Stripe and Bulgarian invoices: a guide for online merchants

You accept card payments through Stripe, the money arrives, customers are happy. Then the month ends and your accountant asks for the documents. This article sums up what a Bulgarian online merchant collecting payments through Stripe actually owes the National Revenue Agency (НАП, the NRA), and which tasks do not solve themselves.

What Stripe does and does not do

Stripe is a payment rail. It collects the money; issuing Bulgarian tax documents remains entirely your obligation.

Stripe also has an invoicing product (Stripe Invoicing), but by default its documents do not meet the requirements of the Bulgarian VAT Act (ЗДДС) for an invoice (фактура):

• The invoice number must be ten digits, Arabic numerals only, ascending without duplicates or gaps (Art. 114, para. 1, item 2 of the VAT Act and Art. 78 of its implementing regulation, ППЗДДС). Stripe numbers invoices with an alphanumeric prefix, a hyphen and a counter, for example 586A2E-0139. Its settings cannot produce a purely numeric ten-digit number.
• Stripe credit notes get an automatic number that cannot be set. A Bulgarian credit note is numbered in the same ten-digit sequence as the invoices (Art. 78, para. 2 of the regulation).
• The date of the tax event, or of the payment received, is a mandatory element (Art. 114, para. 1, item 10 of the VAT Act). Stripe has no dedicated field for it: a supply date per line or a custom field can carry it, but that requires additional configuration or an API integration.
• Stripe Checkout's built-in tax ID field accepts only a VAT number. The ЕИК (company registration number) of a Bulgarian company without VAT registration can be collected in a custom field. Transferring it to the invoice requires additional configuration or integration; fields set at customer level can be inherited by subsequent invoices.

So the settled practice is simple: Stripe collects the payment, and the invoice is issued in a Bulgarian invoicing system, in its own continuous sequence.

Sales to individuals: when is an invoice required at all

For sales to non-taxable natural persons an invoice may be skipped (Art. 113, para. 3, item 1 of the VAT Act). If the customer asks for one, it is issued (Art. 113, para. 6). When the buyer is a company, organisation or public body, the invoice is mandatory and is issued no later than 5 days after the tax event, or after an advance payment is received (Art. 113, para. 4).

Instead of an invoice for every consumer sale, VAT-registered merchants compile a sales report for each month (Art. 119 of the VAT Act). Its content is set by Art. 112, para. 3 of the regulation: tax bases and VAT by rate (20%, 9%, 0%), exempt supplies and other supplies without VAT. The report is compiled by the last day of the month and entered in the sales ledger as one document. Separate reports per day or per outlet are optional.

Cards and the fiscal receipt

This is the most common misunderstanding. An online card payment requires a fiscal receipt as a rule. Art. 3, para. 1 of Ordinance N-18 exempts payments made by a cash deposit into a payment account, credit transfer, direct debit, cash money remittance and postal money order. Card payments, including through Stripe, are not on that list. The NRA has confirmed that the obligation depends on how the customer pays, not on how the merchant receives the money.

An exception that matters for subscriptions: for subscription services with recurring performance, paid remotely by card on the customer's prior consent, a document with the data under Art. 52o, para. 1, items 1 and 5 and the merchant's details is enough instead of a fiscal receipt (Art. 3, para. 1a, item 1 of N-18).

Online shops have an alternative regime (Art. 3, para. 17 of N-18), under which instead of a fiscal device the shop:

1. registers as an electronic shop with the NRA before it starts trading;
2. issues for every sale a document under Art. 52o with a QR code and a ten-digit number that is unique across the whole activity of the online shop and the merchant;
3. submits a monthly audit file to the NRA by the 15th of the following month.

Useful details that are often missed:

• Since 2021 (State Gazette issue 17 of 2021) the regime is also open to shops that accept other payments, for example cash on delivery. Other payments follow the general rules in Art. 3, para. 1: a postal money order through a licensed postal operator does not require a fiscal receipt, but the customer receives a sales document with the required details.
• When an invoice is issued for the sale and it contains the data under Art. 52o, para. 1, items 3 to 6, a separate Art. 52o document may be skipped (Art. 52o, para. 3).
• Card payments must reach a payment account held by the merchant, at a bank or payment service provider in the EU or in a country that exchanges bank information with Bulgaria under a tax treaty. The money may land first with the provider, for example in the Stripe balance, as long as it is then paid out to the merchant's account (Art. 52p).
• The shop registration form asks for the payment service provider and the merchant's identifier with it (Merchant ID). A virtual POS number is entered only if one exists. Stripe does not issue a terminal number, so in practice merchants record Stripe Payments Europe, Limited and their account ID (acct_...).

