Country deep dive
Bulgaria transposed the EU's B2G e-invoicing directive on 1 November 2019, requiring public contracting authorities to receive structured e-invoices — but has never introduced a business-to-business mandate. The next major change is not an invoicing mandate at all: from 1 January 2026, Bulgaria's largest taxpayers must start filing a monthly Standard Audit File for Tax (SAF-T), phasing down to smaller businesses over five years through 2030.
Since 1 November 2019, all Bulgarian public sector contracting authorities must be able to receive and process structured, EN 16931-compliant electronic invoices for public procurement contracts above the EU public procurement thresholds, via the Centralized Automated Information System for Electronic Public Procurement (CAIS EPP). The obligation applies uniformly to central and sub-central government under a single compliance date. Legal basis: Article 115a of the Public Procurement Act (State Gazette 86/18), transposing EU Directive 2014/55/EU.
Unlike neighbouring Romania or Poland, Bulgaria has no business-to-business e-invoicing mandate, real-time clearance system, or continuous transaction control of any kind. Structured e-invoicing between businesses is optional, contingent on mutual agreement, and governed by the Bulgarian VAT Act aligned with EU Directive 2014/55/EU — a supplier and buyer may agree to exchange EN 16931 e-invoices, but neither side is required to.
From 1 January 2026, Bulgaria's largest taxpayers — those with 2023 annual net revenue above BGN 300 million, or annual tax and social-security payments above BGN 3.5 million — must submit a monthly Standard Audit File for Tax (SAF-T) to the National Revenue Agency (NAP): general ledger, accounts payable/receivable, and purchase/sales invoice data, due by the 14th of the following month, plus an annual fixed-asset report. This is a periodic bookkeeping-data filing under the amended Tax and Social Insurance Procedure Code (ДОПК) — it does not require issuing e-invoices or route them through any government platform.
From 1 January 2027, entities classified as medium or small enterprises (under Bulgaria's general accounting size classification) that still exceed the Phase 1 thresholds — BGN 300 million 2024 revenue or BGN 3.5 million 2024 tax/social payments — join the large enterprises already reporting since 2026.
From 1 January 2028, the qualifying threshold falls to 2025 annual net revenue above BGN 15 million, or annual tax and social-security payments above BGN 1.5 million — pulling in a much wider band of mid-sized Bulgarian businesses.
From 1 January 2029, SAF-T reporting extends to all enterprises classified as large, medium or small under Bulgarian accounting law, regardless of revenue or tax thresholds — leaving only micro-enterprises outside the regime for one more year.
From 1 January 2030, SAF-T reporting reaches every remaining VAT-registered entity, including micro-enterprises, completing a five-year phased rollout that began with the largest taxpayers in 2026.
From 1 July 2030, under Council Directive (EU) 2025/516, structured e-invoicing and digital reporting become mandatory for all intra-Community B2B supplies — a firm EU-law floor that applies to Bulgaria regardless of whether it introduces its own domestic B2B mandate first. Bulgaria has announced no domestic B2B e-invoicing plans of its own as of this research round; SAF-T reporting (above) is a separate, parallel obligation.
Bulgaria accepts EN 16931-compliant structured e-invoices for public procurement (B2G) through the Centralized Automated Information System for Electronic Public Procurement (CAIS EPP). For B2B, there is no mandated format or platform at all — trading partners are free to agree on structured e-invoicing or continue with PDF/paper. The separate, incoming SAF-T obligation uses its own XML schema aligned with the OECD SAF-T standard, unrelated to invoice format.
A paper or plain PDF invoice does not satisfy this requirement — Bulgarian contracting authorities must be able to receive and process a genuinely structured e-invoice through CAIS EPP.
SAF-T is a periodic bookkeeping-data export, not an invoice-issuance requirement — it does not change how you issue, send, or receive an invoice, only what accounting data you periodically report to the NRA.
B2G e-invoicing applies to contracts above the EU public procurement thresholds, uniformly across central and sub-central contracting authorities. B2B e-invoicing has no scope at all today because there is no mandate. SAF-T reporting scope is defined purely by size: it starts with taxpayers exceeding BGN 300 million revenue or BGN 3.5 million in tax/social payments (2026), and widens in four further steps to reach every VAT-registered entity, including micro-enterprises, by 2030.
Each phase carries a documented six-month grace period allowing corrections to initial monthly filings without penalty, through the seventh month's deadline.
A Bulgarian business may exchange structured e-invoices with a trading partner today, entirely by mutual agreement — there is no domestic legal requirement pushing it, and no penalty for not doing so.
Most businesses trading with Bulgarian public bodies are likely already compliant with the 2019 B2G requirement. The live compliance question for 2026 onward is SAF-T readiness: large taxpayers need SAF-T-capable accounting software now, and every other business should track which 2027–2030 threshold phase will eventually apply to them.
If you supply Bulgarian public bodies, verify your invoices are structured EN 16931 e-invoices submitted via CAIS EPP — this obligation has applied since November 2019.
Check your annual revenue and tax/social-security payments against the phase thresholds above to find your first mandatory filing date, from 2026 through 2030.
Confirm your accounting or ERP system can produce the required monthly general ledger, AP/AR and invoice-data XML export well before your phase's first deadline — the six-month grace period is for corrections, not for starting from zero.
SAF-T changes what accounting data you report and when — it does not require you to change how you issue or exchange invoices with other businesses, since no such mandate exists in Bulgaria today.
Bulgaria has made no domestic B2B e-invoicing announcement as of this research round, but the 1 July 2030 EU ViDA floor applies regardless — monitor for a domestic mandate that would likely arrive earlier.
Bulgaria has no e-invoicing-specific penalty regime, because it has no e-invoicing mandate to enforce for B2B. SAF-T non-compliance is a distinct, general tax-procedure violation — reported fine figures (BGN 5,000–15,000 for an initial violation, doubling for repeats) come from a single specialist compliance source and are flagged here as plausible rather than confirmed against the primary legal text.
Other countries in the same region, ordered by their next dated milestone. Each links to a full briefing.