Introduction of a Unified Electronic Employment Record and Creating an Employment Register

Amendments to the Labor Code are slated to take effect as from June 1, 2025, whereby the current personal employment booklet will be replaced by a unified electronic employment record, an electronic document containing information about the employment status of a given employee. The employment register will, for its part, serve as a repository for all unified electronic records. This arrangement will make it possible to abolish the cumbersome rules of issuance, filling in, presenting and returning to the employee of the employment booklets, thus eliminating any risk for the employee being unable to prove their employment status as may result from the loss or misplacement of the employment booklet or failure by the employer to return it to the its holder in due course. This new arrangement means that employers will have a clear and easy obligation to enter data in the electronic employment record, eliminating the need to collect in advance the employment booklets of their employees.
To counterbalance these advantages, there emerges the need for the new arrangement to provide a set of rules for access to the electronic employment record – as contained in article 347a: access is granted to the employees themselves, their parents or legal guardians, respectively custodians (for employees under the age of 18), employers (except for data about the employee’s remuneration or compensations paid by former employers; an exception to the exception is the recording of information about the retirement compensation package, which according to the Labor Code is payable as a once-off lump sum). In addition, the employee also has access to the history of views of the electronic employment record, i.e. the identity of persons accessing the information stored in it. An exception is provided for access by authorities engaged in pre-trial proceedings and the State Agency for National Security. Accordingly, the employer is obligated to enter in due course any information relevant to the electronic employment record, and in cases where a court ruling applies to certain aspects of that information (length of service, grounds for termination of employment), if the employer is unable, or had declined, to make a relevant entry, that entry is made by the Labor Inspectorate.
Such a significant change also involves a number of issues that are governed by the Transitional and Final Provisions of the law whereby said amendments to the Labor Code were codified. First off, the employment booklet, respectively the service card, will remain a valid document attesting to the circumstances in effect prior to the entry into force of the amendments.
Not later than June 1, 2026, or upon termination of an employment agreement during the period from June 1, 2025 till June 1, 2026, the employer will request access to the employee’s booklet in order to enter his or her length of service prior to June 1, 2025. The option for ex officio issuance of a replacement booklet by the Labor Inspectorate in case where the preceding one has been misplaced or lost remains in place for making entries of events prior to June 1, 2025.
Specific rules for entry of data into the Employment Register and the concrete unified electronic employment records are set forth in the Regulation on the Employment Register; the National Revenue Agency (NRA) is put in charge of keeping and maintaining the Register. NRA has been authorized to make ex officio entries in, or delete certain data from, the Register. Data is fed into the Employment Register via the NRA electronic services portal, with a qualified electronic signature, or on electronic medium, with a cover letter.