Briefing document & Podcast: SAF-T Implementation in Bulgaria as of Jan 1, 2026

Last update: January 2, 2026

SUMMARY

This briefing document provides an overview of Bulgaria’s upcoming implementation of Standard Audit File for Tax (SAF-T) reporting, scheduled to begin on January 1, 2026. The information is based on a VATupdate article last updated on January 2, 2026, which compiles and summarizes information from various sources, including official announcements and professional services firms. This document outlines the scope, content, timing, and connection to VAT returns related to SAF-T in Bulgaria.

Key Themes and Facts:

Overall Goal: The implementation of SAF-T in Bulgaria represents a significant move towards digital tax administration, aiming to increase transparency and efficiency in VAT compliance. The system provides tax authorities with “full visibility” of transactions.
Scope and Phased Implementation:SAF-T will eventually cover all VAT-registered businesses in Bulgaria.
Implementation will be phased in based on company size, starting January 1, 2026.
Phase 1 (Jan 1, 2026): Largest enterprises with annual net revenue over BGN 300 million (≈ EUR 153 million) or annual tax and social security payments over BGN 3.5 million (≈ EUR 1.8 million). This includes local companies and Bulgarian branches/permanent establishments of foreign entities.
2028: Extends to medium-sized firms above lower thresholds (e.g., annual revenue over BGN 15 million).
2029: All large, medium, and small enterprises must comply.
January 2030: Micro-enterprises within the SAF-T scope are included. Micro-enterprises not VAT-registered are exempt.

“In summary, the SAF-T reporting is initially limited to the biggest taxpayers in 2026 and will gradually include every VAT-registered business in Bulgaria by 2030.”

Content of SAF-T Reports: SAF-T requires a comprehensive electronic report of a company’s accounting records, effectively a “full digital audit trail” of financial activities. This includes:
- General Ledger entries: “All journal entries and accounting transactions recorded in the period. This covers every debit and credit entry in the books.”
- Sales and purchase invoices: “All outgoing (sales) invoices and incoming (purchase) invoices must be reported in detail.” This includes customer/supplier information, invoice date/number, taxable amount, VAT amount, and related-party indicators.
- Payments: All incoming and outgoing payments related to the business, linked to invoices and other cash/bank transactions.
- Master data and codes: Company identification details, information on ultimate owners, chart of accounts, and tax/business nomenclatures.
- Assets and inventory: Fixed assets (purchases, disposals, depreciation) and inventory items (stock movements, balances).
- The data is submitted in a standardized XML format.
Reporting Frequency and Deadlines:
- Monthly SAF-T reports: Due by the 14th of the month following the reporting period (e.g., January 2026 report due by February 14, 2026). Includes general ledger entries, sales invoices, purchase invoices, and payments for the month. This aligns with the monthly VAT return deadline.
- Annual SAF-T reports: Fixed asset information due by June 30 of the following year.
- On-demand (ad hoc) reports: Inventory data is submitted only when requested by the tax authority. Businesses must be prepared to produce inventory records in the SAF-T format upon request.
Grace Period and Penalties:
- A six-month grace period is provided at the start of SAF-T reporting for each newly included group of taxpayers. During this period, corrections or late submissions can be made without penalties.
- After the grace period, fines apply for non-compliance, ranging roughly from BGN 5,000 to 15,000 for late or missing SAF-T files.
Link to VAT Return:
- SAF-T supplements the VAT return; it does not replace it. Businesses must continue filing periodic VAT returns.
- SAF-T provides the transaction-level details to support the figures reported on the VAT return. The VAT return is a summary, while SAF-T is the itemized list of every transaction contributing to those totals.
- Consistency between SAF-T and VAT returns is crucial. Discrepancies will likely trigger questions or audits. Tax technology solutions aim to produce “fully reconciled” SAF-T files.

“The SAF-T does not replace the VAT return; businesses must continue filing their periodic VAT returns (monthly VAT declarations) as before. Instead, the SAF-T serves as a supplementary report that provides all the transaction-level details to support the figures on the VAT return.”

Benefits: The SAF-T should improve accuracy of VAT reporting and simplify audits, as the NRA can analyze SAF-T data to identify discrepancies or risk areas.

Conclusion:

Bulgaria’s SAF-T implementation will significantly impact VAT-registered businesses, requiring them to maintain robust electronic accounting records. Compliance will require businesses to “keep robust electronic records to meet the SAF-T requirements and ensure those records are in sync with their VAT reporting.” The phased approach allows businesses time to adapt, but timely preparation and adherence to the regulations are crucial to avoid penalties. It is linked to the VAT return process so that VAT figures can be verified with underlying data.

