E-Invoicing in Bulgaria (ViDA 2026) for Foreign-Owned Companies

If you own a Bulgarian EOOD and you trade across EU borders, the rules on how you invoice are changing — but not as fast or as broadly as the marketing copy from invoicing platforms suggests. The European Council adopted the VAT in the Digital Age (ViDA) package on 11 March 2025; it entered into force on 14 April 2025; and it phases in obligations from 1 July 2028 through 1 January 2035. The single date that matters most for a foreign-owned Bulgarian EOOD is 1 July 2030 — by then, every intra-EU B2B invoice must be issued as a structured EN 16931 electronic invoice within ten days of the chargeable event, and the supplier must submit Digital Reporting Requirements (DRR) data at the moment of issuance.

Bulgaria has not yet enacted a domestic B2B e-invoicing mandate. SAF-T started on 1 January 2026 but applies only to the largest enterprises in Phase 1. For most foreign-owned EOODs, the right answer in 2026 is not "buy the most expensive e-invoicing platform on the market today" — it is "operate compliantly today, pick an accounting partner with a credible 2030 roadmap, and watch the State Gazette for a Bulgarian B2B mandate that may or may not arrive before 2030." This guide walks the framework end to end.

Why This Matters Now

Three things changed in the last fifteen months that together reset the EU invoicing landscape for any Bulgarian company invoicing EU clients.

1. The ViDA package was adopted. On 11 March 2025 the EU Council adopted Council Directive (EU) 2025/516, Council Regulation (EU) 2025/517 and Council Implementing Regulation (EU) 2025/518. The texts were published in the Official Journal on 25 March 2025 and entered into force on 14 April 2025. ViDA amends the EU VAT Directive 2006/112/EC and the Regulation on VAT administrative cooperation. It is the largest structural change to EU VAT rules since the 2010 VAT package.
2. The legal barrier to national e-invoicing mandates fell. Before April 2025, a Member State that wanted to mandate domestic B2B e-invoicing needed a Council derogation under Articles 218 and 232 of the EU VAT Directive — that was how Italy moved first (mandate effective 1 January 2019), then France, Poland, Romania, Germany and others. Under ViDA, derogation is no longer required. Member States may impose domestic B2B e-invoicing on their established taxable persons by national act alone. This is why the pace of national mandates has accelerated in 2025 and 2026.
3. Bulgaria started SAF-T. Through the Transitional and Final Provisions of the 2025 State Budget Act, Bulgaria amended the Tax-Insurance Procedure Code (Данъчно-осигурителен процесуален кодекс / ДОПК) to introduce SAF-T, the OECD-aligned Standard Audit File for Tax format. The amendments were promulgated in State Gazette issue 26 of 27 March 2025; technical specifications were issued by NRA Executive Director Order of 25 July 2025; Phase 1 started 1 January 2026.

The combined effect for a Bulgarian EOOD with EU clients: the obligation set is shifting from "issue a compliant invoice" toward "issue a structured electronic invoice that the tax authority can read in real time." The Bulgarian implementation is gradual — but the EU cross-border deadline of 1 July 2030 is fixed in directive text, and our advice to clients is to plan toward it, not against it.

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The ViDA Package — Three Pillars

ViDA stands for VAT in the Digital Age. It is built around three pillars, each with its own effective date.

Pillar 1 — Digital Reporting Requirements and structured e-invoicing

From 1 July 2030, intra-EU B2B supplies of goods and services — and domestic supplies subject to mandatory reverse charge under Article 194 of the EU VAT Directive — must be invoiced in a structured electronic format compliant with EN 16931. The European standardisation body CEN published an updated EN 16931-1 on 13 February 2026 specifically extended for B2B and DRR use. A PDF will not qualify as an e-invoice for these transactions. The invoice must be issued within 10 days of the chargeable event, and the supplier submits transaction-level Digital Reporting Requirements data to its Member State at the moment of issuance; the customer transmits its corresponding data within five days of receipt. The recapitulative statement (the VIES return) is abolished from the same date — DRR replaces it.

