Key facts at a glance:

• SAF-T obligation effective from: 1 January 2026

• First reporting period: January 2026

• Filing deadline: 2 March 2026

• Entities concerned: Large enterprises under the Accountancy Act

• Filing method: Electronic submission to the NRA in XML format

Late January is not just a calendar milestone. It is a clear signal for enterprises for which the obligation to submit a Standard Audit File for Tax purposes (SAF-T) has already entered into force as of 1 January 2026. The first reporting period is underway – January 2026, and the statutory deadline for submission is by the end of February 2026.

Since 28 February 2026 is a non-working day, the effective deadline is 2 March 2026. This leaves very limited room for delay. If preparation has not started in practice—but exists only as an intention—the risk of issues during the first submission is tangible.

This article serves as a reminder, not a technical manual. We already have a dedicated in-depth article explaining what SAF-T is and how it works, which can be referenced separately. Here, the goal is clarity:

• who must file;

• what is being filed;

• what SAF-T is not;

• and why, in the last week of January, inaction is no longer a neutral choice.

Which enterprises must submit SAF-T from 1 January 2026

The obligation to submit a Standard Audit File for Tax purposes arises as of 1 January 2026 for:

• large enterprises within the meaning of the Accountancy Act;

• that meet the criteria set out in the transitional and final provisions of the State Budget Act for 2025.

An important clarification, often misunderstood: not all entities registered with the NRA’s Large Taxpayers and Insurers Directorate automatically fall within the scope, and conversely, an enterprise does not need to be administered by that directorate in order to be subject to SAF-T.

The scope is determined strictly by statutory criteria, not by administrative assignment. There are also explicit exclusions under the Tax and Social Security Procedure Code, including:

• micro-enterprises not registered for VAT;

• non-profit legal entities that do not conduct commercial activity;

• other categories exhaustively listed in the legislation.

What SAF-T is – briefly and without myths

SAF-T (Standard Audit File for Tax purposes) is an international standard for electronic exchange of accounting and tax data between businesses and tax authorities.

It was developed by the OECD and has already been implemented in multiple jurisdictions, including nine EU Member States.

In practical terms, SAF-T means:

• data is extracted from a company’s accounting and business systems;

• structured in a standardized XML format;

• and submitted electronically to the National Revenue Agency (NRA).

Crucially: SAF-T is not a manually prepared report. It is an export of existing data.

What SAF-T is not

A common and costly misconception is that SAF-T is “just another report.” It is not.

SAF-T does not require:

• replacing accounting or ERP systems;

• consolidating all data into a single platform;

• changing applicable accounting standards.

The NRA explicitly states that the requirement is solely to export data already maintained in accordance with applicable accounting standards and internal accounting policies, in a standardised format.

Equally important: data may originate from multiple systems—ERP, billing, inventory, and accounting software. There is no requirement for a single source system.

This does not make SAF-T simple. It makes it technical, process-driven, and organizational, rather than purely accounting-related.

Official documentation and technical specifications

The submission rules, format, and content of SAF-T are regulated in Chapter Eight “b” of the Tax and Social Security Procedure Code, with the specific format approved by an order of the NRA’s Executive Director.

The NRA has created a dedicated “SAF-T in Bulgaria” section on its website, which includes:

• current XSD schemas;

• sample XML files;

• completion and submission guidelines;

• an official Q&A document.

These materials are not optional reading—they define how compliance will be assessed.

January 2026 is already the first reporting period

SAF-T does not start in February. It does not start “after the first submission.”

It starts on 1 January 2026, because January is the first reporting period.

If, by late January:

• data sources have not been fully identified;

• current accounting entries have not been tested against SAF-T structures;

• data exports have not been trialed;

then the organization is no longer “slightly behind.” It is already operating under time pressure.

Deadline: why 2 March 2026 is closer than it looks

Formally, the deadline is the end of February 2026. Because 28 February 2026 is a non-working day, the effective deadline is 2 March 2026.

This often creates a false sense of buffer time. In reality:

• February is the shortest month;

• first-time submissions almost always reveal issues;

• technical corrections are rarely instantaneous.

Enterprises that will pass the first filing smoothly are those working on SAF-T now, not in mid-February.

Why the NRA is introducing SAF-T

SAF-T is not intended as an additional administrative burden. Its strategic objectives are:

• standardized communication between businesses and the NRA;

• reduction of subsequent ad-hoc information requests;

• more predictable and efficient tax control.

The implementation is phased:

• from 1 January 2026 – large enterprises;

• from 2027–2028 – large, medium, and small enterprises under specific conditions;

• from 2029 – all large, medium, and small enterprises;

• from 2030 – including micro-enterprises.

SAF-T is not a pilot. It is the new baseline.

Frequently Asked Questions (FAQ) about SAF-T