On 23 September 2026 Bulgaria’s Ministry of Finance published draft amendments to seven tax laws for public consultation. The consultation closes on Friday, 23 October 2026. After that the bills go to the Council of Ministers and then, together with the 2027 State Budget, to the National Assembly.
Two proposals matter more than anything else for ordinary Bulgarian companies: a markedly higher VAT registration threshold from 1 January 2027, and mandatory structured e-invoicing from 1 January 2028. Neither is law yet — but the second is a change you want a good year to prepare for, not a few weeks.
A €75,000 registration threshold
Today a company established in Bulgaria must register for VAT once its taxable turnover reaches €51,130 over twelve consecutive months (Art. 96(1) of the Bulgarian VAT Act, ZDDS). The application is due within seven days of crossing it. The draft raises this mandatory threshold to €75,000 from 1 January 2027, using the flexibility in the EU small-enterprise scheme (Directive (EU) 2020/285). The Ministry of Finance puts the revenue cost at around €94 million a year.
For a small consultancy, a freelancer with their own EOOD or a business selling mostly to consumers, that would be real relief: fewer monthly returns, and no obligation to add 20% to private customers’ bills. Voluntary registration remains available and is often still the better choice if your customers are VAT-registered themselves or you carry significant input VAT. The other grounds for registration are unaffected, such as intra-Community acquisitions or services received from abroad. How registration works today is explained on our VAT registration page.
The same draft carries a counterweight: anyone selling new buildings, the land that goes with them, or regulated building plots would have to register regardless of turnover, generally at least seven days before the tax becomes chargeable. If you hold property through a Bulgarian company and plan to sell, this is the rule to watch.
Structured e-invoicing from 2028 — what it actually means
From 1 January 2028, domestic B2B supplies would require a structured electronic invoice. “Structured” has a precise meaning here, and a PDF sent by e-mail does not meet it.
An invoice would have to meet three conditions: it contains everything the VAT Act already requires (see What a Bulgarian Invoice Must Contain); it is issued, transmitted and received in a machine-readable format based on the European standard EN 16931 (Directive 2014/55/EU); and it carries a unique compliance code generated by the system of the National Revenue Agency (NRA). The invoice counts as issued at the moment that code is generated. Two new mandatory fields are added: a goods or services classification code and the supplier’s bank details.
The obligation covers supplies where the supplier is a VAT-registered business established in Bulgaria and the recipient is a Bulgarian taxable person, a non-taxable legal entity or a state or municipal body. It also applies to invoices for advance payments. Sales to private individuals, intra-Community supplies and triangular transactions are outside it.
For the recipient this is not a formality: without a structured invoice there would be no right to deduct input VAT. If you buy from Bulgarian suppliers, you have as much interest in the switch working on time as if you invoice yourself.
Reporting changes with it. Purchase and sales ledgers disappear, and the NRA builds a draft VAT return from the invoice data, available by the 2nd of the following month. What the system cannot see you still add yourself — B2C sales, Art. 117 protocols, Art. 119 reports — and you still file the VIES return separately. Penalties for a missing structured invoice start only on 1 July 2028, with a minimum of €1,500 for companies and sole traders.
This is not a Bulgarian quirk. It is groundwork for the EU’s “VAT in the Digital Age” (ViDA) package, under which digital reporting of intra-EU B2B supplies becomes mandatory from July 2030.
What else is in the package
Also out for consultation, and all still drafts:
- Corporate tax (ZKPO): the threshold for expensing an asset immediately would rise to €1,000 (currently BGN 700 / €357.90). Losses could be carried forward for ten years instead of five, but the annual set-off would be capped at 70% of profit.
- Meal vouchers: the monthly ceiling per employee would rise to €200, but would then carry a 7% final tax.
- Personal income tax (ZDDFL): the child allowance would rise from €3,067.75 to €5,000 for one child, from €6,135.50 to €8,000 for two, and from €9,203.25 to €11,000 for three or more, plus a new deduction of up to €2,000 per child for health, education and sports expenses. These are deductions from the tax base, so at the 10% rate the saving is one tenth of the amount.
- A one-off 33% windfall tax for 2027 is planned for banks, insurers, telecom operators, large food retailers and fast-loan providers — not for companies in general.
Deadlines that are already fixed
While the 2027 package is still a draft, the following apply now:
- 2 November 2026 — quarterly declaration of tax withheld in the third quarter under Art. 55(1) ZDDFL and Art. 201(1) ZKPO (31 October is a Saturday). VAT-registered companies also report cash balances and receivables from shareholders and employees where these together exceed €25,564.59.
- 16 November 2026 — VAT return and VIES return for October (the 14th is a Saturday), and the last chance to adjust your 2026 corporate tax advance instalments under Art. 88 ZKPO (the 15th is a Sunday). Advances set too low trigger interest under Art. 89(5) ZKPO — if your profit is running ahead of forecast, do the sums first.
- 1 December 2026 — the year’s final corporate tax advance: the quarterly instalment for Q3 or the monthly instalment for December. There is no advance for the fourth quarter.
If your turnover sits between €51,130 and €75,000, model both scenarios before year-end rather than registering reflexively. And if you invoice Bulgarian businesses, ask your accounting or ERP provider now whether they have a plan for EN 16931 and the NRA platform.
ConsulTax has advised companies in Varna and across Bulgaria for over 30 years and works every day with both foreign-run companies and Bulgarian SMEs. If you would like to know which of this applies to you, get in touch.
This article gives general information as at 21 October 2026 and is not legal or tax advice for a particular situation. The 2027 and 2028 measures described are draft legislation; they may change or not be adopted.