Fiscal Representation in Bulgaria

What is fiscal representation in Bulgaria?

Fiscal representation in Bulgaria is a regime where a non-resident business appoints a Bulgarian-resident, VAT-registered party to handle its VAT obligations and assume joint and several liability before the NRA. The statutory term is “accredited representative” (акредитиран представител), set out in Article 133 of the VATA; “fiscal representative” is the common commercial name for the same role.

The regime exists to give the NRA a local party it can audit, invoice, and hold liable when a foreign company fails to pay. Under Article 133 VATA, the representative is jointly and unlimitedly liable for the foreign person’s VAT from the moment its functions begin, and for five years after they end, per the VATA text on lex.bg.

Bulgarian VAT at a glance for non-residents

The table below sets out the core Bulgarian VAT facts a non-resident needs before appointing a representative. Each row cites its source.

Which supplies qualify for Bulgaria’s 9% reduced VAT rate?

Three categories qualify permanently for Bulgaria’s 9% reduced rate: hotel and accommodation services, books and periodicals (print or electronic), and baby foods and hygiene articles such as diapers. The permanent 9% rate took effect by amendment on 13 February 2023, per the VATA. The temporary pandemic-era 9% rate on restaurants and catering was not renewed.

Restaurant and catering supplies reverted from 9% to the standard 20% rate on 1 January 2025, after the 2025 state budget did not extend the measure, as reported by the Bulgarian News Agency.

When does the BGN 100,000 threshold apply?

The registration threshold applies only to businesses established in Bulgaria; non-established businesses have no threshold and must register from their first taxable supply, under Article 96 VATA. The Bulgarian figure, long set at BGN 100,000, was redenominated to EUR 51,130 at the fixed rate and switched to a calendar-year measurement period, effective 1 January 2026, per State Gazette issue 115/2025.

Do I need a fiscal representative in Bulgaria?

Yes if you are non-EU established and required to register for Bulgarian VAT. No if you are EU established, since you can register directly and representation is optional. And possibly no registration at all if the reverse charge, the One Stop Shop (OSS), or the Import One Stop Shop (IOSS) covers your supplies, under Article 133(6) VATA.

Registration triggers for non-residents include:

• Taxable local supplies not fully covered by the reverse charge.
• Imports into Bulgaria for onward supply on the local market.
• Inventory held in Bulgaria for local or intra-Community sales.

Does the reverse charge remove the need to register?

Yes for in-scope business-to-business (B2B) supplies. The Bulgarian VAT-registered customer self-accounts for the VAT, so the non-resident supplier has no Bulgarian registration obligation for those supplies, under the VATA. The mechanism typically covers general-rule B2B services and certain goods categories where the recipient is liable.

This is why many foreign suppliers never need a Bulgarian VAT number or a representative. The liability shifts to the local customer, and the supplier issues an invoice without Bulgarian VAT. Confirm the exact article against the VATA text on lex.bg for your specific supply type.

Can OSS or IOSS replace Bulgarian VAT registration?

Often yes for business-to-consumer (B2C) e-commerce. Since July 2021, the One Stop Shop (OSS) lets a seller report EU-wide B2C distance sales through a single member-state registration, so a seller registered for OSS elsewhere needs no Bulgarian VAT number for those sales, per the European Commission OSS portal. Non-EU sellers use the non-Union scheme.

The Import One Stop Shop (IOSS) covers imported consignments up to EUR 150, and non-EU sellers generally need an EU-established intermediary to use it. OSS and IOSS do not cover local domestic supplies, inventory held in Bulgaria, or B2B transactions. Those supplies push the seller back to standard Bulgarian registration and, for non-EU sellers, fiscal representation.

What about a Bulgarian branch or fixed establishment?

A non-resident operating through a Bulgarian branch registered under the standard procedure registers for VAT directly and needs no accredited representative. Branches are the only exception to the accredited-representative requirement under Article 133 VATA. A fixed establishment making taxable supplies may also register under the general procedure.

The routes differ in liability. A branch is part of the foreign legal entity, so the head office bears VAT liability directly rather than sharing it with a third party. A branch also triggers corporate registration and likely permanent-establishment tax. A branch suits ongoing physical operations; fiscal representation suits trading without a presence.

What are the requirements for a fiscal representative under the Bulgarian VATA?

The representative must be a legally capable individual with a permanent address or residence in Bulgaria, or a Bulgarian legal entity, under Article 135(1) VATA. It must not be in liquidation or insolvency proceedings, and it must have no outstanding tax or social-security liabilities collected by the NRA.

The NRA checks tax-debt and compliance status at appointment. If the representative ceases to exist or can no longer perform its duties, the foreign person must appoint a new accredited representative within 14 days of that event, under Article 133(4) VATA.

What liability does a Bulgarian fiscal representative assume?

The representative takes on joint, several, and unlimited liability with no statutory monetary cap, covering VAT debts, penalties, and interest tied to the foreign company’s Bulgarian VAT number, under Article 135(3) VATA. The liability survives for five years after the representative’s functions end.

Uncapped exposure makes Bulgarian providers selective and more expensive than in capped-liability countries. Narrow carve-outs apply to persons registered under the non-Union OSS scheme and to EU-established businesses covered by Article 133(6).

Are bank guarantees or deposits required?

No statutory security is required of an accredited representative. Guarantees and deposits are commercial practice, driven by the uncapped joint liability the representative accepts under Article 135(3) VATA. Providers set terms to protect themselves, not because the VATA mandates a deposit.

Security is typically sized against anticipated VAT exposure and released after deregistration and final settlement. It protects the representative commercially without limiting the statutory liability owed to the NRA.