INDEPTH ANALYSIS

Overview:

Bulgaria has introduced Standard Audit File for Tax (SAF-T) reporting obligations beginning in 2026. This mandate will gradually cover almost all VAT-registered businesses, requiring them to regularly submit detailed electronic accounting data to the tax authorities. Below is a detailed breakdown of who is in scope, what must be reported, when to submit the SAF-T, and how it ties into the VAT return process.

Scope – Who is in scope for SAF-T in Bulgaria: All businesses that are registered for VAT in Bulgaria will eventually fall under the SAF-T reporting requirement, implemented in phases. The first phase starts January 1, 2026, targeting the largest enterprises. Specifically, companies with annual net revenue over BGN 300 million (≈ EUR 153 million) or annual tax and social security payments over BGN 3.5 million (≈ EUR 1.8 million) must begin SAF-T reporting in 2026. This includes not only local companies but also Bulgarian branches or permanent establishments of foreign entities that meet those size criteria. The SAF-T obligation then expands in subsequent years: by 2028 it will extend to medium-sized firms above lower thresholds (e.g. those with annual revenue over BGN 15 million). By 2029, all large, medium, and small enterprises will be required to comply (covering essentially all VAT-registered businesses except the very smallest). Finally, by January 2030 even micro-enterprises (the remaining smallest businesses that are within the SAF-T scope) come under the mandate. (Note: Micro-enterprises that are not VAT-registered are exempt from SAF-T entirely.) In summary, the SAF-T reporting is initially limited to the biggest taxpayers in 2026 and will gradually include every VAT-registered business in Bulgaria by 2030. [pwc.bg] [ey.com] [vatcalc.com], [sovos.com] [pwc.bg], [sovos.com] [sovos.com]

Content – What transactions and data must be reported:

The SAF-T file in Bulgaria is a comprehensive electronic report of a company’s accounting records. It is designed to give the tax authority full visibility of the transactions underlying a business’s tax declarations. Essentially all accounting transactions and relevant data must be included. According to the legislation, SAF-T reports will cover detailed business and financial information including:

General Ledger entries: All journal entries and accounting transactions recorded in the period. This covers every debit and credit entry in the books. [pwc.bg]
Sales and purchase invoices: All outgoing (sales) invoices and incoming (purchase) invoices must be reported in detail. For each invoice, the SAF-T will include information on the customer or supplier, invoice date and number, taxable amount, VAT amount, and an indication if the transaction is with a related party. (In other words, the full list of all invoices issued and received in the period is part of the SAF-T.) [pwc.bg]
Payments: The file includes all incoming and outgoing payments related to the business. This links to the invoices – showing which invoices have been paid and when – and includes other cash/bank transactions. [pwc.bg]
Master data and codes: SAF-T contains the company’s identification details (e.g. tax identification, registration data) as well as information on its ultimate owners. It also includes the firm’s chart of accounts and any tax codes or business nomenclatures used in the accounting system. This ensures that the authorities can interpret the accounting entries correctly (using standardized codes for accounts, taxes, etc.). [pwc.bg]
Assets and inventory: All fixed assets (e.g. equipment, vehicles, property) and inventory items are included, along with any transactions involving them. For fixed assets, this means the SAF-T will report asset purchases, disposals, and depreciation entries. For inventory, it will capture stock movements (e.g. additions to inventory, sales or usage of stock, stock balances). [pwc.bg]

In short, the SAF-T file is a full digital audit trail of the company’s financial activities for the period. It spans everything from high-level ledger entries down to individual invoice line items. The data is submitted in a standardized XML format defined by the Bulgarian National Revenue Agency (NRA), ensuring it is machine-readable and consistent in structure. This rich dataset allows the tax authorities to analyze a taxpayer’s transactions in detail if needed. [vatcalc.com]

Timing – When and how often the SAF-T must be submitted: Bulgarian SAF-T reporting is split into different components with different submission frequencies: [pwc.bg]

