Review of recent sources regarding Bulgaria’s implementation of the Standard Audit File for Tax (SAF-T).
Purpose: To summarise the key themes, important ideas, and facts presented in the provided excerpts concerning the introduction of SAF-T in Bulgaria.
Executive Summary:
Bulgaria is progressing with its digital tax transformation by introducing the Standard Audit File for Tax (SAF-T), aligning with OECD guidelines and European standards. This initiative, spearheaded by the National Revenue Agency (NRA), aims to enhance tax compliance, streamline audits, and improve tax collection efficiency through structured electronic reporting of accounting data. The implementation is planned as a phased rollout starting in 2026, with mandatory submissions initially for large businesses and gradually extending to all enterprises by 2030. Businesses will be required to submit monthly, annual, and on-demand reports in XML format via the NRA’s digital portal using a qualified electronic signature (QES) or authorised APIs. The NRA has initiated public consultations on the draft order outlining the procedures and technical specifications for SAF-T submission. While grace periods are offered during the initial phase, non-compliance will result in penalties.
Main Themes and Key Ideas:
Digital Tax Transformation and SAF-T Adoption: Bulgaria is embracing digital tax transformation, with SAF-T as a central component. This aligns the country with international standards (OECD) and aims to modernise tax administration.
- “As Bulgaria progresses toward digital tax transformation, it has officially outlined the technical framework for the Standard Audit File for Tax purposes (SAF-T), aligning with OECD guidelines and European standards.”
- “SAF-T is an international standard that allows tax authorities to receive accounting data in a structured format for audit and compliance purposes.”
- “Bulgaria has introduced a draft law mandating the submission of the Standard Audit File for Tax (SAF-T), which is expected to take effect in 2025. The National Revenue Agency (NRA) has adopted SAF-T as part of its strategy to enhance tax transparency and combat fraud.”
Phased Implementation Rollout: The SAF-T obligation will be introduced gradually based on business size and turnover, providing a staggered approach to allow businesses to adapt.
- “Bulgaria implements SAF-T in phases, depending on the type and size of the taxpayer.”
- “Bulgaria’s approach to implementing SAF-T is methodical, with a phased rollout designed to accommodate businesses of different scales.”
- Key dates for phased rollout are detailed:
- January 1, 2026: Large businesses (specific turnover/tax thresholds in 2023)
- January 1, 2027: Large, medium, and small businesses (specific turnover/tax thresholds in 2024)
- January 1, 2028: Large, medium, and small businesses (specific turnover/tax thresholds in 2025)
- January 1, 2029: Mandatory for all businesses regardless of turnover.
- January 1, 2030: Mandatory for micro businesses.
Reporting Frequencies and Data Requirements: Businesses will have different reporting obligations with varying frequencies.
- Monthly Reporting (Starting 01.01.2026): Due by the 14th of the following month. Includes Customers, Suppliers, General ledger accounts, Products, Invoices, Payments, and Tax tables.
- “Monthly Reporting (Starting 01.01.2026): Required by the 14th of each month following the reporting period.”
- “Monthly Submissions (Due by the 14th of the following month): General Ledger Entries, Accounts Payable and Receivable, Sales and Purchase Invoices.”
- Annual Reporting (Starting 01.01.2027): Covers fixed asset data and selected inventory details. Submitted annually with the corporate tax declaration.
- “Annual Reporting (Starting 01.01.2027): Covers fixed asset data and selected inventory details.”
- “Annual Submissions (Due by June 30 of the subsequent year): Fixed Assets.”
- Upon Request by Revenue Authorities (Effective 01.07.2026): May include Inventory stock and movements, and data from banks, insurers, and healthcare providers (with special rules for data protection).
- “Upon Request by Revenue Authorities (Effective 01.07.2026): Revenue authorities may request SAF-T files covering: Inventory stock and movements, Data from banks, insurers, and healthcare providers…”
Technical Format and Submission: SAF-T data must be submitted electronically in a specific format.
- File Format: XML.
- Maximum File Size: 50 GB.
- Submission Channels: Electronically via the NRA’s digital portal using a qualified electronic signature (QES) or authorised APIs.
