Bulgaria — SAF-T, E-Invoicing & E-Reporting Country Booklet

Bulgaria already operates a mandatory, phased SAF-T e-reporting regime. By contrast, the proposed domestic structured e-invoicing system, the National Information System for Structured Electronic Invoicing and Digital Reporting, or NISSEF, and pre-filled VAT returns are contained in a draft VAT Act amendment published for consultation on 23 September 2026. The consultation remains open until 23 October 2026. These measures are therefore not yet enacted and may change. [strategy.bg], [minfin.bg], [nra.bg]

1. Introduction and Country Context

1.1 Tax digitalization journey

Bulgaria’s tax digitalization is developing through three connected but legally distinct components:

• B2G e-invoicing: Since 1 November 2019, Bulgarian public contracting authorities have been required to receive and process structured electronic invoices compliant with EN 16931 for relevant public-procurement contracts. Suppliers are not generally required to issue an e-invoice, so this is primarily a public-sector receiving obligation. [ec.europa.eu], [strategy.bg]
• SAF-T e-reporting: Mandatory SAF-T reporting began for the first group of large enterprises on 1 January 2026. It is a periodic reporting regime involving accounting, invoice, payment, fixed-asset and inventory data, rather than an invoice-clearance system. [nra.bg], [portal.nra.bg], [vatcalc.com]
• Proposed domestic e-invoicing: The Ministry of Finance published a draft VAT Act amendment on 23 September 2026 proposing mandatory structured e-invoicing for specified domestic supplies, real-time transmission to the National Revenue Agency, or NRA, and pre-filled VAT returns from 2028. [strategy.bg], [minfin.bg], [minfin.bg]

1.2 Policy rationale

The stated objectives of the September 2026 proposal are to:

• reduce VAT fraud and the use of false invoices;
• enable continuous or real-time VAT control;
• modernize VAT administration;
• eliminate duplicate entry of invoice information in invoices and VAT ledgers;
• support automatic generation of draft VAT returns;
• improve invoice verification;
• prepare businesses for EU cross-border digital reporting under ViDA. [strategy.bg], [minfin.bg], [taxation-c….europa.eu]

The Ministry estimates that building the national e-invoicing platform will require approximately €20 million and expects an estimated positive budgetary impact of €350 million in 2028. These are government impact-assessment estimates, not guaranteed outcomes. [minfin.bg]

1.3 Regional and international positioning

Bulgaria is:

• already operating a phased OECD-based SAF-T regime;
• an existing adopter of EN 16931 for public-sector invoice receipt;
• proposing a domestic centralized clearance system ahead of ViDA’s 1 July 2030 cross-border digital reporting date;
• seeking to use the European e-invoicing standard to reduce later migration work when ViDA becomes applicable. [ec.europa.eu], [minfin.bg], [nra.bg], [taxation-c….europa.eu]

1.4 EU authorization or derogation

Bulgaria has not needed to obtain a new Council derogation for the September 2026 proposal. Since ViDA entered into force on 14 April 2025, Member States may introduce mandatory domestic e-invoicing under the revised EU framework, subject to the conditions in Directive (EU) 2025/516. [taxation-c….europa.eu], [eur-lex.europa.eu], [kpmg.com]

2. Regulatory Framework

2.1 Primary legislation

Current framework

The principal current legal instruments are:

• The Bulgarian VAT Act, originally published in State Gazette No. 63 of 4 August 2006, governs invoice issuance, content, corrections, VAT reporting and deduction. The English text available from the Ministry of Finance is not fully updated and should not be treated as the definitive consolidated 2026 version. [minfin.bg]
• The Tax and Social Insurance Procedure Code, particularly Articles 71з to 71к, establishes the SAF-T obligation, filing periods and procedural rules. [nra.bg], [portal.nra.bg], [lex.bg]
• The Public Procurement Act, Article 115a, requires public contracting authorities to accept and process EN 16931-compliant electronic invoices for relevant public-procurement contracts. [ec.europa.eu], [strategy.bg]

September 2026 draft

The Ministry of Finance’s draft VAT Act amendment proposes:

• new Articles 120a to 120d governing structured electronic invoices, structured corrective notices and NISSEF;
• new Article 113(16) to (20) defining the persons and transactions subject to structured e-invoicing;
• amendments to Articles 114 to 116 concerning invoice content and corrections;
• changes to VAT deduction rules;
• pre-filled VAT returns generated from e-invoice and customs data;
• abolition of the existing purchase and sales ledgers;
• real-time invoice submission and validation. [minfin.bg], [minfin.bg]

The proposal was published under public consultation 12733-K, running from 23 September to 23 October 2026. It has not yet been adopted by the National Assembly or published in the State Gazette. [strategy.bg]

2.2 Implementing regulations and orders

SAF-T

The NRA’s current technical framework is based on:

• Order No. З-ЦУ-30-1085 of 25 July 2025;
• subsequent changes, including Order No. З-ЦУ-30-1247 of 25 August 2025;
• Order No. З-ЦУ-30-359 of 27 February 2026;
• XSD schema version 1.0.2, applicable from 1 April 2026;
• tabular structure version 1.0.2;
• filing requirements version 1.0.1. [nra.bg], [vatcalc.com], [nra.bg]

Proposed e-invoicing

The September 2026 draft leaves important implementation matters to a future ordinance of the Minister of Finance, including:

• technical issuance requirements;
• transmission and receipt methods;
• semantic and technical validations;
• storage arrangements;
• correction and cancellation procedures;
• interoperability with third-party software. [minfin.bg], [minfin.bg]

No final ordinance, production schema, API documentation or certification regime has yet been published.

