Bulgaria moves toward mandatory structured e-invoicing under proposed VAT Act amendments
Bulgaria’s Ministry of Finance has published draft amendments to the VAT Act that would introduce mandatory structured e-invoicing and digital VAT reporting for specified domestic transactions. Under the proposal, the new e-invoicing and reporting requirements would apply from 1 January 2028 and would rely on a national system operated by the National Revenue Agency (NRA).
The draft is currently subject to public consultation and is not yet law.
Timeline: Bulgaria's proposed 2027 and 2028 e-invoicing dates
The draft legislation is proposed to enter into force on 1 January 2027, with the structured e-invoicing and digital reporting provisions applying from 1 January 2028. The public consultation remains open until 23 October 2026, and the NRA would be required to make testing of the new system available for six months before the mandate takes effect.
Key elements of Bulgaria's structured e-invoicing proposal
The proposal would establish a structured e-invoicing and real-time digital reporting framework for certain domestic transactions involving businesses established in Bulgaria.
Key elements of the proposed regime include:
- Mandatory structured e-invoicing: VAT-registered suppliers established in Bulgaria will be required to issue structured electronic invoices for qualifying domestic supplies to Bulgarian-established taxable persons, certain non-taxable legal persons, and public bodies, subject to exceptions.
- European standard: Structured invoices would need to comply with the European e-invoicing standard, including EN 16931 and applicable supported syntaxes.
- Real-time reporting: Invoices generated will need to be transmitted to the NRA in real time.
- Tax authority validation: The national system would automatically validate submitted invoice data and generate a unique compliance code.
- Legal issuance: An invoice or related credit note would be treated as issued when the compliance code is generated. Suppliers would nevertheless remain responsible for electronically sending the document to the recipient.
- Error correction: Taxpayers notified of validation issues would be required to remedy the non-compliance within 48 hours.
- Pre-filled VAT returns: The NRA will use structured invoice to prepare draft VAT returns, which taxpayers could review, supplement, or correct before filing.
How real-time reporting and compliance codes will work
If adopted, the proposal will require businesses operating in Bulgaria to assess whether their domestic transactions fall within scope and ensure that their invoicing systems can create compliant structured invoices, exchange the required data with the NRA’s national platform, process compliance codes and validation responses, and support the required adjustment processes.
How businesses should prepare for Bulgaria's VAT Act amendments
Businesses should continue monitoring the legislative process and forthcoming technical specifications, as the requirements may change before final adoption.
Fonoa can help you prepare for Bulgaria's structured e-invoicing requirements with one platform for e-invoicing, tax determination, and reporting, so get in touch to see how Fonoa can support your compliance ahead of 2028.
