Bulgaria SAF-T Reporting 2026: What EOOD Owners Need to Know

Bulgaria introduced mandatory SAF-T (Standard Audit File for Tax) reporting starting January 2026. If you own a Bulgarian EOOD, you have likely seen headlines about this new obligation. The good news: SAF-T is being rolled out in phases over four years, and typical small foreign-owned EOODs will not be affected until 2029 or 2030 at the earliest. This guide explains exactly what SAF-T is, who must comply and when, what data is required, and what you should do now to prepare.

SAF-T is part of Bulgaria's broader push to digitise tax administration and align with EU best practices. The National Revenue Agency (NRA) will use the standardised data to conduct more efficient audits, cross-reference transactions between businesses, and detect discrepancies automatically. For businesses, it means exporting accounting data in a specific XML format and submitting it electronically each month.

What Is SAF-T?

SAF-T stands for Standard Audit File for Tax. It is an international data standard originally developed by the Organisation for Economic Co-operation and Development (OECD) in 2005 and updated in subsequent versions. The standard defines a structured XML format for exporting financial and accounting data from a company's bookkeeping system so that tax authorities can review it electronically.

The concept is straightforward: instead of auditors manually reviewing paper ledgers or requesting ad-hoc data exports in various formats, every business subject to SAF-T exports its accounting data in one standardised XML file. The tax authority can then load, cross-reference, and analyse this data using automated tools.

What data does SAF-T contain?

• General ledger entries: every journal entry recorded during the reporting period, including account codes, dates, amounts, descriptions, and counterparty references.
• Accounts payable (AP): supplier invoices received, payments made, credit notes, and outstanding balances.
• Accounts receivable (AR): customer invoices issued, receipts collected, credit notes, and outstanding balances.
• Inventory/stock movements: goods received, dispatched, adjustments, and period-end balances (submitted monthly).
• Fixed asset register: acquisitions, disposals, depreciation, and carrying values (submitted annually with the CIT return).

Bulgaria's SAF-T schema is based on the OECD SAF-T standard but includes country-specific adaptations for Bulgarian accounting rules, the Bulgarian chart of accounts, and NRA reporting requirements.

The Phased Implementation Timeline

SAF-T is not being introduced all at once. Bulgaria adopted a four-phase rollout based on enterprise size and revenue thresholds. The reference data for determining which phase applies is based on financial statements and NRA payment records from prior years.

Does This Affect My Small EOOD?

Almost certainly not in 2026, 2027, or 2028. Here is why:

Bulgarian accounting law classifies enterprises into four categories based on their financial statements:

• Micro enterprises: total assets up to BGN 700,000, net sales up to BGN 1.4M, average employees up to 10.
• Small enterprises: total assets up to BGN 8M, net sales up to BGN 16M, average employees up to 50.
• Medium enterprises: total assets up to BGN 38M, net sales up to BGN 76M, average employees up to 250.
• Large enterprises: exceeding two of the medium thresholds.

A typical foreign-owned EOOD providing consulting, IT, marketing, or e-commerce services with annual revenue between EUR 30,000 and EUR 500,000 is a micro enterprise. Micro businesses are the last category to be brought into SAF-T under Phase 4, which begins in 2029 at the earliest and may extend into 2030.

Even within Phase 4, the NRA is expected to prioritise larger businesses first. A one-person consulting EOOD billing EUR 80,000 per year is about as far from the Phase 1 thresholds as possible.

What Data Must Be Reported?

When your SAF-T obligation begins, the following data categories must be included in each monthly submission:

Monthly submissions (due by the 14th of the following month)

• General ledger: all journal entries for the reporting month. Each entry must include the account code (mapped to the SAF-T taxonomy), transaction date, posting date, document reference, description, debit/credit amounts, and VAT information where applicable.
• Accounts payable: all supplier invoices received, payments made to suppliers, credit notes issued by suppliers, and period-end AP balances. Supplier identification (name, tax ID, address) must be included.
• Accounts receivable: all customer invoices issued, payments received from customers, credit notes issued to customers, and period-end AR balances. Customer identification data is required.
• Stock/inventory movements: goods received, goods dispatched, stock adjustments, and period-end inventory balances by item. Applies to businesses that hold physical inventory.

Annual submissions (with the CIT return)

• Fixed asset register: all fixed assets held by the company, including acquisition date, acquisition cost, depreciation method, accumulated depreciation, disposals during the year, and net book value at year-end.

For a service-based EOOD with no physical inventory, the stock/inventory section will typically be empty or minimal. The core reporting burden is the general ledger and AP/AR data, which your accounting software should already maintain.

