What is the status of e-invoices in Bulgaria?

Across Europe, we can see the trend toward the incorporation of e-invoicing obligations. A large number of countries have already adopted the main regulations, and some of them have already started with e-invoicing. Mostly, it represents a special format for sending invoices and a special platform on which they are sent and processed. But every country has its own rules, phases, subjects, deadlines, technical requirements, etc. The e-invoicing system in Bulgaria is in the implementation phase but is only at the beginning.

During the past couple of years, some projects about e-invoices have been announced by the Bulgarian National Revenue Agency. Certainly, the COVID-19 crisis and other factors had an impact on the more detailed rules and implementation of e-invoices. More precisely, on July 4, 2022, the NRA announced the implementation of a 24-month project aimed at introducing the use of SAF-T. The project is still in its early stages of development and is being rolled out with the support of the European Union. The NRA has not disclosed the exact timeline for when SAF-T will become mandatory.

Then, on August 10, 2022, the NRA released version 11.02 of the tool developed for generating VAT reports, VAT returns, and VAT Information Exchange System (VIES) returns. The tax authority further published an updated user guide reflecting recently adopted VAT amendments.

But, specifically for e-invoicing, the NRA is considering the introduction of mandatory e-invoicing. The NRA is consulting with industry stakeholders to draft a proposal. Therefore, there are still no details about the system or its details. It is expected to be published soon.

If we talk about the approach for receiving and processing e-invoices, we can say that in Bulgaria this will be based on bilateral agreements between economic operators (or solution providers acting on their behalf) and public administrations (B2B, B2G). For the private consumer, it is still unclear whether there will be an obligation and, if so, under what conditions.