DAC8 Reporting in Bulgaria: Practical Guide

Bulgaria has been developing its approach to taxing and regulating crypto-assets as part of its broader alignment with EU frameworks. The Natsionalna agentsia za prihodite (NAP), Bulgaria's National Revenue Agency, is expected to be the competent authority for DAC8 reporting. This guide provides practical information for crypto-asset service providers (CASPs) operating in or serving users in Bulgaria.

Overview

DAC8 extends the EU's automatic exchange of information framework to crypto-asset transactions. CASPs registered or operating in Bulgaria should prepare to collect relevant user data and submit transaction reports to NAP. Bulgaria already participates in CRS and FATCA reporting, and DAC8 is expected to build on this existing infrastructure. Bulgaria's growing digital economy and relatively lower operating costs have attracted some crypto businesses to the jurisdiction.

Competent Authority

The Natsionalna agentsia za prihodite (NAP, National Revenue Agency) is the competent authority for tax administration in Bulgaria, including international exchange of information under CRS and FATCA. NAP is expected to receive and process DAC8 reports. The Ministerstvo na finansite (Ministry of Finance) oversees tax policy and the transposition of EU directives into Bulgarian law.

Detail	Information
Authority name	NAP (Natsionalna agentsia za prihodite, National Revenue Agency)
Parent ministry	Ministerstvo na finansite (Ministry of Finance)
Official gazette	Darzhaven vestnik (State Gazette)
Tax ID format	EGN (Edinen grazhdanski nomer, 10 digits) for individuals / EIK (Edinen identifikatsionen kod, 9 or 13 digits) for entities
Official language	Bulgarian

Key Requirements

CASPs should prepare to report the following under DAC8:

• Reportable users: Individuals and entities tax resident in EU member states who conduct reportable crypto-asset transactions through the CASP.
• Transaction types: Crypto-to-fiat exchanges, crypto-to-crypto exchanges, and transfers of reportable crypto-assets are typically in scope.
• Data elements: Full name, address, date of birth, TIN (EGN for Bulgarian individuals, EIK for entities), transaction gross amounts, number of units, and crypto-asset identification.
• Due diligence: CASPs should implement self-certification collection and TIN validation procedures as specified under DAC8 to identify reportable persons.

Submission Process

NAP has been modernising its electronic filing infrastructure, and DAC8 submissions are expected to be handled through digital channels.

• Format: Reports should follow the OECD CARF XML schema as mandated by DAC8. NAP may publish additional technical specifications, validation rules, and XSD supplements for Bulgarian submissions.
• Language: Official tax administration in Bulgaria is conducted in Bulgarian. XML data fields should follow international standards, but correspondence and supporting materials should typically be in Bulgarian. Note that Bulgaria uses the Cyrillic alphabet, and CASPs should be prepared for potential character encoding considerations.
• Submission channel: NAP may integrate DAC8 reporting into its existing electronic services portal (portal.nap.bg), which is used for CRS and other electronic filings. The exact submission method is to be confirmed by NAP.
• Digital signature: Electronic submissions to NAP typically require a qualified electronic signature (QES). CASPs should ensure they have the necessary digital certificates.

Important Dates

• Transposition deadline: December 31, 2025 (directive must be incorporated into Bulgarian law)
• Data collection begins: January 1, 2026 (reporting entities should start collecting relevant information)
• First reporting period: Calendar year 2026
• First reports due: 2027 (exact date to be confirmed by NAP)

Practical Tips

• Register with NAP and obtain electronic access: Ensure your entity is registered with the National Revenue Agency and has the necessary qualified electronic signature (QES) for electronic filings through portal.nap.bg.
• Monitor the Darzhaven vestnik: All implementing legislation will be published in Bulgaria's State Gazette. Check regularly for transposing laws and ministerial orders.
• Collect EGN/EIK accurately: For Bulgarian-resident users, ensure your systems can capture and validate the 10-digit EGN (for individuals) or 9/13-digit EIK (for entities) during onboarding.
• Address Cyrillic character handling: Ensure your reporting systems can handle Bulgarian names and addresses in Cyrillic script, and understand how NAP expects character encoding in XML submissions.
• Prepare Bulgarian-language capabilities: Your compliance team or local advisors should be able to communicate with NAP in Bulgarian.
• Coordinate with BNB and FSC: The Balgarska narodna banka (BNB, Bulgarian National Bank) and the Komisiya za finansov nadzor (FSC, Financial Supervision Commission) may be involved in MiCA licensing. Be aware of potential coordination between DAC8 reporting and financial regulatory requirements.
• Obtain a qualified electronic signature: If you do not already have a QES, plan ahead as the process of obtaining one from a Bulgarian-accredited provider may take time.
• Engage local professionals: Consider working with Bulgarian danachni konsultanti (tax consultants) experienced in international exchange of information and crypto-asset taxation.

Important Notice

This guide provides general information about DAC8 reporting in Bulgaria. Requirements may change as the directive is transposed into national law. The information presented here should not be considered definitive legal or tax advice. Penalties for non-compliance vary by member state and are determined by national legislation. Always consult NAP and the Ministry of Finance for the latest official requirements. For specific compliance questions, seek advice from qualified Bulgarian tax professionals.