In the special issue No. 26 of the State Gazette, amendments were promulgated to Chapter Eight “b” of the Tax and Social Security Procedure Code (“TSSPC”) and to the State Budget Act of the Republic of Bulgaria for 2025, introducing the obligation for submitting the so-called Standard Audit File for Tax purposes (“SAF-T report”) starting from the beginning of 2026. This is an international standard for submitting accounting data in a unified format from taxpayers to the tax administration, developed by the Organisation for Economic Co-operation and Development (“OECD”).

The obligation to submit SAF-T reports will apply to companies (including branches of foreign traders), sole proprietors, consortia, civil partnerships, joint ventures, other contractual associations in which the parties hold rights to net assets, and local legal entities that are not traders, but carry out economic activity in the country.

As an exception to the general rule above, micro-enterprises, according to the criteria of the Accounting Act (“AA”), are exempt from the obligation to submit SAF-T reports if they are not registered under the Value Added Tax Act (“VATA”). Also excluded from the scope of the new framework are budgetary enterprises, payment funds, insurance funds, trade representations, and other local legal entities not engaged in commercial activity in Bulgaria.

SAF-T reporting will be introduced gradually over a 5-year period.

In other words, the obligation to initially submit SAF-T reports will arise at different times for different types of obligated entities. The criteria are related to the type of enterprise under the AA – large, medium, small, or micro-enterprise – and other specific economic indicators related to the scale of business activity.

For example, large enterprises with annual net revenues exceeding BGN 300 million or paid annual net tax and social security contributions over BGN 3.5 million for 2023 must begin complying with the new framework as of 01.01.2026.

As of 01.01.2027, on the other hand, the obligation to submit a SAF-T report will arise for all large, medium, and small enterprises with annual net revenues over BGN 300 million or annual net tax and social security contributions over BGN 3.5 million for 2024.

The ultimate goal is for the framework to apply to all entities covered by the law by 01.01.2030, including micro-enterprises registered under the VATA.

What information will be submitted in the SAF-T reports?

SAF-T reports will include detailed business and accounting information, such as:

• Identification data of the company and its ultimate beneficial owners;

• Chart of accounts and all accounting entries;

• All purchase and sales invoices, including all suppliers and customers;

• All incoming and outgoing payments, including payment methods;

• All available fixed assets and inventories, as well as their movements;

• Data dictionaries for the submitted information and tax codes for the file.

As a general rule, SAF-T reports will be submitted on a monthly basis, similar to the deadlines for submitting the VAT declaration – by the 14th day of the month following the month to which the data relates.

Certain categories of data (information on fixed assets, including inventories, movements, and accrued accounting and tax depreciation) will be submitted annually, within the deadline for filing the annual corporate income tax return under Art. 92 of the Corporate Income Tax Act.

Naturally, the National Revenue Agency (NRA) may request specific SAF-T-related information, in which case the obligated entity will have to submit a report “upon request,” regardless of the above-mentioned deadlines.

Reports will be submitted electronically using a qualified electronic signature, which is another step towards the digitalization of public administration and is expected to ease the process for obligated entities.

A procedure is also provided for correcting submitted reports in the event that inaccuracies are discovered.

Failure to submit SAF-T reports within the prescribed deadline may result in property sanctions of up to BGN 15,000 per violation and BGN 30,000 in cases of recurrence.

Undoubtedly, the new framework marks another important step towards greater transparency in commercial activity in the country and the alignment of local legislation with EU law. Businesses should carefully analyze, based on the relevant economic indicators, whether the new regulation applies to them and, if so, from what date the obligation to submit SAF-T reports will arise.