Fiscal Representative in Bulgaria: Who Needs One, and Who Does Not
Most guides say a non-resident business “may need” a fiscal representative in Bulgaria. The VAT Act is more specific than that. It names exactly who must appoint one, who is exempt, what the representative is liable for, and how many days you have when the arrangement breaks.
The short answer
Does your business need a fiscal representative in Bulgaria?
Only businesses established outside the European Union need a fiscal representative in Bulgaria. A company established in another EU member state registers under the ordinary procedure and may appoint a representative voluntarily, but is not required to. The rule sits in Article 133 of the Value Added Tax Act: paragraphs 1 and 2 require an accredited representative, and paragraph 6 removes that requirement for anyone established in another member state, or in a third country that has a mutual assistance agreement with the EU. Branches of foreign companies register under the general procedure regardless.
Established in the EU
Not requiredRegister under the ordinary procedure. You may appoint a representative if you want one, and the replacement deadline then does not apply to you.
Established outside the EU
RequiredRegistration goes through an accredited representative, unless your country has a mutual assistance agreement with the EU.
A branch in Bulgaria
Not requiredBranches of foreign companies are named as an exception in Article 133(1) and register under the general procedure.
Article 133, situation by situation
The four cases the law actually describes
The VAT Act does not have a single sentence saying that non-residents need a representative. It has four separate situations, and they are not interchangeable.
| Provision | Who it covers | Representative |
|---|---|---|
| Art. 133(1) | Foreign person with a permanent establishment in Bulgaria carrying on economic activity from it | Required — except branches, which register under the general procedure |
| Art. 133(2) | Foreign person not established in Bulgaria making taxable supplies with place of supply in Bulgaria | Required |
| Art. 133(2), second sentence | Supplier established neither in the EU nor in a third country with a mutual assistance agreement, making supplies of goods under Art. 28 | Mandatory |
| Art. 133(5) | Person from a third country without a mutual assistance agreement who opts into the Union scheme under Art. 156 | Required |
| Art. 133(6) | Any of the above who is established in another member state, or a third country with a mutual assistance agreement | Not required — ordinary procedure, or Chapter 18 |
Paragraphs 1 and 2 were both amended with effect from 1 January 2026. The mutual assistance agreements the law refers to are those comparable in scope to Council Directive 2010/24/EU and Council Regulation 904/2010 — in other words, arrangements that let Bulgaria actually collect a debt from a taxpayer sitting outside its jurisdiction. That is the whole logic of the requirement. Where the tax authority can reach you through an existing treaty, it does not need someone local standing behind you. Where it cannot, it does.
A detail worth knowing before you file late
Under Article 133(7), the revenue authority may register a person on its own initiative under Article 102 even where that person filed the application on time but did not appoint an accredited representative. Missing the representative does not necessarily stop registration from happening. It stops it from happening on your terms.
What the representative actually carries
Joint and unlimited liability, in the law’s own words
This is the part that explains why fiscal representation is a priced service rather than an administrative formality, and why a serious provider will ask questions before accepting.
Article 135(3) states that the accredited representative is liable jointly and without limitation for the registered foreign person’s obligations under the VAT Act. Not for a fee-capped portion of them. Not only for the ones arising after appointment. For the obligations, jointly with the taxpayer, without a ceiling.
The exceptions are narrow: cases under Article 133(5) for persons registered under Article 154 for the non-Union scheme, and cases under Article 133(6) — which is to say, the voluntary appointments by EU-established businesses that did not need a representative in the first place.
Article 135(2) sets the scope of the mandate: the representative acts for the foreign person in all tax relations arising under the VAT Act. It is not a mailing address and it is not a filing agent.
Who may act as one
Article 135(1) restricts the role to two categories. Either a legally capable natural person with a permanent address in Bulgaria or permanently residing there, or a Bulgarian legal person that is not in liquidation, has not been declared insolvent, and has no due and unpaid tax liabilities or social security contributions collected by the National Revenue Agency.