The choice between a fiscal device, an electronic receipt and the alternative regime depends on the specific shop and is worth making together with your accountant. Some questions around payments through payment intermediaries also have official NRA opinions worth reviewing for your case.

Month end with Stripe

Three tasks need attention each month:

• Gross revenue, separate fees. Revenue is booked in full, Stripe fees are a separate expense, and a net amount lands in the bank account. Fees are deducted with every payment, while Stripe issues its invoice for them by the 10th of the following month. That invoice groups fees by the transaction date, not the payout date, so a payout early in a month can contain fees from the month before.
• A protocol under Art. 117 for the fees. Stripe does not charge VAT on its fees to customers in Bulgaria. For the services received from Stripe Payments Europe, Limited, a VAT-registered recipient issues a protocol under Art. 117 no later than 15 days after the tax became chargeable. Payment processing fees are usually an exempt financial service under Art. 46, para. 1, item 3 of the VAT Act, but the protocol is issued even then (Art. 81, para. 6 of the regulation). The NRA takes the same view for the fees of EU payment providers (ref. 53-04-296 of 28 May 2018). In its opinions on Stripe from 2025 and 2026, the NRA treats the fees as exempt when they are financial services under Art. 46, para. 1, item 3, and as taxable when they are not, for example technical services. The National Revenue Agency has not classified fees for services that are not payments, such as Stripe Billing, Radar or Tax. According to the Court of Justice of the EU, the exemption does not cover merely technical services (cases C-350/10 Nordea and C-607/14 Bookit), so the safer treatment is a protocol with 20% VAT, and for a business that is not VAT-registered this means registration under Art. 97a. Confirm the treatment with your accountant.
• Payout reconciliation. Stripe's Balance summary report works like a bank statement for your balance, and the Payout reconciliation report shows which payments make up each payout. Together with the export from the Transactions page and the monthly fee invoice, this is what your accountant will ask for: keep them and reconcile payouts against revenue.

A short checklist

1. Invoices come from a system with a continuous ten-digit sequence, not from Stripe.
2. Consumer sales go into a monthly sales report, and refunds reduce it.
3. The N-18 regime for card payments is settled with your accountant: fiscal device, electronic receipt, the subscription exception or the alternative regime with the audit file.
4. A protocol under Art. 117 is issued for Stripe fees.
5. Payouts are reconciled against revenue every month.
6. Invoices are kept for at least 10 years (Art. 12, para. 1, item 2 of the Accountancy Act) and until 5 years after the limitation period for the obligation they evidence expires (Art. 121, para. 1 of the VAT Act). The longer period applies.

How smetni.app solves this

This exact gap is what smetni.app's Stripe connection closes: it follows the invoices and credit notes in Stripe and issues the Bulgarian document for you, with nothing to touch after the setup.

Connecting is a one-off and takes minutes:

• 01Go to Settings → Integrations and select "Connect Stripe" to create a connection.
• 02Give it a name and choose the series for automatic invoice numbering.
• 03Copy the Webhook URL of the new connection and use it to add a webhook in Stripe.
• 04Paste the signing secret from Stripe into the connection settings.
• 05Select the same supported events in Stripe and smetni.app, save the settings and enable the connection.

From then on, everything above happens by itself:

• Every paid Stripe invoice produces a Bulgarian invoice with the next number of the chosen series and the full requisites under art. 114, and it is paid from the moment of issue. This covers subscriptions and any payment for which Stripe issues an invoice. A one-off Checkout payment without a Stripe invoice does not produce one.
• Stripe credit notes produce Bulgarian credit notes tied to the specific invoice, as art. 115 requires. So refund an invoiced payment through a credit note in Stripe, not only as a plain refund.
• Clients are created and updated from Stripe: name, email and address, and the ЕИК or VAT number is filled in when missing. The numbers go through the same checks as for a client entered by hand.
• Optionally the invoice goes out to the client by email right after issue, with a link to the client portal.

What stays on your list is only what no system can decide for you: the monthly B2C sales report, the fiscal-receipt regime under Ordinance N-18, and the art. 117 protocol for Stripe's fees. Expenses and payments are in the same account. For the whole picture for a SaaS business, see smetni.app for SaaS companies.