Bulgaria proposes mandatory e-invoicing and real-time reporting from January 2028
Bulgaria's Ministry of Finance has proposed making e-invoices mandatory for domestic B2B and B2G supplies from 1 January 2028, with all invoices passing through the National Revenue Agency in real time.
Bulgaria’s Ministry of Finance has put a draft amendment to the VAT Act out for public consultation. VAT-registered suppliers established in Bulgaria would have to issue structured e-invoices for domestic B2B and B2G supplies from 1 January 2028. Every invoice would pass through the National Revenue Agency in real time. Buyers would lose the right to deduct input VAT if the supplier fails to issue a valid e-invoice.
Bulgaria’s Ministry of Finance has proposed making e-invoicing mandatory for domestic business-to-business and business-to-government supplies from 1 January 2028. The draft amendment to the VAT Act (ZDDS) entered public consultation on 23 September 2026 and runs until 23 October 2026.
Under the proposal, every e-invoice would pass through the information system of the National Revenue Agency (NRA) in real time. The stakes for buyers are high. If a supplier fails to issue a valid structured e-invoice, the buyer loses the right to deduct input VAT.
Who must issue e-invoices
The obligation would apply to VAT-registered suppliers established in Bulgaria. It covers supplies with a Bulgarian place of supply, including advance payments received. The buyer must also be established in Bulgaria and be one of the following:
- A taxable person
- A non-taxable legal entity
- A public authority
Suppliers with a Bulgarian VAT registration but no establishment there are outside the obligation. Sales to consumers, intra-Community supplies, and supplies in ABC triangular transactions fall outside the obligation. Sales documented with an extended fiscal or system receipt are also excluded.
Technical requirements
E-invoices must comply with the European standard EN 16931 and the syntaxes listed under Directive 2014/55/EU to allow automated processing. Suppliers must also add a Combined Nomenclature goods code or UN/CEFACT service code per line. The supplier’s bank account numbers are required too.
The proposal does not name a specific network such as Peppol. Technical requirements will be set out in a ministerial ordinance due within six months of the law’s publication.
How the NRA system works
Businesses can create e-invoices directly in the NRA system. They can also use their own software or ERP, which sends data to the NRA immediately. The system validates the invoice semantically. If it passes, the NRA generates a unique compliance code. Only then is the invoice deemed issued and received.
If the system reports a discrepancy, it must be remedied within 48 hours. Incorrectly issued documents are cancelled no later than the 5th day of the following tax period, without a credit note.
VAT deduction and penalties
Holding a valid structured e-invoice would become a substantive condition for VAT deduction. The NRA would make a draft VAT return available no later than the 2nd day of the month after the tax period. Current sales and purchase ledgers would be abolished from 1 January 2028.
Penalties would apply from 1 July 2028. The fine equals the uncharged VAT. The minimum is EUR 750 for natural persons who are not traders and EUR 1,500 for legal entities and sole traders.
The NRA would provide access to a test environment six months before the start date.
Bulgaria joins the CTC trend
Bulgaria follows other Eastern European Member States adopting continuous transaction controls (CTC) models. Poland uses KSeF, Romania uses e-Factura, and Slovakia starts in 2027. Since the adoption of the ViDA package in 2025, Member States may introduce domestic e-invoicing mandates without separate EU authorisation. EN 16931 is the common basis.
The Bulgarian model combines government validation with exchange between the parties: the supplier also sends the e-invoice to the buyer.
What businesses must do now
Any business invoicing a customer in Bulgaria should determine whether it is established there. If so, it would fall under the obligation. A business with only a Bulgarian VAT registration and no establishment is outside the proposal.
Before 1 January 2028, businesses should:
- Determine whether their organisation is established in Bulgaria and which supplies fall under the obligation
- Add Combined Nomenclature or UN/CEFACT codes per item to master data and verify bank details
- Choose a route: create invoices in the NRA system or build a real-time link from ERP, possibly through a Peppol Service Provider or e-invoicing vendor
- Set up a process to remedy discrepancies within 48 hours
- Plan integration tests as soon as the test environment opens
- Follow the consultation until 23 October 2026 and the technical ordinance from the Minister of Finance
The Council of Ministers and the National Assembly must still approve the text, so the proposal may change.