Ministry of Finance Proposes Mandatory Structured B2B E-Invoicing from 1 January 2028; Consultation Closes 23 October 2026
On 23 September 2026, the Bulgarian Ministry of Finance published for public consultation a draft Law amending the VAT Act (consultation no. 12733-K on the Council of Ministers’ strategy.bg portal). According to secondary reports of the draft, which we have not yet been able to read in the original, it would introduce mandatory structured B2B and B2G e-invoicing for domestic supplies from 1 January 2028, validated through a National Revenue Agency (NRA) system, together with pre-filled VAT returns and abolition of the VAT ledgers. The consultation closes on 23 October 2026.
Background
Bulgaria has so far had no domestic B2B e-invoicing mandate. Its recent digital-reporting step was the introduction of SAF-T from 1 January 2026. The new draft implements the VAT in the Digital Age (ViDA) package, Directive (EU) 2025/516, which allows Member States to impose domestic e-invoicing and digital reporting without a prior derogation. The draft is a legislative proposal in consultation, not law.
The Legislative Change
Per the consultation portal, the draft amends the Bulgarian VAT Act. Secondary reports describe a new section on structured e-invoicing (reported as roughly Articles 120a to 120d), under which a structured invoice is treated as issued and received once the national system generates a unique compliance code. This is a legislative proposal; only the headline facts are official-source confirmed (see above).
Scope
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Reported: VAT-registered suppliers established in Bulgaria must issue structured e-invoices for domestic supplies, including advance payments, to Bulgarian-established taxable persons, non-taxable legal persons and public bodies; non-registered suppliers would also be covered when supplying public bodies.
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Reported: invoices must follow the European standard EN 16931; a PDF sent by e-mail would not suffice. Invoices may be issued through the NRA system or through the taxpayer’s own ERP or invoicing software, which must transmit the data to the NRA.
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Reported exclusions include certain intra-Community and triangular supplies, supplies by non-established suppliers, and transactions documented by an extended fiscal-device receipt.
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Reported: recipient consent would no longer be required, but recipients need the technical ability to receive and process structured invoices; failures to validate would generally have to be corrected within 48 hours.
Timeline
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23 September 2026: draft published (official page).
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23 October 2026: consultation closes (official page).
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1 January 2027 (reported): main body of the amending law; the VAT registration threshold would rise from EUR 51,130 to EUR 75,000.
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1 January 2028 (reported): structured e-invoicing, abolition of purchase and sales ledgers, and NRA pre-filled VAT returns (draft by the 2nd day of the following month).
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1 July 2028 (reported): penalties for failing to issue a required e-invoice (reported minimum EUR 1,500 for legal entities and sole traders; EUR 750 for non-trader natural persons).
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Before go-live (reported): NRA to make testing available at least six months before the mandate.
Businesses Affected
All VAT-registered businesses established in Bulgaria that make domestic B2B or B2G supplies, and their customers, which must be able to receive and process structured invoices. Multinationals with Bulgarian entities running SAP will need to connect invoice issuing to the NRA validation system. Reported provisions would also deny input VAT deduction where a required structured e-invoice was not correctly issued, and would expose software providers to sanctions if technical faults block data transmission. These two points are reported only by one secondary source each and are particularly provisional.
Required Actions
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Obtain the official draft text from the consultation page and confirm the provisions above before relying on them.
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Decide whether to submit comments before 23 October 2026, directly or through a business association.
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Map Bulgarian domestic invoice flows, ERP/SAP output formats and customer receipt capability against EN 16931.
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Plan for the deduction-right consequences of invalid or missing structured invoices and for the loss of the VAT ledgers.
Practical Implications
If adopted as reported, Bulgaria would move to a clearance-style model with an NRA-issued compliance code, similar in effect to other CTC regimes, with a short correction window. Technical specifications, the NRA testing environment and secondary legislation are not yet published, so implementation detail cannot be planned yet. Companies already live with SAF-T (since 1 January 2026) should reuse their data-quality work.
Expected Next Steps
Close of consultation on 23 October 2026, publication of the results, Council of Ministers approval and submission to Parliament, followed by NRA technical specifications and a testing environment. Dates may change during the legislative process.
How Can KGT Support You?
KGT supports multinationals with SAP-integrated e-invoicing add-ons and SAP Document and Reporting Compliance (DRC) services, including readiness assessments for new mandates such as Bulgaria’s proposed regime. Contact KGT to assess your Bulgarian invoicing flows and plan your response to the consultation.
This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.