Pillar 2 — Platform economy (deemed supplier)

From 1 July 2028, with a Member State option to postpone to 1 January 2030, platforms facilitating short-term accommodation rental (continuous rental of 30 nights or less — narrowed from the original 45-night proposal) and road passenger transport become deemed suppliers for VAT purposes. The platform charges and collects VAT on the underlying supply where the underlying supplier does not provide a VAT identification number. Member States may exclude underlying suppliers that provide a VAT number and may exclude SME-scheme suppliers. The pillar reshapes how Airbnb, Booking, Uber, Bolt and similar marketplaces invoice the underlying property owner or driver.

Pillar 3 — Single VAT Registration and expanded OSS

From 1 July 2028, the One-Stop Shop is expanded to cover transfer of own goods to another Member State (a new OSS module — relevant for SaaS owners and ecommerce sellers using OSS today; see our Bulgaria SaaS company VAT & OSS guide), broader B2C distance-sale categories, and an expanded mandatory reverse-charge mechanism under Article 194 — applied where the supplier is not established in the Member State of supply and the customer is VAT-identified there. The call-off stock simplification is closed: no new call-off stock arrangements may be entered into from 1 July 2028; pre-existing arrangements end no later than 30 June 2029. The aim is that a taxable person needs only one EU VAT registration in its Member State of establishment for almost every type of EU cross-border supply.

The ViDA Calendar — Dates That Matter

The 1 July 2030 date is the practical anchor. By then a Bulgarian EOOD's invoicing process needs to produce structured EN 16931 invoices and submit transaction-level data to the NRA on each cross-border B2B invoice. Just over four operating years remain to migrate.

What Bulgaria Has Done — and Has Not Done — in 2026

Three things are true today (June 2026) for a Bulgarian-domiciled company.

1. No domestic B2B e-invoicing mandate

Bulgaria has not enacted a domestic B2B e-invoicing mandate. Issuing a paper or PDF invoice with the requisites set in Articles 113 and 114 of the Bulgarian VAT Act (ЗДДС) remains valid. An electronic invoice still requires the recipient's acceptance under the current Bulgarian framework. The Ministry of Finance and the NRA have signalled interest in a clearance-model consultation, but no draft law, no NRA pilot order and no State Gazette entry has been published as of June 2026. Any platform pitch claiming "Bulgaria has mandated B2B e-invoicing" is wrong as a matter of statute.

2. B2G receipt is mandatory since 2019

Bulgarian contracting authorities must receive and process EN 16931-compliant electronic invoices from suppliers since 1 November 2019, transposing Directive 2014/55/EU on electronic invoicing in public procurement through the Public Procurement Act framework. That is a B2G (business-to-government) obligation, not a B2B mandate, and it is on the contracting authority's side — receive and process. A supplier may issue paper or PDF unless the procurement contract requires otherwise. For most foreign-owned EOODs this is irrelevant in day-to-day operations; only those bidding for Bulgarian public procurement contracts have skin in the game.

SAF-T Bulgaria thresholds explained

SAF-T (Standard Audit File for Tax) is an OECD-aligned, machine-readable tax data file that the largest Bulgarian enterprises must submit monthly to the National Revenue Agency from 1 January 2026. The Bulgarian rollout is phased across five steps over 2026 to 2030, with criteria assessed two years before each phase's start date — Phase 1 (1 January 2026) covers only enterprises that crossed BGN 300 million net sales or BGN 3.5 million NRA payments in 2023; Phase 5 (1 January 2030) brings every VAT-registered enterprise including micro-entities into scope. See our full Bulgaria SAF-T 2026 reporting guide for line-item filing detail. Phase 1 (1 January 2026) covers only enterprises that crossed the BGN 300 million net sales revenue threshold or the BGN 3.5 million taxes-and-social-security threshold for the 2023 financial year. With euro adoption from 1 January 2026 at the fixed rate 1 EUR = 1.95583 BGN, those legacy BGN figures convert to approximately EUR 153.4 million and EUR 1.79 million respectively. The next phases bring medium, small and ultimately micro-enterprises in over the following four years.

