Complete Guide to Invoicing in Bulgaria 2026 — VAT, PEPPOL, FAQ

2026-04-27

Complete guide to invoicing in Bulgaria 2026: invoice types, ZDDS Art. 114 requirements, VAT, PEPPOL e-invoicing, FAQ. By Fakturka.bg.

Complete Guide to Invoicing in Bulgaria 2026

💶 All amounts are shown in EUR (the primary currency from 1 January 2026) and BGN (transitional period until 8 August 2026). Fixed rate: 1 EUR = 1.95583 BGN.

TL;DR (quick read):

An invoice is an accounting document required by ZDDS Art. 113-114 (Bulgaria's VAT Act) for B2B transactions.

Bulgaria recognises 6 main invoice types: original, copy, proforma, credit note, debit note, and simplified invoice.

From 2026, e-invoicing through PEPPOL is becoming the standard for B2G (business-to-government) transactions.

The standard VAT rate is 20%, with a reduced 9% (hotels and tourism — permanent reduced rate per ZDDS Art. 66 §2) and 0% (exports, intra-EU supplies).

Mandatory VAT registration threshold: turnover above 100,000 BGN (51,130 EUR) over 12 consecutive months.

Free tooling: Fakturka.bg offers 15 invoices/month free forever.

What an invoice is and why you need one
Invoice types in Bulgarian law
What an invoice must contain under ZDDS Art. 114
How to issue an invoice — step by step
VAT in invoices — duties and deadlines
E-invoicing 2026 — PEPPOL and B2G
Invoicing for special scenarios
Common invoicing mistakes
How Fakturka.bg helps
Frequently asked questions (FAQ)
Sources and further reading

What an invoice is and why you need one

An invoice is a primary accounting document that evidences a supply of goods or services and is the legal basis for payment, expense recognition, and the right to deduct input VAT.

Under ZDDS Art. 113 §1 every VAT-registered person — the supplier — must issue an invoice for each supply of goods or services, or upon receipt of an advance payment before the chargeable event. In short: if you are VAT-registered and selling to another business, issuing an invoice is not optional — it is a statutory obligation.

When an invoice is mandatory

For every supply between VAT-registered persons (B2B).
On receipt of an advance payment before the chargeable event.
For sales to a taxable person in another EU member state (intra-Community supply).
For supplies whose place of performance is outside Bulgaria when the recipient is a taxable person.
For sales to public authorities (B2G), regardless of value.

When an invoice is not mandatory

For B2C sales accompanied by a fiscal cash receipt, unless the customer explicitly requests one (ZDDS Art. 113 §3).
For supplies for personal consumption to non-VAT individuals.
For free-of-charge supplies between related parties (with some exceptions).

Important: Even if your customer is an individual, they have the right to request an invoice and you must issue it within 5 days of the chargeable event.

Legal consequences of missing or defective invoices

Penalties under ZDDS Art. 180 §1 for failure to issue an invoice:

Individuals: between 250 and 1,000 BGN (128 to 511 EUR).
Legal entities (companies and sole traders): between 500 and 5,000 BGN (256 to 2,556 EUR).
Repeat offences double the amount (ZDDS Art. 180 §3).
Breach of Art. 114 requirements: penalty up to the unaccounted VAT, but no less than 1,000 BGN (511 EUR).
The recipient loses the right to deduct input VAT on a defective invoice — which on larger transactions can mean tens of thousands of leva of loss for your customer.

Invoice types in Bulgarian law

Bulgarian practice recognises six main invoice types, each with a different legal and accounting role.

Invoice type	Legal basis	When used	VAT effect
Original invoice	ZDDS Art. 113-114	Standard sale	Charges VAT
Copy of invoice	ZDDS Art. 113 §8	Supplier's archive	None — only the original
Proforma invoice	No statutory definition	Pre-payment, quote	No VAT charged
Credit note	ZDDS Art. 115	Reduction of amount	Reduces VAT
Debit note	ZDDS Art. 115	Increase of amount	Increases VAT
Simplified invoice	ZDDS Art. 119	Under 100 EUR (~195.58 BGN)	Reduced fields

Original (standard) invoice

The bread and butter of invoicing. Issued for every taxable supply and contains all 14 mandatory fields under ZDDS Art. 114. It is the document on which the recipient may exercise the right to input VAT deduction.

Copy of invoice

The supplier keeps a copy (usually marked "copy"). Since 2014, the law no longer requires invoices to be issued in two paper copies — an electronic copy is equivalent.

