VAT Registration in Bulgaria: The 2026 Rules for Freelancers

The three ways you end up VAT-registered

1. You cross €51,130 (Art. 96)

Any taxable person established in Bulgaria must register once their annual turnover in the country exceeds €51,130. You then have seven days from the date you cross it to file the application with the NRA. Not seven days from the end of the month — seven days from the day itself, which means you have to be watching the number, not reconciling it quarterly.

2. You buy or sell a cross-border service (Art. 97a) — no threshold

This is the one that catches people. If you receive services from a taxable person established outside Bulgaria where the place of supply is Bulgaria, you must register under Art. 97a regardless of turnover. Facebook and Google advertising, a Stripe or hosting bill, a software subscription sold from Ireland, a designer in another member state invoicing you — all of it counts. A freelancer earning €12,000 a year who spends €40 a month on ads has the obligation; the €51,130 threshold is irrelevant to it.

Art. 97a registration is not a lesser status that lapses. It lasts as long as the grounds for it exist. It does not give you the right to deduct input VAT on your ordinary purchases, and it does not make your own invoices VAT-bearing — it exists so that the reverse charge on the cross-border service can be accounted for. In practice it means monthly returns for as long as you keep buying.

3. You choose to register (Art. 100)

Voluntary registration puts you on the ordinary regime with no threshold test. It is worth it when your customers are VAT-registered businesses who do not care about the 20% on top, and when you have real input VAT to reclaim — equipment, a vehicle, an office. It is usually a mistake when you sell to consumers, because the 20% comes out of your own margin or out of your price.

What counts towards the €51,130

Art. 168c defines the annual turnover as the sum of the tax bases of what you supplied during the calendar year with a place of supply in Bulgaria:

• supplies taxable under the ordinary rules, including intra-Community supplies of goods;
• supplies that are exempt but carry the right to deduct;
• financial services under Art. 46;
• insurance services under Art. 47;
• exempt supplies of immovable property.

Two exclusions matter. Financial, insurance and property supplies do not count when they are incidental to your main activity, and disposals of fixed assets used in the business do not count at all. So selling the flat your company owned does not, by itself, push you over — but if dealing in property is what you do, it does.

The small-enterprise regimes (Chapter 21b)

The new Chapter 21b creates two regimes, both optional, both aimed at businesses that stay small.

The domestic regime (Art. 168d) is the default and requires nothing from you. If your annual turnover in Bulgaria stays under €51,130, you simply are not registered and you do not charge VAT. Note the condition carefully: turnover must be under the threshold in the current calendar year and in the previous one. Crossing the line once therefore keeps you out of the regime for longer than the year in which you crossed it.

The EU regime (Art. 168e–168g) is the genuinely new thing. It lets a business established in Bulgaria sell VAT-free in other member states too, instead of registering in each one. The conditions are cumulative: your annual turnover across the whole Union must not exceed €100,000, in the current calendar year and the previous one, and you must qualify for the exemption in each country where you want to use it.

The €100,000 is not a Bulgarian number. It is set by Council Directive (EU) 2020/285, which also caps what any member state may set as its national threshold at €85,000 — so Bulgaria's €51,130 sits well under the ceiling it could have chosen.

Unlike the domestic regime, the EU regime has to be applied for. You file a prior application electronically with a qualified electronic signature, listing the member states you want it in, and the NRA issues you an identification number that begins BG and ends in the suffix –EX. Each member state is then activated and deactivated separately, and you file a quarterly turnover report — miss it and Art. 179 applies.

The –EX number covers what you sell, not what you buy. If you are on the EU small-enterprise regime and you buy advertising from Meta, you are still a taxable person receiving a cross-border service, and Art. 97a still applies to you. The two are independent. The only relief the 2026 act added is narrow: the new Art. 97a(6) disapplies the supply side for a Bulgarian-established person supplying Art. 21(2) services into another member state where they are registered for the EU small-enterprise regime.

The rates, once you are registered

Restaurant and catering services went back to 20% on 1 January 2025 after the pandemic-era reduction expired; they are not on the 9% list in 2026.

If you register late

Art. 102 was rewritten. The revenue authority registers you itself, and your registration date is the date the registration act is served on you — but the act also states the date on which you should have been registered had you filed on time, and you owe the tax for the period between the two. In other words, being late does not postpone the liability; it removes your chance to have charged the VAT to your customers, so you pay it out of money you already spent. A fine under Art. 178 applies on top.

This is the practical argument for watching the number monthly rather than annually. The threshold is €51,130 of turnover, which at a typical freelance day rate is not a large business.

Frequently asked questions

Does the €51,130 include income I invoice to clients outside Bulgaria?
Only where the place of supply is Bulgaria. Services to a business customer in another member state are generally supplied where the customer is, under Art. 21(2), so they fall outside the domestic turnover — but they are precisely what triggers Art. 97a. Getting the place of supply right is the whole question, and it is worth an accountant's hour.

I have an EOOD that has not traded yet. Do I need to register?
Not on turnover grounds. But if the company buys a single cross-border service — a domain, a SaaS subscription, an ad campaign — Art. 97a is triggered from that purchase. Many dormant Bulgarian companies are registered under Art. 97a and nothing else.

Can I deregister if my turnover falls?
The small-enterprise regime requires you to be under the threshold in the current and the previous calendar year, so a single bad year does not immediately put you back outside the system.

Is a freelancer taxed differently from an EOOD here?
On VAT, no — the rules above apply to any taxable person. On income tax the difference is real and is covered in freelancing vs. an EOOD and the tax guide.

Do I need a Bulgarian bank account to register?
Not for the registration itself, though you will need one to operate. See opening a bank account.

Sources

• Law amending the Value Added Tax Act, State Gazette issue 115 of 30 December 2025 — Art. 96, Art. 97a, Chapter 21b (Art. 168b–168l), Art. 102, Art. 178–179, in force 1 January 2026
• Council Directive (EU) 2020/285 — Art. 284(1) national threshold ceiling of €85,000, Art. 284(2)(a) Union turnover ceiling of €100,000
• National Revenue Agency — registration forms and the electronic filing portal

This guide describes the law as published and is not tax or legal advice. VAT place-of-supply questions turn on the specific facts of each supply, and the cost of getting one wrong is usually larger than the cost of asking. Verify your own position with a licensed Bulgarian accountant before acting.