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Annual Financial Statements in Bulgaria: the 30 September Filing Foreign Owners Underestimate

Every Bulgarian company must file its annual financial statements with the Commercial Register, where they become public and permanently searchable. For the 2025 financial year the deadline is 30 September 2026, filing is free of charge, and the whole process is electronic. Even so, many companies miss it every year. For foreign owners the reason is rarely the accounting itself; far more often, nobody in Bulgaria can sign the filing.

Current as of 23 September 2026. The rules are in the Bulgarian Accountancy Act (Закон за счетоводството), primarily Art. 38 (publication), Art. 37 (audit) and Art. 74 (penalties). Bulgaria has used the euro since 1 January 2026 at the fixed rate €1 = 1.95583 BGN, and leva amounts still written into older statutory texts are read at that rate. General information, not accounting or legal advice.

If you are reading this in the last days of September 2026 and nothing has been filed, file now with what you have. A late filing still has to be made, and each day of delay shows in the register.

What is actually being filed

Two different obligations are routinely confused, and missing either one is expensive:

Your accountant filing the tax return in June does not discharge the September obligation. They are separate submissions, to separate institutions, under separate laws. This is the most common cause of a penalty for a foreign-owned company: the owner sees the corporate tax paid and assumes the year is closed.

Who has to publish

In practice, everyone who trades through a Bulgarian entity:

• EOOD, OOD, AD, EAD and partnerships, in the Commercial Register;
• branches of foreign companies registered in Bulgaria;
• sole traders (ET), only where a statutory audit applies, which excludes most of them;
• associations and foundations, in the Register of Non-Profit Legal Entities.

Size changes the volume, not the obligation. Micro-entities may publish an abridged balance sheet only; small entities an abridged balance sheet with notes, without the profit and loss account. The category is set by Art. 19 of the Accountancy Act on assets, net revenue and headcount. A dormant holding company and a trading group both file, but what the public sees differs sharply.

That publicity is worth understanding before you file. A Bulgarian bank assessing your loan application, a supplier deciding your credit terms and a buyer doing due diligence on your company will all pull the register. A gap in the filing history reads as a governance problem long before anyone looks at the numbers.

The real obstacle for non-residents: the electronic signature

The G2 application is filed electronically through the Registry Agency portal and signed with a qualified electronic signature (QES) from a Bulgarian trust service provider. That is where a remotely run company stalls, because getting a Bulgarian QES requires identification and is normally done in person.

You have three workable routes:

1. Your accountant files it. The accountant who compiled the statements may file them with their own qualified signature, on the strength of a notarised power of attorney from the company’s manager (Registry Agency guidance under the Commercial Register Act). If you sign that power of attorney abroad, it needs an apostille and a Bulgarian translation. This is the usual route for foreign-owned companies, and after the power of attorney it needs nothing from you beyond approving the accounts.
2. A Bulgarian lawyer files it under a lawyer’s power of attorney. Useful when you have no accounting engagement in place, or when the filing is contested internally.
3. You obtain a Bulgarian QES yourself. Worth it if you file a lot of company changes, but too much effort if this is your one annual submission.

Note what is not on that list. A foreign eIDAS signature is not, in practice, a drop-in substitute in the Commercial Register portal, and paper filing at a counter (still legally possible) means a physical appearance and a slower, error-prone process. Settle the route by early summer: a power of attorney signed abroad has to be notarised, apostilled and translated, which takes weeks.

The document set

A clean G2 submission for a standard EOOD contains:

• the annual financial statements as adopted, signed by the preparer and the manager;
• the owner’s decision or minutes of the general meeting adopting the statements (a missing or undated decision is the most frequent reason for refusal);
• a declaration under Art. 13(4) of the Commercial Register Act;
• a declaration confirming the statements were adopted in the proper order (Art. 62a(2)(2) of Ordinance No. 1);
• the auditor’s report, where an audit is required;
• the management report, where the entity is required to produce one.

The 2025 statements are drawn up in the reporting currency of that year, the lev, while anything you settle in 2026, including a penalty, is paid in euro at the fixed rate. Your first set of statements in euro is the one for the 2026 financial year, filed in 2027.

When an audit is required

A small enterprise is subject to a mandatory independent financial audit if, at 31 December, it exceeds at least two of these three indicators:

These thresholds were doubled from 6 July 2024, so older articles that quote BGN 2 million and BGN 4 million are out of date. Medium and large enterprises, and public-interest entities, are audited regardless. Joint-stock companies (AD/EAD) are in practice audited as a matter of course.

If you are anywhere near two of those numbers, engage the auditor early in the year. An audit commissioned in late summer against a 30 September deadline is expensive and often cannot be delivered in time, and the deadline does not move because your auditor is busy.

Dormant companies file too, but something different

A company with no activity during 2025 does not publish statements. It files a declaration of no activity under Art. 38(9)(2) of the Accountancy Act, with an earlier deadline of 30 June 2026, also free.

Two details matter to owners of holding or shelf companies:

• The declaration is filed once. If you already declared inactivity for an earlier year and the company is still dormant, you do not repeat it annually.
• “No activity” is narrower than it sounds. A single invoice or accrued interest can be treated as activity, and even bank charges on the company account are a grey area. In that case a full set of statements is due by 30 September instead of a declaration by 30 June. When in doubt, ask before you rely on the shorter route.

If you have just bought a dormant Bulgarian company, check its filing history before your first deadline. Inherited gaps become your gaps, and the register shows them to everyone.

Penalties

Under Art. 74 of the Accountancy Act, failure to publish on time attracts:

• for the manager, a fine of €102 to €1,534 (BGN 200–3,000);
• for the company, a pecuniary sanction of 0.1% to 0.5% of net sales revenue for the reporting period, minimum €102;
• double on a repeat offence.

For a small company that is an annoyance. For a company turning over €3 million, half a percent is €15,000, from a filing that costs nothing to make. The sanction does not extinguish the obligation either: you still publish, late, with the delay visible in the register.

A realistic timeline for the filing year

The dates below are for a normal year, planned in advance. For the FY2026 statements the deadline is 30 September 2027.

Filing on 30 September itself leaves no room for the registry official to come back with a correction request, and a refusal on the last day is simply a missed deadline.

Do not confuse it with the euro capital filing

2026 carries a second, unrelated Commercial Register obligation with a 31 December 2026 deadline: redenominating your share capital into euro and filing the amended articles. It is a different application, with its own deadline and document set; see your Bulgarian company’s capital in euro. Handling both with your lawyer at the same time saves a round of fees. Assuming one covers the other means missing both.

For the wider annual cycle (advance corporate tax instalments, VAT periods, payroll filings), start from the Bulgaria corporate tax guide. If you are still setting up, opening a company as a non-resident covers what lands in your first year.

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We prepare, adopt and publish annual financial statements for foreign-owned Bulgarian companies, including the dormant-company declaration and the filing itself under our own qualified signature, so nothing depends on you being in Sofia in September. See our accounting services, company formation and pricing.