--- title: "SAF-T in Bulgaria: Wave Two Starts on 1 January 2027 — Are You in It?" url: https://consultax-varna.com/2026/10/28/saf-t-bulgaria-2027-second-wave/ language: en dateModified: 2026-10-28 --- # SAF-T in Bulgaria: Wave Two Starts on 1 January 2027 — Are You in It? 28 Oct 2026 From 1 January 2027 the second group of Bulgarian companies comes into the SAF-T regime: the Standard Audit File for Tax purposes (*стандартен одитен файл за данъчни цели*), a structured XML file through which the National Revenue Agency (NRA) receives your accounting records directly instead of asking for them during an audit. Most owners of a small Bulgarian company need do nothing on 1 January. But the thresholds are not obvious, the dates are staggered over five years, and one widely repeated claim — that each wave gets a six-month grace period — does not apply. ## Who is in scope, and when Whether you are in a wave is measured on figures from two years earlier, so you can work out your position today. The rollout, set in the transitional provisions of the 2025 State Budget Act, runs in five stages: - **1 January 2026** — large enterprises with net sales above **BGN 300 million** in 2023, or more than **BGN 3.5 million** of taxes and social contributions paid to the NRA. The NRA wrote to around 470 companies. - **1 January 2027** — the same two thresholds, now on 2024 figures, and no longer limited to companies classed as “large”: any large, medium or small enterprise that crosses one of them is in. - **1 January 2028** — the thresholds drop sharply: net sales above **BGN 15 million**, or more than **BGN 1.5 million** of taxes and contributions, on 2025 figures. - **1 January 2029** — all remaining large, medium and small enterprises under the Accounting Act, with no financial threshold. - **1 January 2030** — VAT-registered micro-enterprises. The thresholds are written in leva. At the fixed rate of 1.95583 they are about €153.4 million and €1.79 million for 2026–2027, and €7.7 million and €767,000 for 2028. So for a typical foreign-owned EOOD with a handful of staff, wave two is not your wave. Your date is **1 January 2029** if the company is a small enterprise under the Accounting Act, or **1 January 2030** if it is a VAT-registered micro-enterprise. A micro-enterprise that is not registered for VAT stays outside the regime, and so does a foreign company registered in Bulgaria for VAT only, without a place of business here. ## What you actually file Three different files, not one: **The monthly file** carries the substance: master data (chart of accounts, customers, suppliers, products, tax tables), general ledger entries, and source documents — sales invoices, purchase invoices and payments. It is due **by the end of the month following the reporting month**, so the January file goes in during February. The original rules set the 14th; the NRA moved it to month-end in 2025. **The annual file** covers fixed assets and their movements and is filed **together with the annual corporate tax return** under Art. 92 of the Corporate Income Tax Act (ZKPO) — in practice by 30 June of the following year. **The on-request file** covers stock and movements of goods. It is produced only when a revenue officer asks for it in writing during an audit or other control procedure, within the period set in the request. ## The part most summaries get wrong: no grace period The SAF-T rules in the Tax and Social Insurance Procedure Code (Art. 71z–71k DOPK) contain a six-month easing for an obligation that arises for the first time. But the 2025 State Budget Act, which sets out the five stages, expressly switches that easing off for them. If you are in wave two, the file for January 2027 is due by the end of February 2027. There is no free half-year. What you get instead is a correction window: files submitted in the first twelve months can be replaced with a corrected file. After that, if the NRA finds a discrepancy, you are notified and have seven days to put it right. Penalties are set per breach, and each missed monthly file is its own breach: BGN 5,000–15,000 (about €2,556–€7,669) for companies and sole traders, BGN 500–2,000 (about €256–€1,023) for the individuals responsible, and double for a repeat offence within a year. ## What to do now, even if your date is 2029 SAF-T does not change what you owe. It changes how visible your bookkeeping is, and an automated check is less forgiving than a human reviewer. Two things are worth doing while there is no deadline pressure. **Fix counterparty data.** Every customer and supplier needs a complete, correct record: name, VAT or company number, address. Gaps here are exactly what an automated validation flags first. **Ask your software provider one question, in writing.** Not “do you support SAF-T?” but “which version of the NRA’s XSD schema do you generate, and when will you support the current one?” The schema is revised from time to time; a provider who cannot name a version is not ready. Both pay off twice. The draft VAT Act amendments would make structured e-invoicing to the EN 16931 standard mandatory from 1 January 2028, with the NRA pre-filling VAT returns from the invoice data (see [Bulgaria’s draft 2027 tax package](https://consultax-varna.com/2026/10/21/bulgaria-draft-2027-tax-package-vat-threshold-e-invoicing/)). That is still a draft, but it points the same way as SAF-T: your accounting system, not a spreadsheet, becomes what the tax authority reads. And if your records live partly in a German or Austrian system and are only reconciled in Bulgaria at year-end, that model needs rethinking before your wave arrives. **Not sure which wave you are in?** It takes one look at your 2024 and 2025 figures and your Accounting Act category. [Get in touch](https://consultax-varna.com/contacts/) and we will tell you your date, and what your software needs to do by then. *This article gives general information as at 28 October 2026 and is not legal or tax advice for a particular situation. The e-invoicing measures mentioned are draft legislation and may change before adoption.* ## Frequently asked questions When does my Bulgarian company have to start filing SAF-T? It depends on size. From 1 January 2027 companies with net sales above BGN 300 million (about €153.4 million) or more than BGN 3.5 million (about €1.79 million) of taxes and contributions paid in 2024; from 1 January 2028 those above BGN 15 million or BGN 1.5 million in 2025; from 1 January 2029 all other small, medium and large enterprises; from 1 January 2030 VAT-registered micro-enterprises. A micro-enterprise that is not VAT-registered does not file. Is there a grace period for SAF-T in Bulgaria? Not for the five phased waves. The six-month easing in the Tax and Social Insurance Procedure Code is expressly switched off for them by the 2025 State Budget Act, so a company in scope from January files its January file by the end of February. Files from the first twelve months can be replaced with corrected ones. ## How we can help - [Accounting Services](https://consultax-varna.com/accounting-services/) - [VAT registration](https://consultax-varna.com/vat-registration/)