No B2B mandate — the EU's CTC laggard

Unlike Italy, Poland or Romania, Bulgaria does not require companies to exchange electronic invoices. A "B2B e-invoice" (business-to-business) remains optional: it is only allowed with the buyer's consent. The country made a different choice — periodic accounting reporting (SAF-T) rather than invoice-by-invoice real-time control. It is the European Union, via the ViDA reform, that will set the binding deadline.

History — why Bulgaria never legislated

The European CTC wave started in 2014 with Italy's Sistema di Interscambio (SdI), extended to B2B in 2019. Over the following decade, Poland (KSeF), Romania (RO e-Factura), Serbia (SEF) and Hungary (RTIR) rolled out mandatory systems for invoice transmission or validation. Bulgaria, by contrast, tabled no bill requiring B2B e-invoicing.

The reasons are structural. Bulgaria concentrated its resources on two priority projects: euro adoption (effective 1 January 2026), which absorbed the tax administration and the БНБ (Bulgarian National Bank), and SAF-T, deemed sufficient to strengthen VAT control without the burden of a clearance platform. The country therefore prefers to wait for the EU to harmonise the rules through ViDA rather than build a national system it would later have to realign.

2014-2019  | Italy (SdI 2014, extended B2B 2019) triggers the EU "clearance"
           | CTC wave. Bulgaria does not follow.
           |
2019-11-01 | Transposition of Directive 2014/55/EU: obligation for
           | contracting authorities to RECEIVE B2G e-invoices (art. 115a
           | ЗОП Public Procurement Act). No B2B leg.
           |
2021-2024  | Poland (KSeF), Romania (RO e-Factura), Serbia (SEF) progressively
           | mandate B2B e-invoicing. Bulgaria stays back — no B2B bill tabled.
           |
2025-07    | SAF-T pilot (periodic accounting reporting), not a B2B e-invoice
           | clearance mandate. A deliberate non-CTC choice.
           |
2026-01-01 | SAF-T mandatory for large enterprises. B2B e-invoicing remains
           | voluntary, subject to buyer consent.
           |
2028-2030  | ViDA deadlines: structured e-invoicing by default for intra-EU
           | transactions, cross-border Digital Reporting Requirement (DRR)
           | mandatory on 1 July 2030. It is the EU — not Bulgaria — that will
           | impose the binding horizon.

Governance — buyer consent, art. 114 ЗДДС

The invoice regime in Bulgaria is set by the Закон за данък върху добавената стойност (ЗДДС — VAT Act), transposing Directive 2006/112/EC. Article 114 ЗДДС permits the electronic invoice provided the recipient accepts it ("при условие, че получателят е приел това"). This consent condition — a relic of the pre-ViDA VAT Directive — is precisely what ViDA will remove for intra-EU transactions.

No national body operates a B2B clearance platform. The NRA (Национална агенция за приходите) runs SAF-T (reporting) and B2G receiving; there is no Bulgarian equivalent of Italy's SdI or Poland's KSeF. Supervision is after the fact, by reconciling ДДС returns, purchase/sales ledgers and — since 2026 — SAF-T files.

Technical schema — the Bulgarian CTC void

There is currently no mandated invoice schema in domestic B2B. Bulgarian companies exchange under their private agreements: PDF, EDIFACT (large retail, industry), or UBL Peppol BIS for those connected to the Peppol network. The table below summarises the state of play.

Dimension                | Bulgaria status (June 2026)
-------------------------|----------------------------------------------
B2B e-invoice mandate    | NO — voluntary, buyer consent required
CTC / clearance model    | NO — no real-time validation
Periodic reporting       | YES — SAF-T large enterprises since 2026-01
B2G mandate (receiving)  | YES — since 2019-11, art. 115a ЗОП
Peppol network           | YES — voluntary access point, B2G
Binding deadline         | EU / ViDA cross-border DRR 2030-07-01

Bulgaria vs the European CTC wave

Bulgaria is, along with a few other Member States, one of the last in the EU without a national B2B calendar. Its trajectory now depends entirely on ViDA: Directive (EU) 2025/516 removes the buyer's consent for intra-EU transactions and mandates the cross-border DRR on 1 July 2030.

Adoption — where real B2B stands

• PDF dominant in domestic B2B. Without a mandate, most Bulgarian B2B invoices circulate as unstructured PDF or paper, especially among SMEs.
• EDIFACT in large retail and industry. Chains (Kaufland, Lidl, Billa) and major manufacturers impose EANCOM/EDIFACT on their suppliers by private contract — see the dedicated pages.
• Voluntary Peppol BIS. Growing for cross-border flows and B2G, driven by software vendors and Peppol access points.
• SAF-T as the first structuring milestone. Large enterprises moving to SAF-T in 2026 create the first structured-data obligation — a ramp toward the future ViDA DRR.

Common pitfalls

• Thinking "no mandate" = "nothing to do". B2G, SAF-T and ЗДДС particulars obligations apply regardless of the missing B2B mandate.
• Issuing an e-invoice without consent. In B2B, art. 114 ЗДДС requires the buyer's agreement. Forcing an electronic format without it is legally fragile.
• Waiting until 2030 to prepare. The ViDA DRR mandates a structured EN 16931 format on 1 July 2030; companies already under SAF-T will have a head start in structured data.
• Confusing B2G and B2B. The 2019 obligation (art. 115a ЗОП) only covers receiving by contracting authorities — it creates no obligation between private companies.

Cross-links

• Bulgaria hub — full view
• SAF-T 2026 — NRA rollout
• Peppol B2G — EN 16931 receiving
• ViDA Bulgaria 2026-2030
• ДДС — VAT regimes
• lex.bg — Закон за данък върху добавената стойност (ЗДДС)
• EUR-Lex — Directive 2014/55/EU