When You Must Register for VAT in Bulgaria

The new threshold: €51,130 a year

If you run a small company in Bulgaria, even one you manage entirely from abroad, the VAT registration threshold is the number that decides when you must start charging VAT to your customers. As of 1 January 2026, alongside the euro adoption, the old threshold of BGN 100,000 was replaced with a euro-denominated figure: €51,130 (Art. 96(1) of the Bulgarian VAT Act). The euro figure is simply the old lev amount converted at the fixed exchange rate, so the day-to-day impact for most founders is small, but the shift matters because the threshold is no longer expressed in a currency that's being phased out. Every future reference to it, in your accounting software, your invoices, your NRA correspondence, will now be in euro by default.

The bigger change is how it's counted. Until the end of 2025, turnover was tracked on a rolling 12-month basis, meaning each month added a new one and dropped the oldest from the count. From 2026 onward, it's the calendar year (1 January–31 December), and the National Revenue Agency (NRA) now expects turnover to be monitored daily, not just at month-end. If your business is seasonal, say most of your revenue lands in the summer, this matters: you can't wait for your accountant's quarterly report to tell you where you stand, because by then you may already be weeks past the deadline for filing.

That means if a single sale on 15 June pushes your year-to-date turnover past €51,130, your obligation to register starts that same day, not at the end of the month. In practice, this puts the burden on you, or your bookkeeper, to keep a running total of taxable turnover throughout the year rather than reconciling it after the fact.

Mandatory vs. voluntary registration

Registration becomes mandatory once you cross €51,130 in the current or previous calendar year (Art. 96). You can also register voluntarily at any time, regardless of turnover (Art. 100). Many foreign-owned companies do this from day one, often before they've invoiced a single Bulgarian client, because it lets them reclaim VAT on the costs of setting up: legal fees, office equipment, software subscriptions, and other early-stage expenses.

Voluntary registration usually makes sense if most of your clients are other businesses (B2B), you sell into other EU countries, or you want to reclaim VAT on expenses and setup costs. For clients who are themselves VAT-registered, adding VAT to your invoice doesn't cost them anything extra, since they reclaim it in turn, so you have little to lose and a real cash-flow benefit to gain from being able to deduct VAT on your own purchases. If you mostly sell to consumers, though, waiting until you hit the threshold often works out cheaper: your prices stay the same while VAT-registered competitors have to add 20%, unless they choose to absorb the difference and shrink their own margin instead. The trade-off is administrative: once registered, you owe periodic VAT returns and have to keep purchase and sales ledgers, no matter how small your turnover is in any given month.

Deadlines and how to file

This is the change that catches people out: you now have 7 days from the date you cross the threshold to file your registration application, not "by the 7th of next month," as it was before 2026. Seven calendar days sounds workable until you remember it includes weekends, so if you cross the threshold on a Thursday evening, you effectively have four working days left to get your paperwork together.

You file with the NRA: electronically via portal.nra.bg (fastest, requires a qualified electronic signature) or in person at your local NRA office. Filing electronically is worth setting up in advance if you're running a company from outside Bulgaria, since it removes the need to be physically present at a tax office at exactly the moment you're racing a 7-day clock. The NRA then has 7 days to process it and issue your registration act. Your effective registration date, though, isn't the day the NRA processes your paperwork. It's the day after you crossed the threshold (Art. 103). VAT is owed on everything from that date, whether or not your certificate has arrived yet, which means any invoices you issue in the gap between crossing the threshold and receiving your certificate will need to be corrected afterward to reflect the VAT that was actually due.

What happens if you're late

Missing the 7-day window isn't a small paperwork slip. The NRA can register you ex officio and assess VAT retroactively from the day after you crossed the threshold, whether or not you actually charged your customers. On top of that, Art. 178 of the VAT Act sets a fine of BGN 500–5,000 (roughly €256–2,556) for a missed registration deadline, with the exact amount left to the discretion of the revenue officer handling your case.

In practice: register two months late, and you can end up owing VAT out of your own pocket on sales where you never charged it, plus a fine on top. Say you invoiced €20,000 worth of work in those two months without adding VAT because you hadn't registered yet; the tax on that amount, at the standard rate, comes straight out of your margin, since you can't go back and bill your clients for it retroactively. That's the real reason to track turnover continuously rather than waiting for a "convenient" moment or the next bookkeeping cycle to check where you stand.

Where the euro transition fits in

The threshold is now fixed in euro, but the old lev figure hasn't fully disappeared: until 8 August 2026, every trader in Bulgaria must still display prices in both currencies (at the fixed rate of €1 = BGN 1.95583), including on receipts and online stores. If you invoice consumers directly, this dual-display rule still applies to you. As of this writing, there are only a few weeks left before it ends, so it's worth checking now whether your invoice templates, point-of-sale system, and online store still show both currencies correctly, rather than discovering a compliance gap right before the rule lapses. If you're approaching the VAT threshold around the same time the dual-display period ends, it's a natural point to review both your euro pricing and whether your bookkeeping setup is ready to operate purely in euro, instead of making the two changes separately.

Running more than one Bulgarian company

The €51,130 threshold applies per legal entity, not per owner. If you have one company holding property and another doing consulting, each tracks its own turnover: crossing the threshold in one doesn't automatically register the other, even if the same person owns both and they share a bookkeeper. That's convenient if you're running several small ventures, since it lets you evaluate registration separately for each line of business instead of treating your combined turnover as one number.

One caveat: there's an anti-fragmentation rule (Art. 168в(3)) that aggregates turnover when related parties run the same type of activity, one after another, out of the same commercial premises. The rule exists so that one owner can't split what is really a single business into several companies purely to keep each one under the threshold. If your setup is anywhere near that line, say one company taking over an activity from a related company at the same address, get advice before assuming the thresholds stay separate, because the consequences of getting this wrong mirror a missed deadline: VAT assessed retroactively, plus a fine.

More on managing several companies at once →

How FreeMe.bg helps

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