On 25 July 2025, the National Revenue Agency (NRA) published an Order of the Executive Director under Art. 71k, para. 4 of the Tax and Social Security Procedural Code (TSSPC), which regulates the format and procedure for submitting a Standard Audit File for Tax (SAF-T).
Order of the Executive Director of the NRA
At the end of March this year, amendments were made to the Tax and Social Security Procedural Code (TSSPC), which introduced mandatory SAF-T reporting in Bulgaria (previous publication of KPMG on the topic – here). The detailed requirements regarding the format and procedure for submitting the new report were expected to be specified in an order issued by the Executive Director of the NRA.
A draft version of the order was published by the revenue agency in early May, providing the public with an opportunity to submit comments and suggestions. As a result of the public consultations and the feedback received, the NRA published a summary of the input provided by businesses. This summary indicates that the tax authorities accepted, in whole or in part, more than 130 suggestions. This is reflected in the final version of the Order of the Executive Director of the NRA and its annexes (“the technical documentation”), published on 25 July 2025.
As already noted, the technical documentation regulates the format of the SAF-T report, the procedure for its submission, the nomenclatures for standardizing the reportable information, as well as the related validation rules.
In addition, three XML files – for the monthly, annual, and upon-request SAF-T reports – are included in the package of documents issued on 25 July 2025, along with additional clarifications regarding data reporting in certain specific situations (for example: accounting errors; supplies for which the issuance of an invoice or protocol is not mandatory as per the VAT Act; purchases related to consumables such as stationery or utilities; imports and ICAs; etc.).
Next steps
The technical documentation published on 25 July 2025 is currently final and should serve as a basis for setting up the systems and the technological solutions for generating SAF-T reports used(or to be used) by the business. Since the matter is an evolving topic, further changes cannot be excluded and should be closely monitored. Additional guidance related to SAF-T reporting is also expected to build up over time, following a Q&A approach, for which the NRA has provided a dedicated communication channel.
KPMG’s Assistance
The KPMG team has a ready-made solution for assistance at every stage of the process of introducing mandatory SAF-T reporting:
- Data mapping – comparing and mapping the data available in the entity’s IT system against the legal requirements.
- Coding of algorithms for extracting data from the company's IT system and converting them into the legally prescribed format.
- A technological solution for generating a valid SAF-T report, developed and maintained by KPMG.
- Outsourced SAF-T compliance, where the obligation to prepare, sign and submit SAF-T reports is assigned to KPMG.
Contact us for more information and request an offer for assistance which will be tailored according to your needs.
For information
Ivan Vargoulev
Associate Partner, Tax
Tel: +359 (2) 9697 700
Antoaneta Krasteva
Senior Manager, Tax
Tel: +359 (2) 9697 700