2.3 Official guidance and FAQs

The NRA maintains:

• a dedicated SAF-T information page;
• XSD schemas and sample XML files;
• a tabular data definition;
• filing instructions;
• FAQs that the NRA states will be updated periodically;
• an electronic filing service;
• a dedicated contact address, [email protected]. [nra.bg], [nra.bg], [portal.nra.bg]

No equivalent final FAQ or technical documentation exists yet for NISSEF because the e-invoicing measure remains draft legislation.

2.4 EU legal basis

The relevant EU framework includes:

• Directive 2014/55/EU for B2G e-invoicing;
• Commission Implementing Decision (EU) 2017/1870 identifying the European standard and recognised syntaxes;
• Council Directive (EU) 2025/516;
• Council Regulation (EU) 2025/517;
• Council Implementing Regulation (EU) 2025/518. [ec.europa.eu], [taxation-c….europa.eu], [eur-lex.europa.eu]

3. Scope of the Mandate

3.1 Transactions in scope

Domestic B2B

Current position: No general domestic B2B e-invoicing mandate is yet in force. Electronic invoices may be exchanged by agreement under the existing VAT rules. [ec.europa.eu], [basware.com]

Draft position from 2028: A VAT-registered supplier established in Bulgaria would have to issue a structured electronic invoice for a supply with a Bulgarian place of supply where the recipient is established in Bulgaria and is:

• a taxable person;
• a non-taxable legal person; or
• the state, a state authority or a local authority. [minfin.bg], [minfin.bg]

An ordinary PDF would not meet the proposed definition because the invoice must be issued, transmitted and received in a structured, automatically processable format, comply with the European standard and obtain a NISSEF conformity code. [minfin.bg], [minfin.bg]

Domestic B2G

Currently, public contracting authorities must be able to receive and process EN 16931 invoices, but suppliers are not generally obliged to issue them. The requirement applies particularly to public contracts within the scope of the EU procurement directives and relevant thresholds. [ec.europa.eu], [strategy.bg]

Under the draft, structured invoicing would become mandatory for supplies to the state and state or local authorities:

• for Bulgarian-established VAT-registered suppliers; and
• for Bulgarian-established non-VAT-registered suppliers where the customer is the state or a state or local authority. [minfin.bg], [minfin.bg]

Domestic B2C

The draft does not create a general structured e-invoice obligation for ordinary consumer sales. However, where an invoice is voluntarily issued for a domestic supply to a Bulgarian-established recipient, the draft may require it to be structured in cases covered by the proposed rules. Sales documented through fiscal devices, integrated automated commercial-management systems or electronic fuel systems may remain subject to the fiscal-receipt rules rather than NISSEF invoicing. [minfin.bg], [minfin.bg]

Detailed treatment of consumer-requested invoices, simplified invoices and digital receipts remains subject to the final law and implementing ordinance.

Intra-EU supplies

The draft expressly provides that an invoice for:

• an intra-Community supply; or
• a supply made as intermediary in a triangular transaction,

may be issued outside the Bulgarian structured e-invoicing system. The same applies to related advance payments. These transactions remain subject to existing VAT invoice and VIES rules until the ViDA cross-border framework applies. [minfin.bg], [minfin.bg]

Intra-EU acquisitions

Foreign supplier invoices are not expected to be cleared through NISSEF where the supplier is not established in Bulgaria. Bulgarian customers must continue accounting for acquisition VAT and completing the relevant self-assessment and VAT-reporting obligations. The pre-filled VAT return will therefore require taxpayer-supplied information for transactions not represented by a Bulgarian structured invoice. [minfin.bg], [minfin.bg]

Exports and imports

• Export invoices are not clearly brought within mandatory domestic clearance where the customer is not established in Bulgaria.
• Import supplier invoices issued abroad would not pass through NISSEF.
• The draft provides that customs import and export declarations will feed the pre-filled VAT-return process.
• Existing customs documentation and VAT rules remain necessary. [minfin.bg], [minfin.bg]

Other cross-border B2B supplies

A supply whose recipient is not established in Bulgaria generally falls outside the proposed domestic clearance scope. A non-established supplier registered for Bulgarian VAT would issue a tax document under the ordinary rules rather than a structured NISSEF invoice. [minfin.bg], [minfin.bg]

3.2 Special transactions

Self-billing

The draft’s explanatory materials do not provide a complete dedicated NISSEF workflow for self-billing. Existing Bulgarian VAT rules permit invoicing by the customer on behalf of the supplier, subject to the underlying legal conditions. If a self-billed transaction falls within proposed Article 113(16), the logical result is that the invoice would have to satisfy Articles 120a and 120b and obtain a NISSEF conformity code. However, the authorization, submission party, approval status and technical self-billing indicator remain to be specified. [minfin.bg], [minfin.bg], [minfin.bg]

Triangulation

The draft expressly permits invoices issued by the intermediary in a triangular transaction to remain outside the domestic structured-invoice requirement. The invoice must nevertheless comply with the ordinary VAT rules, including the required reverse-charge wording. [minfin.bg], [minfin.bg]

Chain transactions

No special NISSEF rules for chain transactions have yet been published. Each leg must therefore be classified according to:

• supplier and customer establishment;
• place of supply;
• whether it is the moving or non-moving supply;
• whether it is domestic or intra-EU;
• whether the transaction falls within proposed Article 113(16). [minfin.bg], [minfin.bg]

