Bulgaria proposes mandatory E-Invoicing and Real-Time VAT Reporting from 2028

Bulgaria proposes mandatory structured domestic e-invoicing and real-time VAT reporting from January 1, 2028. Invoice data would be validated by the NRA and used to prepare pre-filled VAT returns, while the current VAT sales and purchase ledgers would be abolished.

Bulgaria is preparing a major change to its VAT compliance system. On September 23, 2026, the Ministry of Finance published draft amendments to the VAT Act proposing mandatory structured electronic invoicing and digital VAT reporting from January 1, 2028. The public consultation remains open until October 23, 2026. The full legislation can be found on:

https://www.minfin.bg/bg/legislation7/624?utm_ 

The proposal would create a national system administered by the Bulgarian National Revenue Agency (NRA). Businesses covered by the rules would issue structured electronic invoices, while transaction information would be transmitted to the NRA electronically. The same information would then be used to prepare pre-filled VAT returns.

Under the proposal, VAT-registered suppliers established in Bulgaria would generally be required to issue structured electronic invoices for domestic supplies and advance payments made to recipients established in Bulgaria.

The scope would include supplies to taxable businesses, non-taxable legal entities and public authorities. Non-VAT-registered suppliers would also be required to issue structured electronic invoices when making supplies to public authorities.

The invoices would have to comply with the European EN 16931 structured e-invoicing standard. This means that a simple PDF sent by email would not be sufficient to meet the new structured e-invoicing requirement.

The proposed mandate would not cover every transaction. According to the draft analysis, exclusions would include certain intra-Community supplies, supplies involving intermediaries in triangular transactions, supplies made by VAT-registered persons not established in Bulgaria and certain transactions documented at the time of sale through an extended fiscal-device receipt.

This last exemption is particularly important for retailers because it indicates that the new e-invoicing framework will have to coexist with Bulgaria's existing fiscal-device rules rather than simply replacing them.

The reform would introduce a national structured e-invoicing and digital reporting infrastructure operated by the NRA.

Businesses would be able to issue invoices through the national system or through their own invoicing, ERP or accounting software. Where companies use their own systems, invoice information would need to be transmitted to the NRA.

The proposed model includes validation by the national system. An electronic invoice would be treated as issued and received after the system validates it and generates the required unique compliance identifier. Recipient consent for receiving this type of electronic invoice would no longer be necessary under the proposed framework.

This creates a direct link between invoice creation and VAT reporting. Instead of businesses first issuing invoices and later separately reporting them in VAT ledgers, the NRA would receive structured transaction information as part of the invoicing process itself.

One of the most important parts of the reform is the proposed introduction of digital transaction reporting.

Invoice information transmitted through the electronic invoicing system would become available to the NRA at the transaction level. This would allow the tax authority to perform VAT controls much earlier than under the traditional periodic reporting model.

The proposed process can be summarized as:

Structured e-invoice → transmission to the NRA → validation → VAT reporting data → pre-filled VAT return

This means e-invoicing and VAT reporting would no longer operate as two largely separate processes. Invoice data generated during normal business transactions would also become the basis for tax reporting.

The reform would also significantly change how Bulgarian VAT returns are prepared. Currently, VAT-registered businesses submit VAT returns together with detailed purchase and sales ledgers. The proposal would abolish the existing VAT purchase and sales ledgers once the new system becomes operational. Instead, the NRA would prepare a pre-filled VAT return using the information already collected through electronic invoices and other available tax data.

The pre-filled return is expected to be made available by the second day of the month following the relevant VAT period. Businesses would then be able to review, supplement and correct the information before submitting their final VAT return.

Importantly, the pre-filled return would not remove the taxpayer's responsibility for VAT compliance. Businesses would still need to verify that the data is complete and correct before filing.

Another important part of the proposal concerns input VAT recovery.

Where a supplier is legally required to issue a structured electronic invoice, possession of a valid e-invoice would become an important condition for the recipient's VAT deduction.

This makes invoice validation important not only for the supplier's invoicing obligations but also for the customer receiving the invoice. An incorrect, missing or improperly processed electronic invoice could potentially affect the recipient's ability to support its input VAT deduction.

The proposal requires the NRA to provide businesses with a testing environment before mandatory implementation.

According to the published proposal analysis, the environment should be available at least six months before the system becomes mandatory. If the January 1, 2028 implementation date remains unchanged, testing should therefore be available by approximately July 2027.

More detailed technical rules are expected to follow through secondary legislation and technical specifications.

This will be especially important for ERP, accounting, POS and e-invoicing software providers, because many of the final integration requirements will depend on those technical specifications.

The proposal also provides a transition period before the new e-invoicing penalties begin.

Mandatory e-invoicing and reporting are planned from January 1, 2028, while specific penalties connected with failure to issue required electronic invoices are expected to begin from July 1, 2028.

This would effectively provide businesses with an initial six-month implementation period before the full penalty framework takes effect.

However, businesses should not interpret this as permission to delay implementation until July. The legal obligation itself is proposed to begin in January.

The proposal also needs to be viewed in the wider context of the EU's VAT in the Digital Age – ViDA reforms. Bulgaria's domestic e-invoicing and reporting regime is proposed to begin on January 1, 2028, while the harmonized EU digital reporting requirements for certain intra-EU transactions are scheduled for July 1, 2030.

In our view, the most significant part of this proposal is that Bulgaria is not introducing e-invoicing as an isolated requirement. The government is effectively connecting invoicing, real-time reporting, invoice validation, input VAT control and VAT return preparation into one digital compliance process.

For businesses, this means implementation cannot be treated simply as an invoice-format project. ERP systems, accounting platforms, tax engines, invoice workflows and reconciliation processes will all be affected.

Implementation impact and what the business should do

Businesses operating in Bulgaria should begin identifying whether their domestic transactions will fall within the proposed mandatory e-invoicing scope and which existing processes will need to change.

Companies should review their ERP, accounting and invoicing systems, assess whether they can generate EN 16931-compliant structured invoices and prepare for integration with the NRA's national system.

Retailers should also examine how the proposed e-invoicing rules will interact with transactions already documented through fiscal devices, because certain fiscal-receipt transactions are expected to remain outside the mandatory e-invoicing scope.

Businesses should also prepare reconciliation processes for incoming invoices, input VAT deductions and the future NRA pre-filled VAT return.

Software providers should closely follow the publication of technical specifications and the NRA testing environment, expected at least six months before implementation.

Most importantly, the rules are currently draft legislation. The consultation closes on October 23, 2026, after which the proposal must continue through the Bulgarian legislative process. Businesses should therefore prepare for the proposed January 1, 2028 implementation date while monitoring whether the scope, technical requirements or timetable change before final adoption. 

The text above is based on the article published by vatcalc. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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