Ordinance N-18 for online stores in Bulgaria: NRA registration and the audit file

What Ordinance N-18 regulates for online stores

Run an online store through a Bulgarian company and you meet a rule set most of Europe does not have. Ordinance N-18 (Наредба Н-18) of the Ministry of Finance governs how sales are registered and reported to the NRA (National Revenue Agency, НАП): through a fiscal cash register, through approved software, or through another document. It is issued under Art. 118 of the VAT Act (ЗДДС) and applies to every seller, VAT-registered or not. Since the end of 2018 it has a dedicated chapter (7„г“) for sellers using an online store.

The VAT Act (§ 1, item 87 of its supplementary provisions) defines an online store as software reached through a browser or mobile app, used to sell at a distance, with a basket or other way to choose goods, delivery details and a payment method. Your own domain, a rented domain or a shop profile on a marketplace all count: Art. 52м of the ordinance names all three.

The key point: your obligations under N-18 do not depend on turnover, legal form or order volume. They depend on how the customer pays. Everything below is organised by payment method.

Two notes. The NRA portal works in Bulgarian, so we give the Bulgarian terms in brackets: the audit file is the „стандартизиран одиторски файл“ and approved sales software is СУПТО. And OSS is a different topic: OSS decides which country's VAT you charge, N-18 decides how a sale is recorded in Bulgaria.

Who is exempt: bank transfers and postal money orders

Art. 3(1) of N-18 removes the fiscal receipt requirement for sales paid by:

• credit transfer (an ordinary bank transfer), direct debit, cash paid into a payment account, or a cash money remittance through a payment service provider;
• a postal money order (пощенски паричен превод) executed by a licensed postal operator.

If your store accepts only these methods, you need no fiscal device and you are not required to file store information with the NRA. The NRA's own page for e-traders says so: the duty applies to stores that accept payments requiring a fiscal receipt. You may still opt into the NRA's public list of online stores.

Postal money orders carry one condition people miss: the customer gets a document, paper or electronic, with your name, address and company ID (ЕИК), the goods, the total and the payment method (Art. 3(1) and Art. 26(1), items 1, 4, 7 and 8). Paper travels with the parcel; electronic goes out by the time the goods leave the warehouse (Art. 25(3)). An invoice with the same data replaces it (Art. 25(4)).

Cash on delivery is the trap. It counts as a postal money order only when the courier is a licensed postal operator for money orders and the amount reaches you as a postal money order under your contract. If the courier simply collects cash, Bulgarian law sees a cash sale: you issue a fiscal receipt, hand it to the courier, and the courier gives it to the customer at payment (Art. 25(2) and (7)). Check your courier contract before you switch COD on.

Cash registers in Bulgaria: when you need one and when you don't →

Who registers the store with the NRA: Annex 33

As soon as you accept even one payment method that requires a fiscal receipt, you file information about the store with the NRA under Art. 52м and Annex 33. The usual triggers are online card payments (through a virtual POS or a payment provider such as a card processor) and cash on delivery that is not a postal money order.

• When: before you start selling, separately for each store.
• How: electronically, signed with a QES (qualified electronic signature, КЕП), through an e-service on the NRA portal. No QES yet? Sort it out early, or ask your accountant how they file for clients.
• What: store name and web address, your details as the seller, the type of goods, the store software and hosting, and the other data in the annex.
• Changes: new domain, new platform, new payment provider: file updated information within 7 days. The same 7 days apply when you close the store.

Registered stores appear on a public NRA list. If the NRA finds inconsistencies, you are notified and get 7 days to fix them, otherwise the store is removed from the list (Art. 52м(6)).

Online card payments: three lawful options

Card payments normally require a fiscal receipt (Art. 118(3) of the VAT Act). For an online store, N-18 gives you three ways to comply:

• A fiscal receipt from a cash register. The paper receipt goes in the parcel. Since the amendment in State Gazette (ДВ) No. 42 of 2025 (Art. 3(19)), an online store may also issue the fiscal receipt electronically, provided it holds the customer data needed to send it and keeps a record of when and how it was delivered. The e-receipt must reach the customer no later than when the goods leave the warehouse (Art. 25(8)).
• СУПТО with order import. If you use software from the NRA's list, store orders can be imported into it (Art. 52з(11)). СУПТО is optional.
• The alternative regime under Art. 3(17). Instead of a fiscal receipt you issue a “sales registration document” with no cash register at all. This is the regime that comes with the monthly audit file.

Conditions for the alternative regime (Art. 52о to 52т):

• the document has a 10-digit sequential number, the order and transaction numbers, the goods and a QR code, and is emailed to the customer at payment;
• card money reaches an account in your name with a provider in the EU or a country that shares bank data with Bulgaria, directly or via the payment processor (Art. 52п);
• the store software numbers every order uniquely and protects data integrity; in an audit the NRA gets full admin panel access and, on request, a Bulgarian translation of the interface (Art. 52с);
• in Annex 33 you also declare payments (methods, providers, accounts, virtual POS) and receive a unique store number (Art. 52р and 52т).

