Bulgaria Links Valid E-Invoices to Input VAT Deduction

Summary

Bulgaria’s draft VAT reform would make possession of a validated structured e-invoice a substantive condition for input VAT deduction where the supplier is legally required to issue one.
The proposed system would validate each invoice and assign a unique compliance code. A PDF sent by email would not qualify as the required structured e-invoice. [dataplus-bg.com]
Failure to issue a required e-invoice would attract a penalty based on the VAT not charged, subject to proposed minimum amounts of EUR 750 for individuals and EUR 1,500 for legal entities from 1 July 2028. [dataplus-bg.com]

Extended article

A particularly important feature of Bulgaria’s proposed e-invoicing reform is the direct connection between invoice validation and the customer’s right to deduct input VAT.

Under the draft legislation, possession of a valid structured e-invoice would become a substantive condition for input VAT recovery whenever the supplier is required to issue an invoice through the national system. This would make invoice-system compliance more than a supplier-side reporting obligation. It would also affect the recipient’s VAT position.

The proposed model is based on central validation. An invoice would pass through the National Revenue Agency’s information system and receive a unique compliance code. Only after that validation would it be considered issued and received. [dataplus-bg.com]

The draft distinguishes a structured electronic invoice from a visual or unstructured electronic document. Public commentary on the proposal explains that a PDF sent by email would no longer be considered an electronic invoice for transactions covered by the mandate. The relevant invoice would instead be a structured data file capable of automated processing and validation. [dataplus-bg.com]

The proposed penalty for failing to issue a required structured e-invoice would equal the VAT not charged, subject to a minimum of EUR 750 for an individual and EUR 1,500 for a legal entity. The penalty would apply from 1 July 2028, six months after the proposed launch of mandatory e-invoicing. [dataplus-bg.com]

For businesses, the proposed link to VAT deduction increases the importance of inbound invoice controls. Accounts-payable processes would need to distinguish a successfully validated invoice from a document that merely looks like an invoice. The published draft establishes the legal direction, while detailed technical requirements are expected to be laid down by ordinance.

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