Do foreign companies with Bulgarian VAT file SAF-T?

International businesses are present in Bulgaria in very different ways: as a Bulgarian subsidiary, as a branch, or only through a Bulgarian VAT registration. Each of these sits differently in the SAF-T phases, so the first step is to be clear which one you are.

Bulgarian subsidiaries

A Bulgarian subsidiary of a foreign group is a Bulgarian company like any other. It keeps accounts under the Accounting Act, has an enterprise category (micro, small, medium or large), and joins SAF-T in the phase that matches its size and its revenue or tax payments:

• 2026 or 2027 if it passed BGN 300 million in revenue or BGN 3.5 million in taxes and contributions in 2023 or 2024,
• 2028 if it passed BGN 15 million in revenue or BGN 1.5 million in taxes and contributions in 2025,
• 2029 as a small, medium or large enterprise,
• 2030 as a VAT-registered micro-enterprise.

For subsidiaries, the practical challenge is usually not the rules but the systems. Group ERP systems are often set up for the parent company’s country and need Bulgarian localisation and mapping to produce a valid SAF-T file.

Branches of foreign companies

A branch registered in Bulgaria keeps its own accounting records here. In practice it should plan for SAF-T in the same way as a Bulgarian company, based on its own category and figures. Because a branch often uses the head office’s systems, the same localisation questions arise.

Foreign companies registered only for VAT

This is the least clear-cut case. Many foreign businesses have a Bulgarian VAT number without a company or branch here, for example to hold stock, import goods or sell to Bulgarian customers. They file monthly VAT returns but do not keep Bulgarian statutory accounts.

The final phase in 2030 extends SAF-T to all VAT-registered persons. How the reporting will work for businesses that only have a VAT registration, and what data they will be expected to provide, depends on the NRA’s rules and guidance for that phase. We recommend checking the position for your specific set-up well before 2030, rather than assuming either way.

What international businesses should do now

1. Map your Bulgarian presence: subsidiary, branch or VAT registration only.
2. Confirm the phase for each Bulgarian entity, using its own figures for the reference years.
3. Ask your ERP team whether a Bulgarian SAF-T export exists, and who will configure and maintain it.
4. Decide who owns the file locally: a SAF-T file needs someone in Bulgaria, or an adviser, who understands both the data and the Bulgarian rules.

How we can help

We work with international groups and foreign businesses in English. We confirm where SAF-T applies, act as the link between your local accounts and your group IT team, and review and submit the files each month. Our SAF-T service · VAT registration