E-Invoicing in Bulgaria: Complete Guide

Bulgaria plans to introduce mandatory structured e-invoicing for domestic transactions from 1 January 2028. On 23 September 2026, the Ministry of Finance published a draft law amending the VAT Act (ЗИД на ЗДДС) for public consultation, which is open until 23 October 2026.

Invoices within the scope of the obligation would only be considered issued once a national system operated by the National Revenue Agency (NRA) has validated them and assigned a unique compliance code. The reform would also abolish the VAT sales and purchase ledgers and replace them with pre-filled VAT returns generated by the NRA.

1. What is a structured e-invoice in Bulgaria?

The draft law creates a new category of invoice: the structured e-invoice (структурирана електронна фактура). An invoice would qualify as a structured e-invoice only if all three of the following conditions are met:

• it complies with the requirements of the VAT Act;

• it is issued, transmitted and received electronically in a structured format that allows its automatic processing, in line with the European e-invoicing standard and the list of syntaxes under Directive 2014/55/EU;

• it has been assigned a unique compliance code by the NRA's national system.

The law would therefore distinguish structured e-invoices from invoices issued in other electronic formats. For transactions subject to the obligation, an invoice that does not meet the structured e-invoice requirements would be treated as incorrectly issued.

With this reform, Bulgaria would make use of the option available to Member States under Article 218 of Directive 2006/112/EC, as amended by Directive (EU) 2025/516 (ViDA), to require e-invoicing for domestic transactions.

2. Implementation calendar

Structured e-invoicing would become mandatory from 1 January 2028 for all taxpayers within its scope, with no phased roll-out by company size. The main milestones are:

• 23 September 2026: the Ministry of Finance publishes the draft law for public consultation.

• 23 October 2026: the public consultation closes.

• 1 January 2028: mandatory structured e-invoicing and pre-filled VAT returns take effect.

• 1 July 2028: the penalty for failing to issue a structured e-invoice starts to apply.

Before go-live, the NRA is expected to provide taxpayers with a six-month testing environment so they can test their integration with the national system.

See our overview of e-invoicing mandates in Europe  

3. Which companies are affected?

The obligation to issue structured e-invoices would apply to suppliers that are VAT-registered and established in Bulgaria. It would cover supplies of goods and services with their place of supply in Bulgaria, including advance payments received for those supplies, where the recipient is established in Bulgaria and is:

• a taxable person;

• a non-taxable legal person; or

• the State or a state or local authority.

The obligation would also extend to two further cases:

• Non-registered suppliers dealing with the public sector: suppliers established in Bulgaria that are not VAT-registered would have to issue structured e-invoices where the recipient is the State or a state or local authority. For all their other transactions, they could continue to issue paper invoices or invoices in other electronic formats.

• Non-mandatory invoices: where an invoice is not mandatory but a registered and established supplier issues one on its own initiative or at the recipient's request, it would also have to be a structured e-invoice if the supply takes place in Bulgaria and the recipient is established there.

4. Which transactions are out of scope?

The structured e-invoicing obligation would not apply in the following cases:

• Suppliers not established in Bulgaria: suppliers that are VAT-registered in Bulgaria but not established there would issue their invoices for supplies taking place in Bulgaria, including advance payments, in a format other than the structured e-invoice.

• Intra-Community supplies and triangular transactions: for intra-Community supplies, supplies made by an intermediary in a triangular transaction, and the related advance payments, the supplier would not be required to issue a structured e-invoice.

• Sales documented with an extended receipt: where a sale is recorded through a fiscal device or sales management system and the invoice is issued at the time of sale as an extended fiscal or system receipt, the obligation would not apply. For fuel sales recorded through the electronic system with fiscal memory (ЕСФП) used at filling stations, this extended receipt would be mandatory regardless of the payment method.

5. How are e-invoices issued and validated? The NISSEF system

The NRA would operate a national information system for structured e-invoicing and digital reporting (НИССЕФ, NISSEF). Structured e-invoices and the related e-notes (debit and credit notes) could be issued directly in this system or through the taxpayer's own software. The system would:

• allow users to create structured e-invoices and the related e-notes;

• receive data from invoices created in other software or systems;

• carry out a semantic check of their compliance with the legal requirements;

• generate a unique compliance code for validated data and notify it to both supplier and recipient;

• give each taxpayer access to the data of all structured e-invoices issued by or to them, and allow them to download it;

• store the data of all structured e-invoices issued.

Taxpayers using their own software would have to transmit to the NRA, immediately and in real time, the data specified in the ministerial ordinance each time they create or cancel a structured e-invoice. The system would then run an automatic compliance check:

• if the data is compliant, it would generate the unique compliance code;

• if it detects non-compliance, it would return an error message, and the issue would have to be corrected within 48 hours.

