Bulgaria has revised its proposed mandatory e-invoicing and real-time e-reporting framework, postponing implementation from 1 January 2028 to 1 July 2028 and replacing the previously proposed centralised validation system with a decentralised interoperability model.
Following the initial e-invoicing and e-reporting proposal published in September 2026, the Bulgarian Council of Ministers approved revised VAT Act amendments on 4 November 2026. The updated draft was submitted to the National Assembly on 5 November 2026 under Bill No. 52-602-01-60.
The revised proposal introduces significant changes to the technical architecture while maintaining the broader objective of digitalising VAT compliance.
1. What Has Changed in Bulgaria’s E-Invoicing Timeline?
Under the revised proposal, mandatory structured e-invoicing and real-time digital reporting for specified domestic transactions would begin on 1 July 2028, six months later than initially planned.
The National Revenue Agency (NRA) would provide access to a testing environment for the national e-invoicing portal and reporting system between 1 January and 30 June 2028.
The revised implementation schedule remains subject to parliamentary approval.
2. Which Transactions Would Be Subject to Mandatory E-Invoicing?
The proposed scope remains largely unchanged.
VAT-registered suppliers established in Bulgaria would generally be required to issue structured electronic invoices for domestic supplies, including advance payments, where the recipient is established in Bulgaria and is a taxable person, a non-taxable legal entity or a public authority.
The obligation would also extend to certain supplies to public authorities by suppliers not registered for VAT.
3. How Will the New Decentralised E-Invoicing Model Work?
One of the most significant changes is the removal of the previously proposed NRA clearance and unique compliance code requirement.
Under the revised framework:
- Structured e-invoices would be considered issued when transmitted to the recipient, without prior NRA validation.
- Businesses could use their own invoicing software, accredited service providers or the NRA’s national portal.
- The invoice exchange network would follow a decentralised architecture, supporting four-corner or five-corner models.
- Structured invoices would follow the European EN 16931 standard, with support for UBL 2.1 and CII formats.
The proposal also introduces a National Register of Electronic Addresses to facilitate electronic invoice exchange and recipient identification.
4. What Happens to Real-Time E-Reporting and VAT Returns?
Although the clearance requirement has been removed, real-time invoice data reporting to the NRA would remain mandatory.
The revised framework would continue to require the automatic transmission of specified invoice data to the tax authority, separately from the exchange of invoices between suppliers and recipients.
The proposal also maintains the planned replacement of existing VAT sales and purchase ledgers with pre-filled VAT returns, prepared by the NRA using structured invoice information and other relevant tax data.
Taxpayers would remain responsible for reviewing, completing and submitting their VAT returns.
5. What Should Businesses Prepare For?
Businesses operating in Bulgaria should assess their invoicing systems, electronic invoice exchange capabilities and real-time reporting processes against the revised requirements.
Particular attention should be given to structured invoice formats, interoperability with service providers, electronic address registration and integration with the NRA reporting infrastructure.
The revised legislation is still a proposal, and further technical specifications are expected through implementing regulations.
