Tracker · last checked 21 October 2026
E-invoicing from 2028: where the draft law stands.
Bulgaria’s Ministry of Finance proposes making structured e-invoices mandatory from 1 January 2028 for VAT-registered businesses established in the country, on supplies in Bulgaria to customers established there. For a group with a Bulgarian subsidiary, the subsidiary’s invoices to Bulgarian customers would pass through the National Revenue Agency’s system and count as issued only once that system assigns a unique code. It is still a draft, published for public consultation from 23 September to 23 October 2026. This page tracks the stage, the dates and what is still open, with a link to every official document.
Compiled by Radko Diev, Sofpact, from the draft law, its motives and the European Commission’s pages. Not tax or legal advice.
A draft, in public consultation
- Stage
- Public consultationOn strategy.bg until 23 October 2026; 11 comments so far
- Next
- Council of Ministers, then ParliamentNo date announced yet
- Start
- 1 January 2028For structured e-invoices, as drafted
Checked against the official sources about once a month; the date at the top is the last check.
Dates
From the draft to the first mandatory invoice.
Dates set in the draft itself are given exactly. The rest run from the day the law is promulgated in the State Gazette.
-
23 Sep 2026Done
Draft published
The Ministry of Finance opened public consultation 12733 on strategy.bg.
-
23 Oct 2026Next
Consultation closes
The last day for comments. The proposals received are then summarised in a report.
-
No date yetAwaited
Government, then Parliament
The Council of Ministers approves the bill and sends it to the National Assembly, which passes it in two votes.
-
No date yetAwaited
Promulgation in the State Gazette
The day the final text becomes law. The deadlines below that depend on it start here.
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1 Jan 2027As drafted
The law takes effect
Most of the bill’s VAT changes take effect on this date. The rules on structured e-invoices take effect later.
-
Within 6 months of promulgationAwaited
Technical ordinance
The Minister of Finance sets how structured invoices are issued, sent, verified, received and stored (§ 104 of the draft).
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Six months; start date unclearAwaited
Testing with the agency
The National Revenue Agency opens six months of testing for the connection to its system (§ 103). The draft’s reference for when that period starts points to a provision that does not exist, so the exact date is still open.
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1 Jan 2028As drafted
Structured e-invoices become mandatory
For supplies in Bulgaria by VAT-registered businesses established in Bulgaria to customers established there: businesses, other legal persons and public bodies (§ 105; new Art. 113(16) of the VAT Act).
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1 Jul 2028As drafted
The penalty provision takes effect
The new Art. 182a, on not issuing a structured e-invoice, takes effect on this date (§ 105, point 2).
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1 Jul 2030EU law
EU digital reporting
Under the EU’s VAT in the Digital Age package, supplies between businesses in different Member States move to digital reporting based on e-invoices.
What the draft says
Ten questions, answered from the text.
Article numbers refer to the VAT Act as the draft would amend it.
| Question | What the draft provides | Provision |
|---|---|---|
| Who issues | A VAT-registered business established in Bulgaria, for supplies whose place of supply is in Bulgaria, advance payments included. | Art. 113(16) |
| To whom | A customer established in Bulgaria: a taxable person, a legal person that is not a taxable person, the state, or a state or local body. Also when an invoice is not required but is issued at the supplier’s or the customer’s wish, to a customer established in Bulgaria. | Art. 113(16) and (19); motives |
| Not established in Bulgaria | Only businesses established in Bulgaria are covered, as supplier and as customer. A business registered for VAT in Bulgaria but not established here keeps issuing invoices that are not structured. | Art. 113(16) and (18); motives |
| Not VAT-registered, as supplier | A structured invoice is required only for supplies to the state or to a state or local body. Otherwise paper or other electronic invoices may continue. | Art. 113(17); motives |
| The customer’s side | The customer’s consent is not needed. The supplier sends the invoice electronically, and the customer must be able to receive and process it, on technical specifications the two agree. | New chapter 11a |
| What counts as structured | Issued, sent and received electronically in a format that follows the European e-invoicing standard and allows automated processing, with a unique compliance code from the agency’s system. | Art. 120a(1) |
| When it is issued | When the agency’s system generates the unique compliance code. | Art. 120a(3) |
| New mandatory details | A code for every product under the EU Combined Nomenclature or for every service under the UN/CEFACT classification (or another code set by the ordinance), and the supplier’s bank accounts where payment is received or expected. | Art. 120a(2) |
| Which software | The agency’s national system, or other software that sends the data to it. | Art. 112(5); new chapter 11a |
| Exceptions | Intra-EU supplies, supplies as the intermediary in a triangular transaction, and advance payments for them: the invoice need not be structured. An invoice issued at the till as an extended fiscal or system receipt: the rule does not apply. | Art. 113(16); Art. 118(24) |
The draft also ties the input VAT deduction to the structured invoice where the supplier was obliged to issue one (Art. 70(7)). What follows from that and the other changes for your returns and deadlines is a question for your accountant.