Special VAT regimes

The draft indicates that certain aggregate sales-reporting rules under special schemes may be removed because structured invoices will provide transaction-level information. However, comprehensive treatment of:

• travel-agent margin scheme transactions;
• second-hand goods;
• works of art and collectibles;
• investment gold;
• flat-rate farmers;
• financial and insurance services;
• OSS and IOSS transactions,

has not yet been fully explained in publicly available technical guidance. [minfin.bg], [minfin.bg]

3.3 Exclusions and exceptions

The draft identifies or implies exceptions for:

• intra-Community supplies;
• intermediary supplies in triangular transactions;
• non-established suppliers registered for Bulgarian VAT;
• specified transactions documented through fiscal systems or expanded fiscal receipts;
• ordinary supplies by non-VAT-registered persons, except relevant supplies to the state or public authorities;
• transactions without a Bulgarian place of supply;
• transactions to recipients not established in Bulgaria. [minfin.bg], [minfin.bg]

The final list is not settled because the legislation remains under consultation.

4. Taxable Persons in Scope

4.1 Established domestic entities

The proposed mandate principally covers VAT-registered suppliers established in Bulgaria making domestic supplies to Bulgarian-established business or public-sector recipients. It is not framed merely as a turnover-based mandate for large enterprises. [minfin.bg], [minfin.bg]

Bulgarian-established non-registered suppliers would generally remain able to issue paper or other electronic invoices, except that structured invoicing would apply to their supplies to the state or state and local authorities. [minfin.bg], [minfin.bg]

4.2 Non-established entities

The draft distinguishes VAT registration from establishment. A person registered for Bulgarian VAT but not established in Bulgaria would not apply the domestic structured-invoice obligation to its Bulgarian supplies. It would instead issue a tax document under the ordinary invoice rules. [minfin.bg], [minfin.bg]

Accordingly:

• a foreign company with a qualifying Bulgarian fixed establishment may fall within scope where that establishment is involved in the supply;
• a foreign company merely holding a Bulgarian VAT number, without Bulgarian establishment, is outside the proposed domestic structured-invoice rule;
• a foreign company without Bulgarian VAT registration is not independently brought into NISSEF by the draft provisions reviewed. [minfin.bg], [minfin.bg]

Detailed fixed-establishment attribution rules have not yet been issued.

4.3 Voluntary participation

The draft allows structured invoices to be used in certain domestic cases where invoicing is not otherwise compulsory but a supplier or customer requests an invoice. However, technical access for fully out-of-scope or foreign participants is not yet documented. [minfin.bg], [minfin.bg]

4.4 Sector-specific treatment

No broad exemption is proposed solely because an entity operates in healthcare, financial services, insurance, utilities, telecommunications or another sector. The VAT treatment and whether an invoice is legally required remain relevant.

Transactions documented through fiscal devices and specified fuel or commercial-management systems receive distinct treatment. Further sector-specific rules may appear in the implementing ordinance. [minfin.bg], [minfin.bg]

5. Implementation Timeline

5.1 Legislative history

• 1 November 2019: Public contracting authorities became required to receive and process EN 16931-compliant e-invoices for relevant public-procurement contracts. [ec.europa.eu], [strategy.bg]
• 25 July 2025: The NRA published its principal SAF-T order and final technical documentation. [nra.bg], [vatupdate.com]
• 1 January 2026: SAF-T reporting began for the first group of large enterprises. [vatcalc.com], [saft-validator.com], [portal.nra.bg]
• 1 April 2026: SAF-T XSD version 1.0.2 became mandatory following NRA Order No. З-ЦУ-30-359/27.02.2026. [nra.bg]
• 23 September 2026: The Ministry published the draft VAT amendments introducing domestic structured e-invoicing and pre-filled VAT returns. [strategy.bg], [minfin.bg]
• 23 October 2026: Scheduled end of the public consultation. [strategy.bg]

5.2 SAF-T rollout

The current phased SAF-T framework has been described as follows:

• 2026: first wave of large enterprises;
• 2027: additional enterprises meeting the highest thresholds;
• 2028: enterprises meeting the lower mid-market thresholds;
• 2029: broader coverage of large, medium and small enterprises;
• 2030: remaining businesses, including micro-enterprises. [saft-validator.com], [globalindi…gement.com]

A separate parliamentary proposal reportedly sought to postpone the second SAF-T wave and link e-invoicing to SAF-T filers. That proposal must not be confused with the Ministry’s broader 23 September VAT Act draft, and it is not yet enacted. [obsidianri.com], [parliament.bg]

5.3 Proposed e-invoicing dates

The draft and accompanying explanatory materials indicate:

• technical and platform development during 2027;
• a test environment to be made available before mandatory implementation;
• mandatory structured domestic e-invoicing from 1 January 2028;
• pre-filled VAT returns and removal of purchase and sales ledgers from 1 January 2028;
• proposed application of the specific failure-to-issue sanction from 1 July 2028. [minfin.bg], [minfin.bg], [dataplus-bg.com]

All these dates remain proposed.

5.4 Grace periods

For SAF-T, the legislation and NRA materials provide special introductory correction periods. The electronic service expressly distinguishes filings made during the statutory “grace periods” and allows corrections under Articles 71к(6) and the transitional provisions of the 2025 State Budget Act. [portal.nra.bg], [vatcalc.com]

No final penalty-free period for NISSEF has been enacted. The planned six-month interval between the proposed 1 January 2028 operational start and the 1 July 2028 specific sanction suggests transitional relief, but its precise effect must be verified in the final legislation.

