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. None of that stops several thousand companies missing it every autumn — and for foreign owners the reason is almost never the accounting. It is the signature.
Current as of August 2026. The rules are in the Bulgarian Accountancy Act (Закон за счетоводството), primarily Art. 38 (publication), Art. 37 (audit) and Art. 74 (penalties). Bulgaria uses the euro from 1 January 2026 at the fixed rate €1 = 1.95583 BGN; leva amounts still written into older statutory texts are read at that rate. General information, not accounting or legal advice.
What is actually being filed
Two different obligations are routinely confused, and missing either one is expensive:
| Criterion | Annual tax return | Annual financial statements |
|---|---|---|
| Filed with | National Revenue Agency (NRA) | Commercial Register (Registry Agency) |
| Form | Art. 92 CITA return | Application G2 plus the statements |
| Deadline for FY2025 | 30 June 2026 | 30 September 2026 |
| Public? | No | Yes — anyone can read it |
| Fee | none | none |
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 single 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 — so 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 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, signed with a qualified electronic signature (КЕП) issued by a Bulgarian certification provider. That is where a remotely-run company stalls, because a Bulgarian КЕП requires identification and is normally collected in person.
You have three workable routes:
- Your accountant files it. Under the Accountancy Act the person who compiled the statements may file them, using their own qualified signature. This is the default for most foreign-owned companies and requires nothing from you beyond approving the accounts.
- A Bulgarian lawyer files it under an express power of attorney. Useful when you have no accounting engagement in place, or when the filing is contested internally.
- You obtain a Bulgarian КЕП yourself. Worth it if you file a lot of company changes; overkill if this is your one annual submission.
Note what is not on that list: a foreign eIDAS signature is not a drop-in substitute in the Commercial Register portal in practice, and paper filing at a counter — still legally possible — means a physical appearance and a slower, error-prone process. Decide the route in August, not on 28 September.
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 — leva — while anything you settle in 2026, including a penalty, is paid in euro at the fixed rate. Your first euro-denominated set of statements is the one for the 2026 financial year, filed in 2027.
When an audit is required
A small enterprise falls into mandatory independent financial audit if, at 31 December, it exceeds at least two of these three:
| Indicator | Threshold |
|---|---|
| Balance sheet total | €1,022,584 (BGN 2,000,000) |
| Net revenue from sales | €2,045,168 (BGN 4,000,000) |
| Average headcount for the period | 50 |
Medium and large enterprises, and public-interest entities, are audited regardless. Joint-stock companies (AD/EAD) are audited in practice as a matter of course.
If you are anywhere near two of those numbers, engage the auditor in the spring. An audit commissioned in August against a 30 September deadline is both expensive and, quite often, undeliverable — 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: 30 June 2026, also free.
Two details that 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 bank charge on the company account, one invoice, or accrued interest can be enough to make the year an active one — in which case a full set of statements is due by 30 September, not 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. And the sanction does not extinguish the obligation: you still publish, late, with the delay visible in the register.
A realistic timeline
| By | Do this |
|---|---|
| Early September | Statements finalised and signed; confirm who holds the qualified signature that will file |
| Mid-September | Owner’s decision adopting the accounts signed and dated |
| By 20 September | G2 submitted through the portal |
| Last week of September | Buffer for a refusal with instructions — the portal is congested and refusals at this stage are common |
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, a different deadline and a different document set — see your Bulgarian company’s capital in euro. Companies that handle both in one trip to their lawyer save a round of fees; companies that assume one covers the other miss both.
For the wider annual cycle — advance corporate tax instalments, VAT periods, payroll filings — start from the Bulgaria corporate tax guide, and if you are still setting up, opening a company as a non-resident covers what lands in your first year.
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.