Online Stores: E-Receipts and Audit File for NRA

The dream of every online store owner is to fully automate their processes. Until a few years ago, the law in Bulgaria required something absurd – even if your entire business was on the internet, you had to have a physical cash register in your office to print paper receipts for every card sale.

Today, there is the so-called alternative regime under Regulation N-18, which allows online stores to operate without a physical cash register. This freedom, however, comes with strict technical requirements: issuing automatic electronic receipts (e-fiscal receipts) and maintaining an „audit file.“

Here is how the system works in depth, step by step.

1. How to switch to the regime without a cash register?

You cannot just stop issuing receipts. To work legally under this method, you must meet two preconditions:

• You must accept only non-present payments. This means payment by credit/debit card (virtual POS), PayPal, Stripe, or other digital wallets.
• If you offer Cash on Delivery (COD), it must be exclusively via Postal Money Order (PPP) through a licensed courier (Econt, Speedy, etc.). If the courier brings you cash in an envelope, this regime does not apply to you. For more on starting a legal business, see What is VAT and when do we have to register for mandatory VAT?.
• You must declare your choice to the NRA (National Revenue Agency). This is done by submitting a special electronic declaration in the NRA’s e-services portal before you start selling this way.

2. What exactly is an electronic receipt?

This is a digital document that has the exact same legal value as a paper receipt from a physical store. Your store’s software must generate it automatically and send it to the customer’s email as soon as the payment is confirmed.

To be recognized by the NRA, the e-receipt must contain several mandatory elements:

• Merchant details (Company Name, UIC/EIK).
• Name of the item, quantity, and price.
• Unique document number (generated by a special algorithm).
• A 2D barcode (QR code) containing encrypted information about the purchase, so the customer or a tax inspector can easily scan it.

3. The heart of the system: The Audit File

To allow you to work without a cash register, the NRA wants full and easy access to your sales data. This is where the requirement for a standardized audit file comes in.

• What it is: This is a very detailed digital report in XML format. It contains a chronological record of every single action in your store – from the creation of the order, through the payment, to the delivery.
• When to provide it: You do not send this file to the NRA every month or with every sale (as physical cash registers do). However, you must have the technical ability to generate it and download it to a flash drive or send it via email immediately upon request by a tax inspector (for example, during an audit).
• How different platforms handle it:
  • Bulgarian SaaS platforms (CloudCart, GombaShop): They usually have a built-in, free functionality that fully meets the NRA’s requirements.
  • WooCommerce: You will need to purchase and install a specific Bulgarian plugin to generate the audit file and e-receipts in the exact format.
  • Shopify: Integration here is the most complex and usually requires an external app or connection to an accounting ERP system to create the file.

4. Returning goods (Refund and Void Operations)

One of the most underestimated details is what happens when a customer returns an item. With a physical cash register, you issue a paper refund or void receipt. Under the electronic regime, your software must have a feature to generate an electronic refund document (e-refund). It is also sent to the customer via email and automatically recorded in the audit file to reduce your reported turnover.

5. Advantages and Risks

Before switching to this model, weigh the pros and cons carefully:

Advantages:

• You save money on buying and maintaining a physical device, as well as monthly SIM card fees for it.
• The process is 100% automated – there is no risk of an employee forgetting to ring up a sale and bringing a fine to the company.
• Accounting is much easier because all data is digital.

Risks and obligations:

• If your site goes down, your database crashes, or the audit file plugin fails and misses orders, the responsibility is entirely yours. Fines for missing information are the same as for not issuing a receipt. Therefore, regular backups of your site are mandatory.
• Before you start, it is highly recommended to discuss your setup with an accountant. For useful info, check Advantages and Disadvantages of an EOOD (Ltd.) and Freelancing.

Conclusion

The alternative regime with electronic receipts and an audit file is the future of e-commerce in Bulgaria. It offers tremendous freedom and automation but requires flawless technical preparation of your online store. Make sure the platform you use is fully compliant with Regulation N-18 before saying goodbye to your physical cash register.