Regulatory updates - Bulgaria

Published on December 9, 2024, the draft law on the State Budget of the Republic of Bulgaria for 2025, among various amendments, introduces the requirement for Bulgarian businesses to submit standard audit files (SAF-T).

Starting from 2026 until 2030, the obligation to submit SAF-T files will cover almost all enterprises, with some exceptions, e.g., micro-enterprises. The timeline is as follows:

• 1 January 2026: Large enterprises, that meet certain requirements, for instance, their net sales revenue for 2023 exceeds 300 million BGN (ca. 153.4 million EUR);
• 1 January 2027: Large, medium or small enterprises, that meet certain requirements, for instance, their net sales revenue for 2024 exceeds 300 million BGN (ca. 153.4 million EUR);
• 1 January 2028: Large, medium or small enterprises, that meet certain requirements, for instance, their net sales revenue for 2025 exceeds 15 million BGN (ca. 7.7 million EUR);
• 1 January 2029: Large, medium, or small enterprises based on the Accounting Act as of 31 December 31, 2026;
• 1 January 2030: enterprises under Art 2 of the Accounting Act.

The enterprises will also have a grace period of 6 months for submitting the first SAF-T.

SAF-T file submission frequency

• The SAF-T file will include the economic activity data and the accounting records of the enterprises in scope;
• Information on accounting entries, payments, etc., will be submitted in the SAF-T file monthly by the 14^th day of the month following the month to which the information relates;
• Information on inventory and movement of fixed assets, which is part of SAF-T, will be submitted annually.

Submission outline

Enterprises will be obliged to submit the SAF-T files electronically, with the qualified electronic signature. The format and manner of transmission will be regulated by the Executive Director of the National Revenue Agency (NRA), who will publish the following order on the NRA website.

Proposal No. 47-254-01-42, released on 21 April 2022, can be resumed in two primary measures that the government wants to implement.

The first is to raise the annual VAT registration threshold, which is currently BGN 50 000 (ca. EUR 25 550), in two phases:

• Phase 1, 1 January 2023 – BGN 100 000 (ca. EUR 51 100)

• Phase 2, 1 January 2024 – BGN 166 000 (ca. EUR 84 220)

Another measure that the Bulgarian tax authority wants to introduce is VAT registration and deregistration processes that will take effect on 1 January 2023 and 1 January 2024.

The main objective of these proposed reforms is to combat soaring prices and reduce bureaucracy with administrative costs placed on small and medium companies and natural persons executing personal economic activities.

The Bulgarian tax authority, NRA (National Revenue Agency), is going to initiate consultations with industry stakeholders about the possibility of new e-invoicing requirements as means of combating tax evasion.

The main idea of the proposal is businesses issuing electronic invoices and continuous transmission of the invoice data to NRA.

This e-invoicing proposal is under discussion, and more information is expected to be released by the end of this year.

Pagero is closely monitoring the developments in Bulgaria and will continue providing the latest available insights to our customers and partners.