You start working as a freelancer, register successfully, and find your first clients. Everything is going great until one of them asks you: “Can I pay in cash?”. You panic – do you need a cash register? Will the NRA fine you?
In this article, we will untangle this issue in simple and understandable language, in line with the rules in 2026.
1. Basic rule: Are you exempt from a cash register?
The good news is that Bulgarian legislation (Ordinance H-18) gives a serious advantage to freelancers. According to the law, if you are registered as such and provide services (for example, you are a designer, programmer, lawyer, architect, or consultant), you do not have an obligation to use a fiscal device (cash register), even when you receive cash in hand.
If you are still wondering whether this legal form is the most suitable for your activity, take a look at The most important things about registering and accounting as a freelance professional.
2. What do you issue instead of a receipt?
Since you do not have a cash register, how do you prove to the tax authorities that you took the money and the client has a document for their expense?
- You must issue a paper or electronic document – a receipt book or an invoice clearly stating that the payment is in cash.
- Remember that in 2026 the official currency is the euro. All your receipts and invoices must be issued in euros, even if the client gave you the exact amount. To know exactly how to account for these amounts, read Accounting transition to the euro: A guide for businesses.
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3. The trap: When DOES a freelancer need a cash register?
This is where many people make a critical mistake. The cash register exemption applies only to services related to your profession. If you start selling goods, the rules change sharply.
- Example: You are a freelance photographer. You shoot events and receive your fee in cash – you do not need a cash register. But if you decide to sell physical cameras, frames, or ready-made merchandise (t-shirts, mugs) in your studio, you are already conducting commercial activity.
At this point, the state starts treating you as a merchant, and a cash register becomes mandatory for all cash payments. If you plan to expand your business to trade physical products, it might be time to consider switching to a company. See more in Pros and cons of EOOD and freelance profession.
4. Online sales and cash on delivery
If you are an artist or artisan (freelancer) and sell your paintings, jewelry, or books online, you can avoid the cash register even when selling physical goods.
The secret is not to accept “cash in hand” payments, but to use Postal Money Order (PMO) through a licensed courier (like Econt or Speedy) or direct bank transfers. With these methods, the courier acts as your “cash register” and issues the receipt instead of you. To understand the exact rules and requirements for this method, be sure to read our article Income from cash on delivery.
If you are thinking of scaling and creating your own online store with different payment methods, familiarize yourself with the specifics in Ordinance H-18 and electronic stores: what changes in 2025.
Conclusion
Being a freelancer gives you the massive flexibility to work without the complex maintenance, monthly fees, and service contracts of a cash register, as long as you focus entirely on your services. If you stick to bank transfers or issue correct invoices/receipts for cash payments, you have no reason to worry in case of an audit.
