Article 97a VAT registration in Bulgaria 2026

A Bulgarian company that is not VAT-registered must register under Article 97a of the VAT Act (ЗДДС) if it buys taxable services from foreign suppliers (Google Ads, Meta, Booking.com, Airbnb, SaaS subscriptions) or sells services to businesses in other EU countries. The application goes to the National Revenue Agency (NRA) no later than 7 days before the first payment or taxable event for the service, whatever the company's turnover. Once registered, the company charges 20% VAT on every such service it receives and pays it itself, without the right to deduct it.

When the Article 97a obligation arises

The law covers two separate cases, which in practice often come together.

1. You receive services from a foreign supplier (Art. 97a(1))

When the supplier is not established in Bulgaria and the customer is a business, the place of supply is Bulgaria (Art. 21(2) VAT Act) and the VAT is due from the customer (Art. 82(2)(3)). This is the reverse charge. Because you have to charge the VAT yourself, and an unregistered person cannot do that, the law requires you to register.

Typical examples for a small business:

advertising on Google Ads (invoiced by Google Ireland Ltd) and Meta (Facebook, Instagram);
Booking.com and Airbnb commissions on accommodation you offer through your company;
fees charged by freelance platforms such as Upwork;
software as a service: CRM, hosting, design tools, cloud services.

The rule does not depend on whether the supplier is in the EU. What matters is that it is not established in Bulgaria. One exception: if the service is an exempt supply (for example payment services under Art. 46(1)(3)), it is not taxable and does not trigger Article 97a registration. For fees charged by payment providers such as Stripe, check how the provider classifies the fee on its invoice.

2. You sell services to businesses in another EU country (Art. 97a(2))

If your company provides general-rule services (software development, design, consulting, marketing) to a customer registered for VAT in another member state, the place of supply is the customer's country and the customer accounts for the VAT. You still have to register in Bulgaria under Art. 97a(2). Since 1 January 2026 the only exception is when you are registered in Bulgaria to use the EU small-business scheme in the customer's country (Art. 97a(6)).

Registration under one paragraph automatically counts for the other (Art. 97a(3)).

Deadline: register before the service, not after

The application must be filed no later than 7 days before the date on which the VAT on the supply becomes chargeable, meaning before the advance payment or the taxable event (Art. 97a(4)). If you prepay by card (typical for Google Ads and Meta), the VAT becomes chargeable on the day of payment (Art. 25(7)). For subscriptions, each period for which payment is agreed is a separate supply (Art. 25(4)).

The NRA completes an Article 97a registration within three days of the application (Art. 101(8)). If you do not apply, the revenue authority can register you itself by an administrative act (Art. 102), and the penalty for not filing the application is BGN 500 to 5,000 under the text of the law, i.e. €255.65 to €2,556.46 (Art. 178).

How the reverse charge works after registration

You receive the foreign supplier's invoice without VAT.
Within 15 days of the date the VAT became chargeable, you issue a protocol under Art. 117 and charge 20% VAT on the taxable amount (Art. 66).
You record the protocol in your VAT ledgers and in the monthly VAT return.
You file the VAT return electronically by the 14th of the following month and pay the VAT by the same date (Art. 125(5)).

The key difference: a person registered under Article 97a has no right to input VAT credit (Art. 70(4)). The VAT you charge is not deducted; you pay it and it stays a cost to the company. The company also may not show VAT on its own invoices (Art. 113(9)).

VIES declaration when you sell services in the EU

If you are registered and supply Art. 21(2) services to customers in another member state, you file a VIES declaration for the same month together with the VAT return (Art. 125(2)). The deadline is the same: the 14th of the following month. Your invoice carries no VAT, but it states the reason VAT is not charged (Art. 114(1)(12)). Example: you invoice a German client €2,000 for software development. The invoice has no VAT, the client accounts for German VAT, and you report the supply in your VIES declaration.

The VAT return is due every month, even when you have no transactions at all (Art. 125(4)). The penalty for a missing or late return is BGN 500 to 10,000 (€255.65 to €5,112.92, Art. 179).

Worked example: Google Ads invoices from Ireland

"Example" OOD is not VAT-registered, has turnover of around €30,000 a year and decides to start Google Ads on 1 December 2026 with a budget of €500 a month, prepaid by card. Google Ireland Ltd issues invoices without VAT.

Step	Date / amount
Last day to apply under Art. 97a	24.11.2026 (7 days before 01.12.2026)
Registration by the NRA	within 3 days of applying
First payment to Google (taxable amount)	01.12.2026 – €500.00
20% VAT on the protocol (within 15 days)	€100.00
VAT return for December and payment	by 14.01.2027 – €100.00
Annual advertising spend	€6,000.00
VAT for the year, not deductible	€1,200.00
Real cost of the advertising	€7,200.00

If the company were registered under Article 96 or voluntarily and made taxable sales, the same €1,200.00 would be charged and deducted as input VAT in the same month.

How it differs from registration at €51,130 turnover

	Art. 97a	Art. 96 (threshold)
Trigger	services received from abroad or supplied to EU businesses	domestic turnover above €51,130 in the calendar year
Deadline	at least 7 days before the VAT becomes chargeable	within 7 days after crossing the threshold
VAT on your invoices	no	yes
Right to deduct input VAT	no	yes
Monthly VAT return	yes	yes

If a company registered under Article 97a crosses the €51,130 threshold, it registers under the procedure and deadlines of Article 96 (Art. 97a(5)). More on full registration is on our VAT registration page.

What it costs in practice

VAT on the services: 20% of their value, with no deduction (€1,200.00 a year in the example).
Admin work: a protocol for every invoice, a monthly VAT return and, for EU sales, a VIES declaration, all filed electronically each month.
Bookkeeping: Fiscala's price depends on the number of documents and on VAT registration, starting at €17 a month; VAT registration costs €0 to €200. See our pricing.

When the company stops receiving such services and has no ground for mandatory registration, it can apply to deregister (Art. 108(1)(4)). Monthly filing dates are in our tax calendar.

FAQ

Do I need Article 97a registration if I only pay €20 a month for software?

Yes. Article 97a has no threshold: any taxable service with its place of supply in Bulgaria, where the VAT is due from the customer, creates the obligation to register.

Can I deduct the VAT I charge on the protocol?

No. A person registered only under Article 97a has no right to input VAT credit (Art. 70(4)). You get that right after registering under Article 96 or voluntarily under Article 100(1).

Does this apply to suppliers outside the EU?

Yes. The reverse charge under Art. 82(2) applies when the supplier is not established in Bulgaria, whether it is in the EU or in a third country.

What if I have already paid for ads without being registered?

The NRA can register you by an act and impose a penalty under Art. 178. Apply as soon as possible and go through every foreign invoice you have received with an accountant.