Do You Actually Need a Cash Register in Bulgaria?

When a fiscal device is legally required

What Bulgarians call a "cash register" (касов апарат) is, more precisely, a fiscal device: a machine registered with NAP, Bulgaria's National Revenue Agency, that prints a receipt for every sale and reports it to NAP in real time over a remote connection. The rules live in Ordinance H-18 of 2006, amended many times since.

• The obligation does not depend on your legal form. An EOOD (single-owner limited company), a freelancer working under a civil contract, and an individual just selling something on the side are all treated the same way.
• It does not depend on turnover either. A single customer paying in cash is enough to trigger it.
• It depends entirely on how the customer pays: the moment someone pays cash or taps a card in person, at a physical point of sale, that sale has to go through a registered fiscal device.
• "Point of sale" is defined broadly: a shop, an office, a market stall, even a table at a trade event, if money changes hands there.

Skip issuing a fiscal receipt for a cash sale, and the fine is real: roughly 250 to 1,000 euro for a company or sole trader on a first offense, rising to around 4,000 euro on a repeat one. NAP can also seal the premises for up to 30 days, independent of the fine.

The exception that saves you the hassle: bank transfer only

Ordinance H-18, Article 3(1) exempts sales from the fiscal-device requirement when payment happens entirely through a bank channel: a credit transfer into a payment account, direct debit, or a cash-to-account transfer at a bank counter. In plain terms: if a customer pays your invoice by bank transfer rather than cash or a card swiped in person, that sale does not need a fiscal device at all.

This is good news for a large share of small businesses running out of Bulgaria: consultants, freelance developers, agencies, anyone invoicing other companies and getting paid by wire. As long as every euro comes in through the bank, a fiscal device never enters the picture.

• The exemption disappears the moment you accept even one cash payment, say a client hands you cash at a coffee shop instead of wiring it.
• It applies the same way whether you invoice individuals or companies, as long as the payment method is a bank transfer.
• You don't need special permission or a NAP registration to rely on this exemption, but keep evidence that payments genuinely came in through the bank.

Running an online store: card, bank transfer, and the fiscal receipt

The same logic applies to an online store, with one extra layer. Article 3(17) of Ordinance H-18 lets an e-shop (defined in Bulgaria's VAT Act) skip the fiscal receipt if payments are entirely card-not-present, meaning the card is entered at checkout rather than swiped on a physical terminal, and the store uses software dedicated only to those sales.

Instead of a fiscal receipt, the store issues the customer an electronic document with a sequential number, order details, and a QR code carrying the sale data registered with NAP. The same exemption applies to bank-transfer payments, under the same logic as a regular invoice.

• "Entirely card-not-present" is strict: if the store also has a physical showroom taking card payments in person, that exemption does not cover those sales.
• Sell through both a website and an offline stand, and you need a fiscal device at least for the stand.
• If you're searching for exactly this, whether an online store needs a fiscal receipt, the answer is: not always, but only for card and bank-transfer payments, not for cash on delivery.

Cash on delivery through a courier is not covered

This is where most online sellers trip up. Cash on delivery, where the customer pays the courier in cash on arrival, is neither a bank transfer nor a card-not-present payment. NAP treats it as a cash sale that simply arrives later, not as something different.

In practice, a store that offers cash on delivery as an option has to register the sale through a fiscal device before the parcel ships, and include the paper fiscal receipt inside the package, or generate it electronically and email it to the customer where that option applies.

• Offer card, bank transfer, and cash on delivery together, and the exemptions cover only the first two: cash-on-delivery orders still need a fiscal device.
• Many small e-shops sidestep the whole issue by dropping cash on delivery entirely and accepting only card and bank transfer, precisely to stay inside the exemption.
• Others register a device just for the cash-on-delivery parcels, while card and bank-transfer orders ship without a receipt.

SUPTO software is voluntary again

SUPTO is the Bulgarian acronym for "sales management software." It used to mean that any software touching sales at a point of sale, a till program, a POS system, even parts of accounting software, had to be declared to NAP and meet dozens of technical requirements under Annex 29 to Ordinance H-18.

After years of pushback from businesses, the mandatory declaration regime was repealed: using SUPTO-compliant software is voluntary. You can run an ordinary invoicing or till program without declaring it to NAP as SUPTO, as long as it doesn't replace the fiscal device's core function.

• As of this writing (May 2026), the Ministry of Finance's official position is that no general obligation for merchants to use NAP-approved software has been introduced.
• NAP's public list carries over 100 declared software products, and fewer than 6,000 outlets nationwide use one voluntarily, far from every merchant.
• The topic stays politically sensitive: the Budget 2026 debate includes language that businesses read as an attempt to bring back a mandatory regime for software vendors, not necessarily for every merchant. If you run specialized sales software, confirm the current status with an accountant, this is one of the faster-moving corners of Bulgarian tax rules.

Check your own case in three questions

The short version: take cash or an in-person card payment, and you need a fiscal device. Get paid entirely by bank transfer or card entered online, and you probably don't. Run an online store with cash on delivery, and you need one at least for those parcels. SUPTO, meanwhile, is not an obligation for anyone right now, unless you've chosen to declare your software voluntarily.

Three questions settle your case: do you ever take cash or an in-person card payment? If you sell online, do you offer cash on delivery, or only card and bank transfer? And do you run sales software you should actually check against NAP's list?

Useful next reads:

How FreeMe.bg issues invoices and tracks which ones got paid by bank transfer
When you need an expert to check your specific case
Invoicing an EU client: when you don't charge VAT

FreeMe.bg doesn't replace a fiscal device, but it tracks every invoice you issue and shows clearly which ones were paid by bank transfer, exactly the record you need to prove you qualify for the exemption. Log in with your Google account and get your invoices organized in one place.