In brief: From 1 January 2028, VAT-registered businesses will issue structured electronic invoices for domestic B2B supplies. An invoice will be valid only once the NRA system gives it a unique code. The purchase and sales ledgers will be abolished, the NRA will prepare a draft VAT return, and without an e-invoice there is no input VAT credit.
Status: these changes are draft bills from the Ministry of Finance (published on 23 September 2026 and discussed at the National Tripartite Council on 23 October 2026). They become law only after Parliament votes on them and they are published in the State Gazette. We will update this article once they are adopted.

Who is affected

  • Supplies with a place of supply in Bulgaria between a VAT-registered supplier and a recipient established in Bulgaria.
  • In some cases, suppliers not registered for VAT as well, when the buyer is the state, a state body or a municipality.
  • It does not cover intra-Community supplies, triangular transactions or advance payments for them. For these, the EU introduces e-invoices from 1 July 2030 under the ViDA package — see VAT in the Digital Age (ViDA).
  • Foreign businesses not registered in Bulgaria continue under the general rules.

What changes in the invoice

TodayFrom 2028 (draft)
Invoice in PDF or on paper, with the recipient's consentStructured e-invoice; the recipient's consent is not needed
The invoice is issued when you create itThe invoice is issued when the NRA gives it a unique code
Standard invoice detailsIn addition: a Combined Nomenclature code (goods) or a UN/CEFACT classification code (services) and the supplier's bank account
Credit and debit notesA structured electronic note that contains the code of the original document

Invoices will be issued in the NRA system or in other software that sends the data to the NRA in real time.

No ledgers — the NRA fills in the return

The purchase and sales ledgers are abolished. By the 2nd day of the month after the tax period, the NRA will provide a draft VAT return built from the e-invoices. You complete it, correct it, add or delete data and file it. The VIES return stays.

Input VAT is claimed in the return for the period in which the right arose. If you miss it, you can claim it by correcting that same return, but no later than 12 tax periods. Errors in filed returns are corrected the same way — within 12 periods.

The key rule: no e-invoice, no credit

If the supplier was required to issue a structured e-invoice and the VAT was not charged with one, the buyer has no right to input VAT credit. Checking your suppliers becomes essential: after 2028, a PDF invoice from a registered Bulgarian supplier will cost you 20% of the amount.

The draft also introduces new, higher penalties — for failing to issue an e-invoice and for blocking data due to software errors.

Preparation checklist for 2027

  1. Ask your accounting and invoicing software provider when it will support the connection to the NRA and the structured format.
  2. Prepare your item list: a Combined Nomenclature code for every product and a UN/CEFACT code for every service.
  3. Add your bank account to all invoice templates.
  4. Check that your customers and suppliers have up-to-date details (UIC, VAT number, address).
  5. Document your process for credit notes and cancellations.
  6. If you are in the SAF-T groups, coordinate preparation for both projects — the data overlaps.
Costs: the Ministry of Finance estimates the system will cost €20 million to build and expects €350 million in additional revenue in 2028 from better control.

Are you ready for e-invoicing?

We check your software, item codes and processes and prepare you for 2028 with no surprises on input VAT.

Get in touch

Frequently asked questions

When does e-invoicing become mandatory in Bulgaria?

Under the draft amendments to the VAT Act — from 1 January 2028 for domestic supplies between registered businesses.

Will PDF invoices still be valid after 2028?

Not for supplies that require a structured e-invoice. Without one, the buyer loses the right to input VAT credit.

Are the VAT ledgers being abolished?

Yes. The purchase and sales ledgers are abolished, and the NRA provides a draft VAT return by the 2nd day of the following month.

Does the change affect invoices to EU companies?

No. Intra-Community supplies are out of scope. For them, the EU introduces e-invoices from 1 July 2030 under the ViDA package.

Sources

This article is general information, not legal advice. Current as of 2 November 2026.

📘 Free guide

10 legal ways to reduce your small company's tax bill — with concrete numbers and worked examples.

Download for free →

Have questions? We have answers.

A free 30-minute consultation, no commitment. We discuss your specific situation.

Book a consultation →