Mandatory e-invoicing in Bulgaria from 2028: what the draft says
Bulgaria plans structured e-invoices for domestic sales from 1 January 2028. Who would be covered, how it would work, and what to do now.
On 23 September 2026 the Ministry of Finance published draft amendments to the VAT Act that would make structured electronic invoices mandatory in Bulgaria from 1 January 2028. The National Revenue Agency (NRA) would check every domestic invoice, and the data would be used to pre-fill VAT returns.
This is a draft. The public consultation runs until 23 October 2026, after which the text goes to the Council of Ministers and the National Assembly, and it can still change. Here is what the proposal says today. We will update this article when the law is adopted.
At a glance
- From: 1 January 2028 (proposed)
- Who: VAT-registered businesses established in Bulgaria
- What: domestic sales and advance payments to businesses, other legal entities and public authorities
- Format: structured invoices under the European standard EN 16931
- Control: every invoice validated by the NRA and given a unique code
- VAT returns: pre-filled by the NRA; today’s sales and purchase ledgers would be abolished
Who would be covered
The obligation would apply to VAT-registered suppliers established in Bulgaria for their domestic supplies to recipients established in Bulgaria:
- other businesses (B2B),
- non-taxable legal entities,
- public authorities (B2G), where suppliers that are not registered for VAT would also have to issue structured invoices,
- advance payments linked to these supplies.
Outside the scope, according to the draft: intra-EU supplies, sales to consumers, sales documented with a fiscal or system receipt, and certain supplies by foreign businesses that are registered for VAT in Bulgaria but not established here.
How it would work
Invoices could be issued in an NRA system or in your own invoicing or ERP software connected to it. Either way, the invoice data goes to the NRA for validation. Once the invoice is validated, the system assigns a unique compliance code, and only then does the invoice count as issued.
Because the NRA would receive every domestic invoice, it could prepare pre-filled VAT returns. The sales and purchase ledgers that businesses file with the VAT return today would no longer be needed.
Early commentary on the draft also points to a risk for buyers: an invoice that should have been issued in the structured format, but was not, may not give the buyer a right to deduct input VAT. Watch how this is worded in the final text.
The proposed timeline
| Date | Step |
|---|---|
| 23 September 2026 | Draft amendments to the VAT Act published |
| 23 October 2026 | Public consultation closes |
| Expected July 2027 | NRA test environment available |
| 1 January 2028 | Mandatory structured e-invoicing starts |
| 1 July 2028 | Penalties for e-invoicing breaches apply |
The dates after the consultation are those reported for the draft. Technical specifications, data formats and connection rules have not been published yet.
How it fits with EU rules
The draft follows the EU’s VAT in the Digital Age package (ViDA), which makes e-invoicing the default across the EU and introduces digital reporting for intra-EU business sales from 1 July 2030. Bulgaria would start with domestic invoices two and a half years earlier.
What about SAF-T?
SAF-T is a separate obligation, with its own phases from 2026 to 2030. Some companies may face both changes in the same period: a company in the 2028 SAF-T phase would start monthly SAF-T files and structured e-invoicing in the same month.
Both rely on the same foundation. Complete customer records, correct VAT numbers and consistent accounting data make SAF-T files valid, and they will also make e-invoices pass the NRA’s checks.
What to do now
- Follow the draft. Key details, including the final scope and penalties, can still change.
- Map your invoice flows. Which invoices are domestic B2B or B2G, and which are intra-EU, export or consumer sales outside the scope?
- Ask your software provider whether it plans to support EN 16931 invoices and a connection to the NRA, and when.
- Clean your customer data now. Missing or wrong VAT numbers and addresses will cause problems for both SAF-T and e-invoicing.
- Plan for testing in 2027, when the NRA test environment is expected.
How we can help
We follow the draft through consultation and adoption, and help you prepare your VAT processes, customer data and software for both e-invoicing and SAF-T. If you are unsure how the change affects your business, we can review your invoice flows in a short call. Our SAF-T service · VAT compliance