Proforma invoice

A proforma is not a tax document. It is a quote or pre-payment notice. No VAT is recognised in the VAT ledger and no income is recorded. After payment is received, the actual (original) invoice is issued.

Credit and debit notes

When the taxable amount changes after the original invoice is issued — e.g. discount, returned goods, complaint, or additional charge — a note is issued. Credit notes reduce the amount (refund); debit notes increase it (additional charge). The note must reference the number and date of the original invoice.

Simplified invoice

For sales under 100 EUR (~195.58 BGN) to taxable persons in Bulgaria, a simplified invoice with reduced fields is allowed (ZDDS Art. 119). It cannot, however, be used for intra-EU supplies, exports, or sales to the state.

Electronic invoice (e-invoice)

An electronic invoice is technically identical to a paper one but is exchanged in a structured format (XML, UBL). Since 2024, Bulgaria has been actively integrating the PEPPOL network for B2G transactions.

What an invoice must contain under ZDDS Art. 114

ZDDS Art. 114 §1 lists 14 mandatory fields that every invoice must contain.

Quick checklist of the 14 mandatory fields

Document name — "invoice", "credit note", or "debit note".
Sequential 10-digit number — uninterrupted sequence.
Issue date — no later than 5 days after the chargeable event.
Date of the chargeable event (if different from issue date).
Supplier name and address — full legal name, registered seat.
Supplier UIC / personal ID.
Supplier VAT identification number (if registered).
Recipient name and address.
Recipient UIC / personal ID.
Recipient VAT identification number (if registered).
Quantity and description of goods/services.
Unit price excluding VAT.
Taxable amount and applicable rate.
VAT amount and total amount due.

Common errors when filling in invoices

Wrong number format (letters or gaps in the sequence).
Missing chargeable-event date for deferred payment.
Mismatch between VAT number and recipient's name.
Rounding that produces a difference in the total.
Missing "reverse charge" wording when that regime applies.

Tip: Fakturka.bg auto-populates all 14 fields, validates VAT numbers in real time via VIES, and prevents number duplication.

How to issue an invoice — step by step

The process follows seven clear steps that cover every scenario.

Step 1: Decide the invoice type

First decide what document you actually need — an original invoice, proforma, credit/debit note. The required fields follow from this choice.

Step 2: Collect customer data

For legal entities: full legal name, UIC (Unified Identification Code), registered office and management address, VAT number. For individuals: full name, personal ID, address. Always validate the VAT number in VIES before issuing an intra-EU invoice.

Step 3: Describe the goods or services accurately

Each line must contain: description, unit of measure (pcs., kg, hours, m²), quantity, unit price. Generic descriptions like "services" or "goods" are not enough.

Step 4: Calculate VAT or mark as exempt

Standard rate: 20%.
Reduced rate: 9% (hotels and tourism — permanent reduced rate under ZDDS Art. 66 §2).
Zero rate: 0% (exports outside the EU, intra-Community supplies, international transport).
Exempt supplies: ZDDS Art. 38-50 (medical, educational, financial services).
Reverse charge: ZDDS Art. 82 §5.

Step 5: Signature and stamp

ZDDS Art. 114 §6 explicitly states that a signature and stamp are not required for invoice validity. Electronic invoices from systems like Fakturka.bg are fully valid without a handwritten signature.

Step 6: Send to the customer

Within 5 days of the chargeable event (ZDDS Art. 113 §4). Delivery may be on paper, by email (PDF), or via PEPPOL for B2G recipients.

Step 7: Archive per Accounting Act Art. 12

Under Art. 12 of the Accounting Act (ZSch) retention periods vary by document type:

Primary documents (invoices, cash receipts, notes): 5 years.
Accounting registers and annual financial statements: 10 years.
Payroll records: 50 years.

Electronic archiving is fully equivalent to paper archiving provided it ensures origin authenticity, content integrity, and readability throughout the retention period.

VAT in invoices — duties and deadlines

The VAT regime is the heart of Bulgarian invoicing. Errors here lead to serious penalties.

Bulgarian VAT rates 2026

Rate	Application	Examples
20%	Standard	Most goods and services
9%	Reduced	Hotels and tourism (permanent reduced rate per ZDDS Art. 66 §2)
0%	Zero	Exports outside the EU, intra-EU supplies, international transport
Exempt	ZDDS Art. 38-50	Health, education, financial services

When you must register for VAT

Under ZDDS Art. 96 §1, registration is mandatory at a turnover above 100,000 BGN (51,130 EUR) over 12 consecutive months. Voluntary registration is possible at any time by application to the National Revenue Agency (NAP).

