Complete Guide to Invoicing in Bulgaria 2026

2026-04-27

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

💶 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% (hotel and holiday accommodation and campsites, books and periodicals (including electronic ones), and baby food and baby hygiene products listed in Annex 4 — ZDDS Art. 66a) and 0% (exports, intra-EU supplies).

Mandatory VAT registration threshold: taxable turnover above 51,130 EUR in a calendar year (ZDDS Art. 96, in force from 1 January 2026).

Free tooling: Fakturka.bg offers 15 invoices/month → 5 for accounts registered from 26.10.2026 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

ZDDS Art. 180 and Art. 182 penalties are not fixed "from–to" amounts — they are calculated on the tax itself. The statute states them in BGN; the EUR figures are the equivalents at the fixed rate of 1.95583.

Tax document not issued (or not recorded in the VAT ledgers), resulting in a lower VAT payable or a higher VAT refundable for the period — ZDDS Art. 182 §1: the amount of the uncharged tax, or of the tax shown on the unrecorded document, but no less than 1,000 BGN (511.29 EUR).
If the document is issued or recorded in the following tax period — Art. 182 §2: 25 per cent of the tax, but no less than 250 BGN (127.82 EUR).
Failure to charge VAT within the statutory deadline — Art. 180 §1: the amount of the uncharged tax, but no less than 500 BGN (255.65 EUR); on a repeat offence, double the uncharged tax, but no less than 1,000 BGN (511.29 EUR).
If the tax is charged late but within 6 months of the end of the month in which it should have been charged — 5 per cent of the tax, but no less than 200 BGN (102.26 EUR), and no less than 400 BGN (204.52 EUR) on a repeat offence (Art. 180 §3); after that, but no later than 18 months — 10 per cent, but no less than 400 BGN (204.52 EUR), and no less than 800 BGN (409.03 EUR) on a repeat offence (Art. 180 §4).
The amounts are the same for individuals and for legal entities. The statute differs only in the label: a fine (глоба) for individuals who are not traders, a pecuniary sanction (имуществена санкция) for legal entities and sole traders.
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. 114(7)	Taxable amount + VAT up to 100 EUR	A normal invoice that may omit three of the 15 particulars

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

Bulgarian law has no separate “simplified invoice” document — ZDDS Art. 112(1) lists exactly three tax documents (invoice, note to an invoice, protocol). What is called a simplified invoice is an ordinary invoice that, under ZDDS Art. 114(7), may omit three of the 15 particulars of Art. 114(1) — the tax rate (item 12), the amount payable where it differs from the taxable amount plus the tax (item 14), and the new means of transport details (item 15) — when the taxable amount and the tax together do not exceed 100 EUR. Art. 114(7) itself excludes supplies with a place of supply in another member state, intra-Community supplies and distance sales of goods. Everything else, including the recipient's name, address and number, stays mandatory — without it there is no input VAT credit under Art. 71(1).

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% (hotel and holiday accommodation and campsites, books and periodicals (including electronic ones), and baby food and baby hygiene products listed in Annex 4 — ZDDS Art. 66a).
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

A signature and a stamp are not among the mandatory invoice particulars listed in ZDDS Art. 114(1), nor in the minimum content required by Accounting Act Art. 6(1). The absence of a handwritten signature does not make an electronic invoice irregular, provided the recipient has accepted electronic invoicing (ZDDS Art. 114(9)) and the issuer ensures authenticity of origin, integrity of content and legibility (ZDDS Art. 114(6) and (10)).

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

Art. 12(1) of the Accounting Act (ZSch) sets exactly three periods — the Act has no "primary documents" category and no five-year period:

Payroll records: 50 years (item 1).
Accounting registers and financial statements, including documents for tax control, audit and subsequent financial inspections: 10 years (item 2).
All other carriers of accounting information: three years (item 3).

All three run "from 1 January of the reporting period following the reporting period they relate to".

Invoices and other tax documents are governed separately by ZDDS Art. 121(1): they must be kept for 5 years after the limitation period expires for the public liability they evidence.

