SAF-T Bulgaria requirements: who files, when and what

The Standard Audit File for Tax (SAF-T) is an XML file of a company's accounting data that enterprises file with the National Revenue Agency (НАП, the NRA) under Chapter 8b of the Tax and Social Insurance Procedure Code (ДОПК, the Tax Procedure Code). The obligation starts in five waves, from 1 January 2026 to 1 January 2030, depending on the enterprise category and its sales or payments to the NRA in a reference year. The monthly file is due by the end of the following month, fixed-asset data once a year by 30 June, and inventory data only on request.

What SAF-T is

SAF-T (Standard Audit File for Tax) is an international standard of the Organisation for Economic Co-operation and Development (OECD) for sending accounting data to the tax administration in a single XML format. In Bulgaria, SAF-T is governed by Art. 71z-71k of the Tax Procedure Code, in force since 31 March 2025 (State Gazette, ДВ, issue 26 of 2025). The rollout schedule is in § 17 of the transitional and final provisions of the State Budget Act of the Republic of Bulgaria for 2025, as amended by State Gazette issue 65 of 2025.

Under Art. 71i, para. 2 of the Tax Procedure Code, the standard audit file contains:

• 01Identification data of the filer and of its beneficial owner (item 1).
• 02Accounting data: accounts, movements and balances, accounting entries in chronological order, tax rates applied and taxes charged (item 2).
• 03Information from purchase and sales documents, including customers and suppliers (item 3).
• 04Payment data, including the payment method (item 4).
• 05Fixed-asset information: balances, movements, book and tax depreciation charged (item 5).
• 06Inventory information: balances and movements (item 6).
• 07Nomenclatures that standardise the data, and technical data about the file and the software it comes from (items 7 and 8).

SAF-T does not replace the VAT return. VAT-registered businesses still file it for every tax period under Art. 125, para. 1 of the VAT Act (ЗДДС).

Who files SAF-T in Bulgaria

SAF-T is filed by the enterprises listed in Art. 2 of the Accounting Act (ЗСч) (Art. 71z, para. 1 of the Tax Procedure Code). These are traders, including sole traders (ЕТ) and branches of foreign traders, local legal entities that are not traders, consortia and civil-law partnerships, and foreign legal entities doing business in Bulgaria through a place of business.

Art. 71z, para. 2 of the Tax Procedure Code excludes:

• 01Micro-enterprises under Art. 19 of the Accounting Act that are not registered for VAT (item 1).
• 02Local legal entities that are not traders and do not carry on business within the meaning of Art. 1 of the Commerce Act, for example an association with no business activity (item 2).
• 03Budget entities, the payment funds and insurance funds under the Social Insurance Code, and commercial representative offices (item 3, with Art. 2, items 3, 5 and 6 of the Accounting Act).
• 04Supplementary pension funds, collective investment schemes and national investment funds that are not self-managed national investment companies (item 4, in force from 1 January 2026, State Gazette issue 30 of 2026).

An individual in a liberal profession who is not registered as a sole trader is not an enterprise under Art. 2 of the Accounting Act and does not file SAF-T.

SAF-T Bulgaria deadlines by wave: when your company starts

The first SAF-T filing obligation arises on one of five dates set by § 17, para. 1 of the transitional provisions of the 2025 State Budget Act. An enterprise falls into waves 1-3 when, at 31 December of the reference year, it has the stated category under Art. 19 of the Accounting Act and, for the same year, meets at least one of two tests: net sales, or payments into NRA accounts of taxes and social security contributions less refunds, above the threshold.

The thresholds in § 17 are in lev, the same currency as the accounts for 2023, 2024 and 2025. At the fixed rate of BGN 1.95583 to €1 they are €153,387,564.36 (BGN 300,000,000), €1,789,521.58 (BGN 3,500,000), €7,669,378.22 (BGN 15,000,000) and €766,937.82 (BGN 1,500,000).

The wave only sets when the obligation first arises. It ends from 1 January of the year after the year in which the filer stops meeting the requirements of Art. 71z, para. 1 of the Tax Procedure Code (Art. 71k, para. 8).

SAF-T for small companies and micro-enterprises

Enterprises that are small at 31 December 2026 file SAF-T from 1 January 2029, and VAT-registered micro-enterprises from 1 January 2030. A small enterprise enters earlier, in wave 2 or 3, only if it exceeded the sales or NRA payments threshold in the reference year.

