Transport Companies – Payroll and Compliance Rules

This article provides a concise, practical, and accurate overview of all key obligations: Posting declarations, payroll calculation, A1 certificates, working time, vehicle return rules, inspections, and minimum daily allowances in the transport sector.

The purpose is to give transport company owners a clear understanding of their obligations and help them avoid the most common mistakes that lead to penalties within the EU.

Drivers engaged in international transport fall under second-category labor, which provides enhanced labor protection, including a minimum of 25 working days of paid annual leave. As of 2025, the minimum monthly wage for a driver in Bulgaria is BGN 1,077. This amount serves as the basis for calculating remuneration, social security contributions, and required top-ups when drivers are posted to other EU Member States. These requirements, together with the rules of Mobility Package I, define the framework within which Bulgarian transport companies must organize work, posting, and driver remuneration.

International drivers are entitled to minimum daily allowances of €35 per day for EU countries and €50 per day for non-EU countries. These amounts represent compensation for expenses and are not included in the calculation of the minimum remuneration under Mobility Package I rules. These are legally defined minimum amounts below which the employer may not pay daily allowances.

A1 Certificate – When It Is Required and Conditions for Issuance

The A1 certificate proves that the driver remains socially insured in Bulgaria while temporarily working in another EU Member State. It is mandatory for all international transport operations, regardless of whether Posting applies or whether the transport is bilateral. The certificate is issued by the National Revenue Agency (NRA) and aims to prevent double social security contributions in different countries.

When is an A1 certificate required?

during international transport of goods or passengers within the EU;
when temporary work is performed in another country while social insurance continue in Bulgaria;
regardless of whether the driver performs bilateral, transit, cabotage, or posting transport.

Conditions for issuance

The company must be able to demonstrate that:

the driver is employed under an employment contract in Bulgaria and is insured there;
the company carries out genuine economic activity in Bulgaria (is not a “post box company”);
the driver performs part of his work in Bulgaria;
the international activity is temporary and does not represent a permanent transfer to another country.

Supports Transport Companies in the Correct Application of Mobility Package I

Situations, rules, and comments on business impact

European Mobility Package I fundamentally changed the rules governing international drivers. If you are a Bulgarian transport company, it is essential to understand the core requirements in order to avoid fines, blocked payments, and increased inspection risk across the EU.

Below you will find the most important points, presented in a concise format and supported by real-life scenarios.

When Is a Posting Declaration Submitted?

Posting applies when a driver from a Member State (e.g. Bulgaria) performs loading or unloading operations in another EU Member State that is not the country where the company is established.

In such cases, the company is required to submit a Posting declaration before the start of the transport operation via the official EU portal:
https://www.postingdeclaration.eu/

Posting is required, for example, when a Bulgarian company carries out:

international transport between two foreign countries (not from or to Bulgaria);
cabotage operations;
transport between an EU country and a third country, where the operation is not bilateral with Bulgaria.

When Posting is NOT required?

Transit
Bilateral operations Bulgaria ⇄ another country
Bilateral operations plus 1 or 2 additional loading or unloading operations
(applicable only with smart tachograph G2V2)

Example situation

A Bulgarian company transports goods from Slovenia to Austria.
Loading and unloading take place in two foreign countries.
Posting is required in Slovenia and Austria.

How Is Remuneration Calculated During Posting?

The company must ensure that for every working hour spent in the host country, the driver receives no less than the applicable local minimum rate.
Daily allowances are not recognized as part of the salary for the purpose of these checks.

Each EU Member State applies its own:

minimum hourly wage;
additional payments (night work, public holidays, specific sector rates).

It is the employer’s responsibility to ensure that the driver receives at least the remuneration that a local worker would receive for the same work.

The posting period depends on the moment of entry into the country, loading, unloading, and exit.

Situation 1: Driver enters a country to unload goods

Posting starts from the moment the driver enters the country. It ends upon unloading, provided no new load is taken. If another load is taken, posting continues until the driver exits the territory.

Situation 2: Transit only

A driver who only passes through a country without loading or unloading is NOT considered posted.

Transport from country A to country C
passing through country B (without loading or unloading)
The driver is NOT considered posted in country B.

Situation 3: Entry with an empty vehicle to load goods

Posting starts from the moment the driver begins traveling to the loading location.

How is the minimum rate surcharge calculated? – Practical Model

Step 1: Determine the working hours in the respective country

Based on: tachograph data, GPS routes, CMR documents, border records.

Example: The driver spent 6 hours in Austria with cargo → 6 hours are subject to Austrian wage rules.

Step 2: Check the minimum rate in the host country

Truck Mobility Info is not an official government source. The information may be useful, but should be verified:

https://truckmobility-info.com/the-minimum-wage-in-eu-countries/

Step 3: Compare with the actual remuneration paid in Bulgaria

Include:

base salary;
additional remuneration for work;
labor-related allowances (night work, hazardous conditions, etc.).

