NRA e-invoicing in Bulgaria: what EDIFACT has to do with it

Bulgaria's e-invoicing mandate

The Bulgarian National Revenue Agency (NRA) has been progressively expanding its e-invoicing requirements for B2B transactions. For enterprises that already use EDIFACT INVOIC messages for trading partner exchange, the question is straightforward: does your existing EDIFACT integration satisfy the NRA requirement, or do you need something separate?

The answer is: you almost certainly need both, but they can be connected.

EDIFACT INVOIC and the NRA schema are different things

EDIFACT INVOIC is a message format for exchanging invoice data between trading partners. It is designed for machine-to-machine communication between two organisations' systems.

The NRA e-invoice requirement is about reporting invoice data to the tax authority in a specific XML schema (based on the European EN 16931 standard and the Bulgarian UBL profile). It is designed for tax reporting, not trading partner communication.

These are two different purposes, two different formats, and two different recipients. A company that sends EDIFACT INVOIC messages to its customers has not automatically satisfied its NRA reporting obligation.

Where they overlap

Both systems use the same underlying invoice data: supplier and buyer identifiers, invoice date and number, line items with quantities and prices, VAT amounts, payment terms. The data is the same — the format and the recipient are different.

This overlap is the foundation for a practical solution.

The translation layer approach

The most efficient way to satisfy both requirements is a translation layer that sits between your ERP and both output channels:

• Your ERP generates invoice data in its internal format
• The integration layer translates this into EDIFACT INVOIC for your trading partners
• The same integration layer translates it into NRA XML for the tax authority reporting
• Both outputs are generated from the same source data, at the same time

If you already have EDIFACT integration in place, adding the NRA XML output is a relatively contained piece of work — you are adding a new output format to an existing data pipeline, not building something from scratch.

What changes with the NRA requirement

The NRA schema requires some data elements that EDIFACT INVOIC messages do not always carry:

• Bulgarian VAT numbers in a specific format (BG + 9 digits)
• The Bulgarian legal entity registration number
• Specific VAT category codes aligned with Bulgarian tax law
• The QR code or unique document identifier required by NRA

Your EDIFACT mapping may need to be enriched with these additional data elements, sourced from your ERP master data.

Practical timeline

The NRA e-invoicing requirements have been rolling out in phases. If you are a large enterprise (above a certain turnover threshold), you may already be subject to mandatory e-invoicing. Smaller enterprises are being brought in progressively.

Check the current NRA guidance at nap.bg for the specific timeline that applies to your organisation.

The recommendation

If you are planning an EDIFACT integration and you are subject to NRA e-invoicing, design for both from the start. The incremental cost of adding NRA XML output to an EDIFACT integration project is small. Retrofitting it later is significantly more expensive.

If you already have EDIFACT integration and need to add NRA compliance, the work is typically 2–4 weeks depending on the complexity of your VAT treatment.

Next steps

For a broader overview of EDIFACT compliance in Bulgaria, read our plain-language EDIFACT guide.

If your business uses SAP and needs to comply with NRA e-invoicing, our article on EDIFACT and SAP message mapping covers the specific integration points.

We have helped multiple Bulgarian enterprises implement NRA-compliant EDIFACT pipelines. Contact our team to discuss your specific setup.