VAT ledgers — mandatory registers

Every registered person must keep two ledgers:

Purchase ledger — all received invoices with input VAT deduction rights.
Sales ledger — all issued invoices.

VAT filing deadlines

Monthly VAT return: by the 14th of the month following the tax period.
VIES return: by the 14th — for intra-Community supplies.
Intrastat: by the 14th — when goods turnover with the EU exceeds the threshold.
VAT payment: by the 14th, together with the return.

Note: Since 2024, filing must be done electronically through the NAP portal, using a Qualified Electronic Signature (KEP) or PIN code.

E-invoicing 2026 — PEPPOL and B2G

PEPPOL (Pan-European Public Procurement OnLine) is a European network for exchanging structured electronic documents. Since 2019 the EU has required all public authorities in member states to accept invoices through PEPPOL.

What is PEPPOL technically?

A standardised UBL XML format exchanged through certified Access Points (APs). Each participant has a unique PEPPOL ID. The system uses the "4-corner model": supplier → AP1 → AP2 → recipient.

When is it mandatory in Bulgaria

B2G (business-to-government): Since 2024, Bulgarian state authorities have been progressively integrating PEPPOL. Full integration for public procurement is expected from 2026.
B2B (business-to-business): Still voluntary, but trending toward mandatory introduction across the EU after 2028 (see the ViDA package).

How Fakturka.bg supports PEPPOL

Fakturka.bg has integrated PEPPOL e-delivery (see "SPECIALIZED → PEPPOL" in the dashboard). Supports:

Sending invoices directly to a recipient's PEPPOL ID.
Automatic monitoring of sent documents (sent inbox).
Receiving inbound invoices from EU partners.
Auto-send toggle for automated B2G compliance.

Invoicing for special scenarios

Beyond standard B2B sales, several regimes need special attention.

Freelancers without VAT registration

If you work as a self-employed professional (journalist, designer, programmer) and turnover is below 100,000 BGN (51,130 EUR), you are not required to register for VAT. You issue invoices without VAT, with the wording "supplier is not VAT-registered".

Exports outside the EU

Supplies to non-EU countries are zero-rated (0% VAT, ZDDS Art. 28). Customs documentation (EX1) is required as evidence. The invoice should state "export per ZDDS Art. 28".

Intra-Community supplies (ICS)

For sales to a VAT-registered person in another EU country: 0% VAT. Mandatory:

Validate the recipient's VAT number in VIES.
Wording: "reverse charge — Art. 138 of Directive 2006/112/EC" or "ICS per ZDDS Art. 7".
File the VIES return by the 14th of the following month.

Reverse charge — ZDDS Art. 82

For certain services (construction, IT consulting between registered persons in the EU), VAT is not charged by the supplier but accounted for by the recipient. The invoice is marked "reverse charge".

SME scheme — ZDDS Art. 156a

From 2025 Bulgaria implements the special EU SME scheme, allowing small enterprises to sell into other member states without local VAT registration up to 100,000 EUR annual cross-border turnover.

Common invoicing mistakes

Based on thousands of invoices processed through Fakturka.bg, these are the top 10 mistakes we see most often:

Sequence gaps — a missing invoice numbered 0000000123 followed by 0000000125.
Wrong VAT regime — charging 20% on an ICS where 0% applies.
VAT number mismatch — invalid or wrong country.
Rounding — sum of line items not equal to the total.
Missing chargeable-event date for advance payments.
Missing exemption basis for exempt supplies.
Wrong foreign-currency rate — must use the Bulgarian National Bank rate on the chargeable-event date.
Issued after the 5-day deadline — breach of ZDDS Art. 113 §4.
Number duplication when several devices issue invoices in parallel.
Address mismatch between invoice and Commercial Register.

NAP penalties at a glance

Breach	Penalty
Failure to issue invoice (individuals, Art. 180 §1)	250 – 1,000 BGN (128 – 511 EUR)
Failure to issue invoice (legal entities, Art. 180 §1)	500 – 5,000 BGN (256 – 2,556 EUR)
Repeat breach of Art. 180	Doubled (Art. 180 §3)
Breach of Art. 114	Up to the unaccounted VAT, min. 1,000 BGN (511 EUR)
Late VAT return	500 – 10,000 BGN (256 – 5,113 EUR)
Missing VIES return	500 – 10,000 BGN (256 – 5,113 EUR)
Defective tax document	Loss of input VAT deduction for the recipient

