In today’s business world, digitalization is becoming increasingly important. One of the key reforms being worked on in Bulgaria is the preparation for the introduction of a standard audit file for tax purposes, known as SAF-T (Standard Audit File for Tax).
What is SAF-T and why should we care?
SAF-T is an international standard for the electronic exchange of accounting data developed by the Organisation for Economic Co-operation and Development (OECD). Its purpose is to facilitate the process of providing detailed accounting information to tax authorities through a single electronic format.
In Bulgaria, the National Revenue Agency is actively working on a SAF-T implementation project. However, as of April 2025, the system is not yet in place as a mandatory requirement for businesses. It is expected that in the future SAF-T will enable companies to transmit their accounting information in a standardised electronic form directly to the NRA, which will simplify current procedures and reduce the administrative burden.
For the time being, however, businesses should continue to file their tax reports and returns under the current rules, while keeping an eye out for official announcements from the NRA on the possible introduction of the new standard.
Why is SAF-T being introduced?
The main objective of SAF-T is to make communication between businesses and tax authorities easier and more efficient. Instead of filing multiple different reports and returns, you will be able to provide the information in one standard format.
This approach has several important advantages:
- Less administrative burden for business
- Greater transparency in reporting
- More effective tax control
- Reducing reporting errors
What is the international experience with SAF-T?
Before looking at the situation in Bulgaria, it is useful to see how this standard works in other countries.
Poland was one of the first countries to introduce a full SAF-T regime. They started in phases in 2016, first with large companies and then expanded to all businesses. Their experience showed how important early testing of systems is.
Portugal introduced SAF-T together with e-invoicing, combining monthly submission of summary data and annual submission of the full SAF-T file.
Norway has been implementing SAF-T since 2020, focusing on standardisation of accounting codes.
France has implemented a partial version of SAF-T focusing on certain transactions and tax aspects.
These examples show that successful SAF-T implementation requires:
- Sufficient preparation time
- Clear technical specifications
- Test periods before mandatory application
- Flexible approach to different business categories
When will SAF-T be introduced in Bulgaria?
In Bulgaria, the SAF-T implementation process is still in the preparatory stage. According to preliminary information from the NRA, the introduction will be phased:
- Pilot Testing: In July 2025, the NRA will launch a pilot testing that will last for 6 months. During this period, companies selected and invited by the Revenue Agency and registered with the Large Taxpayers and Insurers Territorial Directorate of the NRA will voluntarily submit a Standard Audit File for tax purposes.
- Mandatory submission for large enterprises: from 1 January 2026, enterprises that meet the criteria for “large enterprises” under the Accounting Act and are registered with the NRA’s Large Taxpayers and Insurers Territorial Directorate will be required to submit their accounting information to the revenue agency in the SAF-T unified format.
- Phased expansion: over the next five years, it is envisaged that the mandatory submission of accounting data under the new standard will cover all taxpayers registered in the territorial directorates of the NRA who meet the criteria for large, medium and small enterprises within the meaning of the Accounting Act, as well as micro-enterprises registered under the VAT Act.
It is important to monitor official National Revenue Agency (NRA) communications for the most up-to-date information as these deadlines may change.
What information will the SAF-T file include?
The SAF-T file will contain detailed information about:
- Basic information about the enterprise
- Identification data (UIC, tax number)
- Information for the reporting period
- Accounting system data
- General ledger
- Accounting plan information
- Details of all accounting entries
- Account balances
- Invoicing and sales
- Information on issued invoices
- Customer data
- Information on VAT
- Purchases and expenditure
- Details of invoices received
- Information about suppliers
- VAT data on purchases
- Assets and inventories
- Information on fixed assets
- Inventory data
- Depreciation policy
Some of the items mentioned (Basic Enterprise Information) are not explicitly mentioned in the official sources and their inclusion in the SAF-T file cannot be confirmed at the moment. It is advisable to monitor official NRA announcements and documents for up-to-date information on SAF-T file content and specifications.
What are the benefits of SAF-T?
The introduction of SAF-T brings a number of advantages for both your business and the tax administration:
For your business:
- Less administrative burden: instead of submitting multiple different reports, you will have a single standard for data exchange.
- Better accounting information: data structuring requirements will improve internal accounting processes.
