SAF-T in Bulgaria: What Businesses Need to Know

Quick Answer

Bulgaria’s SAF-T (Standard Audit File for Tax) reporting obligation is now live. Large enterprises above certain turnover or tax contribution thresholds have been required to submit structured accounting data to the NRA since January 2026, with the obligation expanding in phased waves to broader categories of businesses through to 2030. For companies involved in intra-EU trade, SAF-T has direct implications for VIES compliance: the NRA can now cross-check VIES declarations against transaction-level accounting data, making inconsistencies far easier to detect.

What Is SAF-T and Why It Matters for Bulgarian Businesses

SAF-T is an OECD-developed standard that allows tax authorities to receive detailed, structured accounting data directly from businesses in a standardised electronic format. Rather than relying solely on summarised VAT returns and periodic declarations, the NRA can now access individual invoices, ledger entries, accounts payable and receivable data, and fixed asset records.

Bulgaria formally introduced the SAF-T obligation through the 2025 State Budget, which embedded the requirement in the Tax and Social Security Procedure Code. The NRA piloted the system with selected volunteers from mid-2025 and launched mandatory reporting for the first wave of large enterprises on 1 January 2026. For businesses involved in intra-EU trade, the consequence is immediate: VIES declarations are no longer assessed in isolation.

Who Is Currently Required to Submit SAF-T

The rollout follows a phased schedule based on enterprise size and financial thresholds, assessed two years prior to the reporting year. The first wave applies to companies classified as large enterprises under Bulgaria’s Accounting Act — specifically those registered with the Large Taxpayers and Insurers Territorial Directorate — that also meet at least one of two additional criteria: net sales revenue exceeding €153.4 million, or net payments to the NRA exceeding €1.79 million, both assessed on 2023 figures. The NRA indicated that approximately 460 companies were expected to fall within this first phase.

The full rollout schedule is as follows:

Phase	Scope
January 2026	Large enterprises: net sales > €153.4M or NRA payments > €1.79M (based on 2023 figures). ~460 companies (NRA estimate).
January 2027	Large, medium, and small enterprises meeting the same criteria (net sales > €153.4M or NRA payments > €1.79M) based on 2024 data.
January 2028	Enterprises with net sales > €7.67M or NRA payments > €0.77M (based on 2025 data).
January 2029	All large, medium, and small enterprises, regardless of turnover.
January 2030	All VAT-registered enterprises, including micro-enterprises.

A six-month grace period applies at the start of each phase, during which initial submissions will not attract penalties. For most small and micro enterprises, the obligation does not arise until 2029 or 2030.

What SAF-T Reporting Requires in Practice

Businesses within scope must submit SAF-T files electronically through the NRA portal using a qualified electronic signature (QES). Files must be in XML format according to the NRA’s technical specification. The submission structure has three components:

Monthly (due by the 14th of the following month): general ledger, accounts payable and receivable, and sales and purchase invoices
Annual (due by 30 June of the following year): fixed assets data
On-demand: inventory data, provided upon NRA request

Most Bulgarian accounting software is being updated to support SAF-T export; businesses should verify with their provider that their system will generate compliant files before their applicable phase date.

How SAF-T Changes VIES Compliance

VIES (VAT Information Exchange System) declarations remain a mandatory reporting obligation for Bulgarian VAT-registered businesses making qualifying intra-EU supplies of goods or services. Until now, these declarations have been assessed on the basis of self-declared aggregated figures, with discrepancies typically detected through manual audit or information requests from other EU tax authorities.

The European Commission’s VIES information page provides an overview of the system and its EU-level function for those unfamiliar with the framework.

SAF-T changes this fundamentally. The NRA can now compare VIES declarations directly against the underlying invoice records, making discrepancies visible far more quickly than through conventional audit. The predictable risk areas include invoice dates that differ between accounting records and VIES reports, VAT codes incorrectly applied to intra-EU supplies, customer VAT numbers that are invalid or have lapsed, and differences introduced by manual adjustments.

For businesses that have historically treated their accounting, VAT, and VIES functions as separate compliance streams, those processes now need to be consistent at the transaction level, not just at the aggregate level.

Practical Steps for Businesses

Businesses approaching SAF-T scope should review their Accounting Act classification and check their financial figures against the relevant phase thresholds. The immediate technical task is verifying that their accounting software can generate SAF-T-compliant XML files, as this may require a version update or active configuration. For businesses with intra-EU trade, the compliance priority is ensuring consistency between VIES declarations and accounting records: the same invoice dates, VAT treatment, and customer VAT numbers across both. Monthly reconciliation between accounting data, VAT returns, and VIES reports is the most reliable way to catch discrepancies before they become audit findings.

Conclusion

SAF-T is a present obligation for businesses above the relevant thresholds, not a future one. The scope expands year by year through to 2030, and for intra-EU traders VIES compliance is now directly connected to the quality of underlying accounting data in a way it has not been before. For a broader view of the reporting obligations that sit alongside SAF-T, the VAT, VIES, OSS and Intrastat overview and the VAT in Bulgaria guide provide useful context.

Working With Aidos

If your business is approaching SAF-T scope, or if you have questions about aligning your VIES reporting with your accounting data, professional review is advisable. You may explore our tax advisory services or contact us to book a meeting for tailored guidance.

FAQ: SAF-T in Bulgaria

Which businesses are currently required to submit SAF-T?

As of January 2026, large enterprises registered with the Large Taxpayers and Insurers Territorial Directorate that also had net sales exceeding €153.4 million or NRA payments exceeding €1.79 million in 2023 are in scope. The obligation extends progressively to medium, small, and micro-enterprises through to January 2030, with each phase assessed against financial thresholds from two years prior.

What data must be included in a SAF-T submission?

Monthly submissions cover the general ledger, accounts payable and receivable, and sales and purchase invoices (due by the 14th of the following month). Fixed asset data is submitted annually by 30 June. Inventory data may be requested by the NRA on an ad hoc basis. All files must be submitted in XML format via the NRA portal using a qualified electronic signature.

Will SAF-T replace VAT returns or VIES declarations?

No. SAF-T is a supplementary obligation that gives the NRA transaction-level visibility to verify the accuracy of existing declarations. VAT returns and VIES reports continue on their current schedules and remain mandatory for all in-scope businesses.

Is there a penalty grace period for new SAF-T filers?

Yes. A six-month grace period applies at the start of each implementation phase, during which errors or delays in initial submissions will not attract penalties. After the grace period, standard penalties under the Tax and Social Security Procedure Code apply.

How does SAF-T affect VIES compliance risk?

SAF-T gives the NRA access to the individual invoices and accounting entries that underlie VIES declarations. This means discrepancies — different invoice dates, incorrect VAT treatment, invalid customer VAT numbers — become detectable through automated cross-checking rather than only through manual audit. Businesses with significant intra-EU trade volumes should review the consistency of their VIES and accounting data as a priority.

Disclaimer

This article is for informational purposes only and does not constitute tax, legal, or accounting advice. Each case requires individual assessment under Bulgarian and applicable international law.

Last reviewed: June 2026