Summary

• Since November 2019, contracting authorities in Bulgaria must use eInvoices for public procurement, complying with EU standards. 

• Since 2018, sales and purchase registers with VAT returns are submitted electronically, covering all transaction types monthly. 

• Bulgaria is planning to adopt a mandatory eInvoicing model, drawing inspiration from Italy and France. 

Highlights

Bulgaria is moving towards a comprehensive mandatory eInvoicing model and advanced digital reporting mechanisms, inspired by successful implementations in other European countries. 

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Legislation

B2G

In the case of payment under public procurement contracts, all contracting authorities are obliged to accept and process eInvoices compliant with the European standard on eInvoicing. This is mandated in Article. 115a. State Gazette (SG) 86/18, in force from 1 November 2019, which transposed Directive 2014/55/EU.[1] 

On 1 July 2020, provisions entered into force regarding electronic means of communication for tender evaluation, conclusion of a contract, ordering, invoicing and payment. 

B2B

In Bulgaria, the use of eInvoicing in B2B transactions is currently optional. Businesses must mutually agree to adopt eInvoicing before they can incorporate it into their contracts. The Bulgarian VAT Act permits the use of eInvoicing in line with EU Directive 2010/45/EU, but there is no mandatory requirement for eInvoicing in B2B transactions. 

B2C

There is no business-to-consumer (B2C) mandate.  

Operating Model for eInvoicing

eInvoicing in Bulgaria is based on bilateral agreements between economic operators (or solution providers acting on their behalf) and public administrations.  

According to the practice of the Commission for Protection of Competition, resolutions for termination of a procedure with participants are served only through CAIS EPP. Article 9k, paragraph 1 of the Regulation for the Implementation of the Public Procurement Act states that the exchange of documents and communications between contracting authorities, candidates, participants and contractors is carried out through the platform.  

CAIS EPP notifies the participants of new publications in the Buyer’s Profile about the procedures in which they participate. 

It is specified that according to Article 9k, paragraph 3 of the Regulation for the Implementation of the Public Procurement Act, the users of the platform are obliged to monitor their profiles for notifications, messages and documents. CAIS EPP also notifies the participants of new publications in the Buyer’s Profile about the procedures in which they participate. 

Status on the implementation of the European eInvoicing standard

The most frequently syntax used when exchanging eInvoicing is XML. The European standard is mandatory by law for all the contracting authorities.  

Use of Core Invoicing Usage Specifications (CIUS) at national level   

 The LASPPA ensures the requirements of eInvoicing Directive transposition and the creation of the Central Automated Information System Electronic Public Procurement (CAIS EPP) as a national platform for electronic public procurement [2]. 

As of 2 May 2020, the Bulgarian PPA announced the renewal of the CAIS EPP, and the update to a 2nd version of the system was carried out. Several measures were implemented, with the aim of increasing the communication flow between public and private bodies.  

The system encompasses three different types of users, (i) the default option ‘economic operator’, (ii) “contracting entity” or (iii) “individual”. CAIS EPP is under the responsibility of the Public Procurement Agency in charge of its set-up and maintenance.  

Digital Reporting Requirements  

 Since January 2018, the sales and purchase registers jointly with VAT returns, shall be submitted electronically. Apart from the method of data transmission, no other changes have been introduced to this VAT reporting requirement.  

The obligation to submit sales and purchase registers apply to all taxable persons registered in Bulgaria for VAT, including non-resident businesses. 

Scope of requirements: 

• All transactions regardless of their value (i.e. there is no threshold). 

• B2B, B2G and B2C. 

• Sales and purchases. 

• Domestic, intra-EU and extra-EU transactions. 

On 4 July 2022, the NRA announced the implementation of a 24-month project aimed to introduce the use of SAF-T. The project is still in its early stages of development and is being rolled out with the support of the European Union.  

On 10 August 2022, the NRA released version 11.02 of the tool developed for generating VAT reports, VAT returns, and VAT Information Exchange System (VIES) returns. The tax authority further published an updated user guide reflecting recently adopted VAT amendments. This new release became effective on 7 September 2022. 

The National Revenue Agency (“NRA”) is considering the introduction of mandatory eInvoicing.  

Next steps  

 Bulgaria has initiated a public consultation to implement a mandatory clearance model for eInvoicing for all contracting entities, following the example of other European nations such as Italy and France. 

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[1] (Public Procurement Act, 2016), [2] (Republic of Bulgaria, 2021), [3] (OECD, 2021),  [4] (VAT in the Digital Age Report, 2022), [5] (Orbitax, 2023) 

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