Monthly SAF-T reports: The core SAF-T submission is monthly. It must be filed by the 14th of the month following the reporting period. For example, the SAF-T for January 2026 must be submitted by 14 February 2026. Each monthly SAF-T file includes the principal accounting information for that month – notably the general ledger entries, and the detailed lists of sales invoices, purchase invoices, and payments for the month. (Notably, the 14th of the following month is also the standard deadline for the monthly VAT return in Bulgaria, which means the SAF-T timeline is aligned with the VAT return schedule.) [pwc.bg]
Annual SAF-T reports: In addition to the monthly files, there is an annual SAF-T component specifically for fixed assets. Information on all fixed assets and related transactions for the year must be submitted by 30 June of the following year. This annual SAF-T covers things like the year’s asset acquisitions, disposals, depreciation, and closing asset balances. By having an annual deadline (six months after year-end) for asset data, the authorities allow companies to report assets once yearly instead of including these in every monthly file. [pwc.bg]
On-demand (ad hoc) reports: Inventory data is handled on an on-demand basis. Companies are not required to file detailed inventory records on a regular schedule, but if the tax authority requests an SAF-T for inventory (for example, during an audit or inquiry), the company must generate and submit one. This on-demand inventory SAF-T would detail stock quantities and movements. Essentially, businesses must be prepared to produce their inventory records in the SAF-T format whenever asked by the NRA. [pwc.bg]

For each newly included group of taxpayers, the law provides a six-month grace period at the start of SAF-T reporting. In practice, this means for the first six monthly submissions after a business comes into scope, corrections or late submissions can be made without penalties up until the deadline of the 7th month’s file. This grace period (January–June 2026 for the first wave) is intended to allow companies to adjust to the new system. After that, fines apply for non-compliance (in Bulgaria’s case, penalties can range roughly from BGN 5,000 to 15,000 for late or missing SAF-T files). All SAF-T files must be submitted electronically through the NRA’s systems, following the exact XML schema and format specified by the authorities. [vatcalc.com], [pwc.bg] [pwc.bg] [vatcalc.com]

Link to VAT return – How SAF-T reporting connects to the VAT return process: The introduction of SAF-T in Bulgaria is closely linked to VAT compliance. The SAF-T does not replace the VAT return; businesses must continue filing their periodic VAT returns (monthly VAT declarations) as before. Instead, the SAF-T serves as a supplementary report that provides all the transaction-level details to support the figures on the VAT return. In other words, the totals that a company reports on its VAT return for a given period should be backed up by the data in the SAF-T for that period. [vatcalc.com]

The relationship can be described as follows: the VAT return is a summary (it shows total taxable sales, total VAT charged, total purchases, input VAT to reclaim, etc.), whereas the SAF-T is the itemized list of every transaction contributing to those totals. For example, if a company’s January VAT return declares €100,000 of taxable sales and €20,000 of output VAT, the January SAF-T file will contain the list of every sales invoice that makes up that €100,000, along with the VAT on each invoice that sums to €20,000. Similarly, the purchase invoices and VAT on them in the SAF-T should sum to the total input VAT the company claimed for that month. [vatcalc.com]

Because of this, consistency between the SAF-T and the VAT return is crucial. The tax authority will be able to cross-check the two. If the totals in the VAT return do not reconcile with the detailed data in the SAF-T file, it will likely trigger questions or audits. Businesses are therefore expected to ensure that SAF-T submissions are fully aligned with their VAT returns. In fact, tax technology solutions explicitly aim to produce “fully reconciled” SAF-T files that match the VAT return declarations exactly. [vatcalc.com], [tpa-global.com]

In summary, SAF-T reporting is integrated with the VAT return process: companies still submit their VAT returns to report tax liabilities, and alongside those, the SAF-T provides the underlying data for verification. This approach enhances tax compliance by giving Bulgarian tax authorities a powerful tool to verify that the VAT reported is correct, through a direct comparison of declared totals versus actual transaction data. It links to the VAT return by acting as a detailed annex or audit file – one that is submitted proactively each period, rather than only during an inspection. Over time, this should improve accuracy of VAT reporting and simplify audits, since the NRA can analyze the SAF-T data to spot any discrepancies or risk areas (such as missing invoices, incorrect tax rates, or transactions not reported on the VAT return).

Conclusion: The SAF-T in Bulgaria (from 2026 onward) represents a major step toward digital tax administration. Who must comply? – All VAT-registered businesses, phased in by size (largest in 2026, all by 2030). What is reported? – A standardized file of all accounting transactions and records (invoices, payments, ledger entries, assets, etc.) for the period. When? – Monthly submissions by the 14th of the next month (plus annual asset reports by June 30, and on-demand inventory reports). How does it link to the VAT return? – It supplements the VAT return, providing granular data so that the SAF-T’s content aligns with and substantiates the VAT return figures, thereby allowing authorities to verify the accuracy of VAT declarations. The result is a more transparent and efficient VAT compliance process, with businesses needing to keep robust electronic records to meet the SAF-T requirements and ensure those records are in sync with their VAT reporting. [pwc.bg], [sovos.com] [pwc.bg] [vatcalc.com], [tpa-global.com]

Sources

Link to the law