5.5 Pre-mandate milestones

The proposed ordinance would establish the final technical requirements. The impact materials anticipate:

• procurement and development of hardware, licences and software during 2027;
• publication of technical standards;
• provision of a test environment before go-live;
• integration testing by ERP vendors and service providers. [minfin.bg], [dataplus-bg.com]

No binding API-publication date, certification deadline or production-onboarding schedule is yet available.

6. Operating Model

6.1 Overall model

Bulgaria will potentially operate a hybrid digital-control environment:

• SAF-T: periodic post-audit reporting;
• NISSEF: proposed real-time centralized validation or clearance;
• B2G: currently decentralized EN 16931 receipt;
• ViDA: future cross-border structured invoicing and digital reporting. [ec.europa.eu], [minfin.bg], [nra.bg], [taxation-c….europa.eu]

The proposed NISSEF model is effectively a clearance system because an invoice is considered issued only after the platform generates a unique conformity code. [minfin.bg], [minfin.bg]

6.2 Proposed invoice lifecycle

1. Creation: The supplier creates an EN 16931-compatible structured invoice through NISSEF or another software system.
2. Submission: Data created outside NISSEF must be transmitted immediately and in real time to the NRA.
3. Validation: NISSEF performs semantic checks against statutory requirements.
4. Clearance: If compliant, the platform generates a unique conformity code. If not, it returns a non-conformity message.
5. Legal issuance: The document is legally issued when the conformity code is generated.
6. Receipt: The draft treats the invoice as received when the conformity code is generated, although the supplier must also make it electronically available to the customer.
7. Processing: The buyer must maintain the capability to receive and process the structured document.
8. Storage: NISSEF stores the invoice data, but the extent to which this replaces taxpayer archiving remains subject to the final law and ordinance. [minfin.bg], [minfin.bg]

6.3 Authentication

For SAF-T:

• access is through the NRA e-services portal;
• a qualified electronic signature is required;
• taxpayers may authorize representatives;
• the file may be pre-signed or signed through the portal component. [portal.nra.bg]

NISSEF authentication, machine certificates, API credentials, electronic seals and representative-access rules have not yet been published.

6.4 Contingency arrangements

The draft does not yet provide a complete offline procedure for NISSEF outages. There is no published rule on:

• emergency invoice numbering;
• temporary paper or PDF issuance;
• post-outage upload deadlines;
• QR marking;
• deemed clearance;
• liability for NRA platform downtime.

These issues should be treated as unresolved pending the ordinance.

6.5 Buyer workflow

The draft does not make commercial buyer approval a condition for legal issuance. Issuance and receipt are linked to generation of the NISSEF conformity code. The supplier must nevertheless transmit the document electronically, and the buyer must support reliable electronic receipt and processing under agreed technical arrangements. [minfin.bg], [minfin.bg]

No final buyer rejection, dispute, acknowledgement or payment-status workflow has been published.

6.6 QR codes and verification

The draft requires a unique NISSEF conformity code but does not yet establish a general QR-code requirement. The format, content and visual presentation of the conformity code remain for secondary legislation.

7. Acceptable E-Invoice Formats

7.1 Mandatory format

The proposed structured invoice must:

• be issued, transmitted and received electronically;
• be machine-processable;
• comply with EN 16931;
• use a syntax recognised under Directive 2014/55/EU;
• receive a unique NISSEF conformity code. [minfin.bg], [minfin.bg]

The draft does not prescribe one final Bulgarian XML syntax. UBL and UN/CEFACT CII are recognised European syntaxes, but the final Bulgarian implementation choices, mappings and extensions remain unpublished. [ec.europa.eu], [minfin.bg]

7.2 Relationship to EN 16931 and Peppol

The draft is explicitly aligned with EN 16931. This supports ViDA readiness and interoperability. It does not, however, confirm that Peppol BIS Billing 3.0 or the Peppol network will be mandatory or supported. [minfin.bg], [taxation-c….europa.eu]

7.3 Legacy formats

• Until the proposed mandate takes effect, paper and ordinary electronic invoices remain legally available under current rules.
• Following implementation, a PDF alone would not be sufficient for an in-scope transaction.
• Paper or non-structured electronic invoices could remain available for transactions and persons outside proposed Article 113(16) and (17).
• Non-established Bulgarian VAT registrants would continue using ordinary tax documents under the draft. [ec.europa.eu], [minfin.bg], [minfin.bg]

7.4 Attachments

No final rules have been published concerning embedded documents, images, PDFs, external attachment references, maximum file sizes or permitted MIME types.

8. Technical and Functional Requirements

8.1 Invoice data

In addition to existing VAT invoice details, proposed Article 120a requires:

• an EU Combined Nomenclature code for goods;
• a UN/CEFACT service code, or another code prescribed by the future ordinance;
• supplier bank-account numbers, virtual account numbers or other identifiers clearly identifying accounts used or expected to be used for payment;
• the unique NISSEF conformity code. [minfin.bg]

Existing invoice content includes the document type, sequential invoice number, issue date, supplier and customer identification, description, quantity, unit price, taxable amount, VAT rate, VAT amount, total and the legal basis for exemption, zero-rating or reverse charge where relevant. [accounting…lgaria.com], [t8gconsulting.com], [minfin.bg]

The final code lists, decimal rules, date formats, mandatory business rules and national EN 16931 extensions are not yet available.

