Invoice to an individual in Bulgaria: when, EGN and GDPR

In Bulgaria an invoice to a non-taxable private individual is optional: it is issued if the customer or the supplier wants one (Art. 113, para. 3, item 1 and para. 6 of the VAT Act, ЗДДС). The invoice states the individual's name, address and personal identification number (ЕГН, usually written EGN). A VAT-registered supplier records sales without an invoice in a monthly sales report (отчет за извършените продажби, Art. 119).

When an invoice to an individual is mandatory

An invoice to a private individual is mandatory when the customer asks for it and in a few cases where the relief for non-taxable persons does not apply. A supplier invoices every supply and every advance received (Art. 113, para. 1 of the VAT Act), but need not do so when the recipient is a non-taxable individual (Art. 113, para. 3, item 1).

A liberal profession (свободна професия) is an independent economic activity, so a freelancer is a taxable person and falls outside Art. 113, para. 3, item 1 (Art. 3, paras. 1 and 2 of the VAT Act).

What the invoice states about the individual

An invoice to an individual contains every element in Art. 114, para. 1 of the VAT Act; for the recipient, the name and address (item 7) and an identification number (item 8). For a recipient not registered for VAT, item 8 refers to the number under Art. 84 of the Tax and Social Security Procedure Code (ДОПК). Individuals outside the commercial and BULSTAT registers are identified by their EGN or, if foreign, the foreigner's personal number (ЛНЧ, LNCh) (Art. 84, para. 2 of the Code). The full list is in Bulgarian invoice requirements.

On the wording of the law, the EGN is an element of an invoice to a Bulgarian individual. The Accountancy Act (ЗСч) also names the EGN and LNCh expressly among the recipient details of a primary accounting document (Art. 6, para. 1, item 3). The Commission for Personal Data Protection (КЗЛД, the Bulgarian data protection authority) has held that the recipient's EGN is a mandatory element of a primary accounting document (decision on complaint No. Ж-1054/28.11.2014, issued on 10 June 2015). The decision applied the previous Accountancy Act and predates the General Data Protection Regulation (GDPR); the current text points to the same number.

The regulation implementing the VAT Act requires the code 999999999999999 in the sales ledger instead of a non-taxable individual's number when the supplier need not state it on the tax document it issued (annex 12). It does not list those cases, so the code is no general licence to omit the EGN.

The EGN on an invoice and the GDPR

An EGN on an invoice does not breach the GDPR when an invoice is issued: the processing is necessary for compliance with a legal obligation to which the controller is subject (Art. 6(1)(c) of Regulation (EU) 2016/679). The basis is the law, not consent.

• 01Data minimisation (Art. 5(1)(c)): collect the EGN when you issue an invoice, not from every customer. The Art. 119 report holds no buyer details.
• 02Purpose limitation (Art. 5(1)(b)): data collected for the invoice is not further processed in a manner incompatible with that purpose, nor the reverse. In its 2015 decision on complaint Ж-1054/2014, made under the Personal Data Protection Act before the GDPR, the authority sanctioned a company that invoiced with a customer's data collected for other contracts.
• 03Storage limitation (Art. 5(1)(e)): the invoice is kept for the periods in Art. 121, para. 1 of the VAT Act and Art. 12, para. 1 of the Accountancy Act; after that it is deleted unless another basis applies.

Sales without an invoice: the Art. 119 report and the fiscal receipt

A VAT-registered supplier records sales for which an invoice is not mandatory and was not issued in a sales report drawn up by the last day of the month (Art. 119, paras. 1 and 2 of the VAT Act). The report holds totals only: taxable amounts and VAT by rate (20%, 9% and 0%), exempt supplies and other supplies without tax (Art. 112, para. 3 of the regulation). It goes in the sales ledger with code 81 and no counterparty details (Art. 112, para. 4 and annex 12).

The report covers supplies for which no invoice was issued under Art. 113, para. 3 of the VAT Act (Art. 112, para. 1 of the regulation). The columns are explained in Bulgarian VAT sales and purchase ledgers.

The report does not replace the fiscal receipt (касов бон): a sale at a retail outlet is registered with one unless payment is made by credit transfer, direct debit, cash deposit into a payment account or money remittance (Art. 3, para. 1 of Ordinance N-18 on fiscal devices). A card payment is not among the exceptions. Online card payments are covered in Stripe and Bulgarian invoices. A supplier without VAT registration draws up no report, and its invoice carries no VAT (Art. 119, para. 1 and Art. 113, para. 9 of the VAT Act).

