SAF-T: the standard audit file for tax

What SAF-T is

SAF-T (Standard Audit File for Tax, стандартен одитен файл за данъчни цели) is a file in a standard format with data on the company's business and accounting: identification details, accounts, balances and entries, purchase and sales documents with customer and supplier details, payments, fixed assets and inventory (Art. 71i of the Tax and Social Security Procedure Code).

The file is filed with the National Revenue Agency (NRA) electronically with a qualified electronic signature, following the procedure and format set by an order of the NRA's executive director (Art. 71k(4) of the Code). The order and the technical guidance are published on the NRA's SAF-T page.

Who files SAF-T

SAF-T is filed by enterprises within the meaning of Art. 2 of the Accountancy Act (Art. 71z(1) of the Code). They include all traders under the Commerce Act, which covers commercial companies and sole traders (Art. 2, item 1 of the Accountancy Act).

The following do not file SAF-T (Art. 71z(2) of the Code):

• micro enterprises that are not registered for VAT;
• local legal entities that are not traders, when they carry out no commercial activity;
• budget-funded enterprises, the payment funds and insurance funds under the Social Security Code, and commercial representative offices;
• supplementary pension funds, collective investment schemes and national investment funds that are not self-managed national investment companies.

Freelancers (свободна професия) are, as a rule, not traders (Art. 2, item 2 of the Commerce Act). They are not enterprises under Art. 2 of the Accountancy Act and do not file SAF-T.

The obligation ends on 1 January of the year after the one in which the company stops meeting the conditions, for example when a micro enterprise is deregistered for VAT (Art. 71k(8) of the Code).

Enterprise categories

When the obligation starts depends on the company's category under the Accountancy Act. An enterprise belongs to a category when, at 31 December, it does not exceed at least two of the category's three limits (Art. 19 of the Accountancy Act):

Large enterprises exceed at least two of the limits for a medium-sized enterprise. Public-interest entities, such as banks, insurers and companies with securities on a regulated market, are large regardless of their figures (§ 4 of the Supplementary Provisions of the Accountancy Act).

The category changes when the enterprise has not met the limits of its current category for two years in a row (Art. 20 of the Accountancy Act).

The law states the limits in leva. The euro amounts use the fixed rate of 1.95583 BGN per euro (Art. 11(2) of the Euro Adoption Act). The Euro Adoption Act restates the same limits as rounded amounts: 450,000 and 900,000 EUR for micro enterprises, 5,000,000 and 10,000,000 EUR for small enterprises and 25,000,000 and 50,000,000 EUR for medium-sized enterprises (§ 43 of the Transitional and Final Provisions of the Euro Adoption Act). The consolidated text of the Accountancy Act still states the limits in leva. If your company's figures fall between the two amounts, discuss its category with your accountant.

When SAF-T starts

The obligation starts in stages (§ 17(1) of the Transitional and Final Provisions of the 2025 State Budget Act):

The amounts paid to the NRA are the receipts into the NRA's accounts from taxes and social security contributions, less the amounts refunded.

For most small companies the obligation starts on 1 January 2029, and for VAT-registered micro enterprises on 1 January 2030.

On 10 September 2026, bill No. 52-654-01-133 was submitted to the National Assembly. It proposes to postpone the stage starting on 1 January 2027 by one year. At the date of the check it had not been adopted.

What is filed and when

For example, the January file is due by the end of February. If the last day of a deadline is a non-working day, the deadline ends on the next working day (Art. 22(7) of the Code).

Corrections in the first year

Companies that join SAF-T in the stages from 2026 to 2030 file from the first month of the obligation. During the first 12 months of the obligation, filed files can be corrected (§ 17(2) of the Transitional and Final Provisions of the 2025 State Budget Act). A correction is made by filing a new file for the month concerned (Art. 71k(6) of the Code).

Companies whose obligation arises later, for example a micro enterprise that registers for VAT after 1 January 2030, file nothing for the first six months, and can correct the files they filed during the following six months (Art. 71k(5) and (6) of the Code).

Outside these periods, if the NRA finds inconsistencies in a filed file, the company has 7 days to fix them. Otherwise the file counts as not filed (Art. 71k(7) of the Code).

Penalties

For a file not filed on time, or not filed when requested by the revenue authority, legal entities and sole traders pay a penalty of 5,000 to 15,000 BGN (2,556.46 to 7,669.38 EUR). For a repeat offence the penalty is 10,000 to 30,000 BGN (5,112.92 to 15,338.76 EUR). The fine for individuals is 500 to 2,000 BGN (255.65 to 1,022.58 EUR), and 1,000 to 4,000 BGN (511.29 to 2,045.17 EUR) for a repeat offence (Art. 277a(1) and (2) of the Code).

The penalty does not release the company from the obligation: it must still provide the file when the revenue authority asks for it (Art. 277a(3) of the Code).

Sources

• Tax and Social Security Procedure Code, including § 17 of the Transitional and Final Provisions of the 2025 State Budget Act
• Accountancy Act
• Commerce Act
• Euro Adoption Act
• NRA's SAF-T page
• Bill No. 52-654-01-133

All sources are in Bulgarian.