Bulgaria e-invoicing: mandatory e-invoices and real-time reporting proposed from 1 January 2028

Sofia, 28 September 2026. On 23 September 2026 the Bulgarian Ministry of Finance put a draft amendment to the VAT Act (ZDDS) out for public consultation that would make Bulgaria e-invoicing mandatory for domestic B2B and B2G supplies from 1 January 2028. Every invoice would pass in real time through the information system of the National Revenue Agency (NRA). The stakes for buyers are high: where the supplier was obliged to issue a valid structured e-invoice and did not, the buyer loses the right to deduct input VAT. The consultation runs until 23 October 2026. The Council of Ministers and the National Assembly follow, so the text may still change.

What the proposal for mandatory e-invoicing in Bulgaria from 2028 covers

Under the draft law, a supplier that is VAT-registered and established in Bulgaria must issue a structured e-invoice for supplies with a Bulgarian place of supply, including advance payments received. This applies when the buyer is also established in Bulgaria and is a taxable person, a non-taxable legal entity or a public authority. An established supplier without a VAT registration only has to e-invoice supplies to public authorities.

Outside the obligation:

• intra-Community supplies and supplies by the intermediary in an ABC triangular transaction;
• suppliers that are VAT-registered in Bulgaria but not established there; they keep issuing ordinary invoices;
• sales documented with an extended fiscal or system receipt;
• sales to consumers.

The e-invoice must comply with the European standard on e-invoicing (EN 16931) and the list of syntaxes under Directive 2014/55/EU, allowing automated processing. On top of the usual invoice requirements, the proposal requires a Combined Nomenclature goods code or a UN/CEFACT service code per line, plus the supplier’s bank account numbers. Buyer consent is not required, but the buyer must be able to receive and process e-invoices reliably by electronic means. The proposal does not name a specific network such as Peppol. Technical requirements will follow in a ministerial ordinance, due within six months of the law’s publication.

NRA real-time reporting and the unique compliance code

Businesses can create an e-invoice directly in the national NRA system or use their own software or ERP, which transmits the data immediately and in real time to the NRA. The system validates the invoice semantically and, if it passes, 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.

The proposal also contains these elements:

• VAT deduction and the e-invoice: holding a valid structured e-invoice becomes a substantive condition for deduction.
• Pre-filled return: the NRA makes a draft VAT return available no later than the 2nd day of the month after the tax period; the current sales and purchase ledgers are abolished from 1 January 2028.
• Penalties: from 1 July 2028, a fine equal to the uncharged VAT, with a minimum of EUR 750 for natural persons and EUR 1,500 for legal entities.
• Test environment: the NRA provides access for integration testing six months before the start.
• Registration threshold: the VAT threshold rises from EUR 51,130 to EUR 75,000 on 1 January 2027.

Context: Bulgaria e-invoicing and the CTC trend in Eastern Europe

Bulgaria follows other Member States with a continuous transaction controls (CTC) model. 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 a separate EU authorisation, with EN 16931 as 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 it means and what to do now

For any business invoicing a customer in Bulgaria, the impact depends on one question: are you established in Bulgaria, for example through a subsidiary or a fixed establishment? If so, you fall under the obligation, and without a valid e-invoice your Bulgarian customer loses the right to deduct VAT from 2028. If you only hold a Bulgarian VAT registration without an establishment, the proposal exempts you. Bear in mind that Bulgarian buyers will build their processes around e-invoices and are likely to ask for them.

What you need in place before 1 January 2028:

1. Determine whether your organisation is established in Bulgaria and which supplies and advance payments fall under the obligation.
2. Add Combined Nomenclature or UN/CEFACT codes per item or service to your master data and check the bank details on your invoices.
3. Choose your route: create invoices in the NRA system or build a real-time link from your ERP, possibly through a Peppol Service Provider or e-invoicing vendor with Bulgarian support. Ask vendors for their roadmap.
4. Set up a process to remedy discrepancies within 48 hours and to cancel incorrect documents before the 5th day of the following period.
5. If you purchase through a Bulgarian establishment, make sure you can receive e-invoices and check the unique compliance code before deducting VAT.
6. Plan integration tests as soon as the test environment opens, six months before 1 January 2028.
7. Follow the consultation until 23 October 2026 and the technical ordinance of the Minister of Finance.

If you need to combine Bulgaria e-invoicing with obligations in other countries, Peppol.now lets you independently compare Peppol Service Providers and e-invoicing solutions that support multiple country mandates.

Sources

1. Public Consultation Portal (strategy.bg): Draft Law amending and supplementing the VAT Act, consultation 12733-K, 23 September to 23 October 2026
2. Bulgarian Ministry of Finance: draft amendment to the VAT Act (ZDDS), PDF
3. RTC Suite: Bulgaria e-invoicing and e-reporting proposal for 2028
4. VATupdate: Bulgaria proposes mandatory domestic e-invoicing from 2028 (26 September 2026)
5. Data Plus: Mandatory electronic invoicing from 2028 (in Bulgarian)