On 25.07.2025, the National Revenue Agency (NRA) published the final order along with the technical annexes to it containing the deadlines, the content of the information, and some other rules regarding the implementation of SAF-T. The order was issued following numerous opinions and a public consultation.
There are three types of SAF-T files – monthly, annual, and upon demand by the NRA. What were the general official guidelines adopted for each type?
1. Regarding the monthly SAF-T File
The monthly SAF-T file consists of several sections:
1.1 Header Section – includes:
- Company information – name, UIC, VAT number, address, IBAN of the bank account, etc.;
- File parameters – file date, reporting period, currency;
- Software information – name of the software company, name of the software product, software version;
- Information on beneficial owners and group affiliation – filling out this section is optional.
1.2 MasterFiles Section – includes key accounting data, namely:
- GeneralLedgerAccounts – debit/credit balances at the beginning and end of the reporting period for each account separately;
- Customers – data is submitted for customers for whom transaction data is reported in the other sections of the file for the respective month;
- Suppliers – data is submitted for suppliers for whom transaction data is reported in the other sections of the file for the respective month;
- Products – data is submitted for all products recorded in the enterprise’s accounting for the respective month, regardless of whether transactions with them were carried out during that month;
- Tax Table;
- UOM (Units of Measure) Table.
1.3 GeneralLedgerEntries Section – includes all accounting transactions during the reporting period.
1.4 SourceDocuments Section, with the following subsections:
- Sales Invoices – issued invoices for the period and related credit/debit notes. In cases of self-assessed VAT protocols for intra-community acquisitions or customs declarations, those documents are reported instead of the related invoices;
- Purchase Invoices – received invoices for the period and related credit/debit notes;
- Payments – payments made and received during the period.
1.5 CorrespondingAccountsReport Section – optional for submission.
1.6 Structures Section.
Each mandatory section and subsection has specific required fields.
The SAF-T file structure also includes optional sections and subsections. Examples include the Corresponding Accounts Report, Owners, and others. The absence of data in these optional sections will not result in the file being rejected or in other negative consequences for the company.
An example of a monthly XML SAF-T file is provided in Annex No 1 to the NRA Order.
The submission is done monthly, by the 14th of the following month, electronically via the NRA portal using a qualified electronic signature (QES) or through an API. In case of discrepancies, the NRA returns the file and provides a 7-day deadline for corrections. Corrections are submitted through a new file for the same period.
There is a mechanism for accounting errors from previous periods and for referencing corrections to those periods.
2. Regarding the annual SAF-T File
The annual SAF-T file contains information on the company’s fixed tangible assets within the following sections:
2.1 Header Section
2.2 MasterFiles Section, with the following subsections:
- Owners – optional for submission;
- Assets – includes data such as the acquisition date, value, depreciation method, accumulated depreciation, and book value of each asset.
2.3 SourceDocuments Section, with the subsection:
- Asset Transactions – acquisition, sale, revaluation, disposal, and other asset-related events.
An example of an annual XML file is provided in Annex No. 1 to the NRA Order.
The file shall be submitted once per year, within the deadline for submitting the annual corporate income tax return under Art. 92 of the Corporate Income Tax Act.
3. Regarding the on-demand SAF-T File (upon NRA’s demand)
The SAF-T file submitted upon demand by the NRA contains data on inventories and the movement of goods, and includes:
3.1 Header Section;
3.2 MasterFiles Section, with the following subsections:
- Tax Table – optional for submission;
- Units of Measure Table (UOMTable);
- Movement Type Table;
- Products;
- PhysicalStock;
- Owners – optional for submission.
3.3 SourceDocuments Section, with the subsection:
- Movement of Goods.
An example XML file for the SAF-T on-demand is provided in Annex No 1 to the Order.
The submission is required only upon formal demand by the NRA, during an audit or inspection, within 14 days of the demand.
4. Some specific requirements for submitting information via the SAF-T file
The requirements concern the data submission:
- by banks within the meaning of the Credit Institutions Act;
- by insurance and reinsurance companies, as well as insurance brokers and agents;
- by medical establishments;
- in cases of identified accounting errors;
- for supplies for which, under the Value Added Tax Act, issuing an invoice or protocol is not mandatory;
- in the SourceDocuments section, under the Purchase Invoices subsection, for documents/invoices related to expenses for the purchase of items with classified product codes, which are immediately expensed and not subject to controlled storage, and for which data is not required to be submitted in the MasterFiles, Products subsection, as well as expenses that are accounted for as current period expenses, in the period in which they were incurred;
- for documents (invoices) in the SourceDocuments section;
- in the TaxInformation section.
The information above is in addition to our article on the introduction of the SAF-T file: https://ivlawfirm.com/en/new-saf-t-obligations-in-bulgaria/.
The order of the Executive Director of the NRA with the appendices can be seen here: https://nra.bg/wps/portal/nra/proekti/sistema-za-schetovodno-otchitane/sistema-za-schetovodno-otchitane.
Compliance with the requirements for submitting the SAF-T file presents businesses with the need to invest in software products for synchronizing and processing commercial and accounting information from the companies’ diverse internal registers, as well as in training human resources.
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.
