Draft Law on the State Social Insurance Budget for 2016.

MR IVAILLO CALFIN
DEPUTY MINISTER-PRESIDENT
ON DEMOGRAPHIC AND SOCIAL POLICY,
MINISTER OF LABOR AND SOCIAL POLICY I
CHAIRMAN OF NSTS

REGARDING: Draft Law on the State Social Security Budget for 2016.

         
DEAR MR CALFIN,

The Confederation of Employers and Industrialists in Bulgaria, after discussing in the Committee "Financial Services", Committee "Taxes and Law" and Committee "Human Resources", the draft budget of the state social insurance, defines the following main parameters as positive:

No increase in the amount of insurance contributions is foreseen in 2016.
Preservation of the zero contribution for the "Guaranteed receivables of employees" fund
Keeping the amount of the maximum insurance income for all insured persons at BGN 2600.

KRIB notes the following main negative aspects in the draft budget of DOO:

The preservation of the system of payment of benefits for temporary incapacity for work for the first three days of incapacity.
The proposed administrative increase in the amount of minimum insurance income by 7,5% in economic activities where no agreement has been reached between the social partners for 2016.

The Confederation of Employers and Industrialists in Bulgaria, after discussing with its members the proposed increase, expresses the following position:

While the text of Article 6, Paragraph 2, Item 3 of the CSR is in effect, we propose that the main mechanism for determining the thresholds be the agreements reached between the social partners at the branch level;

In economic activities where there are no trade union structures and effective negotiations cannot be conducted, the thresholds should be determined based on the proposals of the employer branch structures;

For the economic activities for which no agreement has been reached, no mechanical administrative increase of the thresholds shall be applied. KRIB categorically objects to the MOD in these activities increasing with the average growth of the agreed insurance income in the real sector;

KRIB proposes that the representative employers' organizations and the trade unions negotiate at the national level the MoD for each economic activity and groups of professions in which no agreement has been reached or there are no both employer and trade union representative branch structures;

As early as the beginning of 2016, the social partners and the state must agree on a mechanism for determining the MRL and/or the MOD, which will guarantee sustainability, predictability and stability of the system.

With respect,
Eugene Ivanov
Ex. director