Last update: July 30, 2025
Executive Summary
Bulgaria is set to implement the Standard Audit File for Tax (SAF-T) system, an OECD-backed standard for electronic exchange of tax and accounting information, starting from January 1, 2026. This phased introduction aims to modernise tax compliance, enhance transparency, and reduce administrative burdens for both taxpayers and the National Revenue Agency (NRA). The final technical documentation, including XML formats, use cases, nomenclatures, and validation rules, was published on July 25, 2025, following extensive public consultations. Large enterprises will be the first to comply, with mid-sized and other taxpayers following in subsequent years.
1. Introduction to SAF-T in Bulgaria
Bulgaria is joining a growing list of countries adopting the Standard Audit File for Tax (SAF-T), an international standard developed by the Organisation for Economic Co-operation and Development (OECD). SAF-T provides a “standardised, electronic format for businesses to submit detailed accounting information to revenue authorities, facilitating efficient information exchange.” The system is XML-based, ensuring machine-readable and human-readable data exchange. This initiative reflects a broader European and global trend towards digital tax compliance.
2. Implementation Timeline and Scope
The implementation of SAF-T in Bulgaria will be phased, extending over several years:
- January 2026: Mandatory for “large enterprises” defined by specific financial thresholds. An enterprise is classified as “large” if it generated “over BGN 300 million net sales revenue in 2023 or made net payments exceeding BGN 3.5 million to the NRA for taxes and social security contributions in 2023.” Approximately 460 companies will be initially affected.
- January 2028: Extends to “mid-sized enterprises” with “over BGN 15 million net sales revenue or over BGN 1.5 million in tax/social security payments in 2023.”
- January 2030: Applies to “all other taxpayers.”
The NRA will officially notify companies of their SAF-T reporting obligations through letters, based on data from the Transitional and Final Provisions of the 2025 State Budget Law. A pilot testing phase for the SAF-T system began on July 1, 2025, allowing selected volunteer companies to adapt ahead of mandatory implementation.
3. Types of SAF-T Reports and Submission Deadlines
Bulgaria requires three main types of SAF-T reports, each with specific content and submission frequencies:
- Monthly Report: This is the most frequent report and includes:
- General Ledger: Journals, chart of accounts, balances, movements, transactions, tax rates, and calculated taxes.
- Accounts Payable and Receivable: Supplier/customer master files, invoices, payments, payment methods, and transaction details.
- Sales and Purchase Invoices: Detailed transaction records.
- Deadline: “By the 14th day of the month following the reporting month.”
- Annual Report: This report focuses on long-term assets:
- Fixed Assets: Asset master files, depreciation, and revaluation.
- Deadline: “By 30th June of the following year, aligning with corporate income tax filing deadlines.”
- On-Demand Report: This report is submitted upon request by the NRA:
- Inventory: Product master files and movements, including inventory stocks.
- Submission: “Upon request by the National Revenue Agency (NRA) within a specified timeframe.”
All data must adhere to “standardised nomenclatures” to ensure consistency and uniformity in reported information.
4. Required Data and Technical Specifications
A Bulgarian SAF-T file must be comprehensive, including “identification details of the taxable entity and its beneficial owner, complete accounting records (such as accounts, balances, movements, transactions, tax rates, and calculated taxes), detailed purchase and sales documents with customer and supplier information, payment methods and transaction details, fixed asset information (including depreciation), and inventory stocks and movements.”
Technically, SAF-T reports are XML-based, following an XSD schema. They include “built-in rules for structure, data types, and mandatory fields.” Companies are expected to report “several hundred mandatory data points” out of nearly a thousand in total. Electronic submission requires a “qualified electronic signature” for authenticity and integrity.
5. Role of the National Revenue Agency (NRA) and Public Consultations
The NRA has played a crucial role in the SAF-T implementation process. They:
- Published the “final technical documentation for its 2026 launch of Standard Audit File for Tax (SAF-T)” on July 25, 2025.
- Conducted “public consultations on the draft order defining the SAF-T format and procedure.” This process allowed “businesses and stakeholders to provide comments and suggestions on the draft order.”
- Accepted “over 130 suggestions, in whole or in part,” from the feedback received, demonstrating a commitment to “transparency and public participation.”
- Published the final order, including “three sample XML files (monthly, annual, and on request)” to assist businesses.
- Provided “additional guidelines and explanations for filling in the information in the specific file.”
- Established a dedicated communication channel ([email protected]) for questions, with responses to be included in a Q&A section on the NRA website.
6. Grace Period for Corrections
To facilitate adaptation to the new requirements, a grace period for corrections is provided: “For each wave of implementation, the first six monthly SAF-T reports can be freely corrected. These corrections are permitted up until the deadline for submission of the seventh monthly SAF-T report.”
7. Anticipated Benefits of SAF-T Adoption
The adoption of SAF-T in Bulgaria is expected to bring significant benefits for both the NRA and taxpayers:
- For the NRA: “Faster and more targeted communication,” enhanced “accuracy, transparency, and consistency in tax reporting,” and improved “taxpayer confidence and voluntary compliance with tax laws.”
- For Taxpayers: “Reduced administrative burden through digital data submission,” leading to a more streamlined and efficient compliance process. The system aims to modernise tax compliance overall.
Sources
- Order of the Executive Director of the NRA – approved technical documentation for SAF-T – VATupdate
- 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