Daily allowances (food, travel, accommodation) are NOT included as part of the “salary” for this comparison.

If the paid remuneration is lower, the difference must be paid.

Step 4: Example calculation (simplified)

Example calculation:

The driver spent 6 hours in Austria with cargo.
Austrian minimum rate: €12.26
Bulgarian hourly wage: €6.49

The company must pay the difference:
€5.77 × 6 hours = €34.62

Learn more about our Payroll services

Working Time, Driving and Rest Periods (Regulation 561/2006)

Key rules:

up to 9 hours of driving per day (up to 10 hours twice per week);
56 hours of driving per week, 90 hours over two weeks;
45-minute break after 4.5 hours of driving;
11 hours of daily rest (may be reduced to 9 hours up to three times);
45 hours of weekly rest, which may not be taken in the vehicle cabin.

Driver Return to Company’s Home country

The employer must organize work so that the driver can return:

at least once every 4 weeks to their home or the operational base;
every 3 weeks, if two consecutive reduced weekly rests are taken.

The company must be able to prove that it has ensured the possibility for the driver to return.

Vehicle Return to Company’s Home country

The vehicle must return to Bulgaria once every 8 weeks.
This serves as proof of genuine activity in the country of establishment.

Cabotage and Cooling-Off Period

Up to 3 cabotage operations may be performed within 7 days in one country.

After that, a 4-day cooling-off period applies, during which the same vehicle may not perform cabotage in that country.

Tachographs and Controls (G2V2)

The new rules introduce second-generation smart tachographs, which:

automatically record border crossings;
facilitate checks related to cabotage and posting;
are mandatory for new vehicles, with retrofit deadlines for older ones.

Extension of Rules to Vehicles over 2.5 Tons

In international transport for remuneration, lighter commercial vehicles over 2.5 tons are also subject to certain requirements related to:

tachographs;
market access;
controls and documentation.

Documents Required During an Inspection

Inspection authorities in the EU may request:

a copy of the Posting declaration;
CMR documents/consignment notes;
tachograph data (including country codes);
evidence of the route;
payslips for the relevant period;
proof of paid remuneration;
A1 certificate (mandatory for all international activity).

The employer may be required to submit additional documents within up to 8 weeks via the IMI system.

How Do These Rules Affect Your Business?

Mobility Package I requires:

- precise route planning;
- a clear and compliant working time system;
- accurate calculation of remuneration during posting;

proper documentation of driver and vehicle returns;
reliable and complete tachograph records.

Failure to comply can result in high fines, refusal of payments by partners, vehicle immobilization during inspections, and audits related to fictitious establishment.

Your Partner for Safe and Compliant Application of Mobility Package I

We help transport companies in Bulgaria to:

✔ correctly calculate remuneration during posting
✔ comply with working time requirements
✔ prepare documentation for EU inspections
✔ plan driver and vehicle return schedules efficiently
✔ avoid sanctions and administrative errors

to discuss how our payroll and accounting services can support your business at every stage.

FAQ

When is a Posting declaration submitted for a driver?
A Posting declaration is submitted for international transport involving loading or unloading in an EU country other than the country of establishment, as well as for cabotage. It is not submitted for transit or bilateral transport (with specific exceptions for G2V2 tachographs).

Are daily allowances included in the minimum remuneration?
No. Daily allowances (food, travel, accommodation) are expense compensations and are not included in the calculation of the minimum rate in the host country.

What documents may be requested during a driver inspection in the EU?
CMR documents, tachograph data, route evidence, payslips, payment records, a copy of the Posting declaration, and proof of social security coverage (A1 certificate).

How often must the drivers return to Bulgaria?
At least once every 4 weeks or every 3 weeks (if two consecutive reduced weekly rests are taken) to home or to the company’s operational center in the country of establishment.

How is the top-up to the minimum rate calculated?
The actually paid labor elements (base salary plus labor-related allowances) are compared with the minimum rate of the host country. Expense reimbursements are excluded.

How is the minimum wage supplement calculated?

The actual paid labor elements (base salary + labor allowances) are compared with the minimum wage of the host country. Expense payments are not included.

to discuss how our payroll and accounting services can support your business at every stage.

We offer one-hour free initial consultation to assess your needs, explain our services, and outline the best path forward. Don’t navigate Bulgarian business requirements alone – let our expertise work for you.

Running a business in Bulgaria combines attractive tax benefits with professional standards, EU market access, and strategic location. With proper guidance from experienced advisors like Payroll BG, you can build and grow your enterprise confidently, meeting all legal requirements while optimizing your tax position and focusing on what you do best—running your business. We’re here to make Bulgarian business operations straightforward, compliant, and successful.