Mandatory e-invoicing in Bulgaria from 2028: the draft law

Mandatory e-invoicing in Bulgaria is a proposal in a draft amendment to the VAT Act (ЗДДС), published by the Ministry of Finance on 23 September 2026. If the draft is adopted, from 1 January 2028 VAT-registered businesses established in Bulgaria will issue their invoices to businesses and institutions in the country as structured files that the NRA system checks and confirms with a compliance code. The public consultation on the public consultation portal runs until 23 October 2026. The draft then has to be approved by the Council of Ministers, adopted by the National Assembly and published in the State Gazette, and the text may change.

Below, "Art." refers to the VAT Act as worded in the draft, unless marked "today" or "current", and "§" to a paragraph of the draft bill. The rest of the package is covered in Bulgaria tax changes 2027.

What changes: today and under the draft from 2028

If the draft is adopted, from 1 January 2028 the invoice format, the moment an invoice counts as issued, corrections and the VAT return all change.

Who will issue structured e-invoices from 1 January 2028

Under the draft, structured e-invoices will be issued by VAT-registered suppliers established in Bulgaria for supplies with their place of supply in the country, including advance payments (Art. 113, para. 16). The recipient must be established in Bulgaria and be a taxable person (a company, sole trader or freelancer, registered for VAT or not), a non-taxable legal person, for example an association with no business activity, or a state or local authority. The draft sets no turnover or invoice-count threshold.

What is a structured e-invoice

A structured e-invoice under the draft is a data file under the European standard EN 16931 that the NRA system has confirmed with a compliance code. The three conditions apply together (Art. 120a, para. 1): the invoice meets the VAT Act; it is issued, transmitted and received electronically in a structured format under the standard and the syntaxes of Directive 2014/55/EU; and it has a compliance code.

The reference to EN 16931 was published with Implementing Decision (EU) 2017/1870, which lists two XML syntaxes: UBL and UN/CEFACT Cross Industry Invoice (CII). A PDF sent by email does not meet the second condition. The draft keeps it as an electronic invoice in another format (Art. 112, para. 4, item 2), but only for supplies outside the mandate.

Under the draft, on top of the Art. 114 details, the structured invoice must contain (Art. 120a, para. 2):

• 01the eight-digit Combined Nomenclature code of the goods (Art. 3 of Regulation (EEC) No 2658/87) or the UN/CEFACT code of the service, and where there is none, a code set by the ordinance;
• 02the supplier's bank or virtual account numbers, or other account identifiers, where payment has been or is expected to be received.

Under the draft, all current invoice details remain, including the ten-digit number: the full list is in Bulgarian invoice requirements under Art. 114 of the VAT Act. The technical requirements will be set by an ordinance of the Minister of Finance (Art. 120a, para. 4), due under the draft within 6 months of the law's publication (§ 104). As of 26 September 2026 the ordinance has not been published, so the exact format, connection channels and service codes are not yet known.

What is the NRA compliance code and when is an invoice issued

The unique compliance code is the code the NRA system generates after checking the data, and under the draft the invoice counts as issued the moment it is generated (Art. 120a, para. 3). At the same moment the invoice counts as received by the customer (Art. 120d, para. 2), and the system notifies both parties (Art. 120v, para. 2, item 5).

The draft does not change the deadline in Art. 113, para. 4: the invoice is issued within 5 days of the chargeable event or of receiving an advance. Since the invoice is issued only with the code, the code must be generated within that period. Under the draft, the code is also quoted on the structured debit or credit note (Art. 120b, para. 2), on the protocol under Art. 117 (Art. 117, para. 1, item 11) and on a credit note that cancels a document (Art. 116, para. 4, item 2).

How will e-invoices be issued: in the NRA system or in your own software

The draft allows two ways: the invoice is prepared in the NRA national system (Art. 120v, called НИССЕФ in the explanatory memorandum) or in other software that reports the data to the NRA (Art. 112, para. 5).

With your own software, the data is sent to the NRA immediately, in real time, after the invoice is prepared or cancelled (Art. 120g, para. 1). If the data passes the check, the system generates the code; if not, it returns a message and the error must be fixed within 48 hours (Art. 120g, paras. 2 and 3).

The code does not replace delivery: the supplier sends the file to the customer electronically, without needing the customer's consent, and the customer must be able to receive and process it (Art. 120d, paras. 1 and 3).

