As of June 1, 2025, the traditional paper labour book will be phased out in favor of a digital alternative. All employment data will now be maintained in an electronic employment register managed by the National Revenue Agency (NRA). This transition is part of a broader effort to modernize the Labour Code and digitize employment relationships, aiming to eliminate the risks associated with physical document loss and to ensure that data is always current and accurate.
Transition Process for Employers
Employers are required to complete the paper labour books of their employees by June 1, 2025, and return them to the employees. The final entry must detail the length of service completed by the employee with the employer up to June 1, 2025. This entry should be signed by the chief accountant and the employer, and affixed with the employer's seal if one is available.
Introduction of the Unified Electronic Employment Record
The paper labour book will be replaced by the unified electronic employment record, a key component of the new electronic employment register. This electronic document will contain all pertinent employment data and circumstances, serving as an official supporting document for employment verification.
The format and procedure for data storage in the employment register, as well as the processes for data entry, deletion, and certification of circumstances, will be regulated by a special Ordinance. Although a draft of this Ordinance was available for public discussion until June 20, 2024, it has not yet been officially adopted by the Council of Ministers.
Data Requirements and Submission Procedures
Employers must provide detailed information to the NRA for inclusion in the unified electronic employment record, including amongst others, the employee’s and the employer’s identification, the grounds of the employment contract, basic remuneration details, position codes, working hours and length of service, paid annual leave information, etc.
Deadlines for Data Submission
The deadlines for the provision of employment data to the NRA remain the same, although additional situations will require information to be provided to the NRA, as within three days : the conclusion and amendment of the employment contract, the place of work, term of the employment contract, the duration of working hours, the agreed paid annual leave, etc. and within seven days – the termination of the employment contract, entry into force of certain court decisions, etc.
The employer will also have to submit an electronic employment record with data on the beginning of the performance of the employment contract before the employee starts work.
Submission and Access to Electronic Employment Records
Employers must submit electronic employment records through the NRA's electronic services portal, using a qualified electronic signature. They can also be submitted on an electronic device along with a template cover letter. Upon submission, the NRA issues a protocol detailing the entered records. Employers must provide employees with a copy of this protocol before they commence work.
Accessing the Electronic Employment Register
The NRA will provide access to the electronic employment register for:
- Employees, for their own records.
- Parents or guardians of employees under 18.
- Employers, for data they submitted and for certain data from previous employers except for data on the amount of labour remuneration and benefits.
In addition, employees are entitled to information on the access history of their unified electronic employment record, except for instances of access by the pre-trial proceedings authorities in accordance with the procedure laid down in the Criminal Procedure Code and the State Agency for National Security.
Data Sharing with the National Statistical Institute
The NRA will share employment register data with the National Statistical Institute (NSI) monthly. This data will be used for statistical purposes and published in aggregated form, detailing employment relationships, remuneration, and working hours according to professional and economic classifications. The specifics of this data exchange will be regulated by an agreement between the NRA and NSI.
This modernization represents a significant step forward in digitizing employment records, enhancing data accuracy and accessibility, and streamlining administrative processes for both employers and employees.
By Martina Dimitrova, Senior Associate, Eversheds Sutherland
