Bulgaria has published a draft law to introduce SAF-T files by 2025

The Bulgarian government has announced a new draft law to modernise the nation's tax administration through the utilisation of the SAF-T (Standard Audit File for Tax), with the objective of facilitating communication between taxpayers and tax authorities.

The initial version of the Bulgarian SAF-T XSD scheme is currently available, with its implementation scheduled for 2025. The initial phase will be voluntary, with a duration of six months.

Implementation plan of SAF-T files in Bulgaria

As of 2026, large companies with annual net revenues in excess of BGN 300 million (153 million €) or tax and social security debts surpassing BGN 3.5 million (1.8 million €) will be obligated to report.

In 2027, the obligation will be extended to medium and small enterprises with the same characteristics; and in 2028, large, medium and small enterprises with revenues exceeding BGN 15 million (€ 7.7 million) or annual tax and social security liabilities exceeding BGN 1.5 million (€ 0.8 million) will be obliged.

From 2029, the obligation will extend to all other large, medium and small businesses, and from 2030, the obligation will extend to all VAT-registered businesses.

Which information will be presented with SAF-T?

The SAF-T reports contain business information that will include:

• This includes taxpayer identification data, as well as data on related parties and beneficial owners.
• Sales and purchase invoices.
• A comprehensive record of all financial transactions, including receipts.
• In addition, all assets, inventories and transactions affecting them are to be included.

Is e-invoicing possible in Bulgaria?

In the context of Bulgaria, the implementation of electronic invoicing (e-invoicing) is currently mandatory solely for public administrations. Since 18th October 2018, the Public Procurement Act (PPA), as amended by the Law Amending and Supplementing the Public Procurement Act (LASPPA), has served as the governing legislation for the regulation of e-invoicing in Bulgaria, in accordance with European regulatory frameworks.

As part of this obligation, public administrations are obliged to accept and process electronic invoices for public contracts. However, a uniform platform for the exchange of all B2G e-invoices has not yet been established.

Since January 2018, the submission of sales and purchase records (and VAT returns) has been mandatory in an electronic format. The obligation to submit sales and purchase records extends to all individuals and entities liable for VAT registration in Bulgaria, encompassing both domestic and non-resident businesses.

In the private sector, electronic invoicing is optional for all taxpayers, provided that the recipient accepts it in writing (formal or informal procedure) or by tacit acceptance (by processing or paying the invoices). Furthermore, the authenticity, origin and integrity of invoices must be guaranteed by methods such as electronic signatures or EDI, although no mandatory system exists.

Bulgaria is currently at a pivotal juncture in the modernisation of its e-invoicing system. Following European models such as Italy and France, the government is seeking to implement a pre-validation (clearance) model, where invoices are valid only after approval by the tax authority. This approach has the potential to accelerate the massification of electronic invoicing.

The overarching objective of these initiatives is to enhance the efficiency and transparency of tax management and e-invoicing, thereby establishing itself as a regional exemplar.