That last condition is checked, and it is the reason a representative can become unavailable through no fault of yours.
Fourteen days, not a grace period
Article 133(4): if the representative ceases to exist, or circumstances arise that make it impossible for them to perform their duties under the Act, the foreign person must appoint a new representative within 14 days of the date those circumstances arise. For EU-established businesses that appointed a representative voluntarily under Article 133(6), this deadline does not apply.
The registration with no threshold
Article 97a catches businesses that never planned to register
Ordinary VAT registration in Bulgaria is triggered by turnover. Article 97a is not.
It requires registration by any taxable person who receives services with place of supply in Bulgaria where the tax is due from the recipient under Article 82(2), and by any taxable person established in Bulgaria who supplies services under Article 21(2) with place of supply in another member state where the recipient owes the tax. Registration on one ground counts as registration on the other, in both directions.
There is no turnover threshold in that article. A newly formed Bulgarian company that buys advertising from an Irish entity, or cloud hosting from a Luxembourg one, is inside it from the first invoice. So is a Bulgarian consultancy issuing its first invoice to a German client. The trigger is the nature of the transaction, not its size.
And the timing is tighter than most people expect. Under Article 97a(4), the application must be filed no later than seven days before the date on which the tax on the supply becomes chargeable — which is the earlier of the advance payment or the tax event, not the invoice date and not the payment date.
Seven days before, not seven days after. That single word is the reason a good share of first-year penalties happen.
What changed on 1 January 2026
The threshold, now stated in euro
Article 96(1) was amended with effect from 1 January 2026. A taxable person established in Bulgaria must register once annual turnover in the country, determined under Article 168в, exceeds the national threshold of €51,130. The figure is in euro because Bulgaria adopted the currency on the same date; it is the same threshold restated, not a new policy.
Article 96(2) is the genuinely new part. It brings in the EU small enterprise scheme under Article 168к for businesses established in another member state, with its own conditions. If you are an EU business currently below the Bulgarian threshold, that provision is the one to read before assuming nothing has changed for you.
| Registration ground | Threshold | Deadline |
|---|---|---|
| Ordinary registration, Art. 96(1) | €51,130 annual turnover | On exceeding the threshold |
| Cross-border services, Art. 97a | None | 7 days before the tax becomes chargeable |
| Non-established person making taxable supplies, Art. 133(2) | Per the compulsory registration conditions | Through an accredited representative |
Registration under Article 133(1) and (2) is carried out under Article 101, at the territorial directorate of the National Revenue Agency determined under Article 8 of the Tax and Social Insurance Procedure Code.
Fees
What we charge to act as your accredited representative
Most providers quote this privately, because the price is not really for paperwork. It is for standing behind someone else’s VAT. Ours is published, and so is the condition attached to it.
Setup
€900One-off. Review of what you supply and to whom, the ground you register on, checks on the beneficial owner, and appointment with the National Revenue Agency.
Ongoing
€250 / monthEvery month the registration stays active. Representation before the NRA, the monthly VAT return, and every notice that arrives in your name.
Security
from €5,000Deposit or bank guarantee equal to three months of your estimated VAT, and never below €5,000. Agreed before we accept, returned when the representation ends.
What the fee covers
- Deciding which registration ground applies to your case
- Checks on the company and the beneficial owner
- Appointment and registration with the NRA
- The monthly VAT return and the VIES declaration where it applies
- Correspondence, notices and deadlines tracked in your name
What it does not cover
- The VAT itself, and any interest or penalty on it
- Customs duties and import formalities
- Intrastat registration and declarations
- Bookkeeping for the underlying business
- Defence during a tax audit, quoted separately
Why there is security at all. Article 135(3) makes the accredited representative liable jointly and without limitation for your obligations under the VAT Act. Not a capped share of them. That is set out in full further up this page, and it is the reason the security is not negotiable and the reason we can decline a case.
