Issue No. 205/09.06.2025
TO
MRS. TEMENUZHKA PETKOVA,
MINISTER OF FINANCE
MR. RUMEN SPETSOV,
EXECUTIVE DIRECTOR OF THE
NATIONAL REVENUE AGENCY
DEAR MADAM MINISTER,
DEAR MR. SPETSOV,
In connection with the draft order published on the official website of the National Revenue Agency (NRA) approving the structure, format and procedure for submitting the Standard Audit File for Tax (SAF-T), which obliged entities should provide to the NRA on the basis of Art. 71h of the Code of Civil Procedure, the Association of Bulgarian Employers' Organizations (AOBЕ) expresses its position on the application of this standard for all enterprises, as the initial analysis shows that the concept, terms and scope of the affected persons require further discussion in view of the ratio between the benefits for the tax authorities and the burden for the business. In its previous positions, the business has also raised the alarm regarding its concerns about the introduction of a monthly standard audit file, without a real impact assessment and in connection with the increased expected administrative, personnel and financial burden for the business.
AOBЕ believes that the introduction of SAF-T represents a significant change in the accounting practice of enterprises and requires careful planning and adaptation by the business. The standard audit file for tax purposes requires detailing of all deliveries by type, quantity, unit of measurement and delivery price, regardless of their accounting treatment, which requires adaptation of accounting software and significantly more time for processing documents. We understand that the phased approach, tied to the category of the enterprise, aims for a smoother transition, but we also draw attention to the fact that all enterprises should start preparing early, as the SAF-T is an extremely voluminous and detailed report that requires all documents to be accounted for in the monthly accounting of the enterprise and all accounting entries and accounting operations to be performed before the file can be generated and submitted. Preparation requires reorganization of processes, reliable accounting software and excellent knowledge of the requirements and nomenclatures of the NRA.
For a smooth and successful transition of enterprises to the new reporting regime, we suggest the following specific steps:
1. Need for a cost-benefit analysis - it is not clear whether a thorough analysis of the expected fiscal effect of the implementation of SAF-T has been carried out in relation to the additional administrative and financial burden on business. The expected benefits (fighting the shadow economy, increasing the collection of public revenues, etc.) must be compared with the real burden on enterprises, especially micro, small and medium-sized enterprises. The processing and analysis of structured data will facilitate the NRA in identifying deviations between reported and actually implemented operations. It will probably lead to savings in resources and costs in the NRA when carrying out checks and audits, since the accounting statements will be standardized in advance. All this represents a potential for increasing tax revenues and limiting the possibilities for their evasion, but at the same time, enterprises must acquire or adapt accounting systems capable of generating SAF-T in XML format. For SMEs, this often means a high initial cost for licenses, implementation, integration and testing services, as well as additional costs for each update of the NRA requirements. Many small companies rely on external accounting firms, which will also have to reorient their processes, train their staff and provide new software solutions, and who in turn will pass the costs on to their SME clients. The increased administrative burden will be enormous, as enterprises will have to submit monthly (or upon request) reliable information, which will require monthly inventory of inventories and fixed assets, detailing of bank payments with full references of bank operations, verification of related parties, even when this data is already available in other registers. Many micro- and small enterprises without an internal "IT" department or the ability to pay an external consultant will encounter serious difficulties in meeting the requirements. For some of them, this may prove to be an unbearable expense, which would force them to cease operations or continue working in the gray economy. The effect of implementing SAF-T may be the opposite – individuals who work with low margins or in the grey sector will simply not file, while honest businesses will bear the additional burden and ultimately the tax authorities may lose from undeclared income, instead of increasing it.
2. Simplifying the SAF-T standard for micro and small enterprises – in view of the above in item 1, we propose that during the period of preparation and launch of reporting for large and medium-sized enterprises, the incoming information be analyzed and a second (separate) XSD schema be prepared, containing the data that can be extracted from the accounting software of external accounting firms. Almost always, micro and small enterprises use a combination of free invoicing software with export to the accounting software of an accounting firm, where current accounting standards do not require the keeping of goods turnover at an analytical level by objects or items. In this regard, the requirement to provide such information will lead to the need to restructure software products and the method of data processing, and in most cases, the effort to maintain up-to-date data will be many times greater, which will lead to costs for accounting and administrative information support, many times higher than before.
3. Need for the adoption and implementation of a single and mandatory national chart of accounts – Currently, there is no mandatory national chart of accounts in Bulgaria. Each enterprise creates or adapts its own accounting accounts according to the specifics of the activity – production, trade, services, investments, etc. Full structural compatibility of data from different enterprises – without unification – is practically impossible. SAF-T requires all enterprises to have identical accounts for income, expenses, assets and liabilities in order to obtain correct, aggregated information. AOBE believes that before proceeding with the mandatory submission of SAF-T, a single national chart of accounts should be adopted and implemented, which would be mandatory for all enterprises. This will ensure comparability and automated data matching.
4. The need for a unified banking standard with which banks provide information to enterprises, which would imply automated accounting of bank operations - SAF-T requires that each receipt or payment on a bank account be described with detailed references: payment document number, date, reason, beneficiary, recipient, currency, etc. At this stage, banking institutions provide statements in different formats (PDF, CSV, XML, but each with a different structure), which are not directly compatible with accounting systems. There is no unified structure. AOBE proposes to adopt a regulatory obligation for banks to introduce a unified standard exchange file (e.g. XML) that contains all mandatory fields.
In conclusion - AOBE supports the goals of digitalization, increasing tax transparency and effective risk management for the tax authorities, but emphasizes that the introduction of SAF-T should be accompanied by measures to facilitate business, a clear legal framework and reduce duplicate obligations. In the absence of a realistic approach, we risk the opposite effect - an increase in the informal economy, administrative difficulties and difficulties for actually operating enterprises.
We express the readiness of AOBE to actively cooperate with the Ministry of Finance and the National Revenue Agency in the development of specific regulatory texts, data exchange techniques and effective transitional periods that will ensure sustainable and competitive economic growth in Bulgaria. In the context of achieving joint results and active social dialogue, we express our desire to hold a working meeting with the teams of the Ministry of Finance and the National Revenue Agency as soon as possible. We remain available to agree on details for the meeting, according to your programs.
RESPECTFULLY,
RUMEN RADEV,
CHAIRMAN OF THE BOARD OF DIRECTORS OF BICA,
ROTATING CHAIRMAN OF AOBE FOR 2025, BY ORDER OF , BIA, BCCI AND CEIBG
