Bulgaria’s Ministry of Finance has published a draft amendment to the Value Added Tax (VAT) Act that would introduce mandatory structured e-invoicing for domestic business-to-business (B2B) and business-to-government (B2G) supplies and foresee pre-filled VAT returns. The bill is open for public consultation until 23 October 2026 and is not yet law.
Proposed e-invoicing model
Under the proposed rules, suppliers may issue invoices through the National Information System for Structured Electronic Invoicing and Digital Reporting (NISSEF), operated by the National Revenue Agency, or through third-party software that transmits invoice data to NISSEF in real time. An electronic invoice exists legally only when NISSEF generates a unique compliance code. Suppliers must still send the structured invoices to recipients electronically, and recipients must ensure it can reliably receive and process them. Invoices must conform to EN 16931 and the syntax list under Directive 2014/55/EU.
The obligation applies to VAT-registered suppliers established in Bulgaria for domestic supplies where the recipient is established in Bulgaria and is a taxable person, non-taxable legal person, or state or local authority. Non-VAT registered, but established in Bulgaria suppliers are in scope only when making B2G supplies.
Out of scope are VAT-registered suppliers not established in Bulgaria and intra-community supplies.
Pre-filled VAT returns
Further, the draft expands on pre-filled VAT returns obligation. Using data from structured e-invoices and customs declarations, NRA’s new national platform will automatically populate the returns. Taxpayers will have the option to review, correct, or add to the draft any time before the filing deadline. NRA will make each period’s draft available electronically by the 2nd of the following month.
Timelines foreseen by the draft
The obligations are proposed to take effect 1 January 2028. The National Revenue Agency must provide access for testing data submission to NISSEF for six months before that date. A ministerial regulation, setting the technical requirements, is expected within six months of the law’s enactment.
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