An invoice would be considered issued and received at the moment the system generates the unique compliance code. Issuing it would not require the recipient's consent. However, the supplier would still have to send the invoice to the recipient electronically, and the recipient would be required to be able to receive and process it reliably, in line with the technical specifications agreed between the parties.

The technical requirements for issuing, sending, verifying, receiving and storing structured e-invoices would be set out in an ordinance of the Minister of Finance, to be adopted within six months of the law's publication in the State Gazette (Darzhaven Vestnik).

5.1. Additional mandatory content

In addition to the details required on any invoice, a structured e-invoice would have to include:

• The code of the goods or services. For goods, the EU Combined Nomenclature code (Annex I to Council Regulation (EEC) No 2658/87). For services, the code under the United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT) classification. Where neither provides an applicable code, the code set out in the ministerial ordinance would be used.

• The supplier's payment account. The invoice would have to show the supplier's bank or virtual account number, or another identifier that unambiguously identifies the accounts in which payment has been or is expected to be received.

5.2. Corrections and cancellations

Any change to the taxable amount of a structured e-invoice would have to be made through a structured e-note, which must meet the same requirements as the invoice. The e-note would also have to indicate the unique compliance code of the invoice or e-note it refers to. E-notes would also be issued to correct invoices or e-notes issued in error.

There would be two ways to deal with structured e-invoices issued in error, depending on timing:

• Up to the 5th day of the tax period following the period of issue: the invoice would be cancelled under the procedure set out in the ministerial ordinance, without issuing a credit note.

• If it has already been included in the supplier's or recipient's VAT return: cancellation would require a credit note stating the reason, the number and date of the cancelled document, and its unique compliance code.

6. Pre-filled VAT returns and input VAT deduction

The reform would abolish the VAT sales and purchase ledgers for all VAT-registered taxpayers, including those not established in Bulgaria. Instead, by the 2nd day of the month following each tax period, the NRA would make available a draft VAT return generated from the structured e-invoices issued and received and from import and export customs declarations.

Taxpayers would have to add to the draft any transactions not documented with a structured e-invoice, and could correct, add or delete data up to the filing date. The EC Sales List (VIES return) would remain in place for intra-Community transactions.

Where the supplier is required to issue a structured e-invoice, there would be no right to deduct input VAT on a transaction that has not been documented with such an invoice. The right to deduct would be exercised in the return for the period in which it arises or, by way of correction, within the following 12 tax periods.

7. Penalties

From 1 July 2028, a registered taxpayer that fails to issue a mandatory structured e-invoice would be subject to a fine equal to the VAT not charged, subject to the following minimum amounts:

• EUR 750 for individuals who are not traders;

• EUR 1,500 for legal entities and sole traders.

From 1 January 2028, the draft law also provides for penalties for software producers and distributors whose technical flaws or coding errors block the automatic transmission of data to the national system:

• Legal entities and sole traders: EUR 50,000 to 100,000; for repeat offences, EUR 100,000 to 250,000.

• Individuals who are not traders: EUR 10,000 to 20,000; for repeat offences, EUR 25,000 to 50,000.

For repeat offences, the NRA could also temporarily suspend the software product's access to the national system until the defects are fixed.

8. Transition period, objectives and next steps

The draft law includes several rules for transactions that straddle the old and new regimes:

• Last period under the current rules: the VAT return, the VIES return and the ledgers for the December 2027 tax period would still be filed under the current rules.

• Chargeable event in 2027, invoice in 2028: where the chargeable event occurs on or before 31 December 2027 and the invoice is issued on or after 1 January 2028, a structured e-invoice would be required.

• Advance payments: where a full or partial advance payment has been received for a supply whose chargeable event occurs after 1 January 2028, the supplier would have to issue a structured e-invoice for the full taxable amount.

According to the explanatory memorandum, the reform aims to make invoicing faster, remove the double entry of data in invoices and ledgers, allow taxpayers to verify the validity of the invoices they receive, and lay the foundations for real-time VAT control. It also seeks to align Bulgaria with the European standard ahead of mandatory e-invoicing for cross-border trade, expected in 2030. The Ministry estimates the cost of the system at EUR 20 million and expects additional revenue of EUR 350 million in 2028.

The public consultation will remain open until 23 October 2026. The text may still change during the legislative process, and the technical requirements will be set out in the forthcoming ordinance of the Minister of Finance.

At Marosa by Wolters Kluwer, we are closely monitoring the progress of this reform in Bulgaria and will update this guide as it moves forward. Our e-invoicing solutions already support businesses with mandates in other countries.