The detail that decides the arithmetic: the 5-year limitation period under DOPK Art. 171(1) runs "from 1 January of the year following the year in which the liability fell due". For an invoice issued in 2026 the limitation period expires on 31.12.2031, and the five years under ZDDS Art. 121(1) on 31.12.2036. So the practical recommendation (not a verbatim statutory term) is to keep invoices for about 11 years from the issue date — 10 years after the end of the year of issue. If the limitation period is suspended or interrupted, the ceiling is the absolute 10-year limitation period under DOPK Art. 171(2), which stretches retention to roughly 15 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	Accommodation and campsites · books and periodicals · baby food and baby hygiene products (ZDDS Art. 66a)
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 taxable turnover above 51,130 EUR in a calendar year (in force from 1 January 2026). 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 of goods, supplies as an intermediary in a triangular operation, and Art. 21(2) services to a VAT-registered customer in another member state.
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 generates PEPPOL BIS 3.0 documents (beta, Business plan only; see "SPECIALIZED → PEPPOL" in the dashboard). It is not yet connected to an Access Point, so delivery over the PEPPOL network requires your own Access Point, key and participant. It supports:

Generating the BIS Billing 3.0 (UBL 2.1) document from the invoice.
Validating key EN 16931 rules before sending.

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 your taxable turnover for the calendar year is below 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 Chapter 21b (Art. 168b–168m)

From 1 January 2026 Bulgaria applies the special EU SME scheme, which lets a small enterprise sell into other member states without registering for VAT locally, as long as its annual Union turnover stays at or below the Union threshold of 100,000 EUR (ZDDS Art. 168e §3). Annual Union turnover is not "cross-border turnover" — it includes the supplies made in Bulgaria as well as those in every other member state (ZDDS Art. 168c §11). A second, cumulative condition applies: the national threshold of each member state in which the scheme is to be used must also not be exceeded (Art. 168e §1(3)).

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

Under ZDDS Art. 179–182 the amounts are the same for individuals who are not traders (a fine) and for legal entities and sole traders (a pecuniary sanction). The statute states them in BGN; EUR figures are the equivalents at 1.95583.

Breach	Penalty
Tax document not issued or not recorded, resulting in less VAT payable (Art. 182 §1)	The amount of the uncharged tax, but no less than 1,000 BGN (511.29 EUR)
Same, but the document is issued/recorded in the following tax period (Art. 182 §2)	25 per cent of the tax, but no less than 250 BGN (127.82 EUR)
VAT not charged within the statutory deadline (Art. 180 §1)	The amount of the uncharged tax, but no less than 500 BGN (255.65 EUR); repeat offence — double, but no less than 1,000 BGN (511.29 EUR)
VAT charged late, within 6 / within 18 months of the end of the month in which it should have been charged (Art. 180 §3 and §4)	5 per cent, min. 200 BGN (102.26 EUR) / 10 per cent, min. 400 BGN (204.52 EUR); repeat offence — min. 400 BGN (204.52 EUR) / min. 800 BGN (409.03 EUR)
VAT return not filed, or filed late (Art. 179 §1)	500 – 10,000 BGN (255.65 – 5,112.92 EUR)
VIES return not filed, or filed late (Art. 179 §1)	500 – 10,000 BGN (255.65 – 5,112.92 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).
SAF-T working export with one click — for review; not yet the official file for NAP.
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 → 5 for accounts registered from 26.10.2026. No hidden fees, no credit card on signup, no trial period. Ideal for freelancers, small companies and startups.

Paid plans (Pro 7.50 EUR per month → EUR 12.90 from 01.12.2026, Business 15 EUR per month → EUR 29.90 from 01.12.2026) 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?

Art. 12(1) of the Accounting Act sets three periods: payroll records — 50 years (item 1), accounting registers and financial statements, including documents for tax control — 10 years (item 2), all other carriers of accounting information — three years (item 3). There is no five-year period in Art. 12. Invoices themselves fall under ZDDS Art. 121(1) — 5 years after the limitation period expires (5 years under DOPK Art. 171(1)) — so in practice keep them about 11 years from the issue date. 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 your taxable turnover for the calendar year is below 51,130 EUR, 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 7 days of the date on which the threshold is exceeded (ZDDS Art. 96 §6(1)). Registration takes effect on the day following that date (ZDDS Art. 103(1)) — not on a later date tied to the application. 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 Scope: this article is for information only and is not a substitute for tax or legal advice.

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