Not law: Bulgaria drafts mandatory B2B/B2G structured e-invoicing from 2028

What changed in detail

This is a draft, not law. Bulgaria’s Ministry of Finance published a draft law amending the VAT Act on 23 September 2026, open for public consultation (No. 12733-K) until 23 October 2026. The draft would require VAT-registered suppliers established in Bulgaria to issue structured electronic invoices for supplies taxable in Bulgaria — including advance payments — where the recipient is established in Bulgaria and is a taxable person, a non-taxable legal person, or the state or a public authority. Under the draft’s transitional provisions, the e-invoicing paragraphs would take effect 1 January 2028, with one provision (article 182a) taking effect 1 July 2028. The draft still requires adoption by the Council of Ministers and the National Assembly before it has any legal effect.

What it means

This puts Bulgaria on the same trajectory as the EU’s broader VAT-in-the-Digital-Age structured-invoicing direction, with a domestic B2B/B2G mandate rather than only a cross-border one. The scope as drafted is domestic-to-domestic — a Bulgarian-established supplier invoicing a Bulgarian-established recipient — so cross-border supplies are not described by this draft’s language. With a 2028 effective date and the draft still in consultation, there is no near-term system requirement, but ERP and invoicing vendors serving the Bulgarian market have a multi-year runway to watch this move from draft to enacted law.