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Bulgaria Proposes Mandatory E-Invoicing and Real-Time VAT Reporting From 2028
Bulgaria’s Ministry of Finance has published draft legislation proposing mandatory structured e-invoicing, real-time transaction reporting and pre-filled VAT returns from 1 January 2028.
The draft amendments to Bulgaria’s VAT Act were published for consultation on 23 September 2026. The consultation closes on 23 October.
If enacted, the reform would create a national e-invoicing and reporting system operated by Bulgaria’s National Revenue Agency, or NRA. It would replace the country’s existing VAT sales and purchase ledgers with transaction data collected through the new system and used to prepare draft VAT returns.
Who Would Be Required to Issue E-Invoices?
Under the proposal, VAT-registered suppliers established in Bulgaria would have to issue structured electronic invoices for domestic supplies and advance payments where the recipient is established in Bulgaria for specified transactions.
Electronic invoices covered by the mandate would need to comply with the European standard EN 16931.
The NRA would also have to provide a testing environment at least six months before implementation. If the proposed commencement date remains unchanged, businesses should therefore receive access by July 2027. More detailed technical requirements would be set out separately in an ordinance from the Minister of Finance.
Pre-Filled VAT Returns Would Replace Existing Ledgers
The proposed system would use reported transaction data to prepare a pre-filled VAT return for each tax period.
For finance and tax teams, this would create a direct connection between the transaction recorded in the ERP, the structured invoice validated by the NRA and the amounts subsequently included in the VAT return. Reconciliation controls would need to cover all three stages.
This content is intended to share insights and practical considerations based on industry experience. It does not constitute legal, regulatory, or financial advice. Regulatory requirements vary by jurisdiction and circumstance, so any compliance-related matters should be reviewed and validated with your own professional advisors.
