Key takeaways
- Bulgaria's Ministry of Finance published a draft law on 23 September 2026 that would make structured e-invoicing mandatory for domestic B2B and B2G supplies from 1 January 2028.
- E-invoices must follow EN 16931 and are validated by a National Revenue Agency (NRA) system that assigns a unique code; an invoice only counts as issued once it has that code.
- Sales and purchase ledgers would be replaced by pre-filled VAT returns generated by the NRA.
- Input VAT would only be deductible on a structured e-invoice where one was required.
- Penalties would apply from 1 July 2028. The draft is still in public consultation (to 23 October 2026) and must pass the National Assembly.
In short: Bulgaria plans to make structured e-invoicing mandatory for domestic B2B and B2G supplies from 1 January 2028. Invoices must follow the EU standard EN 16931 and pass through a National Revenue Agency system that validates them in real time. The NRA would also pre-fill VAT returns from e-invoice data. The rules are a draft: consultation closes on 23 October 2026 and the law still needs parliament's approval.
Updated 20 October 2026. This update reflects the Ministry of Finance draft amendment to the VAT Act published for consultation on 23 September 2026. We will update it when the Council of Ministers approves the bill.
What is Bulgaria proposing?
The draft amends the Bulgarian VAT Act to introduce mandatory structured e-invoicing and digital VAT reporting. Key points:
- Start date: 1 January 2028 for domestic B2B and B2G supplies.
- Penalties: from 1 July 2028, giving businesses a six-month adjustment period.
- Format: EN 16931, using the syntaxes allowed under Directive 2014/55/EU.
- Clearance: the NRA system validates each invoice and assigns a unique code. Without that code the invoice is not treated as issued. Errors must be fixed within 48 hours.
- How to send: through the national system directly, or from your own invoicing or ERP software if it transmits data to the NRA immediately.
Who would be covered?
VAT-registered suppliers established in Bulgaria, for supplies to recipients established in Bulgaria: other businesses, non-taxable legal persons, and state and local authorities. Suppliers that are not VAT-registered would still have to send structured e-invoices to public authorities.
E-invoicing would be optional, not mandatory, for intra-Community supplies, intermediaries in triangular transactions and related advance payments. Businesses not established in Bulgaria are outside the mandatory scope in the draft. B2C sales are not addressed.
What changes for VAT returns?
The NRA would build a pre-filled VAT return from e-invoice and customs data, available by the second day of the month after each tax period. VAT sales and purchase ledgers would be abolished. Input VAT could only be deducted if it was charged on a structured e-invoice where one was required; late deductions could be claimed by correcting the return within 12 tax periods.
What are the proposed penalties?
- Failing to issue a required e-invoice: a fine equal to the VAT not charged, with a minimum of €1,500 for companies and sole traders (€750 for other individuals).
- Software producers or distributors whose errors block transmission to the NRA: €50,000 to €100,000.
Timeline
| Date | Step |
|---|---|
| 23 September 2026 | Draft VAT Act amendment published for consultation |
| 23 October 2026 | Consultation closes |
| Mid-2027 (expected) | NRA integration testing opens, six months before go-live |
| 1 January 2028 | Mandatory domestic B2B and B2G e-invoicing starts |
| 1 July 2028 | Penalties apply |
A Ministry of Finance ordinance with the technical requirements is due within six months of the law being published in the State Gazette.
What should businesses do now?
- List the Bulgarian entities and VAT registrations in your group and which of them invoice domestic customers.
- Check whether your ERP or billing system can produce EN 16931 invoices and connect to a real-time clearance platform.
- Plan for input VAT controls: from 2028, deductions would depend on suppliers sending compliant e-invoices.
- Watch for the final law and the technical ordinance, and budget for testing in 2027.
Sources: Bulgarian Ministry of Finance draft amendment to the VAT Act (public consultation, 23 September 2026); EY Global Tax News, "Bulgaria proposes mandatory domestic e-invoicing from 2028" (October 2026).
How Taxually handles this
Taxually's e-invoicing API sends structured invoices to tax authority platforms and over the Peppol network from one integration, and we are tracking Bulgaria's mandate as the rules are finalised. Bulgarian VAT registrations and returns can be handled through CrossTax on the same platform.
Related guides
Frequently asked questions
When does e-invoicing become mandatory in Bulgaria?
Under the draft law, from 1 January 2028 for domestic B2B and B2G supplies, with penalties from 1 July 2028. The law has not been passed yet.
Which format will Bulgaria use for e-invoices?
Invoices must comply with the European standard EN 16931, using the syntaxes allowed under Directive 2014/55/EU.
Does Bulgarian e-invoicing apply to foreign companies?
The draft covers suppliers established in Bulgaria. Non-established businesses and intra-Community supplies are outside the mandatory scope, though e-invoicing is optional for some cross-border cases.
Will Bulgaria have real-time reporting?
Yes. Each invoice is validated by the National Revenue Agency system and given a unique code, and data must reach the NRA immediately when invoices are issued from your own software.
What happens to VAT ledgers in Bulgaria?
Sales and purchase ledgers would be abolished and replaced by VAT returns pre-filled by the NRA from e-invoice and customs data.
