Bulgaria Proposes Mandatory Domestic E-Invoicing from 2028

• Bulgaria’s Ministry of Finance has published draft legislation introducing mandatory structured e-invoicing for specified domestic supplies from 1 January 2028. Invoices would have to comply with European standard EN 16931. [dataplus-bg.com]
• E-invoices would pass through a national system operated by the National Revenue Agency. An invoice would be considered issued and received after validation and generation of a unique compliance code. [dataplus-bg.com]
• The proposal would also raise the mandatory VAT registration threshold to EUR 75,000, introduce pre-filled VAT returns and abolish the existing sales and purchase ledgers when the e-invoicing system takes effect.  [dataplus-bg.com]

Extended article

Bulgaria’s Ministry of Finance has opened a public consultation on a significant amendment to the VAT Act. The proposal combines mandatory domestic e-invoicing, digital reporting, pre-filled VAT returns and changes to the VAT registration rules. The consultation runs until 23 October 2026. The draft must subsequently be approved by the Council of Ministers and adopted by the National Assembly before becoming law.

Under the proposal, VAT-registered suppliers established in Bulgaria would be required to issue structured electronic invoices for supplies and advance payments where the place of supply is Bulgaria and the recipient is established in Bulgaria. Covered recipients would include taxable persons, non-taxable legal persons and public authorities. Non-registered suppliers would also have to issue structured e-invoices when supplying public authorities.

The electronic invoice would need to comply with EN 16931. The obligation would not cover intra-Community supplies, supplies made by intermediaries in triangular transactions, supplies by VAT-registered businesses not established in Bulgaria, or sales documented at the point of sale using an extended fiscal receipt.

Invoices would be issued, transmitted and stored through a national information system operated by the National Revenue Agency. Taxpayers could interact directly with the system or use their own software to transmit invoice data in real time. Validation by the national system and generation of a unique compliance code would determine when an invoice is considered issued and received. Buyer consent would not be required.

Where a supplier is required to issue a structured e-invoice, possession of a valid e-invoice would become a substantive condition for the customer’s input VAT deduction. The draft would also abolish the current sales and purchase ledgers. Instead, the National Revenue Agency would make a pre-filled VAT return available by the second day of the month following the tax period. Taxpayers would remain able to supplement and correct that return.

The e-invoicing provisions would apply from 1 January 2028. The National Revenue Agency would have to provide a testing environment six months before implementation. A penalty for failure to issue a required e-invoice would apply from 1 July 2028. , [dataplus-bg.com]

Separately, the draft would increase the mandatory VAT registration threshold from the equivalent of EUR 51,130 to EUR 75,000 from 1 January 2027. The current threshold is BGN 100,000, according to the Ministry of Finance’s published VAT information. [minfin.bg]

External links

• Read the detailed overview of the Bulgarian draft [dataplus-bg.com]
• Review Bulgaria’s existing VAT registration rules [minfin.bg]
• Review the current Bulgarian e-invoicing and SAF-T landscape [edicomgroup.com]
• Read the Bulgaria e-invoicing and e-reporting country overview [vatupdate.com]