- Reduced risk of error: automated data generation reduces the likelihood of human error.
- More predictable tax inspections: a structured environment for interacting with tax authorities reduces the stress of inspections.
For the tax administration:
- More effective control: better access to necessary information.
- Increased transparency: reduced opportunities for error and abuse.
- Better risk analysis: Ability to identify irregularities without physical checks.
- Improved collection: more effective controls lead to higher tax revenue collection.
Challenges and how to prepare
Despite its many benefits, the introduction of SAF-T poses some significant challenges for businesses. Firstly, there is a need to adapt accounting systems, which includes updating accounting software, ensuring compatibility with the international standard and standardising the nomenclatures and codes used.
Staff training is also a significant challenge as staff need to familiarise themselves with the new requirements and develop the skills to work with the updated systems.
The introduction of SAF-T also implies an initial investment related to software update costs as well as funds for training and consultancy. In addition, changes in the accounting policies of companies may be required in terms of adjustments to procedures and updating of internal workflow.
How to prepare according to the size of the business?
For micro and small enterprises (with implementation in 2029-2030):
- Already now (2025-2026): Understand the basic principles and requirements of SAF-T. Start planning a budget for software upgrades, training and possible consulting. Identify which accounting processes will require changes.
- 2-3 years before mandatory implementation (2026-2027): Select accounting software that supports or will be upgraded to support the SAF-T standard. Agree with the software provider on updates. Begin training of accounting and administrative staff.
- 1 year before implementation (2028): Conduct test generation of SAF-T files to ensure systems are working correctly. Analyze results, correct errors, and update internal control procedures. Schedule regular compliance checks.
For medium enterprises (with implementation in 2028):
- Now (2025) – Analysis of current systems and choice of strategy: This is absolutely correct and mandatory. Medium-sized enterprises should conduct a complete review of their accounting and ERP systems to assess how ready they are for SAF-T, and choose a specific adaptation strategy.
- 2 years before implementation (2026) – Implementation of software solutions and staff training: This is also logical and recommended. Two years before mandatory filing is the right time to select, test and implement software, as well as train accountants and administrators.
- 6 months before implementation (2027) – Final testing and adjustment: This step is absolutely necessary. Testing actual SAF-T files and checking them for compliance with NRA requirements will ensure a seamless transition to the new model.
For large enterprises (with deployment in 2026-2027):
- Immediate – Form a working group and develop a strategy: It is imperative for large enterprises to form a working group (IT professionals, accountants, internal audit, management) and develop a detailed implementation strategy in the first half of 2025. This should include an implementation plan, budgeting, risk assessment and infrastructure preparation.
- 1 year prior to deployment – Selection and deployment of software solutions and staff training: For some large enterprises (especially pilot test participants) this activity should be nearly complete by the end of 2025 to be ready for testing and actual submission.
- 6 months prior to implementation – Test and validate SAF-T files and update accounting policy: Testing and validation of SAF-T files is mandatory to ensure that the data generated is correct. In addition, accounting policy changes, including standardization of internal processes and workflows, are an important compliance step.
Conclusion
The introduction of SAF-T in Bulgaria is an important step towards the digitalization of the tax system, which brings both challenges and opportunities for the optimization of your business.
The key to a successful transition is early preparation and gradual adaptation of your systems and processes. With professional support from ATP Konsult, your company can turn this change into a competitive advantage and make the most of the new standard.
Don’t wait until the last minute – start preparing now to face the changes prepared and confident.
SAF-T FAQ
What is the technical format of the SAF-T file?
The SAF-T file is generated in XML format with a specific structure defined by the tax authorities. Most modern accounting systems will add functionality to automatically generate these files.
How does SAF-T differ from current requirements?
Unlike current summary reports and returns, SAF-T requires detailed information about each individual transaction in a single standardized format that is automatically generated by the accounting software.
How often will we need to submit a SAF-T file?
Depending on the final requirements, filing may be on demand by the tax authorities, monthly or annually, with the frequency likely to depend on the size of your business. For more information, keep an eye on the official NRA website.
How will data security be ensured?
Security will be provided through encrypted communication channels, electronic signatures and strict data access protocols, in accordance with the requirements of the GDPR and the Data Protection Act.