Third country drivers in Bulgaria: licence exchange and the Code 95 qualification

A driver from a third country needs two separate things before taking a truck out in Bulgaria. First, a Bulgarian driving licence, which the Interior Ministry issues in exchange for the foreign one only on specific grounds. Second, a driver qualification card carrying Code 95, issued by the Executive Agency Automobile Administration under its own procedure.

Employers usually plan for the first only. The second is why start dates slip by months, because Code 95 does not arrive with the licence exchange and is not carried over by the foreign document.

When the Interior Ministry exchanges a licence without a test

The Road Police within the Interior Ministry exchanges a foreign national driving licence for a Bulgarian one without a test on two grounds only. The first is that the issuing state is a contracting party to the Convention on Road Traffic (Vienna, 8 November 1968) and the licence itself meets the requirements of Annex 6 to that convention. Annex 6 sets out what the document must contain, including the categories and the way entries are made. A licence from a contracting state that does not meet Annex 6 does not pass this route.

The second ground is a bilateral agreement between the state concerned and the Republic of Bulgaria on mutual recognition and reissue of driving licences. The list of such agreements is short, and the employer should check the specific country of origin before committing to a start date.

Licences issued by an EU member state, and by Iceland, Liechtenstein, Norway and Switzerland, are exchanged under a lighter procedure. That is a separate case and does not cover drivers from Nepal, India, the Philippines, Uzbekistan or Kyrgyzstan, who make up most of the corridors feeding the Bulgarian transport sector.

The fee for the exchange is set by Tariff No 4 on the fees of the Interior Ministry and is paid by the applicant when the application is filed. The qualification course is paid separately to the training centre.

If neither ground applies, the driver goes through training and a test at a Bulgarian driving school like any other new candidate for that category. This case is not rare, and it belongs in the screening stage, not in the week after arrival.

Code 95 is a second procedure, not part of the licence

The driving licence itself grants the right to drive a vehicle of the relevant category. It does not grant the right to carry goods or passengers professionally. For that, the Automobile Administration requires a driver qualification card bearing the harmonised Code 95 under Directive 2003/59/EC of 15 July 2003 on the initial qualification and periodic training of drivers, as amended by Directive (EU) 2018/645 of 18 April 2018. The card is issued after an initial qualification course, or a periodic training course, at a licensed training centre, followed by an examination before the agency.

The practical consequence is that a driver holding a properly exchanged Bulgarian licence still cannot be put on an international run until the card is issued. The initial qualification course runs in weeks rather than days and is delivered in Bulgarian at the training centre, which in turn raises a language question during screening.

Why the order of steps moves the start date

The licence exchange happens after the worker already holds a Bulgarian residence permit, that is, after the migration leg closes. So the date of the first Code 95 course depends on the migration timetable, not on recruitment. An employer counting forward from the signature on the employment contract gets a forecast that will not hold.

The real sequence is: work and residence authorisation, then the type D visa and entry, then address registration and the residence permit, then the licence exchange at the Road Police, and only then the course and examination for the qualification card. Each step has its own authority and its own clock. The permit leg is set out in the single permit procedure for employers, and the visa leg with its processing times and fees is in the type D visa.

The most common failure in this corridor is specific. The employer signs a haulage contract with a start date two months out, the driver arrives on time, the licence is exchanged, and then the initial qualification course waits for the training centre to fill the next group. The truck stands still, the driver is on a contract and insured from day one, and there is no revenue against the cost. Those day one obligations are covered in social and health insurance for third country workers.

Plan backwards from the qualification examination, not from the arrival date. If you are building a transport corridor into Bulgaria, send us the country of origin, the categories and the headcount, and we will check which ground the exchange runs on before a start date is fixed. More on how we work with employers: the employers page.