Under the draft, the NRA provides access for integration testing for 6 months before the start (§ 103), that is from around July 2027 if the start stays 1 January 2028. For a software producer or distributor that is a legal entity or sole trader and whose product blocks data reporting because of coding errors, the draft provides a financial penalty of €50,000 to €100,000, and for a repeat offence €100,000 to €250,000 (Art. 192b).

Are the VAT ledgers abolished, and how will the VAT return be filed

Yes, under the draft the purchase and sales ledgers are abolished from 1 January 2028 (Art. 124, paras. 1-6 repealed), and the NRA provides every registered person with a draft VAT return (Art. 125, para. 3). The draft return is generated from the structured invoices and notes issued and received and from customs declarations (Art. 125, para. 15) and is available in the NRA e-services by the 2nd of the month following the period (Art. 125, para. 18). The filing deadline stays the 14th (Art. 125, para. 5), and the VIES return stays (Art. 125, para. 23).

Under the draft, the credit is claimed in the return for the period in which the right arose and, if missed, by correcting that same return up to 12 periods later (Art. 72).

What happens to invoices around 1 January 2028

The draft has no parallel period: December 2027 is reported under the old rules, and from 1 January 2028 every invoice in scope is structured.

• 01The VAT return, VIES return and ledgers for December 2027 are filed under the current Art. 124 and 125, that is by 14 January 2028 (§ 101, para. 1).
• 02A chargeable event up to and including 31 December 2027, invoiced after 1 January 2028, is documented with a structured invoice (§ 102, para. 2). Example: a service completed on 30 December 2027 and invoiced on 4 January 2028.
• 03Where an advance, full or partial, has been received for a supply whose chargeable event falls after 1 January 2028, the supply is documented with a structured invoice showing the whole taxable amount (§ 102, para. 3).

The draft does not say how an advance invoice issued under the old rules is corrected when the final invoice shows the whole taxable amount. Review contracts with advances and long delivery periods with an accountant before the end of 2027.

How to correct an erroneous structured invoice

Under the draft, an erroneous structured invoice is cancelled without a credit note no later than the 5th of the tax period following the period of issue, in the way set by the ordinance (Art. 116, para. 9). If the document is already included in the VAT return of the supplier or the customer, the cancellation is made with a credit note stating the reason and the number, date and unique code of the cancelled document (Art. 116, para. 4).

Under the draft, a change in the taxable amount, for example a discount or returned goods, is documented with a structured note that quotes the code of the original invoice (Art. 120b); when to issue a debit and when a credit note is explained in credit and debit notes. A paper or PDF invoice for a supply in scope counts as erroneous (Art. 116, para. 10).

Example. An invoice dated 14 January 2028 has the wrong customer VAT number. Found on 3 February, the error is fixed by cancelling the invoice by 5 February and issuing a new one. Found on 20 February, after the January return has been filed, it is fixed with a credit note quoting the code of the wrong invoice and a new invoice.

What are the penalties for a structured invoice not issued

Under the draft, a registered person who has not issued a structured invoice is penalised from 1 July 2028 under the new Art. 182a (§ 85 and § 105, item 2). A fine (глоба) applies to individuals who are not traders, and a financial penalty (имуществена санкция) to legal entities and sole traders.

With €400.00 of VAT not charged, the penalty for an EOOD would be €1,500.00 because the minimum is higher; with €3,000.00 of VAT not charged it would be €3,000.00. The six months until 1 July 2028 are not a grace period for the customer: under the draft, the input VAT credit is lost under Art. 70, para. 7 from 1 January 2028 (§ 105, item 1).

How the draft relates to ViDA and EU digital reporting from 2030

The draft uses an option from the EU package "VAT in the Digital Age" (ViDA): Council Directive (EU) 2025/516 of 11 March 2025 allows Member States to require businesses established in their territory to issue e-invoices for domestic supplies (a new paragraph in Art. 218 of Directive 2006/112/EC), without the recipient's acceptance (a new paragraph in Art. 232). According to the European Commission, this has been possible since the package entered into force on 14 April 2025.

From 1 July 2030 the directive introduces digital reporting for cross-border business transactions in the EU:

• 01by default, invoices are electronic and follow the EN 16931 standard (new Art. 217 and 218 of Directive 2006/112/EC);
• 02the invoice for an intra-EU supply of goods and for supplies where the customer owes the VAT is issued within 10 days of the chargeable event (new Art. 222); for an intra-EU supply of goods the Bulgarian VAT Act now allows until the 15th of the following month (Art. 113, para. 5);
• 03the supplier sends the data on each intra-EU supply to the tax authorities when the invoice is issued (new Art. 262 and 263), instead of in a summary return such as the VIES return.

