Executive summary

The draft State Budget Act for 2025 includes amendments to the Tax and Social Security Procedure Code (TSSPC) that introduce the obligation for Bulgarian businesses to submit a Standard Audit File for Tax (SAF-T).

The SAF-T is an international standard for electronic exchange of data between taxpayers and tax authorities. The standard, developed by Organisation for Economic Co-operation and Development (OECD), has been introduced in a number of countries, the latest being Romania and Ukraine.

SAF-T details

Obliged persons

The reform comes into force in Bulgaria on 1 January 2026 for large enterprises meeting the cumulative conditions listed in the draft Law and, by 2030, will apply to almost all enterprises with minor exceptions (micro-enterprises, budget enterprises and others). Foreign businesses with presence in the country (e.g., in the form of a permanent establishment) could be obliged to submit as well, depending on the size of their activities.

A six-month "grace period" is envisaged for the first submission.

Frequency of reporting

To reduce the administrative burden related to the SAF-T, the reform provides for main portions of the file to be submitted at different times. Thus, submissions related to accounting entries, purchase and sale invoices and payments would be due by the 14th of each month. Information on assets should be submitted on an annual basis, and data on the movement of stocks will be due upon request from the National Revenue Agency (NRA).

Scope

The scope of SAF-T includes information on suppliers and customers, as well as data on purchase and sales invoices, payments, stock movements, assets and products. An order of the Executive Director of the NRA will specify details related to the scope of data required to fill in the SAF-T file, mandatory and optional sections and subsections and nomenclatures.

Implications

Companies affected by the SAF-T requirement in Bulgaria will want to contact their tax advisors for assistance in understanding their SAF-T obligations and preparing for compliance with the new information exchange requirements set by the NRA. Helpful approaches could include training on the implementation of SAF-T in Bulgaria as well as assistance with the submission. Regardless, as a first step, the crucial point will be for each business to assess whether it falls within the scope of "obliged persons" and, if so, when it will be required to submit its first SAF-T file.