginning of the year. Accountants should keep an eye out for this change and inform self-insured individuals that they may need to make additional contributions for the first months of 2025 (on the difference above £933).

The Maximum monthly insurable income currently also remains at the 2024 level of 3750 BGNtita.bg. This is the ceiling above which no contributions are due for the time being. It is possible that this maximum will be updated with the 2025 BAPA (there are proposals for an increase, e.g. to around £4,130 from 2025 mediapool.bg), but until there is a law passed, amounts above £3,750 are not taxable. If the maximum income is subsequently increased retrospectively from 1 January, employers with highly paid employees should be prepared to contribute the difference above £3,750 (up to the new cap) as well.

Differentiated contributions for occupational accident and sickness - no change for now

In the budget of the Social Insurance Institution (SEI), the amounts of contributions to the occupational accident and disease fund are determined annually by groups of main economic activities (differentiated percentage rates according to the risk). As the 2025 LWL is not in force, the 2024 rates continue to apply under this item. For each company, the rate for this fund remains the same as it was last year - between 0.4% and 1.1% depending on the economic activity, determined under Schedule 2 to Article 14 of the 2024 tita.bg. Accountants should use the current percentages when calculating the contributions due for January and the following months until a new decree or law is issued with an update.

The good news is that there is also no change in the contribution to the Guaranteed Employees' Claims Fund - it remains 0%, as it was in 2024 tita.bg. This means that employers do not contribute separately to this fund in 2025 unless a new law decides otherwise (which is unlikely at this stage).

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

Don't make abrupt changes based on anecdotal information. In periods of regulatory uncertainty, the best approach is to comply with the rules and laws currently in force, without guessing what might be enacted. Follow the current legislation to date, namely: apply the 2024 thresholds and percentages along with the new 2025 minimum wage already in effect. Avoid entering projected values into software or spreadsheets - wait for official changes.

Don't delay current liabilities and reports. In other words, don't delay filing returns and reports (e.g. Obrazets #1 and #6 returns for social security) in the hope that the new law will come out soon so you can file them directly with the new data. The law may be further delayed, and in the meantime missing deadlines will result in violations. It's better to file on time under the current rules than to risk late penalties. If a correction is subsequently needed (for example, to a declared social security income), it can be made with a radiovelikotarnovo.com correction return. Practice shows that tax systems and regulators are prepared to accept such adjustments when legislative changes radiovelikotarnovo.com.

Plan ahead, but also be flexible. You can inform your management or clients which parameters are expected to change (e.g. higher maximum insurance income or thresholds) and how this would affect you financially. Prepare with different scenarios, but don't take action until the changes are official. For example, if you anticipate an increase in a particular contribution threshold, you might set aside a reserve for additional contributions rather than paying these amounts out as other expenses.

Watch the official sources - the Ministry of Finance, the National Social Security Institute, the NRA. Pay attention to the transitional and final provisions of the law when it comes out, because they often specify how to proceed retroactively. There may be instructions or directions from the NRA for corrections without penalties, and extended deadlines for certain returns. Your role is to be informed and ready to react as soon as the regulatory changes come into force.

Patience and a pragmatic approach - key qualities now

In periods of regulatory uncertainty patience is particularly important. For accountants, it means keeping calm and continuing their routine work under current rules without succumbing to the stress of anticipated changes. Panic or hasty action can lead to mistakes - miscalculated contributions or missed deadlines, for example. 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 when changes occur.

Pragmatism at work also helps you communicate with managers and employees. Explain the situation to them: that the rules are temporarily the same as last year, but changes are expected. Assure them that you are monitoring developments and will make the necessary adjustments in due course. This demonstrates professionalism and builds trust.

Last but not least, patience will protect you from unnecessary strain. Instead of repeatedly changing payroll, down payments or paperwork, wait for final decisions. This saves double the work-entering data now and re-correcting it later. Calm down and act wisely now will save you effort and potential penalties in the future.

Will the NRA impose late penalties because of the changes?

Many accountants are concerned about whether late or corrected returns for objective reasons (due to the late passage of the law) will result in penalties from the National Revenue Agency. Historically, the NPA has been understanding in situations of regulatory change. On similar occasions in the past, when social security thresholds or incomes have changed retroactively, the agency has issued instructions for corrections without penalizing bona fide payers who made the necessary corrections in a timely manner radiovelikotarnovo.com.

It is important to make a distinction: there will be no penalties if you meet the current deadlines and then correct as necessary. However, if you decide to delay filing returns or paying contributions yourself without a formal extension of time, then you are subject to a penalty under the current rules. In other words, the NPA will not fine you for filing correct information under the old rules and then correcting it under the new - this is expected behavior. But the NRA could fine you if you don't file the information at all or file it after the statutory deadline without justification.

Upon the passage of HBDO 2025, there may have been explicit instructions from the NRA or statutory language that treated the period prior to passage. Watch for such instructions. For example, a grace period may be given for contributions to be made, without interest, if made by a certain date after the promulgation of the law - similar measures have been taken in the past. In the absence of such directions, the standard rules on interest in case of late payment will automatically apply.

Summary: If you act under the law now and then in good faith bring your statements and deposits into compliance with the new requirements, the risk of penalties is minimal. The NRA is mainly interested in collecting the contributions due correctly, not in penalising businesses in an emergency situation for everyone. Your job is to meet your ongoing obligations and be ready to respond to change - as professionalism demands.

In conclusion, the waiting period for BBA 2025 requires accountants to exercise caution but should not cause undue stress. Stick to the current rules, monitor official sources for new developments and be prepared to adapt your work. With the right balance of patience and proactivity, you will ensure legality of accounting and peace of mind for your organisation and clients.