SAF-T is filed monthly by the 14th of the following month for general ledger, accounts receivable, accounts payable, sales and purchase invoices, and payments. Fixed-asset data is filed annually by 30 June of the following year. Inventory data is filed on NRA request. Files are submitted electronically through the NRA portal under a qualified electronic signature. The NRA has confirmed a 6-month no-penalty grace period for each phase's first submissions.

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What Applies to Your Bulgarian EOOD Today

Strip away the 2030 anchor for a moment. The rules a Bulgarian VAT-registered EOOD must follow today are these — and they sit inside the broader Bulgaria EOOD compliance calendar a foreign owner needs to run year-round.

Bulgaria invoice requirements 2026 — Article 114 in plain English

The Bulgarian VAT Act requires an invoice to be issued within 5 days of the chargeable event (or 5 days of receipt of an advance payment), with the requisites set in Article 114. In plain English a compliant Bulgarian invoice in 2026 must show:

• Supplier and customer identification — full legal name, registered address, UIC (Bulgarian unified company code) and Bulgarian or foreign VAT number where applicable.
• Invoice number and date — sequential and unbroken across the year.
• Description of the supply — nature, quantity, unit, period of performance.
• Taxable amount, VAT rate and VAT amount — in EUR from 1 January 2026.
• Reverse charge or exemption marker — explicit reference (e.g. "reverse charge — Article 196 of Directive 2006/112/EC") where Bulgarian VAT is not charged.
• Signature — not required where the invoice is issued electronically or auto-generated by the accounting system.

Article 115 governs corrective documents (credit and debit notes), also subject to the 5-day rule. None of these provisions has been amended for e-invoicing as of June 2026 — a paper or PDF invoice that meets Article 114 remains a valid Bulgarian VAT invoice.

VAT registration — 51,130 euro threshold

Bulgaria's mandatory VAT registration threshold is EUR 51,130 annual taxable turnover, effective 1 January 2026, measured on a calendar-year basis (the prior 12-rolling-month measurement was discontinued at the end of 2025) — see our full Bulgaria VAT registration 2026 guide for the practical filing detail. Registration must be filed within 7 days of crossing the threshold. Voluntary registration is available below the threshold and is common where the EOOD wants an EU VAT number from day one — for example, to operate Article 97a registration for intra-EU services or to display a VAT number on cross-border invoices to EU B2B clients. See our detailed piece on voluntary VAT registration in Bulgaria for the decision framework.

Article 97a — partial registration for intra-EU services

Independent of the turnover threshold, Article 97a of the Bulgarian VAT Act requires a partial VAT registration for any Bulgarian taxable person that supplies B2B services to EU business customers — or receives such services from EU suppliers — under the place-of-supply rules of Article 21(2). The 97a-registered person does not charge Bulgarian VAT on supplies, does not have input VAT credit, files monthly VAT and VIES returns, and applies reverse charge mechanically. This registration is the one most foreign-owned EOODs miss in their first year, and it is what drives the monthly compliance load until ViDA's DRR replaces VIES on 1 July 2030.

VIES recapitulative statement — through 30 June 2030

Monthly VIES declaration, filed by the 14th of the month following the reporting period, for any intra-EU supply of goods or B2B service taxable in another Member State — see our Bulgaria tax calendar 2026 for all monthly filing deadlines. From 1 January 2026 all values are reported in euro. The format and frequency are unchanged from 2025; the obligation continues without amendment until ViDA Pillar 1 takes effect on 1 July 2030.

What format and platform to use

For B2G invoicing to Bulgarian contracting authorities: EN 16931-compliant electronic invoice, typically Peppol BIS Billing 3.0 (UBL 2.1 XML) via a Peppol access point. For B2B invoicing: PDF or paper is still valid as a matter of Bulgarian statute; an EN 16931 e-invoice is permitted with the recipient's acceptance. The smart bet for a Bulgarian EOOD with EU clients today is to choose an accounting and invoicing platform that already supports EN 16931 / Peppol BIS Billing 3.0 outbound — even if you do not use that capability yet — so the 2030 migration is configuration rather than replacement.

