Bulgaria has proposed mandatory structured e-invoicing and real-time e-reporting from 1 January 2028. Under the draft amendments to the VAT Act, invoice data would flow through a national system operated by the National Revenue Agency (NRA). The NRA would then use that data to prepare pre-filled VAT returns, replacing the current VAT sales and purchase ledgers.
The Ministry of Finance published the proposal on 23 September 2026. The public consultation runs until 23 October 2026, and the rules may change before the legislation is adopted.
1. Which Transactions Would Require E-Invoicing in Bulgaria?
A VAT-registered supplier established in Bulgaria would be required to issue a structured electronic invoice for a supply with a place of supply in Bulgaria, including an advance payment, where the recipient is established in Bulgaria and is:
- a taxable person;
- a non-taxable legal person; or
- the state or a state or local authority.
Bulgarian-established suppliers that are not VAT-registered would also have to issue structured e-invoices when supplying public authorities.
The draft permits intra-Community supplies and supplies made as an intermediary in a triangular transaction, including related advance payments, to be invoiced outside the proposed structured format. A supplier that is VAT-registered but not established in Bulgaria would not be subject to the structured-invoicing obligation under the proposed Article 113(16).
Businesses will therefore need to assess their transaction flows by reference to the supplier’s establishment, the place of supply and the recipient’s status.
2. What Would Qualify as a Structured E-Invoice?
The proposed Article 120a requires a structured e-invoice to meet the VAT Act’s requirements, be issued, transmitted and received in a structured electronic format compliant with the European e-invoicing standard, and carry a unique compliance code generated by the national system.
The draft would also add information requirements beyond the existing invoice particulars, including a goods or services classification code and an identifier for the supplier’s account used or expected to be used for payment.
A structured e-invoice would be considered issued when the national system generates its unique compliance code. Consequently, sending a PDF by email would not, on its own, satisfy an obligation to issue a structured e-invoice.
Where the taxable amount on a structured e-invoice changes, the supplier would have to issue a structured electronic notice referring to the compliance code of the earlier invoice or notice.
3. Bulgaria’s Proposed Real-Time E-Reporting Model
The NRA would operate a national information system for structured electronic invoicing and digital reporting. Businesses could create invoices directly in the national system or use their own invoicing software or ERP systems.
Where another system is used, the invoice and notice data specified by a future Ministry of Finance ordinance would have to be transmitted to the NRA immediately and in real time after the document is created or cancelled. The national system would automatically check the submitted data and generate a unique compliance code when the requirements are met. If it identifies a discrepancy, the draft provides 48 hours to remedy it.
NRA validation would not replace electronic delivery to the customer. Although the invoice would be deemed received when its compliance code is generated, the supplier would still have to send it electronically to the recipient. The recipient would have to provide for reliable electronic receipt and processing under technical specifications agreed between the parties. Recipient consent to structured e-invoicing would not be required.
The detailed submission data, technical requirements and system procedures remain to be set out in the future ordinance.
4. Pre-Filled VAT Returns and the End of VAT Ledgers
The proposal would repeal the provisions governing Bulgaria’s existing VAT purchase and sales ledgers. Instead, the NRA would make a pre-generated draft VAT return available to each VAT-registered person for every tax period.
The draft return would draw on structured e-invoices and related notices, as well as import and export customs declarations. The NRA would have to make it available through its electronic services by the second day of the month following the relevant tax period.
Taxpayers would still need to review and complete the return. In particular, they would have to add information for supplies that do not require structured e-invoices, reports under Article 119, and VAT charged through protocols under Article 117. They would be able to correct, add or delete information in the pre-filled draft before filing.
The proposed rules would place amounts from incoming structured invoices in the draft return’s fields for full input VAT deduction. Businesses would need to check whether those amounts match their actual deduction entitlement, particularly where input VAT is only partly deductible or cannot be deducted.
5. Proposed Timeline and VAT Implications
The principal e-invoicing, real-time e-reporting and pre-filled VAT return provisions are proposed to take effect on 1 January 2028. The draft also provides for an NRA integration testing environment during the six months before implementation. Technical requirements would be issued separately by the Minister of Finance.
The proposal links input VAT deduction to the required structured document. Where a supplier is obliged to issue a structured e-invoice but fails to do so, the recipient would not have a right to deduct input VAT for that supply under the proposed rule. A new penalty for failing to issue a required structured e-invoice is scheduled to apply from 1 July 2028.
These dates and consequences remain proposals until the legislation is adopted.
6. What Should Businesses Prepare For?
Businesses with operations in Bulgaria should review which transactions may fall within the proposed e-invoicing requirement and whether their invoicing systems can produce the required structured data. They should also consider how they will receive customer and supplier invoices, handle corrections, and check the NRA’s pre-filled VAT return against their own records.
The detailed technical rules have not yet been published, and the proposal may change during the legislative process. For now, the draft gives businesses a clear reason to examine both their invoicing processes and the VAT data behind them.