What changes in the work
Four changes for the people who handle invoices.
The draft amends a tax law, yet much of what it changes lands on the teams that issue, receive and check invoices. The rules behind these four are in the draft’s new chapter 11a.
Issuing goes through the agency
A structured invoice would count as issued only once the agency’s system returns its compliance code. Invoicing would depend on a working connection to that system, from your own software or in the agency’s system itself.
Rejections with a deadline
If the automatic check finds that an invoice sent from your own software does not meet the requirements, the system returns a notice, and the draft gives 48 hours to put it right. Someone has to see the notice and act on it the same day or the next.
Received once the code is generated
A structured invoice would count as received when the system generates its code, whether or not anyone has opened it. The customer would have to be able to receive and process it electronically.
Checking remains
Retyping can end for invoices from suppliers in scope, once your software imports them; those from abroad or from unregistered suppliers may still arrive as PDF or paper. Matching each invoice to the order, the delivery and the agreed price, and resolving the differences, remains. That is the work worth automating first.
What to prepare
Four things to do now, before the text is final.
In 2023, 15.8% of Bulgarian businesses with ten or more staff sent e-invoices fit for automated processing, against 38.7% across the EU, and 75.6% sent paper invoices (Eurostat; excludes agriculture, mining and the financial sector).
- 01
Count the invoices
How many you issue and receive a month, which systems produce them, and which are still typed by hand in Word or Excel.
- 02
Check the codes
Under the draft, every structured invoice would carry a product code under the Combined Nomenclature or a service code under UN/CEFACT, and the supplier’s bank accounts. See whether your item lists hold the codes and whether your invoices show the accounts you are paid into.
- 03
Ask your software provider
When your invoicing or accounting software will issue the structured format and connect to the agency’s system, and what the change will need from you.
- 04
Name the owners
Who sees a rejection notice and puts the invoice right within 48 hours, who resolves a price or quantity difference, and who watches incoming invoices, since they would count as received once the compliance code is generated.
What this page cannot tell you
A record of the draft, not advice.
It is a draft: the text may change, or the law may not be adopted. Still open: the technical format (the ordinance is not yet published), when testing starts, and whether the dates survive Parliament. This page reports what the documents say and what follows for your processes. It is not tax or legal advice; for input VAT, reporting and deadlines in your case, ask your accountant.
Sofpact sells no invoicing software and takes no commission from any vendor. Once the law is promulgated, this page will be updated to the final text; the date at the top shows when it was last checked.
FAQ
Questions people ask.
What is a structured e-invoice?
An invoice in a machine-readable format under the European standard, which the customer’s software can process without anyone retyping it. Under the draft it would also receive a unique code from the National Revenue Agency’s system, and only then count as issued.
We have a Bulgarian subsidiary: what changes?
If it is registered for VAT and established in Bulgaria, as drafted its invoices to customers established in Bulgaria would have to be structured and pass through the agency’s system from 1 January 2028, and it must be able to receive structured invoices from its Bulgarian suppliers. Invoices between it and group companies abroad stay outside this rule; EU digital reporting for supplies between businesses in different Member States starts on 1 July 2030.
Is a PDF invoice sent by email structured?
No. A PDF is an electronic invoice but not a structured one: under the draft, a structured invoice must also follow the European format and carry the agency’s compliance code. PDF invoices remain possible where a structured one is not required.
When does it become mandatory?
As drafted, from 1 January 2028, for supplies in Bulgaria by VAT-registered businesses established in Bulgaria to customers established in Bulgaria: businesses, other legal persons and public bodies. The law has not been passed, so the date may change.
Does it affect businesses not registered for VAT?
As issuers, only when they supply the state or a state or local body; otherwise, according to the draft’s motives, they may carry on with paper or other electronic invoices. As customers, they can be affected: Art. 113(16) requires the supplier to be VAT-registered but describes the customer only as a taxable person, and the draft obliges a customer to be able to receive and process structured invoices electronically.
Can invoices be issued directly in the agency’s system?
Under the draft, yes: the system would let businesses compose structured invoices, as well as receive the data from other software. The conditions are left to the technical ordinance.
When will the final text be known?
When the law is promulgated in the State Gazette. This page will then be updated to the final text.
Sources, checked on 21 October 2026
- Public consultation portal: draft law amending the VAT Act, consultation 12733 Stage, deadline and comments (in Bulgarian)
- Draft act, version 1.0 (PDF) §§ 6, 33, 34, 40, 42, 85 and 103 to 105 (in Bulgarian)
- Motives to the draft, version 1.0 (PDF) Scope, businesses not registered for VAT, the national system (in Bulgarian)
- European Commission: VAT in the Digital Age (ViDA) EU dates; Directive (EU) 2025/516
- Eurostat: integration with customers and suppliers, dataset isoc_eb_ics E-invoice and paper-invoice shares, 2023
Written with AI assistance. Facts link to the primary sources named above; Radko Diev decides what is published.
Further reading AI for office documents: which document to start with
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