The current wording of Art. 3(17), after ДВ No. 17 of 2021, does not require the store to avoid other payment methods. You can run the alternative regime for cards and a cash register for cash on delivery. The audit file even has a separate code for payments covered by a fiscal receipt.

The Bulgarian fiscal receipt: what it contains and when it is not enough →

The NRA audit file for e-shops: content and deadline

The standardised audit file is a monthly XML file under Annex 38, required only from stores in the alternative regime (Art. 52т(2)). If you issue a fiscal receipt for every card payment, you never file one.

• Deadline: by the 15th of the month after the month it covers. Orders delivered in September are due by 15 October.
• Scope: orders for which goods or services were actually delivered during the month, not every order placed.
• How: through the e-service “Стандартизиран одиторски файл от лице по чл. 3, ал. 17 от Наредба № Н-18/2006 г.” on the NRA portal, signed with a QES. The NRA publishes an XSD schema and a sample XML, and the portal checks the file for logical and arithmetic consistency on upload.

What goes in the file:

• header: company ID, the NRA-issued store number, own domain or marketplace, web address, month and year;
• per order: number and date, sales document number, the items with quantity, unit price before VAT, VAT rate and amount, discount and total;
• a payment method code (virtual POS, payment provider, COD by postal money order, other exempt payment, or payment covered by a fiscal receipt) plus the POS number, transaction reference or payment provider ID where relevant;
• orders refunded in the month: number, amount refunded, date and refund method.

All amounts are in euro: Annex 38 was converted by ДВ No. 42 of 2025, effective 1 January 2026, when Bulgaria joined the euro area.

Your store platform or a plugin generates the file. Before you choose the alternative regime, confirm that your platform produces a file matching the NRA's current schema, in euro. International platforms rarely know Bulgarian rules, so ask before you commit.

What is in force as of October 2026, and what is not

• In force for years: the e-shop chapter (ДВ No. 80 of 2018), the alternative regime and the monthly audit file (ДВ No. 8 of 2020). The 2020 and 2021 transition deadlines expired long ago, so there is no grace period to wait for.
• In force since 26 February 2021 (ДВ No. 17 of 2021): СУПТО is optional, and the alternative regime can be combined with other payment methods.
• In force after ДВ No. 42 of 2025: electronic fiscal receipts for online stores (Art. 3(19)), and the audit file in euro from 1 January 2026.
• Nothing promulgated in 2026: at the time of writing, the latest amendment to N-18 is ДВ No. 42 of 23 May 2025. If you read about “new e-shop obligations” without a State Gazette reference, treat it as a rumour until you see the published text.

Penalties and practical risk

N-18 is issued under Art. 118 of the VAT Act, so penalties come from Art. 185 and 186 of that Act. Amounts are converted to euro at the fixed rate of 1.95583.

• Failing to issue a receipt or sales document (Art. 185(1)): roughly EUR 511 to 2,045 for a company or sole trader, and roughly EUR 1,023 to 4,090 for a repeat offence.
• Other breaches of the ordinance (Art. 185(2)), which under the general rule includes not filing store information or the audit file: roughly EUR 3,068 to 10,226 for a company. Where the breach does not lead to unreported revenue, the lower Art. 185(1) range applies instead.
• Sealing of the business premises for up to 30 days, on top of the fine, for failing to issue a sales document (Art. 186(1)).

The alternative regime adds a practical risk: stop meeting any condition and you lose the regime, and the NRA may delist the store (Art. 52у). Every card sale without a fiscal receipt then counts as a sale with no sales document.

Checklist for a small e-shop with a Bulgarian company

• List every payment method your store offers: bank transfer, card (including through a payment provider), cash on delivery.
• Bank transfer or postal money order only: no cash register and no NRA registration, but for postal money orders you still issue the Art. 3(1) document or an invoice with the same data.
• Check your courier contract: is COD a postal money order from a licensed operator?
• Card or COD without a postal money order: file Annex 33 with a QES before you start selling.
• Choose how you record card payments: fiscal receipt (paper or electronic), СУПТО with import, or the alternative regime.
• Alternative regime: check the document numbering and QR code, your accounts and payment providers, and put the 15th of every month in the calendar.
• New domain, platform or payment provider: update the NRA within 7 days.

If you sell from abroad with no Bulgarian company or business presence, N-18 is built around sales recorded in Bulgaria, and whether it reaches you is a question for a Bulgarian tax adviser, not a blog post. VAT on cross-border sales to consumers is a separate matter handled through OSS.

How FreeMe.bg helps

N-18 governs how you record a sale at the moment of payment. Everything after that is accounting: invoices, expenses, VAT returns, deadlines. That is where FreeMe.bg comes in: you issue invoices, keep the company's expenses in one place, and an accountant takes care of the filings. The N-18 audit file comes from your store software, so check there that it is ready for the NRA schema.

See how invoicing works in FreeMe.bg →
See how taxes and filings are organised →
VAT for online stores: the EUR 10,000 threshold and OSS →

This article is general information as of October 2026, not legal advice. If your store combines several payment methods, a warehouse in another country or marketplace sales, walk through the setup with an accountant before you pick a regime.