- “Submissions must be made electronically via the National Revenue Agency’s (NRA) digital portal using a qualified electronic signature (QES). Alternatively, authorized APIs are provided for system-to-system integration to support automated submissions.”
Correction and Resubmission Rules: Procedures are in place for correcting and resubmitting invalid files.
- If an initial submission is invalid, companies have seven days to correct and resubmit.
- Multiple correction files are allowed within a reporting window, and each correction must include the complete dataset for the period.
- “If the initial submission is found to be invalid due to formatting errors, schema non-compliance, or missing QES, it will be rejected. Companies are then given seven days to correct and resubmit the file.”
Special Reporting Considerations: Specific rules apply to sensitive sectors like healthcare and financial institutions.
- Healthcare providers must omit personal health information.
- Banks, financial institutions, insurers, and reinsurers submit aggregate data to protect confidential information.
- “Healthcare Providers: Must omit personal health information. Only summary data is accepted.”
- “Banks and Financial Institutions: Submit aggregate data for financial instruments.”
- “Insurers and Reinsurers: Only submit aggregated financial data to protect insurance secrets.”
Grace Periods and Penalties: A transition period with grace periods is provided, but non-compliance will eventually lead to penalties.
- An initial six-month grace period applies for the first submission for a business’s inclusion in the mandate.
- A six-month correction window is available for amending submitted reports.
- Penalties for non-compliance range from BGN 500 to BGN 2,000 for individuals and BGN 5,000 to BGN 15,000 for legal entities and sole traders, with doubled fines for repeated violations.
- “Initial Six-Month Grace Period: For the first six months following a business’s inclusion in the SAF-T mandate, non-compliance will not result in penalties.”
- “Correction Window: Businesses can amend any inaccuracies in their submitted SAF-T reports within six months of the original submission.”
- “For Individuals: Fines ranging from BGN 500 to BGN 2,000.”
- “For Legal Entities and Sole Traders: Penalties between BGN 5,000 and BGN 15,000.”
Public Consultation: The NRA is engaging in public consultations regarding the draft order for SAF-T submission procedures and format.
- “On 9 May, Bulgaria’s National Revenue Agency (NRA) launched a public consultation on the phased rollout of the Standard Audit File for Tax (SAF-T), set to begin in 2026.”
- “The National Revenue Agency (NRA) has published for public consultations a draft order of the Executive Director, which will approve the structure, form, content and method of submission of the Standard Audit File for Tax Purposes (SAF-T)…”
- Opinions and proposals are accepted until June 9, 2025.
Most Important Ideas or Facts:
- Mandatory SAF-T reporting is being introduced in Bulgaria starting in 2026.
- The implementation will be phased, beginning with large businesses and expanding to all enterprises by 2030.
- SAF-T requires the submission of structured accounting data (General Ledger, Accounts Payable/Receivable, Invoices, Fixed Assets, Inventory) in XML format.
- Reporting frequencies include monthly, annual, and on-demand submissions.
- Electronic submission is mandatory via the NRA portal using a qualified electronic signature (QES) or APIs.
- Grace periods are available during the initial transition, but non-compliance will incur significant penalties.
- The NRA is currently conducting public consultations on the specific procedures and technical details of the SAF-T submission.
Conclusion:
Bulgaria’s adoption of SAF-T represents a significant step towards digital tax governance. Businesses, particularly those falling under the initial phases of the rollout, must proactively prepare to ensure compliance with the new reporting requirements. Understanding the phased timeline, data requirements, technical specifications, and correction procedures is crucial to avoid penalties and facilitate a smooth transition to this new digital reporting environment. Participation in the ongoing public consultations is also an opportunity for businesses to provide feedback on the implementation process.
Sources
- Bulgaria Implements SAF-T for Enhanced Digital Tax Compliance and Reporting Requirements – VATupdate
- Bulgaria Set to Launch SAF-T Reporting in 2026 – VATupdate
- Bulgaria Mandates SAF-T Reporting from 2026: A Complete Guide for Businesses – VATupdate
- NRA holds public consultations on draft order for SAF-T submission – VATupdate
Link to the law
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