8.2 SAF-T specifications

The current SAF-T format is an XML-based Bulgarian implementation derived from OECD SAF-T 2.0. Current NRA documentation includes:

• XSD version 1.0.2;
• sample XML files;
• tabular data definitions;
• standard nomenclatures;
• validation rules;
• filing and naming requirements. [nra.bg], [globalindi…gement.com], [vatupdate.com]

The reported content includes:

• file header and taxpayer identifiers;
• accounting master data;
• chart of accounts;
• customers and suppliers;
• products and tax codes;
• general-ledger entries;
• accounts receivable and payable;
• sales and purchase invoices;
• payments;
• fixed assets;
• inventory and stock movements when requested. [nra.bg], [vatcalc.com], [saft-validator.com]

8.3 Signature and integrity

SAF-T files are submitted using a qualified electronic signature. [portal.nra.bg]

The proposed structured-invoice model appears to rely primarily on:

• structured format controls;
• NRA semantic validation;
• the conformity code;
• NISSEF storage;
• agreed electronic transmission controls.

The draft does not clearly require a separate qualified signature on every structured invoice. Final integrity, authenticity and readability methods will be established by the implementing ordinance. [minfin.bg], [minfin.bg]

8.4 Processing timing

• NISSEF data would be transmitted immediately in real time.
• SAF-T remains periodic rather than real-time.
• Public performance targets, response times and availability commitments for NISSEF have not been issued. [minfin.bg], [nra.bg]

9. Correction of Errors

9.1 Structured invoice corrections

The draft distinguishes between errors identified promptly and documents already reflected in VAT reporting:

• A wrongly issued structured invoice may be cancelled under the future ordinance if cancellation occurs no later than the fifth day of the tax period following the period of issuance.
• If the incorrect document has been included in the supplier’s or customer’s VAT return, cancellation requires a credit note.
• The credit note must state the reason for cancellation and reference the number, date and conformity code of the cancelled invoice.
• Changes to the taxable amount require a structured electronic credit or debit notice.
• The corrective notice must reference the previous invoice’s or notice’s conformity code.
• The corrective document must itself satisfy the structured-invoice requirements and pass through NISSEF. [minfin.bg], [minfin.bg]

The exact resubmission statuses and error codes will be defined in secondary legislation.

9.2 SAF-T corrections

The NRA portal permits multiple submissions before the filing deadline. The last successfully uploaded and accepted file is treated as final. [portal.nra.bg]

Where a timely file receives an incoming number but fails format or content validation:

• the NRA rejects it;
• the filer receives an electronic notification;
• inconsistencies must normally be corrected within seven days;
• if they are not corrected, the file is treated as not submitted.

Different correction periods apply during statutory grace periods. [portal.nra.bg]

The taxpayer can also submit a previous-period file where no accepted file exists for that period. Detailed procedures for replacing already accepted files after the deadline should be verified against the current NRA instructions and Articles 71з to 71к.

10. Transmission and Workflow

10.1 Platforms

• SAF-T: NRA electronic services portal.
• Proposed e-invoicing: NISSEF, operated by the NRA.
• B2G: CAIS EPP supports public procurement, but invoice processing remains partly decentralized between individual authorities. [portal.nra.bg], [minfin.bg], [ec.europa.eu]

10.2 Transmission channels

For SAF-T, the presently documented channel is electronic upload through the NRA portal using a qualified electronic signature. [portal.nra.bg]

For NISSEF, the draft anticipates:

• direct creation through the government system;
• transmission from another software application or system;
• immediate real-time delivery of data to the NRA.

It does not yet confirm:

• API protocols;
• web-service standards;
• bulk submission;
• a free invoicing application;
• mobile applications;
• Peppol access;
• use of certified intermediaries. [minfin.bg], [minfin.bg]

10.3 Service providers

No NISSEF service-provider accreditation regime or public provider register has yet been established.

10.4 Interoperability

The statutory alignment with EN 16931 supports semantic interoperability, but technical interoperability with:

• Peppol;
• CAIS EPP;
• ERP providers;
• payment systems;
• customs;
• SAF-T;
• EU ViDA reporting systems,

has not been fully specified. Customs declarations are expressly expected to contribute to pre-filled VAT returns. [minfin.bg], [minfin.bg]

10.5 Deadlines

• Ordinary Bulgarian invoices are generally issued within five days of the taxable event or advance payment.
• Intra-Community supply invoices are generally issued by the fifteenth day of the following month.
• SAF-T monthly files are filed within the statutory period for the following month.
• Annual fixed-asset SAF-T data is due by 30 June of the following year.
• Inventory information is filed within the deadline specified by the NRA request.
• Proposed NISSEF submission would occur immediately in real time. [accounting…lgaria.com], [t8gconsulting.com], [portal.nra.bg], [minfin.bg]

11. Self-Billing

11.1 Current permissibility

Self-billing is permitted under the general Bulgarian VAT framework where the applicable agreement and acceptance conditions are met.

11.2 NISSEF treatment

The September draft does not contain a sufficiently detailed self-billing workflow. For an in-scope domestic transaction, a customer-generated invoice would nevertheless need to meet the substantive definition of a structured invoice and obtain a conformity code. [minfin.bg], [minfin.bg]

11.3 Outstanding issues

The following are not yet specified:

• whether the supplier or buyer submits the file;
• prior platform registration or notification;
• supplier approval or deemed approval;
• a specific self-billing type code;
• rejection procedures;
• how a foreign buyer without a Bulgarian identifier submits an invoice;
• division of liability between supplier and customer.

Businesses should not design the final workflow until the ordinance and technical schema are published.

