Annual Financial Statements in Bulgaria

Preparation of year-end accounts and publication documents, with checks on company activity, approval requirements and whether an audit is needed.

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Published
09.14.2021

A client’s annual financial statements depended on documents held by several people, and responsibility for the deadlines was unclear. ARG checked the work already completed, identified missing records and organised the remaining tasks with those involved. Specific explanations helped the client understand what still needed attention and who needed to provide the underlying information.

Preparing the accounts involves decisions about the company’s activity, accounting records, audit position and corporate approval. Tax and statistical submissions also need to be checked against the year-end figures. Missing records or an unresolved audit question can delay publication even where a return has already been filed. Establishing the reporting route and assigning each task early gives management a basis for coordinating the accountant, auditor and authorised filer.

ARG can help when you need to

  • Bring together year-end records held by your accountant, directors and other people responsible for the company’s documents.
  • Check whether the full reporting period supports an inactivity declaration or requires annual financial statements.
  • Establish audit and adoption requirements before arranging Commercial Register publication.
  • Identify outstanding tax, activity-reporting and publication tasks and assign responsibility for completing them.

At a glance

(001)
Closed accounting records

Provide reconciled ledgers, bank statements, assets, stock, loans and year-end adjustments; the statements must reflect the full reporting period.

(002)
Activity status

No sales is not enough for inactivity. Test all four statutory conditions and check whether the one-time declaration has already been filed.

(003)
Standards and audit

Establish the enterprise category, accounting basis and audit or group requirements before finalising the reports and approval timetable.

(004)
Approval and publication

Arrange valid corporate adoption and an authorised filer. Ordinary publication is due by 30 September; first-period inactivity declarations by 30 June.

What are annual financial statements in Bulgaria and why are they separate from tax and activity reporting?

Annual financial statements are the company’s formal year-end account of what it owns and owes, its income and expenses, and the information needed to understand those figures. In Bulgaria the annual financial report is commonly called the GFO. Its components depend on the enterprise category and accounting framework: a microenterprise’s permitted shortened presentation differs from a complete set required for a larger business. The figures must come from reconciled accounting records; downloading a balance-sheet template does not complete the underlying accounting work.

The Bulgarian Accountancy Act (Закон за счетоводството, ЗСч) regulates preparation, accounting basis, form, corporate adoption and publication. Under Articles 16, 18 to 19, 29 and 38(1), the required components and presentation depend on the company’s category, accounting basis, legal form and any additional reporting requirements. Accountancy Act, Arts. 16, 18–19, 29 and 38

Support the accounts with reconciled books and evidence for assets, liabilities, income, costs and year-end adjustments. Owners, directors, lenders, counterparties and public authorities may rely on the published figures. A profit or loss does not determine whether reporting obligations have been completed.

The Bulgarian Corporate Income Tax Act (Закон за корпоративното подоходно облагане, ЗКПО) governs the separate annual corporate-tax return under Article 92. For entities within scope, the annual activity report accompanies that return. It supplies statistical information and does not replace the annual financial statements or their Commercial Register publication. NRA guidance on the Art. 92 return

Reconcile the information across accounts, tax and activity reporting. Director transactions, payroll liabilities, stock movements and foreign-currency balances may affect more than one submission, although each has its own content, method and conditions.

A foreign parent may request a group reporting package in English, but the Bulgarian subsidiary still needs its own statutory accounts. Agree the accounting basis, reporting currency and reconciliation to the group package before closing. Differences in depreciation, provisions or revenue recognition must be explained so that management can understand why the local accounts and the parent’s reporting figures differ.

Before preparing submissions, ARG checks the reporting period, current and prior-year records, enterprise category, accounting framework, corporate-tax position and potential audit requirement. These facts establish the work and professional input needed.

Management remains responsible for preparation and publication. The engagement should identify who will reconcile the records, prepare the accounts, obtain corporate approval and submit the publication documents.

Can my company use an inactivity declaration instead of annual financial statements?

The inactivity route requires no activity within the statutory meaning during the reporting period. No sales, low turnover, no profit or no VAT registration does not by itself establish eligibility.

