Bulgaria proposes VAT and E-Invoicing changes from 2027 and 2028

Bulgaria has proposed major VAT changes, including mandatory structured B2B e-invoicing from January 2028 and a higher VAT registration threshold from 2027. The reform would affect retailers and software providers, while the existing B2C fiscalization system would largely remain unchanged.

On September 23, 2026, the Bulgarian Ministry of Finance published draft amendments to the Value Added Tax (VAT) Act, introducing significant changes to invoicing, VAT reporting and certain retail-related procedures. It can be found here: https://www.minfin.bg/bg/legislation1/624 

The proposal is open for public consultation until October 23, 2026, meaning the new requirements have not yet been adopted and may still change.

The reforms goals are to modernize VAT administration, improve tax control and reduce administrative reporting through greater digitalization. For retailers, the most important changes concern B2B invoicing at the point of sale, integration between POS and ERP systems, and new invoicing requirements for fuel retailers.

However, the proposal does not introduce a completely new fiscalization system or replace existing fiscal devices used for ordinary consumer transactions.

What Will Change for B2B Electronic Invoicing?

One of the most significant proposed changes is the introduction of mandatory structured electronic invoicing from January 1, 2028. The requirement would generally apply to domestic transactions involving suppliers established and VAT-registered in Bulgaria and recipients that are taxable persons, non-taxable legal persons or public authorities established in Bulgaria. Advance payments for qualifying transactions would also be covered.

Unlike ordinary PDF invoices, structured e-invoices would need to comply with prescribed technical requirements and be processed through the National Revenue Agency (NRA) system.

In contrast, ordinary B2C transactions, such as a consumer purchasing clothing or groceries, would generally remain outside the mandatory structured e-invoicing system. Consequently, retailers must distinguish between B2C fiscal receipt procedures and B2B invoice issuance.

Will the Existing Fiscalization System Change?

The proposed reform does not fundamentally change Bulgaria's existing fiscalization framework under Article 118 of the VAT Act and Ordinance H-18. Retailers would continue issuing fiscal receipts through fiscal devices or system receipts through approved integrated automated business management systems, where applicable. The draft does not introduce general requirements for replacing fiscal printers, changing fiscal memory, obtaining new fiscal-device certification or implementing a new POS certification system.

Existing provisions concerning electronic receipts, store registration, fiscal-device communication and electronic journals would also remain relevant.

For online retailers, the proposal does not introduce a new general B2C e-commerce fiscalization model. Existing Ordinance H-18 requirements, including applicable online-shop registration, remote card payment and fiscal receipt procedures, would continue to apply.

An important provision concerns invoices issued directly through a fiscal device or system.

Under the proposal, a separate structured electronic invoice would not be required when the invoice is issued as an expanded fiscal receipt or expanded system receipt.

This distinction could significantly affect POS software architecture.

Retailers issuing qualifying expanded fiscal receipts may continue using that invoicing method without generating an additional structured e-invoice.

However, when a POS issues only a standard fiscal receipt and the B2B invoice is subsequently generated by ERP or invoicing software, that invoice may need to comply with the new structured e-invoicing requirements.

POS and ERP providers will therefore need to determine which transaction procedures fall under each rule and ensure the appropriate documents are generated.

Fuel retailers could face a more direct fiscalization-related change. Currently, Article 118(24) of the VAT Act requires invoices for fuel sales registered through an Electronic System with Fiscal Memory (ESFP) to be issued as expanded fiscal receipts for specified payment methods, including cash, cards, vouchers and similar instruments.

The proposal would extend this requirement regardless of the payment method.

This means fuel retailers may need to ensure that all qualifying fuel invoices are issued through the ESFP as expanded fiscal receipts, including transactions involving payment methods not specifically covered by the existing wording.

Unlike the broader B2B invoicing reform, this amendment directly affects fiscal-device-related procedures in the fuel retail sector.

What Other VAT Changes Are Planned?

The draft also proposes increasing the mandatory VAT registration threshold from €51,130 to €75,000 from January 1, 2027.

This would particularly benefit smaller shops, independent merchants and small e-commerce businesses that may remain below the mandatory VAT registration threshold for longer. However, exemption from mandatory VAT registration does not automatically remove fiscalization obligations.

From January 1, 2028, the traditional VAT purchase and sales ledgers would be abolished under the proposal. Instead, the NRA would prepare draft VAT returns using structured e-invoice information and other available tax data. Businesses would still need to complete or supplement information concerning transactions not automatically covered by the new system. The proposal also introduces additional invoice information, including applicable commodity or service classification codes and supplier bank account details.

Invoices would be considered issued once the NRA system generates a unique compliance code. Where an invoice submitted through business software fails validation, identified discrepancies would generally need to be corrected within 48 hours.

These requirements would create additional technical responsibilities for ERP providers, invoicing software developers and retailers managing B2B transactions.

In our view, the most important aspect of this reform is not a change to Bulgaria's existing fiscalization system, but the introduction of a new digital invoicing layer alongside it.

For retailers, the main challenge will be ensuring that POS, ERP and invoicing systems work together correctly, particularly when a retail transaction involves a business customer requesting an invoice.

Implementation Impact and What Businesses Should Do:

Although the amendments remain proposals, retailers and technology providers should begin assessing their existing invoicing and reporting processes. Businesses should first identify whether their POS systems issue expanded fiscal receipts or whether B2B invoices are generated separately through ERP or invoicing software. This distinction will determine the potential integration changes required from 2028.

POS software vendors and ERP providers should monitor the forthcoming technical specifications for structured e-invoicing, including invoice validation, mandatory data fields, communication with the NRA and the unique compliance code.

Fuel retailers should review their ESFP invoicing procedures and determine whether changes would be necessary for transactions involving different payment methods.

Smaller retailers should assess the proposed €75,000 VAT registration threshold while remembering that existing fiscal receipt obligations may continue regardless of VAT registration status.

Businesses should also prepare for changes to VAT reporting, particularly the proposed replacement of traditional purchase and sales ledgers with NRA-prepared draft VAT returns.

The key dates to monitor are January 1, 2027, for the proposed VAT threshold increase; January 1, 2028, for mandatory structured e-invoicing and the new VAT reporting model; and October 23, 2026, the consultation deadline.

The central recommendation is to review B2B invoicing workflows and system integration requirements without assuming that Bulgaria is replacing its current B2C fiscalization system.

The findings presented above are based on comprehensive consultant research and the text published by the Bulgarian Ministry of Finance. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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