Executive summary

The State Budget Act for 2025 introduces the obligation for businesses to submit a Standard Audit File for Tax (SAF-T file), effective on 1 January 2026 for certain large entities.

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), depending on the size of their activities, could be obliged to submit as well.

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 different frequencies in the submission of the main parts of the file. 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 by 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 tax administration. 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 (1) whether it falls within the scope of the obliged persons and (2) when precisely the submission obligation enters into force.