In recent years, the profession of psychologist and psychotherapist has undergone a huge transformation. From traditional office sessions, the practice has expanded to online consultations, group webinars, selling e-books, and corporate training.
Entering 2026 with the new European rules for small enterprises, tax authorities are monitoring where your income comes from much more closely. The main problem for specialists in this field is one – the law treats healthcare and the sale of digital content fundamentally differently. If you are a freelance psychologist, this article will help you clearly separate your income and avoid fines from the NRA. For a broader overview of your profession, we recommend reviewing our main article Accounting for Psychologists and Psychotherapists.
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1. When are your services EXEMPT from VAT?
The Bulgarian VAT Act (VATA) provides a tax exemption for healthcare-related services (Art. 39). For your service to be VAT-exempt (meaning you do not charge 20% tax and do not accumulate turnover for mandatory VAT registration), it must meet the following conditions:
- Have a therapeutic or diagnostic purpose (treating depression, anxiety, clinical conditions).
- Be performed by a person practicing a regulated medical profession (e.g., a clinical psychologist or psychiatrist listed in the relevant registers).
- Be performed within a medical facility or as a registered individual practice under the Health Act.
If you meet these conditions, the income from your sessions is VAT-exempt. Even if you have a turnover of 60,000 euros for the year solely from treating patients, you will not be subject to mandatory VAT registration on this basis.
2. When do you fall into the VAT trap (Taxable services)?
This is where the biggest problems arise. Many specialists think that just because they have a psychology degree, everything they do is a “health service”. The tax authorities, however, do not think so. The following activities are taxable and generate turnover for VAT registration (whose threshold in 2026 is 51,130 euros):
- Life coaching and personal development: If you help a client achieve career goals or improve their motivation, this is not treating an illness. This is a consulting service.
- Selling electronic books (e-books): Selling PDF files, manuals, or digital journals is an “electronically supplied service”.
- Paid webinars and online courses: If you sell access to a pre-recorded video course on stress management, this is a standard commercial transaction.
- Corporate team building and lectures: Training employees of a given company is a taxable B2B business service.
If these taxable activities exceed the threshold of 51,130 euros (100,000 BGN) within the current calendar year, you are obliged to register. See more about the registration mechanism itself in What is VAT and when should we register under VATA?.
3. How to separate your income for accounting?
If you practice a hybrid model (you have both clinical patients and sell online courses), you perform so-called mixed supplies. Your accountant must keep strict analytical records:
- Revenue stream 1: Clinical consultations (Exempt).
- Revenue stream 2: Coaching, books, seminars (Taxable).
Important for 2026: If you sell your e-books to individuals in other European Union countries, you can take advantage of the new “SME Scheme”, which allows you to sell without VAT across Europe, as long as your total European turnover is under 100,000 euros.
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4. Do you need a cash register (Fiscal device)?
This is the second most frequently asked question after VAT.
- For medical services: If your practice is registered under the Medical Treatment Facilities Act, you are exempt from the obligation to have a cash register. You can issue standard paper receipts from a receipt book or invoices.
- For non-medical services (coaching, seminars): If you receive cash payments for non-medical services, a cash register is mandatory.
The easy solution: Avoid cash payments. If your clients pay entirely by bank transfer (direct transfer) or by postal money order (PMO) through a licensed operator, you do not need a cash register for any of your activities. For more details about payments without a fiscal device, read Income from cash on delivery.
Conclusion
The psychology profession is flexible and offers multiple opportunities for additional income through digital products. The key to working peacefully in 2026 is not to mix “treatment” with “commerce” in your invoices and contracts. Clearly defining each service protects your practice from unexpected tax audits.
