SAF-T in Bulgaria: Preparing for the Digital VAT Era Starting 2026

Bulgaria is preparing to join the growing list of European countries adopting the Standard Audit File for Tax (SAF-T), with expectations for mandatory implementation starting in 2026. This initiative is aligned with OECD recommendations and EU-wide efforts to digitize VAT reporting, enhance tax transparency and fight fraud. However, for companies already using SAP, these changes require both technical and governance readiness. In this article, we, at vAIsko IT, made a detailed overview of what Bulgarian companies must anticipate and how to prepare for the mandatory rollout.

What Is SAF-T?

SAF-T (Standard Audit File for Tax) is a standardized XML format used to exchange accounting and tax data with tax authorities. Developed by the OECD, the format enables auditors and tax administrations to receive consistent, machine-readable data from ERP systems such as SAP. According to the preliminary proposal by the Bulgarian Ministry of Finance:

• From 1 January 2026: SAF-T will be mandatory for companies with annual turnover exceeding 300 million BGN in 2023 or taxes above 3.5 million BGN.

• From 1 January 2027: The obligation will expand to large, medium and small businesses with turnover exceeding 300 million BGN in 2024 or taxes above 3.5 million BGN.

• From 1 January 2028: Large, medium, and small businesses with turnover exceeding 15 million BGN in 2025 or taxes above 1.5 million BGN.

• From 1 January 2029: SAF-T submission may become mandatory for all VAT-registered entities, regardless of size and turnover. ‍

• From 1 January 2030: Mandatory for small-scale businesses as well.

This tiered approach aims to give businesses time to prepare according to their size and administrative capacity.

What is Changing for Bulgaria and My Business?

While the final technical specification has not yet been published by the NRA, the reporting is expected to follow a standardized XML file format based on OECD SAF-T 2.0, with specific local extensions. Depending on a company’s size or turnover, submission will likely be required on a monthly or quarterly basis, and files will need to be submitted digitally via a secure web service or API integration with the NRA portal.

Unlike traditional VAT declarations, SAF-T covers transaction-level data, offering a full audit trail. As tax authorities are provided with much more visibility and control, having clean, accurate and well-structured data in your SAP system is crucial beforehand. The tax authority has outlined several obligations regarding SAF-T reporting. Businesses are required to submit the following accounting documents monthly:

• General Ledger: A comprehensive record of all financial transactions, organized by account.
• Accounts Payable and Receivable: Details of outstanding debts to suppliers and amounts receivable from customers.
• Purchase and Sales Invoices: A detailed record of all commercial transactions, including income from sales and expenses from purchases.
• Submission Deadline: These documents must be submitted by the 14th of the month following the relevant accounting period.

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At vAIsko, we specialize in preparing SAP landscapes for regulatory change, ensuring your master data, reporting structure, and system logic are fully aligned and audit-ready well before SAF-T becomes mandatory. If you are curious about it, check out our Master Data Readiness article.

SAP Integration for SAF-T

SAP customers need to ensure their systems are ready to meet the new regulatory demands. The process starts with pulling the necessary data from key SAP modules, including Finance (FI), Materials Management (MM), Sales & Distribution (SD), and Asset Accounting (AA). Once the data is gathered, it needs to be converted into an XML file format that matches the Bulgarian tax authority’s (NRA) requirements — including proper mapping of tax codes to NRA categories. Companies will also need to securely transmit their SAF-T files, likely using SAP Process Integration (PI), Cloud Platform Integration (CPI), or through a certified local partner.

If you're running SAP S/4HANA, there are added benefits. Tools like SAP Document and Reporting Compliance (DRC) can help automate SAF-T generation — assuming localization for Bulgaria is available. You can also leverage custom ABAP reports, CDS Views, or SAP SLT to extract and structure your data according to SAF-T standards.

In addition, a strong collaboration between finance and IT teams is a must. For full compliance with the SAF-T schema, as well as timely data integrity checks and submissions, both parties need to be aligned on the reporting requirements, data structures and technical setup.

What Challenges to Expect and How to Prepare for Them

Apart from regulatory monitoring your master data quality, you need to consider the technical implementation. Existing VAT declaration processes must be reviewed and aligned too. Building and validating the SAF-T file requires strong SAP expertise, which if your team lacks, you need to consider further SAP training. Providing your team with the right knowledge from the start not only eases the technical transition, but gives them the confidence to adopt the change faster.

Early preparation on these challenges will minimize risk of penalties or reporting delays. Here is a summarized list of what you could do to avoid unpleasant surprises and pressure on your team:

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• Review current VAT and ledger processes and identify gaps in audit readiness.
• Clean master data (especially VAT numbers, GL accounts, and customer/vendor info).
• Monitor NRA publications for the official SAF-T specification and implementation calendar.
• Pilot XML generation using sample transactions to identify data structure and mapping challenges.
• Align IT and finance teams to manage compliance and testing.

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