How to Submit SAF-T Files

SAF-T files are submitted electronically through the NRA's electronic services portal. The process requires:

1. Qualified Electronic Signature (QES): the person submitting the file (typically the accountant or an authorised representative) must hold a valid Bulgarian QES issued by a licensed certification authority (e.g., B-Trust, Evrotrust, InfoNotary, StampIT).
2. XML file generation: your accounting software must export the data in the Bulgarian SAF-T XML schema. The file must validate against the NRA's published XSD (XML Schema Definition) before submission.
3. Upload and confirmation: the XML file is uploaded through the NRA portal. The system performs automated validation checks and returns a confirmation or error report.

Deadline: monthly SAF-T files must be submitted by the 14th of the month following the reporting period. For example, the SAF-T file for January must be submitted by 14 February. The annual fixed asset and stock data are submitted together with the annual CIT return (deadline: 30 June of the following year for most businesses).

The Grace Period

Bulgaria's SAF-T implementation includes a generous grace period designed to give businesses time to adapt:

• 6-month initial grace period: from the date your SAF-T obligation begins, you have 6 months during which no penalties will be imposed for failure to submit or for errors in submitted files. This means if your obligation starts on 1 January 2026 (Phase 1), you have until 30 June 2026 to begin submitting without penalty risk.
• 6-month correction period: after you begin submitting SAF-T files, you have an additional 6 months to correct any errors in previously submitted files without facing penalties. This gives you time to refine your data mapping, fix software issues, and ensure data quality.

In total, businesses have up to 12 months of penalty-free adjustment from the start of their obligation. This is a pragmatic approach that acknowledges the complexity of implementing a new reporting standard.

After the grace period expires, the NRA can impose penalties for late submission, non-submission, or submission of materially incorrect data. The specific penalty amounts are defined in the Tax and Social Insurance Procedure Code (DOPK) and can range from BGN 500 to BGN 5,000 per violation, with higher penalties for repeated non-compliance.

What You Should Do Now

Your action plan depends on the size of your business:

If you are a small or micro EOOD (most foreign owners)

1. Do not panic. SAF-T is not your problem in 2026, 2027, or 2028. Your obligation will likely begin in 2029 or 2030 under Phase 4.
2. Confirm with your accountant that the accounting software they use is being updated (or will be updated) to support Bulgarian SAF-T XML export. Most major Bulgarian accounting platforms (Microinvest, Aladdin, Ajur, and others) are already developing SAF-T modules.
3. Keep your books clean. SAF-T works best when your chart of accounts is well-structured, transactions are properly categorised, and there are no unexplained journal entries. Good bookkeeping practices now make SAF-T compliance easier later.
4. Budget for a potential minor fee increase. When SAF-T becomes mandatory for your business, your accountant may charge a small additional fee for the monthly SAF-T file preparation and submission. This is typically BGN 30-100 per month, depending on the complexity of your accounts.

If you are a larger business (Phase 1, 2, or 3)

1. Audit your accounting software immediately. Confirm it can generate SAF-T XML files compliant with the Bulgarian schema. If not, plan a migration or software upgrade.
2. Map your chart of accounts to the SAF-T taxonomy required by the NRA. This mapping exercise can take weeks for complex businesses with hundreds of accounts.
3. Run test exports during your grace period. Generate SAF-T XML files, validate them against the NRA's XSD schema, and identify data quality issues before the grace period ends.
4. Designate a responsible person with a valid QES who will handle the monthly submissions through the NRA portal.

SAF-T in the Context of EOOD Taxation

SAF-T is a reporting obligation, not a tax. Your EOOD's tax burden remains unchanged:

• Corporate income tax (CIT): 10% on taxable profits.
• Dividend withholding tax: 5% on distributed profits.
• Combined effective rate: 15% (10% CIT + 5% dividend tax). The two taxes are separate levies — corporate tax on profit, dividend tax on distribution — and the combined rate is always expressed as 15% (10% + 5%).
• VAT: 20% standard rate (mandatory registration if turnover exceeds BGN 166,000 in the preceding 12 months, or voluntary registration at any time).
• Social security contributions: approximately 32-33% total (employer + employee portions) on management remuneration, capped at BGN 3,750 per month.

SAF-T does not add a new tax layer. It adds a new data transmission requirement to the existing accounting and reporting obligations that your EOOD already fulfils through its monthly and annual NRA filings.

Frequently Asked Questions

Disclaimer: This article provides general information about Bulgaria's SAF-T reporting requirements and does not constitute tax or legal advice. SAF-T implementation details, thresholds, and timelines are subject to change by the National Revenue Agency (NRA) and Bulgarian legislation. The information reflects the regulatory framework as of April 2026. Consult a qualified Bulgarian accountant or tax adviser for guidance specific to your business. Last updated: April 14, 2026.