12. Triangulation and Special Scenarios

12.1 Triangulation

Invoices issued by an intermediary in an EU triangular transaction may remain outside the proposed Bulgarian structured-invoicing system. The ordinary invoice must carry the correct reverse-charge treatment and the transaction remains reportable under current VAT and VIES procedures. [minfin.bg], [minfin.bg]

12.2 Chain transactions

No dedicated NISSEF chain-transaction guidance exists. Each legal supply must be analyzed separately. A Bulgarian domestic leg between Bulgarian-established parties may be in scope, while the intra-EU moving supply or a foreign leg may remain outside NISSEF.

12.3 Cross-border reverse charge

• Outbound cross-border invoices generally remain outside the proposed domestic clearance scope where the recipient is not Bulgarian-established.
• Inbound foreign invoices are not cleared through NISSEF.
• The Bulgarian recipient must continue producing the legally required self-assessment protocol where applicable.
• Such protocol data will need to be added to or reflected in the pre-filled VAT return because it will not originate from a domestic structured supplier invoice. [minfin.bg], [minfin.bg]

12.4 Zero-rated and exempt supplies

A transaction is not automatically outside the proposed mandate merely because it is zero-rated or exempt. The decisive factors include place of supply, establishment and whether a VAT invoice is required. The structured invoice must include the relevant exemption, zero-rate or reverse-charge basis under the ordinary VAT rules. [minfin.bg], [t8gconsulting.com]

Exports and intra-Community supplies are expected to remain outside domestic NISSEF clearance but continue to require appropriate documentary evidence and reporting.

12.5 Other local nuances

Particular attention will be required for:

• VAT groups, if and when applicable under Bulgarian rules;
• fixed establishments;
• fiscal representatives;
• call-off stock and its ViDA phase-out;
• construction reverse charge;
• consignment arrangements;
• travel-agent and dealer margin schemes;
• supplies documented by fiscal devices;
• fuel sales documented through electronic fuel systems;
• self-assessment protocols and adjustments. [minfin.bg], [minfin.bg], [taxation-c….europa.eu]

13. Archiving and Retention

13.1 Central storage

The draft states that NISSEF will store data for all structured invoices and related notices. It does not clearly establish that this central storage fully replaces taxpayers’ independent record-retention obligations. [minfin.bg], [minfin.bg]

13.2 Format

For in-scope invoices, businesses should expect to retain:

• the original structured file;
• the NISSEF conformity code and platform status;
• corrective notices and links to original documents;
• transmission and receipt evidence;
• a human-readable rendition where operationally necessary.

The final legal archiving format remains subject to the ordinance.

13.3 Retention period

Current advisor summaries generally identify a 10-year electronic-invoice retention period, with invoices required to remain accessible to the tax authorities. The controlling requirement should be verified against the current Bulgarian VAT, accounting and procedural legislation for each document category. [basware.com], [e-invoicin…corner.com]

13.4 Storage location

No NISSEF-specific rules have yet been published on domestic, EU/EEA or third-country storage. General EU VAT principles permit electronic storage subject to:

• prompt online access;
• authenticity and integrity;
• readability;
• availability to the competent authority.

The future ordinance may impose additional requirements.

13.5 Integrity and authenticity

Under the current voluntary system, authenticity and integrity may be ensured through business controls, electronic signatures or other reliable methods. Under NISSEF, validation, the conformity code and platform data will form important elements of the audit trail. [basware.com], [minfin.bg]

13.6 Audit access

Businesses must preserve records in an accessible form and provide them during an audit. NISSEF would give the NRA direct access to structured invoice data, while SAF-T provides broader accounting records periodically and on request. [minfin.bg], [nra.bg]

14. Penalties and Enforcement

14.1 Transitional enforcement

SAF-T has statutory introductory correction arrangements. Files rejected for technical or content issues normally have a seven-day correction period, except where the special grace-period rules apply. [portal.nra.bg], [vatcalc.com]

For NISSEF, a finalized educational or penalty-free period has not been enacted.

14.2 Proposed e-invoicing penalties

The draft reportedly introduces a new Article 182a addressing failure to issue a required structured invoice, with proposed application from 1 July 2028. Because the measure remains draft and the publicly extracted materials do not provide a sufficiently reliable complete penalty scale, specific amounts should not be treated as final until the adopted text is published in the State Gazette. [dataplus-bg.com], [strategy.bg], [minfin.bg]

14.3 Other risks

Potential consequences include:

• an invoice not being legally issued because no conformity code was generated;
• denial of input VAT where the supplier was required to issue a structured invoice but failed to do so;
• late-invoicing sanctions;
• VAT-return penalties;
• SAF-T filing penalties;
• rejection of technically invalid files;
• general accounting and record-retention sanctions;
• increased exposure where errors are intentional or form part of VAT fraud. [minfin.bg], [minfin.bg], [portal.nra.bg]

The proposed loss of deduction is especially significant. Draft Articles 70 and 71 link deductibility to possession of the required document where structured invoicing applies. [minfin.bg]

15. Pre-Filled VAT Returns

15.1 Current position

Bulgaria does not currently operate the proposed comprehensive NISSEF-generated periodic VAT return. VAT-registered persons presently file the VAT return and associated reporting records electronically. [nra.bg], [mi.government.bg]

15.2 Proposed implementation

The September draft proposes that the NRA generate a draft VAT return automatically for each registered person and make it electronically available no later than the second day of the month following the tax period. [minfin.bg]

15.3 Data sources

The draft return would use:

• issued structured invoices;
• received structured invoices;
• structured corrective notices;
• import customs declarations;
• export customs declarations;
• other information held by the NRA. [minfin.bg]

15.4 Taxpayer input

Taxpayers would remain responsible for adding or reviewing information not fully available from NISSEF, including potentially:

• self-assessed VAT;
• protocols;
• acquisitions and imported services;
• transactions documented through fiscal reports;
• adjustments;
• transactions without recovery entitlement;
• deductible VAT based on documents outside the domestic structured system. [minfin.bg], [minfin.bg]

Taxpayers would be permitted to add, correct or delete information before filing. The return would therefore be pre-filled, not automatically final.