Peppol in Bulgaria — what it is and who uses it

Peppol (Pan-European Public Procurement OnLine) is a Europe-wide interoperability network for structured business documents, governed by OpenPeppol AISBL in Brussels. The current invoicing standard on the network is Peppol BIS Billing 3.0 — a UBL 2.1 XML schema that is fully compliant with EN 16931 and acts as the de facto EU interoperability layer for cross-border structured invoicing. In Bulgaria, Peppol is used today primarily on the B2G side — Bulgarian contracting authorities receive supplier e-invoices through Peppol access points in line with the 2019 B2G receipt obligation. There is no Bulgarian B2B mandate to issue Peppol invoices in 2026, but the largest EU clients of Bulgarian EOODs increasingly request Peppol-compatible XML as a contractual default. If the EOOD's accounting platform can issue Peppol BIS Billing 3.0 today, the ViDA 2030 cross-border DRR migration is largely a configuration change.

Member State E-Invoicing — Where Bulgaria Sits

For context, here is the current snapshot of national B2B e-invoicing mandates across the largest EU economies.

The pattern is consistent: Member States with high VAT-gap exposure (Italy, Romania, Poland, Greece) have moved early and aggressively; Member States with lower VAT-gap exposure and a more constrained tax administration capacity (Bulgaria, Slovakia, Cyprus) have moved later. Bulgaria's structural position is closer to the second cluster. A domestic Bulgarian B2B mandate before 2030 is plausible — particularly given the parallel SAF-T rollout — but not certain, and any timing speculation is just that, speculation.

Preparing for 1 July 2030 — Without Overspending Today

Five practical steps that we run for foreign-owned EOODs on retained tax-and-accounting engagements.

1. Get today right first. Confirm that every invoice issued by the EOOD meets Articles 113 and 114 of the VAT Act — issued within 5 days, with all statutory requisites, correctly applying reverse charge where the EU client is VAT-identified. We audit the last 90 days of invoices on every new retainer; in our experience roughly half of new foreign-owned EOOD invoices have at least one requisite gap that survived prior accountants.
2. Complete Article 97a registration if you serve EU B2B clients. Independent of the EUR 51,130 turnover threshold. File monthly VAT and VIES returns from the first cross-border invoice. We see at least one foreign-owned EOOD per quarter that has skipped 97a registration for years and faces backdated correction.
3. Choose an accounting and invoicing platform with a 2030 roadmap. EN 16931 / Peppol BIS Billing 3.0 outbound capability is becoming a baseline feature in 2026. Reputable Bulgarian and EU platforms publish public roadmaps. Avoid platforms that show no roadmap commitment — these are precisely the platforms that will force a costly migration in late 2029 or early 2030.
4. Do not invest in SAF-T tooling until you are in scope. For an EOOD below the BGN 15m (≈ EUR 7.67m) net sales threshold and the BGN 1.5m (≈ EUR 767k) NRA payment threshold, you are out of scope through 1 January 2029 at the earliest. The cleanest path: keep accounting in a platform whose provider has committed publicly to delivering SAF-T export capability before the relevant phase. Most reputable Bulgarian providers have done so.
5. Watch the State Gazette and NRA orders weekly. A Bulgarian domestic B2B e-invoicing mandate will arrive as primary legislation through the State Budget Act's transitional provisions or as a standalone amendment to the VAT Act. The typical Member State lead time is 12 to 24 months between publication and binding effect. As soon as a draft is published, the timeline locks. We monitor for our retained clients and flag immediately.

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What This Costs — and What It Should Not Cost

The market for EU e-invoicing services in 2026 has a wide cost spread. Three reference points for a foreign-owned EOOD.

Baseline accounting and VAT compliance

For a single-contractor or small-team EOOD with EU clients and Article 97a registration, monthly accounting plus VAT and VIES filings sit in the EUR 1,500 to 3,500 annual range with reputable Bulgarian accounting partners — depending on transaction volume, multi-currency exposure, and the platform stack. This is the irreducible baseline; e-invoicing readiness should be included within it, not added on.

EN 16931 / Peppol BIS Billing 3.0 capability

Outbound Peppol BIS Billing 3.0 capability on a reputable accounting platform is typically included in the standard subscription tier — not an enterprise add-on. Where a provider quotes a separate "e-invoicing module" for an additional EUR 50 to 200 per month, that is a signal to compare alternatives before committing.