How Fakturka.bg helps

Fakturka.bg is a Bulgarian SaaS platform built by and for Bulgarian accountants and entrepreneurs. We solve the real pain points of running a business:

Key features

Auto-fill by UIC — enter only the UIC, we pull all company data from the Commercial Register and NAP.
AI expense extraction — photograph a receipt or PDF and Gemini AI extracts all data automatically (also available in the mobile app).
NAP SAF-T export with one click — for larger businesses, with full format support.
Multi-currency invoicing — automatic BNB rate, support for EUR, USD, GBP and others.
PEPPOL B2G integration — sending to public authorities across the EU.
Automatic VIES validation — before every ICS invoice.
Auto-generated VAT ledger — without manual entry of every invoice.
Electronic signature and stamp — optional, for companies with brand requirements.

Free plan

Fakturka.bg offers a fully free plan with up to 15 invoices/month. No hidden fees, no credit card on signup, no trial period. Ideal for freelancers, small companies and startups.

Paid plans (Pro 7.50 EUR / 14.67 BGN per month, Business 15 EUR / 29.34 BGN per month) add unlimited invoices, multi-user access, premium integrations and priority support.

Frequently asked questions (FAQ)

When is an invoice mandatory?

An invoice is mandatory for every supply between VAT-registered persons, for advance payments, for intra-EU supplies, exports and sales to public authorities. For sales to individuals it is mandatory only if the customer requests it (ZDDS Art. 113 §3).

Can an invoice be handwritten?

Yes — the law allows handwritten invoices on paper, provided all 14 fields under ZDDS Art. 114 are filled in legibly. For higher volumes we recommend electronic issuance — faster, error-free and auto-archived.

How long must I keep invoices?

Under Art. 12 of the Accounting Act: primary documents (invoices, cash receipts) — 5 years, accounting registers and annual financial statements — 10 years, and payroll records — 50 years. Electronic archiving is equivalent to paper.

What is the difference between an invoice and a proforma?

An invoice is a tax document that charges VAT and triggers a payment obligation. A proforma is a quote or pre-payment notice — it does not charge VAT and is not entered into the sales ledger. After payment is received, the real invoice is issued.

How do I issue an invoice without VAT registration?

If turnover is below 100,000 BGN (51,130 EUR) over 12 months, registration is not required. You issue invoices without VAT with the wording "supplier is not VAT-registered". Fakturka.bg supports this regime even on the free plan.

Can I invoice a foreign customer?

Yes. To a VAT-registered EU buyer — ICS at 0% VAT (with VIES validation). To a non-EU buyer — export at 0% VAT with customs documentation. To an EU individual — standard 20% or the OSS scheme if you are OSS-registered.

What is reverse charge in ZDDS?

Reverse charge under Art. 82 ZDDS shifts the VAT accounting from supplier to recipient. It applies to certain cross-border services between registered persons in the EU, construction services, and waste supplies. The invoice is marked "reverse charge".

When is an invoice invalid?

An invoice is defective if any of the 14 mandatory fields is missing, the number is duplicated, the VAT regime is wrong, or the recipient's VAT number is invalid. The recipient loses input VAT deduction rights and the supplier faces a penalty.

How much does VAT registration cost?

Mandatory VAT registration with NAP is free. It requires filing a Form Art. 96 ZDDS application within 14 days of crossing the threshold. Registration takes effect on the 14th of the following month. If you use an accountant, they will charge for paperwork (typically 50-200 BGN / 26-102 EUR).

What is PEPPOL?

PEPPOL (Pan-European Public Procurement OnLine) is a European network for standardised exchange of electronic invoices in UBL XML format. Since 2019 all EU public authorities have been required to accept invoices through it. Bulgaria has been progressively rolling out PEPPOL for B2G transactions since 2024.

Sources and further reading

All legal references in this article were taken from official sources and verified as of 2026-04-27.

Bulgarian legislation

VAT Act / ZDDS — lex.bg
Accounting Act / ZSch — lex.bg
VAT Implementation Regulations / PPZDDS — lex.bg
Tax-Insurance Procedure Code / DOPK — lex.bg

State institutions

National Revenue Agency (NAP) — e-services, forms, guidance
Bulgarian National Bank (BNB) — official daily exchange rates
Ministry of Finance — regulations and guidance

European resources

VIES — VAT number validation — European Commission
Directive 2006/112/EC — the EU VAT directive
PEPPOL official site — technical documentation

Last updated: 2026-04-27 Author: The Fakturka.bg team Legal review: Certified accountant, member of the Institute of Certified Public Accountants of Bulgaria

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