The accounting memorandum: the document your accountant writes for itself

The accounting memorandum: an internal document with no invoice behind it

If you ever look through your Bulgarian company's accounting folder, you will eventually run into a document called an accounting memorandum, in Bulgarian счетоводна справка, that does not resemble any invoice or receipt you have seen. Here is what it actually is.

• An accounting memorandum is an internal primary accounting document. Your accountant writes it themselves, it does not come from a supplier, a client, or a bank.
• It serves two purposes: to record a transaction for which no external document exists or can exist, or to summarize and derive a figure already recorded elsewhere in the books, for example the total accrued payroll for the month.
• It belongs to the broader category of "primary accounting documents," the paperwork every bookkeeping entry has to rest on. The difference from an invoice is that it originates inside the company, not outside it.
• On its own, a memorandum does not prove a transaction happened with a third party. It is an internal tool that justifies why the accountant made a particular entry.

If you spot one of these in your accounting software or in the monthly document folder, it is not misfiled among your invoices. It explains the logic behind a specific bookkeeping entry, it does not evidence a payment or a delivery.

When your accountant writes an accounting memorandum

An accounting memorandum shows up wherever a calculation or a judgment call is needed, rather than simply registering an external document. The most common situations are these.

• Accruals: interest accrued but not yet paid on a loan, rent accrued for a month whose invoice has not arrived yet, unused staff leave accrued for the period.
• Corrections and reclassifications: moving an amount from one account to another because of an error in the original entry, or because a payment was initially booked to the wrong category.
• Depreciation: the monthly depreciation charge on a company's fixed assets, laptops, cars, equipment, does not arrive with an invoice every month. It is calculated and booked through an accounting memorandum.
• Period-end and year-end closing entries: transferring income and expense accounts, allocating shared costs across activities or locations.
• Foreign-currency revaluation: receivables, payables, or cash held in a currency other than the euro get revalued as of the balance sheet date, and the difference is booked through a memorandum.
• The basis for a journal voucher: the accounting memorandum is often the supporting document behind a мемориален ордер, the journal voucher that actually posts the entry into the ledgers and the trial balance.

In every one of these cases, the memorandum answers the same question: why this exact amount was booked on this date, to these accounts.

Mandatory content under the Accounting Act

An accounting memorandum is not free-form text an accountant writes however they like. The Bulgarian Accounting Act, Article 6, sets requirements for the content of every primary accounting document, internal ones included, for it to count as a valid basis for an entry.

• Name and number: the document has to be titled as an accounting memorandum, or an equivalent term, and carry a number so it can be traced and retrieved later.
• Date of issue: the day the accountant actually prepared the document, if that differs from the date of the underlying transaction.
• Issuer: the company's name and the person who prepared the document, usually the accountant or the responsible staff member.
• Subject and basis of the operation: a short but specific description of exactly what is being booked and why, for example depreciation accrued for a given month on fixed assets under the depreciation schedule.
• Amount: the exact figure being booked, in euro.
• Signature of the preparer: the person responsible for the accuracy of the document's data.

Missing any of these elements makes the memorandum a weak basis for the entry it supports, and in a tax audit, poorly justified internal documents are the first thing inspectors question.

Internal vs. external documents: memorandum vs. invoice

The internal-versus-external distinction sounds like a technicality, but it has direct consequences for how a document holds up in an audit by NRA or an auditor.

• An external document, an invoice, a receipt, a bank statement, is issued by a third party, a supplier, a client, or a bank, and confirms that a transaction actually took place between two independent parties.
• An internal document, an accounting memorandum, is issued by the company for the company. It does not prove a transaction with a third party, it justifies an accounting judgment or calculation.
• That is exactly why internal documents get more scrutiny in an audit: there is no counterparty to confirm the amount, so the accuracy of the Article 6 elements and the soundness of the stated basis are the company's only defense.
• An accounting memorandum never replaces an invoice when a real delivery or service from an outside supplier exists. If the supplier is real but the invoice is missing, the fix is to chase the invoice, not to write an internal memorandum instead of it.

In short: the memorandum is a tool for situations where, by definition, nobody can issue you an invoice, not a substitute for one you lost or never received.

A practical checklist: what a solid accounting memorandum looks like

If you keep an eye on part of your own bookkeeping, or just want to understand what your accountant is doing, these points help you recognize a properly prepared memorandum.

• Check that the memorandum has its own number and date, separate from the date of the underlying transaction it describes.
• Read the stated basis: one sentence should be enough for you to understand why that specific entry was made, even without an accounting background.
• Check the amount against the calculation behind it, a depreciation schedule, the day's exchange rate, a computed ratio, do not take the final figure at face value.
• Make sure the document carries the preparer's signature. A memorandum without a signature is an unfinished document.
• Keep memoranda together with the rest of the year's accounting records, even when they do not look like a "real" document. In an NRA audit, these are exactly what explains the logic behind closing and correcting entries.

An accounting memorandum is not bureaucracy for its own sake. It is how the books stay traceable even when there is no invoice behind a given figure.

The memorandum is one piece of a bigger documentation picture

The accounting memorandum is one of several types of primary documents you run into as a small company owner, alongside invoices, cash receipts, and the annual financial statement. Understanding which role each one plays makes conversations with your accountant a lot easier.

Useful next reads:

Which expenses ЗКПО recognizes and how to document them
How VAT and tax filing will work with FreeMe.bg
When you actually need an accountant or a consultant
The annual financial statement: what it contains and why it matters

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