Member States that already had or had legislated for real-time domestic reporting on 1 January 2024 align their systems with the EU model by 1 January 2035. The Bulgarian draft does not require structured invoices for intra-EU supplies for now and keeps the VIES return, and according to the explanatory memorandum, using the standard from 2028 will ease the transition in 2030.

How mandatory e-invoicing in Bulgaria relates to SAF-T

SAF-T and structured invoices are separate obligations: SAF-T is an audit file under Art. 71z-71k of the Tax and Social Insurance Procedure Code (ДОПК), filed monthly by the end of the following month (Art. 71k, para. 1), and the VAT Act draft does not change it. For a company in the third wave, SAF-T starts on 1 January 2028, the same day as structured invoices under the draft, and both use the same data on customers, numbers, amounts and rates. Who files and when is explained in SAF-T in Bulgaria.

Example: one e-invoice through 2028

The example shows how one invoice would travel if the draft is adopted unchanged. Web studio "Primer" EOOD, registered for VAT, delivers a finished website on 12 January 2028 to "Klient" OOD in Plovdiv, also registered for VAT. The price is €2,000.00, VAT at 20% is €400.00, and the amount payable is €2,400.00.

Today the same invoice would be a PDF sent by email and entered in both companies' ledgers (current Art. 124, paras. 2 and 4). Under the draft there are no ledgers, and the data reaches the NRA when the invoice is issued.

What to prepare in 2027

Much of the preparation does not depend on the ordinance. If the draft is adopted, check in 2027:

1. Customers. Name, address, ЕИК (company ID) and VAT number (Art. 114, para. 1, items 7 and 8), whether the customer is established in Bulgaria and what it is: company, organisation, public body or individual.
2. Codes. An eight-digit Combined Nomenclature code for every product; for services the ordinance will specify the codes (Art. 120a, para. 2, letter "a").
3. Bank accounts. The IBANs where you receive payments, in your invoicing software (Art. 120a, para. 2, letter "b").
4. Numbering. A ten-digit number without duplicates or gaps, in one or more series (Art. 114, para. 1, item 2 and Art. 78, paras. 2 and 4 of the Regulation implementing the VAT Act, ППЗДДС). If you invoice from several programs, each uses its own range.
5. Deadlines. Invoice within 5 days of the chargeable event (Art. 113, para. 4); errors must be caught by the 5th of the following month.
6. Software. Ask your vendor when it will report data to the NRA and how it will accept incoming structured invoices. With few invoices, the NRA system is also an option (Art. 112, para. 5).
7. Incoming invoices. Who receives them and how you will separate purchases without full input VAT credit (Art. 125, paras. 17 and 20).
8. Contracts with advances. Supplies with an advance in 2027 and delivery after 1 January 2028 (§ 102, para. 3).

Comments on the draft can be submitted until 23 October 2026 through the portal or by email to the addresses listed in the consultation.

Common mistakes

• 01"We send PDFs by email, so we already e-invoice." Under the draft a PDF is not a structured invoice and, for supplies in scope, counts as an erroneous document (Art. 116, para. 10).
• 02"It only affects large companies." The draft has no threshold: it covers every VAT-registered supplier established in Bulgaria (Art. 113, para. 16).
• 03"There is a grace period until 1 July 2028." Under the draft, only the Art. 182a penalty is deferred; the customer loses the credit under Art. 70, para. 7 from 1 January 2028.
• 04"Invoices to individuals are out of scope." Under the draft, an invoice issued on request to an individual in Bulgaria is structured too (Art. 113, para. 19).
• 05"The law has already been adopted." As of 26 September 2026 the text is a draft in public consultation.

In smetni.app

Today smetni.app issues invoices in the Sales module as PDFs, with gapless numbering in one or more series. The app does not create structured EN 16931 invoices or obtain an NRA compliance code: the law is still a draft. The invoice arithmetic already follows the standard's approach: VAT is calculated once per rate, on the total taxable amount at that rate, and line discounts and a whole-document discount are kept separate. The purchase and sales ledgers and the VAT return are in the Declarations module, on the Business and Enterprise plans. See the Sales and Declarations guides and plans and pricing.