15.5 Purchase and sales ledgers

The Ministry proposes abolishing the current purchase and sales ledgers because transaction-level structured invoice data would already be available to the NRA. This is intended to eliminate duplicate reporting. [minfin.bg]

15.6 Relationship with ViDA

ViDA does not impose a general EU pre-filled VAT-return system. Bulgaria’s proposal is a national administrative simplification based on real-time domestic invoice and customs data. It nevertheless supports the wider ViDA objective of digital, transaction-level VAT control. [minfin.bg], [taxation-c….europa.eu]

16. ViDA Readiness

16.1 Position relative to ViDA

ViDA was adopted on 11 March 2025, published on 25 March 2025 and entered into force on 14 April 2025. Cross-border B2B Digital Reporting Requirements apply from 1 July 2030, and existing domestic real-time reporting systems must conform to EU requirements by 1 January 2035. [taxation-c….europa.eu], [eur-lex.europa.eu], [taxation-c….europa.eu]

Bulgaria’s proposed 2028 domestic system would place it ahead of the EU cross-border go-live.

16.2 Areas of alignment

The proposal supports ViDA through:

• use of EN 16931;
• structured, machine-processable invoices;
• real-time transmission;
• transaction-level reporting;
• removal of customer consent;
• use of data for automated VAT compliance. [minfin.bg], [taxation-c….europa.eu]

16.3 Potential gaps

Further work will be necessary to ensure:

• full compatibility with the final ViDA semantic data model;
• support for cross-border reporting fields;
• interoperability rather than purely domestic clearance;
• consistent treatment of corrections and status messages;
• compatibility with EU VAT-information exchange systems;
• avoidance of duplicate SAF-T, NISSEF and ViDA reporting;
• appropriate treatment of non-established businesses. [minfin.bg], [taxation-c….europa.eu]

16.4 Business implications

Businesses should avoid treating Bulgarian SAF-T, the proposed NISSEF mandate and ViDA as separate data projects. The preferred design should use:

• one governed transaction-data model;
• reusable EN 16931 mappings;
• consistent tax codes;
• central master-data governance;
• shared reconciliation between invoice, SAF-T, VAT-return, customs and VIES information.

17. Impact on SMEs and Startups

17.1 Phased onboarding

SAF-T is phased by company size and thresholds, with micro-enterprises joining last. By contrast, the proposed e-invoicing mandate is primarily linked to VAT registration, establishment and transaction type rather than a broad SME deferral. [saft-validator.com], [minfin.bg]

17.2 Free tools and support

The draft states that NISSEF will support invoice creation as well as receipt of invoices produced by external software. This suggests a government creation function, but no final free portal, user limits or SME service specification has been published. [minfin.bg], [minfin.bg]

For SAF-T, the NRA already provides:

• schemas;
• sample XML files;
• technical guidance;
• FAQs;
• an electronic submission portal;
• test-filing functionality;
• a dedicated support email address. [nra.bg], [portal.nra.bg]

17.3 Threshold-based relief

The draft proposes increasing the domestic VAT-registration threshold from €51,130 to €75,000. Businesses falling below the threshold and remaining outside VAT registration would generally remain outside domestic B2B structured invoicing, except for relevant supplies to public authorities. [minfin.bg], [minfin.bg]

This is an indirect SME exclusion, not an e-invoicing turnover threshold.

17.4 Subsidies

No dedicated subsidy, tax credit or grant for SME NISSEF implementation has been identified in the available official materials.

17.5 Compliance costs

Likely one-time costs include:

• accounting or ERP upgrades;
• EN 16931 mapping;
• integration with NISSEF;
• product and service classification;
• bank-account master-data remediation;
• testing;
• employee and supplier training;
• redesign of invoice corrections and self-billing.

Ongoing costs may include:

• software maintenance;
• service-provider charges;
• monitoring;
• master-data management;
• reconciliation;
• archive and audit controls.

The Ministry acknowledges additional financial burden for affected persons, while estimating €20 million of public expenditure for the platform. [minfin.bg]

17.6 Potential benefits

Possible benefits include:

• reduced manual data entry;
• removal of purchase and sales ledgers;
• earlier detection of invalid invoices;
• improved accounts-payable automation;
• improved supplier and customer reconciliation;
• fewer fraudulent invoices;
• better VAT-return preparation.

These benefits depend on reliable platform operation and stable specifications. [minfin.bg], [nra.bg]

17.7 Net administrative effect

The long-term model may reduce recurring reporting work, but the transition could be significant for SMEs using basic accounting products. The addition of mandatory classification codes and payment-account identifiers may be particularly burdensome.

17.8 Market impact

The reform will favor businesses and software providers that already support:

• structured invoice standards;
• API integration;
• automated tax determination;
• digital archives;
• invoice-status monitoring;
• SAF-T extraction.

A major risk is fragmented implementation if businesses build separate SAF-T, NISSEF, B2G and ViDA solutions.