A qualifying inactive entity follows a separate route instead of ordinary publication of full annual financial statements. Under Article 38(9)(2), its declaration is published once for the first inactive reporting period, by 30 June of the following year. It is not repeated for every later inactive year after that statutory declaration has been made. The Register Agency confirms this structure. Register Agency guidance on inactivity declarations the Accountancy Act, including Art. 38

Review the full period’s transactions. Bank movements, supplier costs, director or employee payments, assets, financing and operational accounting entries may affect the assessment. Their nature and context matter; turnover alone is insufficient.

The statutory inactivity definition in Additional Provisions § 1(30) requires all four conditions for the period: no commercial transactions under Commercial Act Article 1(1), no circumstances requiring revenue recognition, no investment, production or sale activity, and no purchases of goods or services intended to earn income or profit. A new company buying stock or preparing a revenue-generating operation may therefore be active before its first customer pays. Review what each payment was for, when the activity occurred and how it was recorded; a zero sales ledger alone cannot support the declaration. Accountancy Act, § 1(30) and Article 38(9)

Before choosing the route, reconcile the following evidence for the full reporting period:

  • Bank statements and cash records, including any payments or receipts
  • Sales and purchase invoices, contracts and expense support
  • Payroll, social-security and director-remuneration records
  • Asset, loan, shareholder and related-party movements
  • Bookkeeping ledgers and year-end balances
  • Prior tax filings, VAT records where relevant, and statistical submissions

Provide the reporting period, ledgers, bank evidence and prior filings for an initial route assessment. ARG can identify whether annual financial statements or the inactivity declaration is appropriate and what further accounting or filing work is required.

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Which deadlines apply to 2025 accounts, tax reporting and Commercial Register publication?

For a calendar-year company, distinguish the tax and activity-reporting timetable from Commercial Register publication:

  1. From 1 March to 30 June 2026, an entity within scope ordinarily files its Art. 92 corporate-tax return electronically and submits the annual activity report through the connected NRA and NSI process. NRA guidance on the Art. 92 return
  2. By 30 September 2026, an active trader ordinarily publishes its adopted 2025 annual financial statements in the Commercial Register under Accountancy Act Art. 38(1). Accountancy Act, Art. 38
  3. By 30 June 2026, a qualifying inactive company had to publish its one-time declaration for its first inactive reporting period. That route does not extend a tax-return deadline where a tax obligation remains.

The annual calendar contains separate obligations. Completing the June tax return does not complete the September publication requirement, while publication does not settle unpaid corporate tax. For each reporting year, retain the accepted tax-return receipt, activity-report confirmation, corporate approval and Register publication result in the company’s annual file. A liquidation, transformation or other special event can create separate reporting periods and deadlines that should be scheduled alongside the ordinary annual obligations.

Reconcile the ledger and year-end evidence, establish the accounts and audit position, check NRA and NSI submissions, obtain corporate adoption and complete publication. Missing approvals, attachments or audit work can prevent a complete filing near the deadline.

For the 2025 annual activity report, the National Statistical Institute requires Bulgarian lev or thousands of lev, as specified in the form. This guidance concerns the activity report. Confirm the presentation of the company’s 2025 financial statements against its accounting basis, policy and applicable euro-transition guidance. NSI guidance for the 2025 annual activity report

Build the timetable backwards from publication. Management supplies year-end estimates and missing documents, the accountant completes the accounts, the auditor completes any required independent audit, and the competent corporate body adopts the final version. Overseas owners should arrange signature and representation requirements early. The applicant then prepares the publication package and checks the Register result; the internal date on a PDF does not establish that it was submitted or published.

How should my company prepare for audit and Commercial Register publication?

Establish whether the accounts require mandatory independent audit under Accountancy Act Art. 37 before arranging adoption and publication.

The Commercial Register and Register of Non-Profit Legal Entities Act (Закон за търговския регистър и регистъра на юридическите лица с нестопанска цел, ЗТРРЮЛНЦ) governs the application and review. The registration officer checks whether the act is subject to publication, the applicant is authorised and the required documents are present. Commercial Register Act, Arts. 13, 19(8), 21, 22 and 24

G 2 is the ordinary electronic application for publishing annual financial statements. The applicant must complete the required information and attachments and have authority to apply for the company. Portal access alone does not establish that authority. Register Agency G 2 application guidance

For an ordinary G 2 filing, identify the company by its EIK, the Bulgarian unified identification number, and select the correct reporting period and acts. Check the applicant’s legal capacity and any required authorisation, attach the adopted final accounts and supporting documents, and review the portal’s validation messages before signing. Preserve the submission reference and monitor the result. Do not assume that sending statistical data to NSI has itself published the adopted accounts in the Commercial Register. Registry Agency G 2 instructions

Audit assessment may depend on legal form, assets, net sales, average employees, public-interest status, group position and other Art. 37 criteria. Turnover alone does not settle it. Where audit is mandatory, complete the auditor’s work before publication.