A receipt was issued and the customer now wants an invoice

When a customer asks for an invoice after the fiscal receipt, the supplier issues it (Art. 113, para. 6 of the VAT Act) within 5 days of the tax event: the deadline in Art. 113, para. 4 has no exception for invoices on request. The Accountancy Act points the same way: a primary document may be omitted for a fiscal receipt to an individual who is not a trader, unless that individual asked for one (Art. 7, paras. 2 and 4).

• 01Several purchases in one month with separate receipts can be covered by one summary invoice with the receipts attached (Art. 32, para. 2 of Ordinance N-18), issued by the last day of the month in which the tax became chargeable (Art. 113, para. 13 of the VAT Act).
• 02The sale is counted once: when the receipt and the invoice fall in the same month, the invoiced amount stays out of the report (Art. 112, para. 1 of the regulation).
• 03Neither the VAT Act nor the regulation expressly covers a correction when last month's report already includes the sale (receipt on the 30th, invoice on the 2nd), or a request after the 5 days. Settle both with your accountant.

Example: a €500.00 service plus VAT, invoiced on request

A VAT-registered company sets up Ivan Petrov's home network on 2 October 2026. He pays by transfer and asks for an invoice, issued on 5 October within the Art. 113, para. 4 deadline of 7 October. Its only other October sales are to individuals without invoices: €2,000.00 plus €400.00 VAT.

The October sales ledger shows two lines:

Without the invoice, the report would show €2,500.00 plus €500.00 of VAT with no customer details, and the tax for the month would be the same.

Credit note to an individual

A credit note to an individual is issued only if the individual received an invoice, since a note relates to one (Art. 115, para. 1 of the VAT Act; Art. 79, para. 1 of the regulation). If the sale was only in the Art. 119 report, the VAT Act has no separate rule for the refund. In practice, reflected also in opinions of the National Revenue Agency (НАП, the NRA), the reduction is shown as a negative amount in the report for the month of the refund, based on a document for the refund. See credit and debit notes in Bulgaria.

Individuals from abroad

A service to an individual in another member state carries Bulgarian VAT as a rule, because it is supplied where the supplier is established (Art. 21, para. 1 of the VAT Act). Telecommunications, broadcasting and electronic services and distance sales of goods are taxed in the customer's country once their combined EU value exceeds €10,000 in the current or previous year (Art. 20b), usually through the Union scheme (OSS). A person registered under Art. 96 or Art. 100, para. 1 draws up a separate report for those supplies even when invoiced (Art. 119, para. 5). A foreigner with an LNCh is identified by it (Art. 84, para. 2 of ДОПК). See how to invoice foreign and EU clients.

Invoices from an individual

An individual without VAT registration who is not a sole trader need not issue an invoice when a document under a special law, a statement of amounts paid (сметка за изплатени суми) or a document under Art. 9 of the Personal Income Taxes Act (ЗДДФЛ) is issued for the supply, or when ЗДДФЛ requires no document (Art. 113, para. 3, item 7 of the VAT Act).

• 01Civil contract or rent: the company paying the income issues a statement of amounts paid and gives it to the individual (Art. 45, para. 4 of ЗДДФЛ), except for a self-insured contractor, below.
• 02Other business activity without a fiscal receipt, for example a liberal profession: the individual issues a document for the income with the elements in Art. 6, para. 3 of the Accountancy Act (Art. 9, para. 2 of ЗДДФЛ), except in the cases in Art. 9, para. 3, for example when the payer issues a statement of amounts paid.
• 03A contractor who is self-insured (самоосигуряващо се лице) and has declared this in writing to the payer: for business income, such as a civil contract or a liberal profession, the payer withholds no advance tax and issues no statement of amounts paid, and the contractor pays the tax themselves (Art. 43, paras. 5 and 6 and Art. 45, para. 6 of ЗДДФЛ). When the payer is a business or self-insured person that applies the Accountancy Act, the contractor issues the Art. 9, para. 2 document even when paid by bank transfer, and adds the name, address and company number (ЕИК), EGN or LNCh of issuer and recipient under Art. 6, para. 1, item 3 of that Act (Art. 9, para. 3, item 4 and para. 4 of ЗДДФЛ).
• 04An individual registered for VAT issues invoices like any supplier (Art. 113, para. 1 of the VAT Act).

The right document depends on the type of income; confirm it with your accountant.

In smetni.app

In smetni.app a client is created as a company or as an individual, and the type cannot be changed later. For a Bulgarian individual the required fields are first name, last name, country, city, postal code and address; the EGN, email and phone are optional. The invoice PDF prints the first and last name, and the EGN only if entered, so enter the client's EGN before issuing an invoice for which the law requires it. Clients are on every plan, in numbers that depend on the plan: see plans and pricing. The steps are in the Clients, Sales and First invoice guides, and the module is on the Sales page.