What changed in 2026?
For taxable persons established in Bulgaria, the general registration obligation arises when annual turnover in Bulgaria exceeds EUR 51,130.
Turnover is monitored for the current calendar year. The control process should therefore identify both the cumulative amount and the exact transaction that takes it above the threshold.
When is the application due?
The application under the general rule is due within seven days after the threshold is exceeded. Registration takes effect from the following day.
If turnover is EUR 48,500 through August and two September transactions bring the annual total to EUR 52,000, the deadline starts from the transaction that crosses the threshold. Waiting for the month-end close may be too late.
Which transactions count towards turnover?
Adding together all bank receipts does not automatically produce the turnover used for Bulgarian VAT registration. The supplies, place-of-supply rules, and their VAT treatment must be analysed.
Advance payments, disposals of assets, and specific cross-border transactions require review based on their substance, not merely on the movement of funds.
Below the threshold does not always mean no registration
The general threshold is only one ground. Registration may arise independently of turnover for certain services received from foreign suppliers, services supplied to business customers in another EU Member State, intra-Community acquisitions, and other specific cases.
A typical example is a new business buying advertising, software, or cloud services from a foreign supplier. Article 97a should then be reviewed before the first relevant supply or payment.
Voluntary registration is a separate business decision
A business does not always need to wait for mandatory registration. Voluntary registration should be assessed against the customer base, planned purchases and investment, input VAT recovery, and the effect on final prices.
The commercial impact may be very different for a B2B company and a business selling mainly to consumers.
What do we review?
A reliable conclusion requires more than one number or a bank statement.
- Where is the taxable person established?
- What activity and supplies are involved?
- Where is the place of supply?
- Which transactions form annual turnover?
- Is there a separate registration ground?
- On what date did the relevant ground arise?