• 01The category is set under Art. 19 of the Accounting Act at 31 December on three indicators: balance sheet total, net sales and average number of staff. A micro-enterprise does not exceed at least two of them, with a staff limit of 10; for a small enterprise the staff limit is 50.
• 02The category changes when, for the last two reporting periods, the enterprise stops meeting two of the three indicators, and only from the start of the third period (Art. 20, para. 1 of the Accounting Act). One strong year does not turn a micro-enterprise into a small one.
• 03A micro-enterprise without VAT registration does not file SAF-T (Art. 71z, para. 2, item 1 of the Tax Procedure Code).
• 04A VAT-registered micro-enterprise is in the last wave even with high sales, because waves 1-4 cover only enterprises that are large, medium or small at the relevant 31 December. If it is already a small enterprise at 31 December 2026, it starts on 1 January 2029.
• 05When the obligation arises outside the schedule, for example when a micro-enterprise registers for VAT after 1 January 2030, no file is due for the first six months, and the files for the next six months can be corrected (Art. 71k, paras. 5 and 6 of the Tax Procedure Code).

Which files are filed and when

SAF-T is filed as a monthly file plus two separate parts: annual fixed-asset data and inventory data on request.

The file is submitted electronically with a qualified electronic signature (КЕП, QES), in the procedure and format set by an order of the NRA executive director (Art. 71k, para. 4 of the Tax Procedure Code). From 1 April 2026, files follow XSD schema version 1.0.2, approved by order No. З-ЦУ-30-359 of 27 February 2026. On its SAF-T project page, the NRA publishes the schema with sample XML files, the file structure in table form and the requirements for format and submission.

SAF-T monthly file: due by the end of the following month

The monthly SAF-T file is due by the end of the month following the month the data relates to (Art. 71k, para. 1 of the Tax Procedure Code, as amended by State Gazette issue 65 of 2025). The file for October 2026 is due by 30 November 2026. The current text contains no "14th of the month" deadline.

When the last day of a deadline is a non-working day, the deadline ends on the next working day (Art. 22, para. 7 of the Tax Procedure Code). The first wave-1 file, for January 2026, was due on 2 March 2026 because 28 February 2026 was a Saturday.

SAF-T annual file for fixed assets

Fixed-asset balances and movements are filed once a year, by the deadline for the annual tax return under Art. 92 of the Corporate Income Tax Act: from 1 March to 30 June of the following year (Art. 71k, para. 2 of the Tax Procedure Code and Art. 92, para. 2 of the Corporate Income Tax Act). Wave 1 files its 2026 data by 30 June 2027.

The fixed-asset data includes book and tax depreciation (Art. 71i, para. 2, item 5), so the fixed-asset register has to keep both and its balances have to agree with the general ledger.

Inventory data is not filed routinely, only on request from a revenue authority, within the period it sets (Art. 71k, para. 3 of the Tax Procedure Code). Under Art. 22, para. 1 of the Tax Procedure Code, the revenue authority cannot set a period shorter than 7 days.

Corrections: a 12-month window instead of a grace period

Enterprises entering under the 2026-2030 schedule file from the first month: the six-month exemption in Art. 71k, para. 5 of the Tax Procedure Code does not apply to them (§ 17, para. 2 of the transitional provisions of the 2025 State Budget Act). Instead, the correction period in Art. 71k, para. 6 is 12 months and runs from the date the obligation arose.

• 01An error in a filed file is corrected by filing a new file for the same period (Art. 71k, para. 6 of the Tax Procedure Code).
• 02The correction window does not postpone filing: each month's file is due by the deadline in Art. 71k, para. 1, and a file never filed is not a correction.
• 03According to the NRA, the files for the first 12 months, including files rejected for errors, are corrected with a new file by the end of February of the following year: for an obligation starting on 1 January 2026, the files for January to December 2026 can be corrected until the end of February 2027 (NRA SAF-T questions and answers, March 2026, question II.2.2).
• 04Outside the correction window, if the format or content of a file does not meet the requirements, the NRA notifies the filer to fix it within 7 days. If it is not fixed, the file is treated as not filed (Art. 71k, para. 7).

SAF-T penalties in Bulgaria

For a monthly file, fixed-asset file or requested inventory file not filed on time, companies and sole traders pay a financial penalty and individuals a fine (Art. 277a, paras. 1 and 2 of the Tax Procedure Code).

The penalty does not end the obligation. An enterprise that has not filed must provide the file when a revenue authority asks for it, and failing to do so carries the same penalty (Art. 277a, para. 3).

