E-invoicing in Bulgaria from 2028: a guide for companies
According to bill no. 52-602-01-60 amending the VAT Act, as introduced, structured e-invoices become mandatory between companies and to the state from 1 July 2028. The invoice will be a document in UBL 2.1 or CII under EN 16931, not a PDF. The bill has passed only a first reading, on 12 November 2026, so the text may change.
What does the bill provide?
The bill provides for mandatory structured e-invoices between companies (B2B) and to the state (B2G) from 1 July 2028. They will travel over the CEF eDelivery AS4 network in UBL 2.1 and CII under EN 16931.
The issuer will send the invoice only to the recipient's address in a National Register. There will be accredited providers and certified software. The conditions for them will be set in an ordinance.
What are the dates?
The dates below follow the text as introduced. The ordinance is not out yet, so its deadline is a provision, not a fact.
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5 Nov 2026
Introduced in the National Assembly
Bill no. 52-602-01-60 amending the VAT Act.
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12 Nov 2026
First reading
Passed at first reading. The text may change before the second.
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1 Jul 2027
Deadline for the ordinance
The conditions for accredited providers and for software. The ordinance is not out yet.
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1 Jul 2028
Mandatory e-invoices
Between companies and to the state, over the CEF eDelivery AS4 network, in UBL 2.1 and CII.
What is a structured e-invoice?
A structured e-invoice is a document in which every item of data sits in a named field that software can read without text recognition. A PDF is not such a document: it displays the data, it does not describe it.
The EN 16931 standard gives every field a code. Here is an excerpt of an invoice in UBL 2.1, with the field codes in the left column:
<Invoice …>BT-1<cbc:ID>0000000124</cbc:ID>BT-2<cbc:IssueDate>2026-11-12</cbc:IssueDate>BT-3<cbc:InvoiceTypeCode>380</cbc:InvoiceTypeCode>BT-5<cbc:DocumentCurrencyCode>EUR</cbc:DocumentCurrencyCode>…<cac:TaxTotal>BT-110<cbc:TaxAmount currencyID="EUR">200.00</cbc:TaxAmount></cac:TaxTotal><cac:LegalMonetaryTotal>BT-115<cbc:PayableAmount currencyID="EUR">1200.00</cbc:PayableAmount></cac:LegalMonetaryTotal></Invoice>| Code | What it means |
|---|---|
| BT-1 | Invoice number. Ten digits, no gaps (Art. 114(1)(2) VAT Act). |
| BT-2 | Issue date. |
| BT-3 | Document type. 380 is an invoice, 381 is a credit note. |
| BT-5 | Document currency. |
| BT-110 | Total VAT amount. |
| BT-115 | Amount due for payment. |
What happens to the recipient?
According to the text as introduced, the recipient loses the input VAT credit if there is no structured e-invoice. So it is not only issuers who need to be ready: companies that only receive invoices will also want the documents in this form.
How will the invoice be sent?
The issuer will send only to the recipient's address in a National Register, over the CEF eDelivery AS4 network. The details of the register and of the providers will be in the ordinance. Those conditions are not published yet.
What is still unclear?
The ordinance with the conditions for accredited providers and certified software is not out yet. According to the text as introduced, its deadline is 1 July 2027. No approval from the National Revenue Agency exists today, and Fakturist does not claim one. Nor do we claim to meet requirements that have not been set.
What should a company do now?
- Check your numbering: ten digits and no gaps. Art. 114(1)(2) of the VAT Act already requires it.
- Ask your accountant and your software provider whether they will issue UBL 2.1 or CII, not only PDF.
- Keep counterparty data accurate: company ID, VAT number and address. A structured document carries them in separate fields.
- Follow the ordinance and the text at the second reading. The conditions for providers and software will decide what is needed.
What does Fakturist already do today?
Every document is issued as both UBL 2.1 and CII under EN 16931, the free plan included. Not available yet, but planned: Sending and receiving over the e-invoicing network (2027-Q3); Reporting to the National Revenue Agency (2028-Q1); Data for SAF-T (2027-Q4); PDF for your customer (undefined).
Sources
The facts above follow the text and the file of the bill. Check them at the source.