Bulgaria Accountancy Act 2026: annual accounts and changes

The Accountancy Act (Закон за счетоводството, ЗСч) is the backbone of financial reporting in Bulgaria, but the text in force, promulgated in State Gazette (ДВ) issue 95 of 8 December 2015, has already been amended dozens of times. In 2026 a new bill is expected to transpose Directive (EU) 2026/470, which narrows the scope of the sustainability report, and at the same time the changeover to the euro affects the preparation of annual financial statements. This article offers a systematic map of the act for accountants, tax and corporate lawyers, financial controllers and compliance specialists, together with a precise distinction between what is really changing now and what is still at the draft stage.

What the Accountancy Act regulates: subject matter and scope

The current ЗСч transposes Directive 2013/34/EU on annual financial statements and replaces the repealed Accountancy Act of 2001. This change matters in practice: when you search legal databases, the old 2001 version often comes up, and it should not be used for current citations. The authoritative text is the one promulgated in State Gazette (ДВ) issue 95 of 2015.

The circle of obliged persons is wide. The notion of enterprise within the meaning of the act goes beyond the classic trader and includes specific entities such as social security funds, which in practice is an often underestimated detail when determining the applicable reporting regime.

Structurally, the act is organised in nine chapters, from the general provisions to the administrative penal provisions. Knowing this architecture makes it quick to find your way around: the categories of enterprises are in Chapter Two, financial statements and the accounting framework in Chapters Three and Four, and the sanctions in Chapter Nine.

Categories of enterprises and groups (Chapter Two)

Categorisation is the first analytical step in any accounting regime, because the scope of the financial statements, the relief available and the obligation for an independent financial audit depend on it. The act distinguishes micro, small, medium and large enterprises by three indicators.

Particular attention should be paid to the rule on changing category, which is a common mistake when citing the act. The change does not occur when the indicators are exceeded once. The authoritative provision is Art. 20, not Art. 19, and it requires a lasting deviation for two consecutive reporting periods.

Financial statements and the applicable accounting framework (Chapters Three and Four)

The content of the annual financial statements and the applicable accounting framework depend directly on the category of the enterprise. Micro and small enterprises enjoy significant relief in scope, while for a defined group of entities the application of the International Accounting Standards is mandatory.

Preparers of financial statements: requirements

The preparer of financial statements is subject to a special regime. The act sets requirements at the same time for education obtained, for professional experience and for the absence of certain convictions, and it separates who prepares the statement from the conditions that person must meet.

Responsibility for preparing and publishing the statement on time stays with the manager of the enterprise. Outsourcing the accounting to an external person or a specialised enterprise does not shift this responsibility, which is essential when assessing administrative violations under Chapter Nine.

Publicity of the ГФО: deadlines for filing with the Commercial Register

The publicity of the annual financial statements is achieved by applying for publication in the relevant register. The general deadline is 30 September of the year following the reporting period, and the addressee of the application depends on the type of obliged person.

The provision of Art. 38(2) is often wrongly read as a general grace period. That is not so. It regulates a specific situation: where the statement was initially applied for on time, a refusal under Art. 22(5) ЗТРРЮЛНЦ followed, and a new application was filed within 14 days of the refusal coming into force.

The sustainability report and the changes in 2026

The sustainability report is the area with the most movement in 2026 and at the same time the area where it is easiest to mix up the law in force, the directive adopted at EU level and the Bulgarian bill that has not yet been adopted. A precise distinction here has practical value.

The current rules already transpose Directive (EU) 2022/2464 (CSRD) with amendments promulgated in State Gazette (ДВ) issue 79/2024. They introduce the sustainability report in Art. 41 and the mandatory assurance engagement by registered auditors under Art. 37а, initially with a limited level of assurance.

At European level the change is already a fact. Directive (EU) 2026/470, known as Omnibus I, has been adopted and is in force. It narrows the scope of the sustainability reporting requirements. It is important, however, to keep in mind the difference between adoption at EU level and national transposition.

The full text of the directive is available in the Official Journal of the EU. It amends Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760, and the deadline for transposition by the Member States is 19 March 2027.

The draft provides for a numerical threshold for the obligation to publish a sustainability report. According to the position of an employers’ organisation on the draft, only enterprises that exceed both 1,000 employees on average and 450 million euro in net revenue at the same time would be obliged, with the thresholds introduced in Art. 39(2) and Art. 41(1).

The thresholds for enterprises from third countries are a separate question. They are not regulated in Art. 39 or Art. 41 but in Art. 52б, which is a common mistake when citing the act. Here too we are talking about a draft, not law in force.

Sanctions for violations (Chapter Nine)

The administrative penal provisions in Chapter Nine are often cited inaccurately, with heavy sanctions attributed to the wrong offences. Below is a systematic summary of the actual regime in the version in force, with all amounts in leva (BGN). Euro amounts should not be reproduced from memory, because the amounts in the act in force are denominated in leva.

For tax and corporate analysis the ЗСч is rarely considered in isolation. The accounting financial result is the starting point for corporate taxation, so it is useful to compare it with the regime under the Corporate Income Tax Act (ЗКПО). For wider context see the analysis of the 2026 changes to the ЗКПО, and for the compliance aspects of financial control the legal analysis of the Public Procurement Act is also relevant.