Bulgaria officially launched its SAF-T reporting regime on January 1, 2026, joining a growing list of European nations adopting the OECD Standard Audit File for Taxation. The National Revenue Agency (NRA) now requires large enterprises, approximately 460 companies with 2023 net sales revenue above BGN 300 million or tax and social security contributions exceeding BGN 3.5 million, to submit monthly SAF-T XML filings through the NRA’s e-portal. This represents the first phase of a five-phase rollout that will eventually encompass all Bulgarian VAT-registered taxpayers by January 2030.
First deadline: The first SAF-T filing for January 2026 data was due by February 14, 2026. Companies in scope should verify their submissions have been accepted by the NRA portal.
Phased Rollout Timeline
Bulgaria is following a five-phase approach to SAF-T implementation, as set out in Art. 71к of the Tax and Social Insurance Procedure Code (ДОПК), giving businesses progressively more time to adapt based on their size:
Phase 1: January 2026 - Large Enterprises
Approximately 460 large companies are in scope for the first phase. These are enterprises with 2023 net sales revenue exceeding BGN 300 million or tax and social security contributions above BGN 3.5 million. These businesses must submit monthly SAF-T filings starting with the January 2026 reporting period.
Phase 2: January 2027 - Extended Large Enterprise Scope
The second phase extends the obligation to enterprises with 2024 net sales revenue exceeding BGN 300 million or tax and social security contributions above BGN 3.5 million. This captures additional large businesses whose qualifying figures are assessed based on the year two years prior to the reporting year.
Phase 3: January 2028 - Mid-Sized Enterprises
The third phase extends the obligation to enterprises with 2025 net sales revenue exceeding BGN 15 million or tax and social security contributions above BGN 1.5 million. These businesses will have had two years to observe how large enterprises handle the requirements, adopt suitable software, and prepare their data infrastructure.
Phase 4: January 2029 - All Large, Medium, and Small Enterprises
The fourth phase brings all large, medium, and small enterprises into scope, regardless of specific revenue thresholds. Only micro-enterprises remain excluded at this stage.
Phase 5: January 2030 - Micro Enterprises
By 2030, all Bulgarian VAT-registered enterprises will need to file SAF-T reports, including micro-enterprises as defined under Article 2 of the Accounting Act. Smaller businesses that currently rely on simpler accounting tools will need to upgrade their systems before this deadline.
Tip for mid-sized companies: Even though Phase 3 does not begin until 2028, starting your SAF-T readiness assessment now gives you time to evaluate your accounting software capabilities, ensure your data fields align, and run test submissions.
Technical Requirements
Bulgaria’s SAF-T implementation follows the OECD SAF-T schema with country-specific adaptations. The NRA published comprehensive technical documentation on July 25, 2025, covering XML format specifications, validation rules, and required nomenclatures (code lists). The NRA subsequently updated the schema to version 1.0.2, effective April 1, 2026, with revised technical files and validation rules.
File Format and Submission
- •Format: SAF-T XML following the NRA’s published official schema
- •Submission channel: NRA e-portal (electronic filing platform)
- •Authentication: Qualified Electronic Signature (QES) required for filing
- •Validation: NRA performs automated validation upon submission; rejected files must be corrected and resubmitted
Reporting Frequency
Bulgaria adopts a dual reporting cadence:
- •Monthly reporting: General ledger entries, sales and purchase invoices, payments, and tax data must be filed monthly, by the 14th of the month following the reporting period.
- •Annual reporting: Fixed asset registers and certain summary data are submitted annually, due by June 30 of the following year.
NRA Technical Documentation
The NRA released its technical documentation package on July 25, 2025, which includes:
- •Technical guides, sample files, and validation requirements covering all SAF-T sections
- •Nomenclatures: Official code lists for tax types, account categories, document types, and other enumerated values
Software vendors and internal IT teams should use these official specifications as the authoritative source for building SAF-T export functionality. The NRA’s official SAF-T documentation is published at nra.bg.
Penalties for Non-Compliance
Bulgaria has established penalties for late or non-submission of SAF-T filings under the Bulgarian Tax Procedure Code. There is a six-month grace period for first submissions during which no penalties will be imposed. After that grace period, the following penalties apply:
- •Individuals: Fines ranging from BGN 500 to BGN 2,000 for late or non-submission of SAF-T filings
- •Legal entities: Fines ranging from BGN 5,000 to BGN 15,000 for late or non-submission
- •Repeat violations: Penalty amounts are doubled for subsequent offences
- •Audit consequences: Failure to comply may trigger more intensive tax audits and additional scrutiny
How Businesses Should Prepare
Whether your company is already in scope or preparing for a later phase, the following steps will ensure a smooth transition to SAF-T reporting:
- •Assess ERP readiness: Confirm whether your accounting software supports Bulgarian SAF-T XML export. Contact your vendor for a roadmap if it does not.
- •Ensure your data fields align: Identify gaps between your current data structure and the NRA’s SAF-T requirements. Pay particular attention to code lists and nomenclatures.
- •Clean master data: Ensure customer, supplier, and account records are complete, consistent, and properly coded.
- •Run test submissions: Generate SAF-T files for historical periods and validate them against the NRA schema before the first live filing.
- •Establish internal processes: Define who is responsible for SAF-T generation, validation, and submission. Build monthly workflows with clear deadlines.
- •Engage tax advisors: Work with Bulgarian tax professionals who understand both the technical requirements and the broader compliance context.
SAF-T Adoption Across Europe
Bulgaria joins Luxembourg, Portugal, Poland, Norway, Austria, Lithuania, and Romania in adopting SAF-T-based reporting. European tax authorities are increasingly moving toward standardised digital audit files to improve compliance oversight and reduce the tax gap. For a full country-by-country breakdown, see our SAF-T adoption across Europe overview. Businesses operating across multiple European jurisdictions should adopt a unified approach to SAF-T readiness rather than treating each country implementation in isolation.
For companies already familiar with Luxembourg’s FAIA or Poland’s JPK, the Bulgarian SAF-T will feel structurally similar, since the core OECD schema provides a common foundation. However, country-specific code lists, reporting frequencies, and submission mechanisms differ, requiring tailored implementation for each jurisdiction. The EU ViDA initiative is expected to further accelerate this convergence across the bloc.