17.9 Readiness assessments

The government impact analysis identifies businesses generally as affected stakeholders and acknowledges implementation costs. No detailed, independently validated SME-readiness assessment for the 2028 mandate has yet been published. [strategy.bg], [minfin.bg]

18. Official References and Sources

18.1 Government and tax authority sources

• Bulgarian public consultation 12733-K [strategy.bg]
• Ministry of Finance explanatory memorandum [minfin.bg]
• Draft VAT Act amendment [minfin.bg]
• NRA SAF-T information and documentation [nra.bg]
• NRA SAF-T filing portal [portal.nra.bg]
• Bulgarian State Gazette search [dv.parliament.bg]
• Bulgarian National Assembly bills register [parliament.bg]

18.2 EU sources

• European Commission e-invoicing profile for Bulgaria [ec.europa.eu]
• European Commission ViDA portal [taxation-c….europa.eu]
• Council Directive (EU) 2025/516 [eur-lex.europa.eu]

18.3 Technical specifications

• The current official SAF-T XSD, sample files, tabular structure, validation documentation and filing instructions are accessible through the NRA SAF-T page. [nra.bg], [nra.bg]
• No final NISSEF schema, API specification, test environment, national EN 16931 extension or provider-certification documentation is yet available.

18.4 Advisor and specialist analysis

• VATupdate Bulgaria country booklet [vatupdate.com]
• VATupdate summary of NRA SAF-T documentation [vatupdate.com]
• VATCalc Bulgaria SAF-T update [vatcalc.com]
• EY global e-invoicing developments tracker [ey.com], [taxnews.ey.com]
• KPMG ViDA analysis [kpmg.com]
• Basware Bulgaria compliance overview [basware.com]

Some commercial sources published before 23 September 2026 still state that no firm domestic implementation date exists. Those summaries were accurate when published but are now incomplete because they predate the Ministry’s new draft. [vatupdate.com], [e-invoicing.org], [leinonen.eu]

19. Summary and Key Takeaways

19.1 Scope

• SAF-T is already mandatory for the first taxpayer cohort.
• Domestic B2B structured e-invoicing is proposed from 1 January 2028.
• The proposed mandate primarily covers domestic supplies by Bulgarian-established VAT-registered suppliers to Bulgarian-established business, legal-person and public-sector recipients.
• Non-established VAT registrants and most cross-border transactions are outside the proposed domestic clearance scope.
• Domestic B2C transactions are not subject to a general e-invoice mandate.
• Special rules or exceptions apply to intra-Community supplies, triangulation, fiscal-device transactions and public-sector supplies. [minfin.bg], [minfin.bg], [nra.bg]

19.2 Format

• EN 16931-compatible structured format.
• Recognised European syntax.
• Unique NISSEF conformity code.
• Additional goods or services classification and payment-account data.
• Final Bulgarian schema and implementation guide remain pending. [minfin.bg], [minfin.bg]

19.3 Timeline

• SAF-T: live from 1 January 2026 and expanding through 2030.
• Draft consultation: 23 September to 23 October 2026.
• NISSEF development and testing: expected during 2027.
• Proposed e-invoicing and pre-filled VAT returns: 1 January 2028.
• Proposed specific e-invoicing sanction: 1 July 2028.
• ViDA cross-border DRR: 1 July 2030.
• Domestic system alignment with EU standards: no later than 1 January 2035. [strategy.bg], [minfin.bg], [taxation-c….europa.eu]

19.4 Operating model

The proposed NISSEF model is centralized real-time clearance. An invoice becomes legally issued only when the NRA system generates its conformity code. SAF-T remains a separate periodic reporting obligation. [minfin.bg], [minfin.bg], [nra.bg]

19.5 Key obligations

Businesses potentially need to prepare for:

• structured invoice creation;
• immediate transmission;
• platform validation;
• receipt and processing capability;
• structured corrections;
• reconciliation with SAF-T and VAT returns;
• preservation of original structured data;
• maintenance of accurate classification and bank-account information.

19.6 Main risks

The principal risks are:

• treating the draft as enacted law;
• underestimating the 2028 implementation lead time;
• loss of input VAT where the required structured invoice is missing;
• mismatches between NISSEF, SAF-T, customs, VIES and accounting data;
• inadequate handling of foreign registrations and fixed establishments;
• unresolved self-billing and correction workflows;
• operational dependency on NRA platform availability. [minfin.bg], [minfin.bg], [portal.nra.bg]

19.7 SME implications

The higher proposed VAT-registration threshold may remove some small businesses from the principal B2B scope. Nevertheless, VAT-registered SMEs appear to face the same 2028 domestic mandate unless final legislation introduces phasing or relief. No dedicated subsidy has yet been announced. [minfin.bg], [minfin.bg]

19.8 ViDA readiness

The proposed use of EN 16931 and real-time structured data provides a strong foundation for ViDA. However, Bulgaria must still define how NISSEF will interoperate with the EU cross-border reporting model and avoid overlapping reporting through NISSEF, SAF-T, VIES and future ViDA channels. [minfin.bg], [taxation-c….europa.eu]

19.9 Critical next steps

Businesses should:

• monitor consultation 12733-K and subsequent parliamentary amendments;
• identify Bulgarian-established entities and fixed establishments;
• map domestic, cross-border, B2G and fiscal-device flows separately;
• assess EN 16931 readiness;
• remediate customer, supplier, product-code, service-code and bank-account master data;
• align SAF-T and invoice data models;
• design controls over NISSEF conformity codes;
• assess self-billing, credit-note and cancellation processes;
• engage ERP and service providers once technical specifications are published;
• retain flexibility because the 2028 framework remains draft as of 26 September 2026.