Bulgaria proposes a higher VAT threshold and structured e-invoicing from 2028

Bulgaria's Ministry of Finance has published a draft amendment to the Value Added Tax Act. It would raise the mandatory VAT registration threshold from 1 January 2027, and require structured e-invoices for domestic B2B sales from 1 January 2028. The draft is a proposal. It must be approved by the Council of Ministers and adopted by the National Assembly before it applies.

The draft is on the Ministry's legislation page (in Bulgarian). The Ministry's partial preliminary impact assessment sets out the reasoning.

What is proposed

• Registration threshold from 1 January 2027. The mandatory VAT registration threshold would rise from €51,130 to €75,000. The Ministry says the current level encourages businesses to split turnover to stay below it.
• Structured e-invoices from 1 January 2028. Structured e-invoicing would apply to supplies whose tax event falls after that date, and to advance payments received after that date. It would cover domestic supplies between VAT-registered businesses. The Ministry's assessment says the invoice follows the European standard under Directive 2014/55/EU.
• Unique compliance code. An invoice counts as issued once the National Revenue Agency's system generates a unique compliance code for it. The invoice is then processed in the national information system for structured e-invoicing and digital reporting.
• No more purchase and sales ledgers from 1 January 2028. The VAT purchase and sales ledgers would be abolished. The Revenue Agency would prepare a draft VAT return from the structured invoice data.
• Testing access. The Revenue Agency would give businesses access to test their integration with the system six months before the law takes effect.

The Minister of Finance would set the technical format rules in an ordinance, due within six months of the law's publication.

What to do now

• Watch the final text. Dates and thresholds can change during consultation and parliamentary review.
• If you invoice Bulgarian businesses, plan for structured invoice data before 2028. Your invoices will need the fields the ordinance requires, and each one will need the compliance code.
• Test in the sandbox once the format rules are published, before the 2028 start.