Prepare the filing in this order:

  • Confirm the reporting entity, reporting period, accounting basis and applicable report components.
  • Assess mandatory independent audit and identify any required auditor deliverable.
  • Ensure the competent corporate body has adopted the accounts and that the adoption evidence matches the documents to be published.
  • Identify the available publication channel and the authorised applicant.
  • Review the final attachments for completeness and internal consistency before submission.

Under Accountancy Act Art. 38(2), a timely original application can retain its timely status after a refusal under Commercial Register Act Art. 22(5) if the repeat application is submitted within 14 days after the refusal becomes final. Correct the omissions and retain evidence of both submissions and the finality date. Accountancy Act, Art. 38(2)

What should I provide before ARG begins the annual financial statements process?

ARG assesses the reporting route, identifies missing work and coordinates the accountant, auditor and authorised filer. Agree the scope before work starts: accounts preparation, bookkeeping corrections, tax and activity-report filing, Register representation, corporate approvals, translations and audit liaison may be separate tasks. Management retains responsibility for preparation and publication.

Provide the accounting record: trial balance, reconciled ledgers, sales and purchase invoices, material contracts, bank and cash records, and support for year-end adjustments.

Provide balance-sheet evidence: asset and ownership records, stock records where relevant, loan documents, shareholder and related-party balances, receivable and payable reconciliations, and support for significant provisions and liabilities.

Provide employment and tax information: payroll, social-security and director-remuneration records, relevant VAT records, prior corporate-tax returns, annual activity reports and material correspondence or confirmations.

Provide company history and corporate documents: previously filed accounts, any inactivity declaration, current Register details, the reporting period and adoption documents. Identify the authorised applicant and available electronic access.

An inactivity assessment requires the full period’s bank, cash, accounting and tax evidence. Confirmation that there were no customer invoices is insufficient.

Disclose asset acquisitions or disposals, shareholder financing, cross-border transactions, bank movements, employee or director payments, changes of legal form, group membership, any appointed auditor and any rejected Register application.

Confirm the 2025 activity position, completed tax and activity-reporting submissions, possible audit requirements and the assistance required from ARG. These facts determine the document request, responsibilities and publication timetable.

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Questions and answers

01 / 06

What is the Bulgarian GFO and does it replace the tax return?

GFO means the annual financial report under the Bulgarian Accountancy Act. It explains the company’s financial position and results using the applicable accounting framework. The Article 92 corporate-tax return calculates taxable profit, while the NSI activity report supplies statistical information. These are separate obligations. Reconcile the figures, obtain corporate adoption of the final accounts and retain confirmation of each required submission and publication.

Can a company with no sales declare that it was inactive?

Only if all four conditions in Additional Provisions § 1(30) of the Accountancy Act are met for the reporting period. They cover commercial transactions, revenue recognition, investment or production or sale activity, and purchases intended to earn income or profit. Buying stock before launch can prevent inactivity treatment even without sales. Provide the complete bank, expense, asset and contract records. A qualifying company publishes the one-time first-period declaration by 30 June of the following year; continuous subsequent inactivity does not require repeating that declaration.

When must annual accounts be published?

For an active Bulgarian trader subject to Accountancy Act Article 38(1), the ordinary deadline is 30 September of the following year. The accounts must be final and adopted by the competent corporate body, with any required auditor’s report. The ordinary corporate-tax return and payment follow a separate 30 June deadline. Agree the closing, audit, approval and submission dates early, particularly where owners sign from abroad.

What happens if the Register refuses the filing?

Read the refusal and identify whether the problem concerns authority, adoption, attachments or consistency of the reports. Article 38(2) preserves the timeliness of an originally timely application if the repeat application is made within 14 days after the refusal becomes final. This rule does not cure an originally late filing. Correct the documents, preserve evidence of the original submission and finality date, and check the outcome of the repeat application.