General vs limited fiscal representation in Bulgaria: what’s the difference?

Bulgarian law recognizes only general, full-scope representation. “Limited fiscal representation” is a commercial label for a contractually narrowed service scope; it is not a statutory regime in Bulgaria, unlike in the Netherlands or Belgium. Non-EU businesses must plan for full-scope liability, not a limited import-only role.

How do you appoint a fiscal representative in Bulgaria?

Choose a qualifying representative, sign a notarized power of attorney, file the VAT registration application with the NRA through the representative, and receive a BG VAT number. The representative submits its own details alongside the foreign company’s documents.

The appointment steps are:

1. Confirm whether your activities create a Bulgarian VAT registration requirement, and whether you are EU or non-EU established.
2. Select a qualifying accredited representative that meets the Article 135(1) VATA criteria.
3. Agree terms and any commercial security, then sign the representation agreement and power of attorney.
4. Compile and translate the required documents.
5. File the VAT registration application through the representative.
6. Onboard invoicing, Enterprise Resource Planning (ERP), and reporting so Bulgarian data flows to the representative for monthly filings.

The documents required are set out below.

The resulting VAT number is BG plus 9 digits for legal entities, or 10 digits for individuals, following the EU Commission tax-identification-number schema and Article 94(2) VATA. The 9-digit code is built on the Unified Identification Code (EIK/BULSTAT) issued by the Registry Agency.

How do you choose the right representative?

Choose a representative with a clean tax record, proven Bulgarian VAT experience, and a clear security and insurance policy. It should know your sector and transaction flows, handle monthly cycles and ERP integration, and communicate responsively in English.

Because the representative assumes uncapped joint liability under Article 135(3) VATA, the choice directly affects your compliance stability, audit readiness, and financial risk exposure. Treat it as a strategic decision, not a procurement formality.

What does a fiscal representative in Bulgaria do?

The representative files monthly VAT returns by the 14th of the following month, pays VAT due, maintains sales and purchase ledgers, issues VATA-compliant documentation, and fronts all NRA contact, under Article 125(1) VATA. VAT due is payable by the same 14th-of-the-month deadline.

The representative also stores ledgers, protocols, and supporting documents for the statutory retention period. You can track those filing deadlines across jurisdictions with Commenda’s compliance calendar.

What happens during an NRA audit?

The NRA can audit the non-resident’s Bulgarian VAT position at any time. The representative acts as the local point of contact and remains jointly liable for any assessed VAT, penalties, and interest, under Article 135(3) VATA. Audits often follow refund claims, late filings, or a deactivation history.

Assessments can be challenged through administrative appeal and then the courts. The representative compiles the records, responds to NRA queries, and manages the procedural timeline. Confirm the exact appeal deadlines for your case before relying on them.

Can a fiscal representative claim Bulgarian VAT refunds for you?

Yes, many representatives handle refund claims, and eligibility depends on where you are established. EU businesses without Bulgarian supplies reclaim through the electronic cross-border procedure under Directive 2008/9/EC. Non-EU businesses use the 13th Directive route, which Bulgaria applies subject to reciprocity.

The representative compiles invoices, files the claim, and responds to NRA queries. Confirm Bulgaria’s current reciprocity list and the applicable filing deadlines before you rely on a refund, because both depend on your country of establishment.

What are the penalties for operating without a fiscal representative in Bulgaria?

The NRA can refuse or deactivate the Bulgarian VAT number, assess retroactive VAT with interest, and impose VATA penalties. UK companies lost Bulgarian registrations after Brexit for failing to nominate a representative once the transition period ended on 1 January 2021, per NRA statement No. 274 of 30 December 2020.

Deactivation blocks legal invoicing with Bulgarian VAT and raises audit risk. VAT compliance is often a condition for customs clearance, so a lapsed registration can disrupt imports and logistics. Verify current VATA penalty amounts against the statute before you budget for exposure.

How do you change or end a fiscal representation arrangement in Bulgaria?

Appoint and notify the NRA of a replacement before the old appointment lapses, or apply for VAT deregistration. Obligations end only when the NRA approves deregistration and confirms all liabilities are settled. A replacement is due within 14 days of a disqualifying event, under Article 133(4) VATA.

Deregistration runs through an application, a final VAT return, and settlement of the final liability. A lapsed appointment with no replacement leads to deactivation of the VAT number and enforcement exposure, because the foreign person no longer has a liable local party.

How has Bulgaria’s euro adoption affected VAT and fiscal representation?

Bulgaria adopted the euro on 1 January 2026 at the fixed rate of 1 EUR = 1.95583 BGN, set by Council Regulation (EU) 2025/1409 and confirmed by the EU Council in 2025. VAT amounts, returns, and invoices shifted to euro from that date.

The practical effects are below.

VAT numbers keep the BG-prefix format, so existing registrations continue without renumbering. Existing representation appointments carry over, so a non-resident does not re-register because of the currency switch.

How we help with fiscal representation in Bulgaria

Commenda coordinates Bulgarian VAT registration and fiscal representation through vetted local partners that meet the VATA criteria, and its global indirect tax platform centralizes monthly Bulgarian filings alongside your other EU and non-EU VAT obligations. You get one view of what is due, when, and whether it is done.

Commenda supports 100+ ERP, API, and custom integrations, so your invoicing data flows cleanly to the representative for each monthly return. Pair that with Commenda’s compliance calendar to track the 14th-of-the-month deadline, and tax ID verification to validate counterparties before you invoice.

Book a demo call to get a free assessment of whether your Bulgarian activities trigger mandatory fiscal representation: schedule a demo.