How to Choose an E-Invoicing Provider Compliant with Bulgarian Tax Laws

Choosing an e-invoicing provider compliant with Bulgarian tax laws means proving the vendor handles four current obligations (ZDDS VAT invoice, Accountancy Act records, B2G Peppol, QES signing) and two upcoming ones (SAF-T BG on your wave, the planned NRA clearance regime). Use the framework below as a vendor-RFP scoring grid.

The 8-criterion framework

The 8-criterion framework includes: ZDDS-compliant invoice field set (BG VAT, 20%/9%/0%, reverse-charge under art. 82 / art.

1. ZDDS-compliant invoice field set (BG VAT, 20%/9%/0%, reverse-charge under art.82 / art.163a).
2. Sequential invoice numbering without gaps (chronologic, per art.114 ZDDS).
3. Accountancy Act compliant retention (10 years, immutable archive).
4. SAF-T BG XML generation for the SourceDocuments (monthly), MasterFiles (annual), GeneralLedger (on demand) blocks.
5. Peppol BIS Billing 3.0 routing for B2G via certified Access Point.
6. Qualified Electronic Signature support (BG QES TSP integration for SAF-T envelopes and B2G PDFs).
7. Roadmap and contractual commitment for the upcoming domestic B2B CTC mandate.
8. Auditability: full audit log linking each invoice to its lifecycle events, the SAF-T export, and any Peppol receipts.

ZDDS field coverage

ZDDS art. 114 mandates: sequential invoice number, date, supplier and recipient details (incl.

ZDDS art.114 mandates: sequential invoice number, date, supplier and recipient details (incl. BG VAT identification number), description, quantity, unit price, tax base, VAT rate and amount, total. Reverse-charge invoices must carry the explicit "обратно начисляване" annotation plus the legal basis (art.82 c.2 / art.163a). Triangulation under art.65a must be flagged. Verify the vendor renders all of this on the standard PDF and in the SAF-T SourceDocuments block.

Accountancy Act retention

Bulgarian Accountancy Act (Закон за счетоводството) art. 12 requires 10-year retention of primary accounting documents, including invoices.

Bulgarian Accountancy Act (Закон за счетоводството) art.12 requires 10-year retention of primary accounting documents, including invoices. The archive must be immutable and addressable per document. Look for object-lock or WORM-equivalent guarantees, not just "we keep backups".

SAF-T BG readiness

The NRA published the SAF-T BG technical specification with the OECD SAF-T 2. 0 base schema plus Bulgarian code lists.

The NRA published the SAF-T BG technical specification with the OECD SAF-T 2.0 base schema plus Bulgarian code lists. Verify the provider:

• Generates conformant SourceDocuments (sales, purchases, payments, movements of goods).
• Generates conformant MasterFiles (chart of accounts, customers, suppliers, tax codes).
• Generates the on-demand GeneralLedger.
• Signs the envelope with a BG-qualified electronic signature before submission.
• Submits through the NRA portal (or guides you through the manual submission).

Peppol B2G

Public Procurement Act art. 39a mandates Peppol for tenders.

Public Procurement Act art.39a mandates Peppol for tenders. The provider must hold (or partner with) a certified Peppol Access Point and register your business under scheme 9938:VAT-number. Verify the provider can show buyer-side acceptance from at least one major Bulgarian public buyer.

Future CTC clearance

The Ministry of Finance consultation paper points to a clearance-style regime on the Italian SdI model.

The Ministry of Finance consultation paper points to a clearance-style regime on the Italian SdI model. The provider's roadmap should commit to:

• Live integration on the official go-live date (large enterprises first).
• Schema and code-list updates without customer downtime.
• Sandbox availability at least 6 months before the live date.

Vendor RFP questions

Vendor RFP questions includes: "Show me an end-to-end ZDDS reverse-charge invoice under art. 163a in your demo.

• "Show me an end-to-end ZDDS reverse-charge invoice under art.163a in your demo."
• "Generate a sample SAF-T BG SourceDocuments file for my chart of accounts."
• "Which BG QES TSP do you integrate for envelope signing?"
• "Which Peppol Access Point operator do you use, and what is your SLA?"
• "What is your commitment date for the NRA domestic CTC mandate?"
• "What is your retention architecture under Accountancy Act art.12?"

Key takeaways

Key takeaways includes: Compliance is multi-surface: ZDDS invoices today, SAF-T tomorrow, CTC the day after. Treat the SAF-T and CTC roadmap as contract terms, not marketing.

• Compliance is multi-surface: ZDDS invoices today, SAF-T tomorrow, CTC the day after.
• Treat the SAF-T and CTC roadmap as contract terms, not marketing.
• Peppol B2G is non-negotiable if you ever tender for public contracts.

Authority sources

• NRA Bulgaria — official portal
• Agency for Public Procurement
• Ministry of Finance

Related reading

Related reading includes: NRA Bulgaria explained Best platforms for Bulgarian SMBs

• NRA Bulgaria explained
• Best platforms for Bulgarian SMBs
• 12-point multi-jurisdiction checklist