If you are established in the EU, you do not need this service. The obligation reaches businesses established outside the EU. An EU-established business may appoint a representative, but is not required to, and in most cases should not pay for one.
The questions we get
Frequently Asked Questions
Does an EU company need a fiscal representative in Bulgaria?
No. Article 133(6) provides that where the person is established in another member state, registration is carried out under the ordinary procedure or under the special procedure of Chapter 18. The company may appoint a representative if it prefers to, and in that case the 14-day replacement deadline in Article 133(4) does not apply to it.
Is a Bulgarian branch of a foreign company treated the same as the parent?
No. Article 133(1) names branches of foreign persons as an explicit exception — they register under the general procedure rather than through an accredited representative.
What exactly is the fiscal representative liable for?
Under Article 135(3), jointly and without limitation for the registered foreign person’s obligations under the VAT Act. The exceptions are the non-Union scheme cases under Article 133(5) and the voluntary appointments under Article 133(6).
Can any Bulgarian company act as a fiscal representative?
Not any. Article 135(1) requires either a legally capable natural person with a permanent address or permanent residence in Bulgaria, or a Bulgarian legal person that is not in liquidation, has not been declared insolvent, and has no due and unpaid tax or social security liabilities collected by the National Revenue Agency.
What happens if my representative resigns or is dissolved?
Article 133(4) gives the foreign person 14 days from the date the circumstances arise to appoint a new accredited representative. The clock runs from the event, not from the date you find out about it.
Do I need to register for VAT before I reach the turnover threshold?
Often yes, on a different ground. Article 97a has no threshold and applies to cross-border B2B services in both directions, with the application due no later than seven days before the tax on the supply becomes chargeable.
Is a fiscal representative the same as a registered address or a local director?
No. Article 135(2) makes the representative act for the foreign person in all tax relations arising under the VAT Act, and Article 135(3) attaches joint and unlimited liability to that role. A registered office is an address; a fiscal representative carries the tax debt with you.
Getting it right the first time
What usually needs deciding before you file
The registration ground determines the deadline, the paperwork and whether a representative is needed at all. Choosing it after filing is the expensive order to do things in.
Establish where you actually are
Whether you are established in Bulgaria, in another member state, or outside the EU decides which paragraph of Article 133 applies to you, and therefore whether a representative is required, optional, or irrelevant.
Identify the registration ground
Ordinary turnover registration, Article 97a for cross-border services, or registration of a non-established person. The grounds carry different deadlines and different deduction consequences.
Then keep it filed
Monthly returns, VIES statements where relevant, OSS where you sell to consumers, and the records behind them. Registration is the beginning of the obligation, not the end of it.
Tell us where the company sits and what it sells
Where the business is established, what it supplies, to whom, and where those customers are. That is enough to say which registration ground applies, whether a representative is required, and what the deadline is — before anything is filed.
Every rule, traced
Sources
Every article number, deadline and threshold on this page is taken from the consolidated text of the Bulgarian Value Added Tax Act, read directly rather than summarised from a secondary guide.
- Value Added Tax Act (Закон за данък върху добавената стойност), consolidated text — Articles 96, 97a, 101, 133, 135, 154, 156
- National Revenue Agency — VAT in Bulgaria — the administering authority
Last verified: August 2026. Articles 96(1), 133(1) and 133(2) were amended by State Gazette issue 115 of 2025, in force from 1 January 2026. The mutual assistance agreements referred to in Article 133 are those comparable in scope to Council Directive 2010/24/EU and Council Regulation (EU) 904/2010. This page describes the statutory framework and is not tax advice for a specific business.
Daniel Malbašić is a business expert with extensive experience in the field of business consulting, organization and business optimization. His expertise includes market analysis, strategic planning, and implementation of effective business solutions. Daniel is dedicated to helping companies grow and improve their operations, providing them with comprehensive support in making key business decisions.