The Tax and Social Security Procedure Code (TSSPC) has been amended with the Transitional and Final Provisions to the State Budget Act of the Republic of Bulgaria for 2025, promulgated in the State Gazette on 27th of March 2025.
A new obligation has been introduced for the submission of a Standard Audit File for Tax (SAF-T), for which an entirely new chapter has been added to the TSSPC. The SAF-T was developed by the Organisation for Economic Co-operation and Development) (OECD) and has already been implemented in several countries.
As stated by the National Revenue Agency (NRA), the purpose of SAF-T file is to achieve better, more targeted, and timely communication between taxable entities and the revenue authorities, more effective risk management for the public finances (both at the national and EU level), reduction of the administrative burden on businesses and the tax administration, enhancement of voluntary compliance by taxable entities, etc.
A scheme for implementation of the SAF-T system in Bulgaria has been developed, where:
- 31st of March 2025 – entry into force of the legal amendments, i.e., the amendments to the TSSPC;
- 1st of July 2025 – 31st of December 2025 – testing period: trial submission of SAF-T files by large taxable entities which meet the criteria for obligatory submission of SAF-T file as of 1st of January 2026 and which have been invited and have given their consent to participate in the testing phase;
- 1st of January 2026 – Phase 1 – obligatory implementation of SAF-T system begins, but only for large enterprises as defined in Art. 19, para. 1 of the Accounting Act (AA) as of 31st of December 2023, and which meet at least one of the following conditions: the net income from sales for 2023 exceeds BGN 300,000,000 or in 2023, the amounts received in the NRA’s accounts from taxes and social security contributions, reduced by refunded amounts, exceed BGN 3,500,000;
- 1st of January 2027 – Phase 2 – SAF-T system becomes obligatory for large, medium-sized, and small enterprises as defined in Art. 19, para. 1 of the AA as of 31st of December 2024, and which meet at least one of the following conditions: the net income from sales for 2024 exceeds BGN 300,000,000 or in 2024, the amounts received in the NRA’s accounts from taxes and social security contributions, reduced by refunded amounts, exceed BGN 3,500,000;
- 1st of January 2028 – Phase 3 – SAF-T system becomes obligatory for large, medium-sized, and small enterprises as defined in Art. 19, para. 1 of the AA as of 31st of December 2025, and which meet at least one of the following conditions: the net income from sales for 2025 exceeds BGN 15,000,000; or in 2025, the amounts received in the NRA’s accounts from taxes and social security contributions, reduced by refunded amounts, exceed BGN 1,500,000;
- 1st of January 2029 – Phase 4 – SAF-T system becomes obligatory for large, medium-sized, and small enterprises as defined in Art. 19, para. 1 of the AA, as of 31st December 2026;
- 1st of January 2030 – Phase 5 – SAF-T system becomes mandatory for micro-enterprises, as defined in Art. 19 of the AA, that are registered under the VATA.
Entities subject to the obligation for submission of the SAF-T file are those under Art. 2 of the AA, excepted for:
- micro-enterprises as defined in Art. 19, para. 1 of the AA, which are not registered under the VATA;
- local legal entities that are not traders and do not carry out activities within the meaning of Art. 1 of the Commercial Act;
- budgetary enterprises;
- payment funds and insurance funds within the meaning of the Social Security Code;
- representative offices.
The SAF-T file shall be submitted in a standardised format, and contain data about the economic activity and accounting records of the obligated person, namely:
- information from purchase and sales documents, including data about clients and suppliers;
- data about the payments, including method of payment;
- information on the fixed tangible assets, including availability, movements, and assessed accounting and tax depreciation;
- inventory data, including availability and movements;
- standardised taxonomies used for submission;
- technical data regarding the submitted SAF-T file and software, source of the data in the file.
The SAF-T file shall be submitted monthly, by the 14th day of the month following the reporting period, except for:
- information on the availability and movements of fixed tangible assets and inventories, which shall be submitted within the deadline for submission of the annual corporate income tax return under Art. 92 of the Corporate Income Tax Act;
- information on inventory availability and inventory movement – submitted upon request by the revenue authority, within a term specified by the authority.
Submission of the SAF-T file shall be done electronically, using a qualified electronic signature.
Failure to submit the SAF-T file within the legal term is subject to administrative penalties: fines for individuals and pecuniary sanctions for legal entities.
The present article is for information purposes only. It is not a (binding) legal advice. For a thorough understanding of the subjects covered and prior acting on any issue discussed we kindly recommend Readers consult Ilieva, Voutcheva & Co. Law Firm attorneys at law.
