Bulgaria Makes Progress in Tax Digitization with SAF-T and a New Electronic Invoicing Project

Bulgaria continues to advance the digitization of its tax processes through two key initiatives: the phased implementation of the SAF-T (Standard Audit File for Tax) system and the development of a new structured electronic invoicing model.

While the SAF-T reporting requirement has already begun to take effect in 2026 for the first group of taxpayers, on September 23, 2026, the Bulgarian Ministry of Finance published a draft amendment to the VAT Act proposing the introduction of mandatory structured electronic invoicing for certain domestic transactions.

The draft is currently in the public consultation phase, so its provisions may still be subject to change before final approval.

Bulgaria Proposes a New Mandatory Electronic Invoicing System

The Bulgarian Ministry of Finance has published a legislative draft to amend the VAT Act and introduce a national system for structured electronic invoicing and digital reporting.

The proposal was published on September 23, 2026, and is open for public comment through October 23, 2026.

According to the draft, Bulgaria would establish a national system managed by the National Revenue Agency (NRA) for the exchange and verification of structured electronic invoices.

The proposal stipulates that invoices subject to the requirement must be generated in a structured format that allows for automatic processing. The model would be based on the European electronic invoice standard EN 16931.

The draft bill provides that the main provisions related to electronic invoicing will take effect on January 1, 2028. However, as this is still a draft bill, both the timeline and the final requirements will need to be confirmed once the legislative process is complete.

Proposed Timeline for Electronic Invoicing in Bulgaria

Currently, the timeline should be considered provisional, as it is based on a legislative proposal that has not yet been definitively approved.

September 23, 2026: Publication of the draft amendment to the VAT Act.

October 23, 2026: Expected end date of the public consultation.

January 1, 2028: Proposed effective date for the main obligations related to structured electronic invoicing and the new digital reporting model.

Companies operating in Bulgaria should monitor the progress of the legislative process and the future publication of technical specifications to determine the specific impact on their invoicing and ERP systems.

Which transactions would be subject to mandatory electronic invoicing in Bulgaria?

According to the published draft, the requirement would primarily affect certain domestic transactions carried out by suppliers established in Bulgaria.

Transactions included in this requirement include:

• Domestic B2B transactions.
• B2G transactions with public agencies and government bodies.
• Transactions with taxable persons and non-taxable legal entities established in Bulgaria.
• Advance payments related to domestic transactions falling within the scope of application.

For B2G transactions, the draft also provides for certain scenarios applicable to suppliers established in Bulgaria who are not registered for VAT purposes.

Therefore, the future model would have a primarily domestic scope and would represent a significant change in the way businesses generate and exchange their invoices in Bulgaria.

Transactions Excluded from the Electronic Invoice Project

The proposal also establishes certain exceptions to the mandatory use of structured electronic invoices.

These include:

• Intra-Community supplies.
• Triangular transactions.
• Certain transactions carried out by suppliers registered for VAT purposes but not established in Bulgaria.
• Other specific transactions that fall outside the scope of the proposed national system.

The final scope of these exceptions will be confirmed once the legislation is adopted and the corresponding implementing regulations are published.

How would the new electronic invoicing system work?

The project proposes the creation of a national system called the National Information System for Structured Electronic Invoicing and Digital Reporting (NISSEF), managed by the NRA.

The proposed model goes beyond the simple exchange of electronic invoices between suppliers and customers. The information from structured invoices would be transmitted to the tax authority, allowing the NRA to access transaction data digitally.

According to the proposal, invoices could be generated using the national system itself or through other software and systems connected to the platform.

When external systems are used, certain invoice data must be transmitted electronically to the NRA for validation. The system will verify the information and, when the document meets the established requirements, generate a unique compliance code.

In addition, the proposal links the new electronic invoice model to greater automation of VAT compliance, including the use of data available to the administration to prepare draft VAT returns.

However, the final technical and operational specifications necessary to implement the system have not yet been published. Aspects such as data schemas, APIs, connection procedures, and other technical rules will need to be specified through subsequent regulatory developments.

SAF-T in Bulgaria: Mandatory Starting in 2026

In parallel with the development of electronic invoicing, Bulgaria is progressively rolling out the Standard Audit File for Tax (SAF-T).

Unlike the electronic invoicing project, SAF-T is already a mandatory requirement for the first group of taxpayers.

As of January 1, 2026, certain large companies are required to submit their accounting and tax information to the NRA using this standardized format.

The Bulgarian tax authority also provides a dedicated electronic service for submitting SAF-T files and has published the structure, format, content, and submission procedure.

The implementation of SAF-T is taking place gradually to progressively include different groups of taxpayers.

SAF-T Implementation Timeline in Bulgaria

The introduction of SAF-T in Bulgaria has been designed as a phased process that began in 2026.
The first phase applies to large taxpayers who meet the criteria established by the regulations. Subsequently, the scope of the system will be progressively expanded to include new groups of companies.

The NRA has already launched its dedicated electronic service for SAF-T and has published technical documentation to facilitate compliance with the requirement.

Companies must verify each fiscal year whether they meet the criteria determining their inclusion in the system, as the timeline is implemented in phases until a much broader scope of application is reached.

What information does SAF-T include in Bulgaria?

SAF-T allows for the structured transmission of a wide range of information from companies’ accounting and financial systems.

Among the key data included in the model are:

• General ledger and accounting data.
• Information on customers and suppliers.
• Accounts receivable and accounts payable.
• Sales and purchase invoices.
• Payment information.
• Data on fixed assets.
• Inventory information, when applicable.

The structure, format, and submission procedure for the file have been defined by the NRA and may be updated to adapt to changes in the system.

SAF-T Submission Frequency

The Bulgarian model establishes different reporting frequencies depending on the information submitted.

Monthly Reporting

Companies subject to this requirement must periodically submit accounting and transactional information via SAF-T.

The first mandatory submission was for the January 2026 period for companies included in the first phase of the mandate.

Annual Reporting

Certain data, particularly that related to fixed assets, is included in the annual reporting.

Information Upon Request

The NRA may also request certain additional information, such as detailed inventory data, in accordance with the rules established for SAF-T.

How to Prepare for the New Tax Requirements in Bulgaria?

Companies operating in Bulgaria should view tax digitization as a gradual process that affects both reporting and invoicing.

In the context of SAF-T, companies in the various phases must have mechanisms in place capable of extracting, transforming, validating, and transmitting accounting information in accordance with the structure established by the NRA.

With regard to electronic invoicing, the draft published in September 2026 makes it possible to begin assessing the potential impact on invoicing and ERP systems. However, it will be necessary to wait for the final approval of the regulations and the publication of the technical specifications to determine the specific integration requirements.

Having a platform capable of centralizing electronic invoicing, tax reporting, and integration with ERP systems will enable companies to adapt more efficiently to changes in Bulgaria’s tax compliance model.

EDICOM continuously monitors regulatory changes related to electronic invoicing and international tax reporting to adapt its solutions to the new technical and legal requirements of each country.