Example: a medium company that starts in 2028

Primer OOD is a medium enterprise under Art. 19, para. 4 of the Accounting Act at 31 December 2025. Its net sales for 2025 are BGN 12,400,000 (€6,340,019.33), below the BGN 15,000,000 threshold. In 2025, BGN 1,710,000 of taxes and social security contributions (€874,309.12) were paid into NRA accounts, and the NRA refunded BGN 90,000 of VAT (€46,016.27). Net payments are BGN 1,620,000 (€828,292.85), above the BGN 1,500,000 threshold. For 2024 the company met neither wave-2 test, so it is in wave 3 (§ 17, para. 1, item 3, letter b).

Primer OOD has no six-month exemption: the January 2028 file is due on time, and the company can correct errors in it later with a new file.

What to prepare now

Preparing for SAF-T is mostly cleaning up data you already keep (Art. 71i, para. 2 of the Tax Procedure Code).

• 01Work out your wave. Check your category under the Accounting Act at 31 December 2025 and your 2025 net sales and payments to the NRA: they decide whether you start in 2028 or later.
• 02Map your chart of accounts. The file describes accounts, movements and balances (item 2) and standardises the data with the NRA nomenclatures (item 7), so every account and sub-account has to map to them.
• 03Clean up customer and supplier data (item 3). Record a company number (ЕИК) or VAT number, country and address for every counterparty, and merge duplicate records for the same company.
• 04Check document numbering. Invoices and notes carry ten-digit numbers that increase without duplicates or gaps (Art. 78, para. 2 of the regulation implementing the VAT Act), and the file shows each document separately.
• 05Link payments to documents. The file contains payments and the payment method (item 4), so every payment has to point to an invoice or an expense.
• 06Prepare the fixed-asset register with book and tax depreciation for every asset, and reconcile it with the general ledger (item 5).
• 07Record your beneficial owner details (item 1) and arrange a qualified electronic signature for filing (Art. 71k, para. 4).
• 08Check that your software produces a file under XSD schema 1.0.2. Test it with one month of data before the obligation starts.

For invoice content and numbering, see the full list of invoice requirements under Art. 114 of the VAT Act.

SAF-T and mandatory e-invoicing from 2028 (draft law)

SAF-T and mandatory structured e-invoices are two separate obligations, and the second is still a draft law. The draft act amending the VAT Act is in public consultation No. 12733 on strategy.bg from 23 September to 23 October 2026. It does not amend Chapter 8b of the Tax Procedure Code, so SAF-T stays after 2028.

For a VAT-registered wave-3 company the two changes coincide: if the draft is adopted, from 1 January 2028 it will issue structured invoices, and its first monthly SAF-T file will be for January 2028. Both use the same counterparty data, numbers and amounts. The other proposals are covered in tax changes 2027.

Common mistakes

• 01"The monthly file is due by the 14th." The current Art. 71k, para. 1 of the Tax Procedure Code (as amended by State Gazette issue 65 of 2025) sets the end of the month after the reporting month.
• 02"Every wave has a six-month grace period." For the 2026-2030 waves, § 17, para. 2 expressly excludes Art. 71k, para. 5. Filing starts in the first month, and the 12 months are a correction window.
• 03"The inventory file is due within 14 days of the request." The revenue authority sets the period (Art. 71k, para. 3), and it cannot be shorter than 7 days (Art. 22, para. 1 of the Tax Procedure Code).
• 04"From 2030 all micro-companies file SAF-T." Micro-enterprises not registered for VAT are excluded (Art. 71z, para. 2, item 1).
• 05"A micro-company with high sales enters in wave 3." Waves 1-4 cover only large, medium and small enterprises, so a VAT-registered micro-enterprise starts in 2030, unless it is already a small enterprise at 31 December 2026 (then in 2029).
• 06"SAF-T replaces the VAT return." The VAT return is filed for every tax period under Art. 125, para. 1 of the VAT Act.
• 07"A generated file is a filed file." The file is submitted to the NRA with a qualified electronic signature (Art. 71k, para. 4). Downloading it from software is not filing.

In smetni.app

In the Declarations module (Business and Enterprise plans), the SAF-T section checks whether the data for a month or a year is ready, and generates and downloads the monthly file and the annual fixed-asset file. The annual file can be generated for every closed year the books in the app cover. The current version of the monthly file supports only companies that provide services: for a company that works with goods, the readiness check reports that the monthly file is not supported. For how such a company works in the app, see smetni.app for service businesses. The fixed-asset register keeps book and tax depreciation, and you file with the NRA separately, with your own qualified electronic signature. See the declarations guide, the accounting guide and plans and pricing.