Bulgaria Proposes Mandatory E-Invoicing and Real-Time VAT Reporting from 2028
Bulgaria’s Ministry of Finance released draft amendments to the country’s VAT legislation on September 23, 2026. The proposal would make structured e-invoicing and real-time digital reporting mandatory for domestic transactions as of January 1, 2028, and would replace the existing VAT sales and purchase ledgers with pre-filled VAT returns.
Public consultation on the draft is open until October 23, 2026. Once it closes, the proposal will still need to be approved by the Council of Ministers and the National Assembly.
The draft implements elements of the EU’s VAT in the Digital Age (ViDA) package and uses the new possibility for Member States to introduce mandatory domestic structured e-invoicing. The Bulgarian regime would take effect before ViDA’s harmonized digital reporting requirements for intra-EU B2B transactions, which apply from July 1, 2030. The two frameworks will not have identical scope or timelines, but both follow the same move toward structured transactional VAT data.
Implementation Timeline
- September 23, 2026 – publication of the draft VAT amendments
- October 23, 2026 – end of public consultation
- By July 2027 – expected availability of the NRA testing environment
- January 1, 2028 – start of mandatory domestic e-invoicing and real-time digital reporting
- July 1, 2028 – new e-invoicing penalties take effect
- July 1, 2030 – ViDA digital reporting requirements for intra-Community supplies apply
Scope of the Mandate
Under the draft, VAT-registered suppliers established in Bulgaria would have to issue structured electronic invoices for domestic supplies and advance payments when the customer is:
- A taxable person established in Bulgaria,
- A non-taxable legal person, or
- A public authority.
Suppliers that are not registered for VAT would also be covered when they supply public authorities. All e-invoices would have to comply with the European standard EN 16931.
The obligation would not extend to certain transactions, including:
- Intra-Community supplies
- Supplies made by intermediaries in triangular transactions
- Supplies by VAT-registered persons not established in Bulgaria
- Transactions documented at the time of sale with an extended fiscal-device receipt
National Platform and Real-Time Reporting
The new e-invoicing and digital reporting system would be administered by the National Revenue Agency (NRA). Businesses could either issue invoices directly on the national platform or continue using their own invoicing software. In the second case, invoice data would have to be transmitted to the NRA in real time.
An e-invoice would be treated as issued and received once the national system has validated it and assigned a unique compliance code. The recipient’s consent would not be required. The reform, therefore, goes beyond a requirement concerning invoice format: e-invoicing and transaction reporting would in practice form one continuous VAT compliance process.
Pre-Filled VAT Returns
The NRA would use the same transaction data to prepare VAT returns. The current VAT sales and purchase ledgers would be abolished, and taxpayers would receive a pre-filled VAT return by the second day of the month following each VAT period. Businesses could supplement and correct the return before submitting it.
The proposed model creates a direct data chain: structured e-invoice → real-time reporting to the NRA → validation → pre-filled VAT return.
Input VAT Deduction
Where the supplier is obliged to issue an e-invoice, holding a valid e-invoice would become a substantive condition for the recipient’s right to deduct input VAT. As a result, invoice validation and reconciliation would matter not only for e-invoicing compliance but also for securing VAT recovery.
Testing, Technical Requirements, and Penalties
The NRA would be required to provide a testing environment at least six months before the system goes live. If the January 2028 start date is maintained, businesses should gain access by July 2027. Detailed technical requirements will be set out separately in an ordinance of the Minister of Finance.
From July 1, 2028, failure to issue a required e-invoice would result in a penalty calculated on the basis of the VAT not charged, subject to the following minimum amounts:
- EUR 750 for individuals,
- EUR 1,500 for legal entities.
According to the Ministry’s estimates, the new system will cost approximately EUR 20 million and generate around EUR 350 million in additional VAT revenue in 2028.
There’s more you should know about e-invoicing in Bulgaria – learn more about the new and upcoming regulations.
