Bulgaria: E-invoicing proposal for 2028

What is changing?

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 is part of draft amendments to the VAT Act. The consultation period is open until 23 October 2026, so details may still change before final legislation is adopted.

Why it matters

This is a reason to contact customers with Bulgarian entities and check whether they may be affected if the proposal moves forward.

The proposal connects invoice creation, structured invoice data, real-time reporting and VAT return preparation. For customers, readiness would therefore depend on more than invoice format alone. ERP configuration, tax logic, customer and supplier master data, validation rules and reporting processes all become relevant.

Start with these customer questions:

– Does the customer have VAT-registered entities established in Bulgaria?
– Which domestic supplies or advance payments could fall in scope?
– Can the ERP produce EN 16931-compliant invoice data?
– Are VAT codes, customer data and supplier data complete and consistent?
– How are invoice data and VAT reporting currently connected?
– Who monitors the consultation outcome and future technical guidance?

One detail to check carefully

This is still a proposal, not final law. Customers should avoid treating the current draft as confirmed legislation.

If the proposed 1 January 2028 start date remains unchanged, a testing environment should be available at least six months before implementation. That would make system testing an important milestone in 2027.

Talking point

“Bulgaria has proposed mandatory structured e-invoicing and real-time VAT reporting from 2028. Shall we check whether your Bulgarian entities could be affected and whether your invoice data, ERP setup and VAT reporting flows would be ready if the proposal is adopted?”

What should partners do next?

Contact customers with Bulgarian entities and arrange a short impact review with finance, tax and IT. Focus on entity scope, invoice issuance, ERP data, EN 16931 readiness, VAT reporting flows and the consultation outcome before making firm implementation assumptions.