SAF-T export capability

For an enterprise crossing into SAF-T scope, the cost of the export module varies widely — from no additional cost on platforms whose providers prioritised SAF-T early to several thousand euros annually on legacy stacks requiring third-party connectors. Out of scope for most foreign-owned EOODs through 2028 at the earliest; planning matters, immediate spend rarely does.

Common Myths to Ignore

"Bulgaria has already mandated B2B e-invoicing."

False as a matter of statute. The Bulgarian VAT Act permits paper or PDF invoices with recipient acceptance for electronic ones. The B2G obligation since 2019 is a separate, narrower regime. SAF-T from 1 January 2026 is a tax data file, not an e-invoicing mandate.

"Bulgaria has a Peppol mandate from 2028."

No statute, no NRA order, no State Gazette entry to support this claim as of June 2026. Peppol is the most likely transport network if and when Bulgaria does mandate, given its EU prevalence — but there is no Bulgarian Peppol mandate.

"ViDA forces every B2B invoice to be structured XML from 2025."

False. ViDA's structured EN 16931 e-invoicing obligation applies to intra-EU B2B transactions and supplies subject to Article 194 reverse charge, and the effective date is 1 July 2030 — not 2025. Domestic B2B in Member States that have not enacted a national mandate remains permissibly on paper or PDF.

"SAF-T applies to my small EOOD from January 2026."

False. SAF-T Phase 1 applies only to enterprises that crossed BGN 300m net sales revenue or BGN 3.5m NRA payments for 2023 — i.e. only Bulgaria's largest taxpayers. Micro-enterprises enter scope only on 1 January 2030.

"I should buy the most expensive e-invoicing platform on the market now."

Almost always wrong. For a single-contractor or small-team EOOD, the right answer is a reputable accounting platform with EN 16931 / Peppol BIS Billing 3.0 capability built in and a credible SAF-T export roadmap. The premium e-invoicing platforms marketed at enterprise scale are sized for taxpayers with thousands of monthly invoices, not for foreign-owned EOODs with EU client portfolios in the dozens.

Frequently Asked Questions

Sources & Legal References

Primary EU instruments and Bulgarian statutes referenced in this article.

• Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age — the core ViDA directive.
• Council Regulation (EU) 2025/517 of 11 March 2025 amending Regulation (EU) No 904/2010 on VAT administrative cooperation — introduces the central VIES.
• Council Implementing Regulation (EU) 2025/518 of 11 March 2025 — implementing measures for ViDA.
• Council Directive 2006/112/EC — the EU VAT Directive (as amended).
• Directive 2014/55/EU on electronic invoicing in public procurement — basis of the B2G obligation in force in Bulgaria since 1 November 2019.
• European Commission — VAT in the Digital Age (ViDA) official guidance and adoption announcements.
• European Commission — eInvoicing in Bulgaria — country profile maintained by DG DIGIT.
• Закон за данък върху добавената стойност (ЗДДС) — Bulgarian VAT Act, Articles 96, 97a, 100, 113, 114, 115, 117.
• Tax-Insurance Procedure Code (Данъчно-осигурителен процесуален кодекс / ДОПК) — Transitional and Final Provisions of the 2025 State Budget Act introducing SAF-T, promulgated in State Gazette issue 26 of 27 March 2025.
• NRA Executive Director Order of 25 July 2025 — SAF-T technical specifications, schemas and validation rules.
• Peppol BIS Billing 3.0 specification — the EU interoperability standard for structured invoicing.

Disclaimer: This article provides general information on EU and Bulgarian electronic-invoicing obligations as of June 2026. It does not constitute individual legal or tax advice. ViDA effective dates and the Bulgarian SAF-T phased rollout are subject to amendment by the EU Council and the Bulgarian legislator respectively; the cross-border B2B mandate of 1 July 2030 is fixed in Directive (EU) 2025/516 as adopted. Any Bulgarian domestic B2B e-invoicing mandate referenced as "plausible" or "in consultation" is forward-looking and not enacted. For a specific case please consult counsel. Last reviewed: June 5, 2026.