Electronic Invoicing in Bulgaria

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Electronic Invoicing, NISSEF, SAF-T in Bulgaria: we clarify all the concepts and explain what you need to know.
The strategy is divided into two main pillars: on the one hand, the progressive implementation of the SAF-T (Standard Audit File for Tax) file and, on the other, the development of a new national electronic invoicing system.
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The Bulgarian tax authority, the National Revenue Agency (NRA), has confirmed the adoption of SAF-T as part of its strategy to boost tax transparency, similar to other European countries. Companies, both local and foreign, must be aware of the changes that will come into force from 2026 to 2028. In this article, we explain everything you need to know about electronic invoicing in Bulgaria, the regulations, model, accepted formats, and how Brait can help you adapt your company to these changes.

How will the electronic invoicing system work? Meet NISSEF

The central axis of the new electronic invoicing model will be the NISSEF (National Information System for Structured Electronic Invoicing and Digital Reporting), a platform managed directly by the NRA.

This system will not be limited to being a simple exchange channel between client and supplier, but will allow the tax administration to receive and validate commercial transaction data in real time. The platform will work as follows:

• Flexible issuance: companies will be able to generate their structured invoices directly on the NISSEF portal or use their own billing software (ERP) integrated with the platform.
• Validation and unique code: if external software is used, the data must be transmitted to the NRA immediately. The system will perform a semantic validation and, if everything is correct, it will issue a unique compliance code.
• Error management: in case the system detects any discrepancy, it will return an error message and the issuer will have a period of 48 hours to correct it.
• Legal validity: the invoice will be considered officially issued and received at the moment the compliance code is generated, without the need for the recipient's prior consent. However, the supplier will still have the obligation to send the document to the customer electronically so they can process it.
• VAT automation: in the long term, the NRA's goal is to use all this structured information to offer automatic draft VAT returns.

It should be noted that the final technical specifications (schemas, APIs, and connection rules) will be published in an ordinance by the Ministry of Finance in the coming months.

Which companies and transactions are obligated?

The scope of the new structured electronic invoicing regulations will mainly affect:

• Local B2B and B2G transactions: suppliers established and registered for VAT purposes in Bulgaria that supply goods or provide services (including advance payments) to customers (companies or public entities) also established in the country.
• Non-VAT registered suppliers (B2G only): those companies established in Bulgaria but not registered for VAT purposes must also issue structured electronic invoices when their customer is a public sector entity. For the rest of their operations, they may continue using traditional formats.
• Voluntary invoices: if an established supplier issues an invoice voluntarily (or at the customer's request) for a local transaction, this must also comply with the structured format.

Exceptions: Which transactions are out of scope?

The most important thing to remember, and according to the current draft, for electronic invoicing (NISSEF) to be mandatory, the company must meet two requirements: be registered for VAT purposes and be established in Bulgaria (have a permanent establishment/branch). If a multinational only has a Bulgarian VAT number but is not physically established there, it is excluded from the obligation to issue electronic invoices.

‍In addition, the regulations contemplate certain transactions that will not require the issuance of a structured electronic invoice through NISSEF:

• Non-established companies (as referred to above): suppliers that are registered for VAT purposes in Bulgaria, but do not have a permanent establishment in the country, are excluded from this obligation.
• Intra-Community transactions: intra-Community supplies, triangular transactions, and their respective advance payments do not fall within the scope of the rule.
• Sales with an extended receipt: those transactions that are recorded through a fiscal device or sales management system at the point of sale (such as gas stations), where an extended fiscal receipt is issued, will also not require an additional electronic invoice.

Calendar for the adoption of Electronic Invoicing in Bulgaria

It is essential not to confuse the electronic invoicing project with the implementation of SAF-T, which is advancing in parallel but with already confirmed and effective deadlines.

While the technical details of electronic invoicing are still pending regulatory development, accounting and tax reporting through SAF-T will be a reality starting January 1, 2026.

The adoption of this standardized format will be carried out in stages:

• January 2026: large taxpayers (companies with a turnover exceeding 300 million BGN in 2023 or that have paid taxes exceeding 3.5 million BGN).
• January 2027: companies with a turnover exceeding 300 million BGN in 2024 or taxes exceeding 3.5 million BGN.
• January 2028: companies with a turnover exceeding 15 million BGN in 2025 or taxes exceeding 1.5 million BGN.
• January 2029: obligation extended to all companies, regardless of their turnover volume.

The NRA has already enabled a specific electronic service and published the structure and procedures for submitting these files.

We help you prepare for Electronic Invoicing in Bulgaria

For multinational companies with a permanent establishment in Bulgaria, it is vital to start adapting their ERP systems to these new requirements mandatory electronic invoicing. Managing electronic invoicing and SAF-T reporting in isolation can generate inefficiencies and compliance risks (it should be remembered that, if your company only has a Bulgarian VAT registration but is not established in the country, it will be exempt from the electronic invoicing obligation, although it must monitor its reporting obligations).

With our SAP connector, Invictia, you will be able to invoice globally whether in Spain, Germany, France, Italy,Poland, Belgium or any other country.