Draft legislation would introduce structured e-invoicing, real-time transaction reporting and pre-filled VAT returns from 1 January 2028.
Bulgaria has published draft legislation proposing mandatory structured e-invoicing, real-time transaction reporting and pre-filled VAT returns from 1 January 2028. If adopted, the reform would create a national e-invoicing and reporting system operated by Bulgaria’s National Revenue Agency.
The proposal was published by Bulgaria’s Ministry of Finance on 23 September 2026 as part of draft amendments to the country’s VAT Act. The consultation period is open until 23 October 2026, which means the details may still change before final legislation is adopted.
What is being proposed?
Under the draft legislation, Bulgaria would introduce a new national system for structured e-invoicing and real-time VAT reporting. The system would replace the existing VAT sales and purchase ledgers with transaction data reported through the new framework.
The reported data would then be used to prepare pre-filled VAT returns for each tax period. This would create a closer connection between the invoice created in the ERP, the structured data reported to the tax authority and the figures included in the VAT return.
This fits into a wider European shift where e-invoicing and VAT reporting are increasingly connected. We see similar developments across Europe, both through national mandates and through broader initiatives such as ViDA-related reporting pilots.
Who would be in scope?
According to the draft proposal, VAT-registered suppliers established in Bulgaria would be required to issue structured electronic invoices for specified domestic supplies and advance payments where the recipient is also established in Bulgaria.
The invoices covered by the mandate would need to comply with EN 16931, the European standard for electronic invoicing. This aligns Bulgaria with the broader European move towards structured invoice data. Recent standardisation developments, including the UBL 2.5 update, show how invoice formats and validation rules continue to evolve as mandates become more detailed.
Testing environment expected before go-live
The draft legislation also requires the National Revenue Agency to provide a testing environment at least six months before implementation. If the proposed 1 January 2028 start date remains unchanged, businesses should receive access to testing by July 2027.
This testing phase will be important for companies that need to connect ERP systems, billing processes and tax reporting flows to the new national system. As with other European mandates, readiness will depend on more than technical connectivity. Invoice data, tax logic, validation rules and exception handling all need to work together.
Why this matters for finance and tax teams
Bulgaria’s proposal shows that e-invoicing is becoming part of a broader digital tax control model. For businesses, compliance is no longer only about sending an invoice in the right format. It is about making sure structured invoice data can support reporting, reconciliation and VAT return preparation.
Finance and tax teams will need to review whether invoice data is complete, consistent and aligned with their reporting processes. ERP configuration, customer and supplier master data, tax codes, invoice validation and internal ownership all become part of readiness.
For companies operating across multiple countries, Bulgaria adds another mandate to monitor alongside reforms in countries such as France, Poland, Spain, Germany and Belgium. Our article on how companies can prepare for European e-invoicing mandates explains why businesses should approach these changes as part of a scalable compliance strategy rather than isolated country projects.
What companies should do now
The Bulgarian proposal is still in consultation, so companies should avoid treating the current draft as final law. However, businesses with Bulgarian entities should already start assessing potential impact.
- Confirm whether Bulgarian entities may fall within scope.
- Review current invoice issuance and VAT reporting processes.
- Assess whether ERP systems can produce EN 16931-compliant invoice data.
- Check the quality of customer, supplier and tax master data.
- Monitor the consultation outcome and future technical guidance.
- Prepare for system testing once the NRA environment becomes available.
Key takeaways
- Bulgaria has proposed mandatory structured e-invoicing and real-time VAT reporting from 1 January 2028.
- The proposal is part of draft amendments to the VAT Act and is under consultation until 23 October 2026.
- The system would be operated by Bulgaria’s National Revenue Agency.
- VAT sales and purchase ledgers would be replaced by transaction data reported through the new system.
- Pre-filled VAT returns would be prepared based on reported transaction data.
- Structured e-invoices would need to comply with EN 16931.
- A testing environment should be available at least six months before implementation.
Bulgaria’s proposal is another example of how e-invoicing and VAT reporting are becoming more closely connected across Europe. Businesses that prepare early can reduce compliance risk and build invoice processes that are ready for multiple country models.
Need to manage e-invoicing requirements across several countries? Explore Routty or visit our e-invoicing mandate overview.
