On September 10, 2026, eight members of Bulgaria's 52nd National Assembly, led by Bozhidar Bozhanov and Martin Dimitrov, introduced bill 52-654-01-133 amending the Tax and Social Insurance Procedure Code (DOPK, State Gazette No. 105 of 2005). The Assembly registered it the same day on the National Assembly bills register.
The draft mandates electronic invoices in a SAF-T-compatible format between persons already required to file a Standard Audit File for Tax, lifts the SAF-T specification from a National Revenue Agency (NAP) director's order to a Minister of Finance ordinance, drops duplicate VAT and corporate-income-tax filings for SAF-T filers, requires standardized bank-account statements, and moves the second SAF-T obligated cohort from 2027 to 2028. No committee or first-reading date is set. This is not the Council of Ministers DAC8/DAC9 bill (No. 52-602-01-10).
What does the bill change inside the SAF-T file?
Paragraph 1 adds four new paragraphs to DOPK Article 71. A SAF-T submission may be a set of audit files that together meet the statutory requirements, under the ordinance issued under Article 71k(4). Data already held by a primary data administrator is not re-filed; NAP collects it ex officio under the Electronic Government Act. Invoice data not issued under new VAT Act Articles 113(16) and 113(17) is filed in aggregated form. The same ordinance will set recommended chart-of-accounts nomenclatures.
Paragraph 2 rewrites Article 71k(4): the current NAP executive-director order is replaced by an ordinance of the Minister of Finance. A new Article 71k(9) provides that a wrong optional field is not a ground to reject the file.
Who must issue electronic invoices, and in what format?
Persons required to file a SAF-T under Chapter Eight "b" of the DOPK must issue and send invoices whose recipients are also SAF-T-obligated persons in electronic form, in the order and format set by the Article 71k(4) ordinance (new VAT Act Article 113(16)). Non-obligated persons may use that procedure when the recipient is SAF-T-obligated (new Article 113(17)). The mandate covers flows between obligated filers only, not every Bulgarian VAT invoice.
New VAT Act Article 125(15) drops the VAT return-declaration (spravka-deklaratsiya) for registered persons who file a SAF-T. New Corporate Income Tax Act Article 92(9) drops from the annual tax return any data already filed in those SAF-T files. Paper or PDF invoices to SAF-T peers will land in the recipient's file only as aggregates.
When does the second SAF-T round move, and what must banks do?
Paragraph 3 amends paragraph 17 of the Transitional and Final Provisions of the 2025 State Budget Act (State Gazette No. 26 of 2025, in force January 1, 2025): 2027 becomes 2028 and 2024 becomes 2025. The motives call this a one-year postponement of the second SAF-T obligated round. The bill does not restate the cohort thresholds.
Paragraph 6 inserts a new Article 69b into the Payment Services and Payment Systems Act (State Gazette No. 20 of 2018). Payment-service providers must give legal-entity and sole-trader clients account statements in a standardized machine-readable format set by the ordinance under Article 67(5). Paragraph 7 requires the Bulgarian National Bank (BNB) to align that ordinance by February 1, 2027. Paragraph 8 brings the law into force on the day of State Gazette promulgation, except paragraph 6, which enters into force on July 1, 2027. The DOPK, VAT Act and Corporate Income Tax Act changes therefore apply on promulgation; only the bank-statement duty waits. The e-invoice format will sit in the Minister of Finance ordinance, not in the bill.
| Measure | Instrument | Trigger if adopted |
|---|---|---|
| SAF-T file rules, optional-field safe harbour, finance-ministry ordinance | DOPK Arts. 71, 71k | Day of promulgation |
| E-invoices between SAF-T filers; drop of VAT return-declaration | VAT Act Arts. 113(16)-(17), 125(15) | Day of promulgation |
| Drop of duplicate data from the annual CIT return | Corporate Income Tax Act Art. 92(9) | Day of promulgation |
| Second SAF-T round: 2027 becomes 2028 | 2025 State Budget Act, TFP para. 17 | Day of promulgation |
| BNB aligns the account-statement ordinance | Payment Services Act Art. 67(5) | By February 1, 2027 |
| Standardized statements for legal entities and sole traders | Payment Services Act Art. 69b | July 1, 2027 |
What should tax, software and bank teams do before first reading?
The bill is at introduction. Two readings still lie ahead, with written amendment motions between them. Nothing binds until adoption, presidential promulgation and State Gazette publication. The immediate work is mapping, not filing.
- SAF-T-obligated issuers: identify counterparties who are also obligated; those flows become the e-invoice perimeter under Article 113(16).
- Non-obligated suppliers to obligated buyers: opt into Article 113(17), or accept aggregated reporting on the buyer side.
- Tax-software and e-invoicing vendors: treat the forthcoming Minister of Finance ordinance, not the current NAP order, as the governing specification.
- Banks and other payment-service providers: diary the BNB ordinance deadline of February 1, 2027 and the July 1, 2027 start for standardized statements.
- Second-round SAF-T candidates: plan against a 2028 start, if the bill survives both readings in this form.
Continuous, per-jurisdiction real-time monitoring surfaces a National Assembly filing the day the signature is stamped, not when the State Gazette later sets the deadline.
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