Bulgaria

Bulgaria does not currently require businesses to issue structured e-invoices, either B2B or to the public sector. Under the Public Procurement Act, public bodies have had to receive and process EN 16931 e-invoices since 1 November 2019, but suppliers can still choose how they invoice.

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At a glance

B2B

Not mandated

B2G

Partially mandatory (public bodies must receive e-invoices; suppliers are not generally required to issue them)

Infrastructure

EN 16931 for public procurement; NRA SAF-T reporting

Next deadline

None announced for e-invoicing

Key e-invoicing deadlines

1 November 2019
Completed

Public bodies must receive EN 16931 e-invoices

Article 115a of the Public Procurement Act, transposing EU Directive 2014/55/EU, requires public sector entities to receive and process structured e-invoices compliant with EN 16931. It creates an obligation on buyers rather than a general duty for suppliers to issue them.

1 January 2026
Completed

SAF-T reporting begins for the largest taxpayers

Phased mandatory SAF-T reporting to the National Revenue Agency (NRA) started with the largest taxpayers. This is a tax reporting obligation based on accounting data, not a mandate for structured e-invoice exchange, and it widens in phases.

1 January 2030
Upcoming

SAF-T reporting extends to all VAT-registered businesses

The phased SAF-T calendar runs to 2030, when all VAT-registered businesses are expected to be covered. Timing for smaller taxpayers depends on the NRA's phase schedule, so businesses should monitor official guidance.

Overview

Bulgaria does not currently require businesses to issue structured e-invoices, either B2B or to the public sector. Under the Public Procurement Act, public bodies have had to receive and process EN 16931 e-invoices since 1 November 2019, but suppliers can still choose how they invoice. The main digital tax development is SAF-T.

The National Revenue Agency has introduced phased mandatory SAF-T reporting from 1 January 2026, beginning with the largest taxpayers and extending towards all VAT-registered businesses by 2030. The NRA has also consulted on a clearance model for e-invoicing, following examples such as Italy and France. No date has been enacted. Businesses should avoid confusing SAF-T reporting with a mandate to exchange structured e-invoices.

Who must comply

For B2G, public sector entities must be able to receive EN 16931 e-invoices, while suppliers are not generally required to issue them. A supplier who chooses to send e-invoices can use the structured route to public buyers. For B2B, e-invoicing is voluntary and typically relies on agreement between the parties.

SAF-T reporting is different. It applies to businesses in phases, with the largest taxpayers first. Companies should check which phase applies to them based on turnover and tax paid, and should not assume that SAF-T replaces invoicing rules.

Requirements

There is no general legal duty to issue an e-invoice in Bulgaria. If a supplier chooses to send structured e-invoices to public bodies, they should follow EN 16931, in UBL 2.1 or UN/CEFACT CII syntax. Bulgaria does not apply a national CIUS or extension. For tax compliance, businesses within the SAF-T phases must file SAF-T XML files in the format prescribed by the NRA, and the first filings for January 2026 fell due in early March 2026.

A grace period has been reported for each phase. Ordinary invoices, including PDFs, remain legally acceptable for B2B. Businesses should ensure their ERP can export accurate SAF-T data and can produce EN 16931 invoices on request.

Formats and infrastructure

For public procurement, Bulgaria has adopted the European standard EN 16931, using UBL 2.1 or UN/CEFACT CII. The National Electronic Billing System (NEFS) is referenced as the national system for electronic invoicing, and a public consultation has looked at a possible clearance model. SAF-T is separate and is filed to the NRA in XML according to the NRA's specification.

Peppol is not a mandatory national channel, although suppliers can use certified providers or Peppol for cross-border exchange. Retail businesses also face separate fiscalisation obligations using certified devices, which are unrelated to e-invoice exchange. Businesses should treat B2G e-invoicing, SAF-T reporting and retail fiscalisation as three distinct workstreams.

How HubBroker can help

For Bulgaria, the practical priority is clean data. HubBroker's ERP integration and data transformation capabilities can help extract accounting and invoice data and reshape it into formats suited to SAF-T workflows, with the exact route confirmed during scoping.

We do not claim a direct NRA connection. If you invoice Bulgarian public bodies or customers who prefer structured invoices, we can generate EN 16931 UBL invoices from your ERP data. Intelligent Document Processing can turn inbound PDF supplier invoices into structured data, and the same platform serves your other European markets.

Frequently asked questions

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No. B2B e-invoicing is voluntary. A clearance model has been consulted on, but no mandate or date has been enacted.

Partly. Public bodies must receive EN 16931 e-invoices under the Public Procurement Act. Suppliers are not generally required to issue e-invoices.

SAF-T is phased tax reporting of accounting data to the NRA, starting with the largest taxpayers from 1 January 2026. It is not a structured e-invoice exchange requirement.

No. HubBroker connects your existing ERP, helps transform data for reporting workflows and can produce EN 16931 invoices where customers request them.