Is it legal to record a meeting in Bulgaria?

No provision found in the Наказателен кодекс criminalises recording a conversation you are party to. The correspondence provisions require a message not addressed to the recorder, and the intelligence-means provisions require state surveillance equipment.

One caveat worth carrying: Чл. 339а punishes holding a special technical means for covert collection with one to six years. The word негласно, covert, should exclude an announced recorder, but that is a reading rather than a decided point.

And Bulgaria has no civil code, so there is no counterpart to Slovakia's Občiansky zákonník § 12(1), Hungary's Ptk. § 2:48 or Czechia's Civil Code §§ 84 to 90. There is no general private-law provision requiring consent to make an audio recording of a person. That absence is the structural reason Bulgaria is the least constrained country in its region, and it is a finding rather than a gap: in Slovakia and Hungary the binding rule is a civil consent provision, in Romania a criminal provision with a conditional exception, and in Bulgaria the Constitution plus GDPR.

Yes on the criminal layer. But the binding rule is constitutional, and it is the most interesting sentence in this region.

Конституция Чл. 32(2): "Никой не може да бъде следен, фотографиран, филмиран, записван или подлаган на други подобни действия без негово знание или въпреки неговото изрично несъгласие освен в предвидените от закона случаи." No one may be followed, photographed, filmed, recorded or subjected to other similar acts without his knowledge or notwithstanding his express disagreement, except in the cases provided for by law.

Read the structure, because it differs from every other country here. The prohibition has two independent triggers joined by или, or: recording someone without his knowledge, or recording someone notwithstanding his express disagreement.

So the constitutional baseline is knowledge, not consent. An announced recording satisfies the first limb. But the second limb is a veto: once a participant expressly disagrees, recording them is prohibited regardless of how well they were informed. Bulgaria converges on the same practical instruction as the consent countries by a different route, and the difference shows up in one place that matters: in Bulgaria the answer to "what if someone objects" is that you must stop, and that is not a courtesy.

One honest hedge: Bulgarian constitutional rights bind the state directly, and the extent to which Чл. 32(2) is applied between private persons rather than through ordinary law was not verified. No Constitutional Court decision was opened.

Bulgaria is the one country in this region where the baseline is knowledge rather than consent, which changes the shape of the advice.

Knowledge is the constitutional threshold, so the announcement is doing the primary legal work rather than merely evidencing consent. An express objection is a veto and must be honoured, so the announcement has to be one that invites objection, and the objection has to be actionable.

Before we start: I'm recording and transcribing this meeting so I have accurate notes. It runs on my own laptop and nothing is uploaded. Say so now if you'd rather I didn't, and I'll turn it off.

Whether a calendar-invite line constitutes знание: no authority found. It is a better fit under a knowledge standard than under a consent standard, since the question is only whether the person knew, but an invite reaches only the invited. Whether implied consent matters at all largely does not arise, because Чл. 32(2) does not ask for consent. That is a genuine simplification relative to Slovakia and Hungary, and it comes with the veto attached.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Bulgaria is the country where a GDPR-first page and a national-law page give the most similar answers, and the only one in its region where that is true. Note that Чл. 32(2)'s knowledge threshold does not substitute for a full Art. 13 notice.

Written internal rules and procedures covering scope, obligations and method, with employees notified, under ЗЗЛД Чл. 25и.

No employee representation requirement was found: no consultation and no consent right. That makes Bulgaria the easiest of its region for a rollout on the procedural layer.

The hardest local obstacle is not procedural at all. It is Чл. 32(2)'s express-objection veto: a Bulgarian participant can say no, and the user must be able to comply. An always-on recorder with no way to exclude a conversation is something an objector can veto and the user cannot obey, which is a product problem rather than a wording one.

КЗЛД, the Bulgarian Commission for Personal Data Protection. Nothing specific on meeting recording was opened in our research, and nothing on the horizontal effect of Чл. 32(2) between private parties, which is the question most worth answering for Bulgaria.

Because the binding layer in Bulgaria is data protection rather than criminal law, this is where the product's architecture does real work. Transcription runs on your own device, the audio is never written to disk, and nothing is sent anywhere. There is no cloud component, so on our reading we are not a processor under Art. 4(8), which processes personal data on behalf of a controller and presupposes receiving it. That means no Art. 28 data processing agreement to sign with us, no sub-processor list, no international transfer and no transfer impact assessment, because there is no transfer. We found no decision squarely holding that an on-device-only vendor is not a processor, so that is reasoning you can check rather than a settled point.

What it does not do is disclose anything. There is no bot in the participant list and no banner on anyone else's screen, so the transparency obligation rests entirely on you saying something. Earkeep does not make anyone compliant and could not: a tool cannot be compliant, only a processing operation can be lawful.

Where it helps in the room is that stopping is real and checkable. A pause from the live edge releases the microphone and the system audio stream, so your operating system's own recording indicator goes dark in front of the person who asked. A meeting on a connected calendar can be marked never-record. And a stretch of the day, or a saved meeting with its transcript, can be purged from the file on your own disk, with no server copy anywhere to reconcile against.

• Конституция на Република България, Чл. 32
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.