Oct
Bulgaria proposes mandatory domestic e-invoicing from 1 January 2028
Who this will interest: Businesses trading in Bulgaria.
Key point(s): draft legislation has been published introducing mandatory structured e-invoicing for domestic supplies from 1 January 2028.
Action points: Businesses trading in Bulgaria should assess whether these changes will impact their invoicing and accounts payable processes.
In detail
On 23 September 2026, the Bulgarian Ministry of Finance published a draft Law amending the VAT Act. The intention is to have VAT-registered suppliers established in Bulgaria issue e-invoices for domestic supplies and advance payments. The e-invoices should be issued where sales are made to:
- Bulgarian businesses,
- non-taxable legal persons and
- public authorities.
Non-registered suppliers would also have to issue e-invoices to public authorities.
The following categories would be excluded from the requirement to issue e-invoices:
- intra-Community supplies,
- supplies made by non-established VAT-registered persons in Bulgaria,
- supplies by intermediaries in triangular transactions,
sales for which a tax receipt has been issued via an authorised device.
The e-invoices have to be compliant with the EN 16931-standard and should be issued and received through the system developed by the National Revenue Agency (NRA).
The intention is to replace the sales and purchase ledgers with VAT returns pre-filled by the NRA using the data from the e-invoicing system. Having a valid e-invoice would also become a substantive condition to recover input VAT.
A penalty for failing to issue an e-invoice would apply from 1 July 2028. It would equal the VAT not charged on the invoice plus a minimum of EUR 750 for individuals or EUR 1,500 for legal entities.
Impact on businesses
Businesses trading in Bulgaria will need to assess whether the new requirements apply to them and adapt their invoicing and accounting systems to the new requirements.