Bookkeeping for online sales, refunds, marketplace fees and payment settlements, with VAT treatment reviewed against how and where you sell.
An e-commerce client came to ARG with records held by different people and no clear view of the outstanding work. ARG checked what had already been completed and organised the missing documents, deadlines and responsibilities. The practical explanations made it easier for the client to understand the position and contribute what was needed.
That same problem is common when Shopify, Amazon, Stripe, PayPal and other marketplace records develop separately. Bulgarian e-commerce accounting is not limited to posting payments. The accounting file may also need to connect orders, sales documents, store data, payment accounts, VAT treatment and annual reporting. The right setup depends on how each sales channel operates and what evidence it produces.
ARG can help when you need to
Provide the legal seller, marketplace contracts, warehouses and actual dispatch countries so each sales flow can be classified.
Identify cash, cards, transfers and courier arrangements; check fiscal receipts, e-store notification and any eligible alternative route.
Supply order, refund, fee, reserve and payout exports that reconcile to bank and payment-provider balances.
Monitor domestic turnover, foreign services and destination sales; assign monthly, OSS/IOSS and annual deadlines separately.
The Bulgarian VAT Act defines an electronic store in Supplementary Provisions § 1, point 87: software accessed through a browser or mobile application that enables a distance sale, lets the customer choose goods or services through a basket or another method, and collects contact, delivery and payment information. A catalogue that only advertises products is therefore different from software through which customers conclude purchases. An electronic store can operate on a third-party platform; owning the domain is not decisive. For accounting, the practical task is to connect each order to the legal seller, delivery, sales document, payment and any later refund. Review the actual checkout process, marketplace agreement and payment-provider contracts before choosing the Bulgarian fiscal-receipt and reporting setup. Those facts determine which notification, records and sales-document requirements apply; the platform’s brand name alone does not.
The classification matters because the file must connect several layers of evidence.
A marketplace sale can therefore be part of an electronic store file even when the seller uses a third-party platform, because the accounting question is not who hosts the interface alone. The key issue is whether the online channel is being used as a sales mechanism whose data must be tracked and preserved in a compliant structure. For a client, that changes how the bookkeeping is built. Stripe, PayPal, card receipts, platform settlements, order numbers, refunds, and store logs cannot be treated as separate administrative files. They must reconcile to the same sales trail.
If the channel is treated as an electronic store, the accounting work has to support three practical outcomes. First, it must show that each sale belongs to a traceable order. Second, it must make the source data recoverable if the tax authority asks for it. Third, it must allow later VAT and income accounting to be tied back to the original online transaction. In practice, this is the difference between a spreadsheet that records cash movement and a compliance file that can stand up to inspection.
For a seller, the point is especially important when the business uses more than one sales route. For example, a Shopify store, an Amazon storefront, and a separate payment gateway may all produce revenue, but they do not all produce the same documentary chain. ARG would look at the systems together and decide which records belong to the same electronic store file, which records are only payment evidence, and which records must be retained as core transactional data.
The first review should follow one completed order from checkout to the bank, then repeat the exercise for a return, a partial refund and an unsettled order. Obtain the gross sale, VAT, platform fees, payment fees, reserves, currency conversion and final payout. A platform payout often combines different dates or countries and is not itself the value of that period’s sales. Keep open balances owed by the platform separately and reconcile them into the following month. This reveals missing sales, duplicated imports and fees wrongly netted against revenue before they distort VAT or profit.
The NRA notification under OrdinanceH-18 Article 52m applies to sellers using an electronic store who accept payments requiring a fiscal receipt. A seller accepting only payment methods for which no fiscal receipt is required is not obliged to submit this information, although voluntary submission is possible. Where notification is required, submit the store information electronically with a qualified signature before sales start. Changes to notified facts and cessation must be reported within seven days. Therefore, assess payment methods first, then check the store, seller, software, hosting and payment details that need to be supplied.
Payment method is a legal classification, not a checkout label. Ordinary cash or card payment generally calls for fiscal reporting unless a specific rule applies. Specified bank and payment-service transfers and postal money orders through a licensed postal operator fall within exceptions. A cash-on-delivery arrangement is not automatically a postal money order: check the courier contract and settlement document. For the postal-transfer exception, the seller must still provide the customer with the required sales information. Keep the contract and an example of each payment flow in the accounting onboarding file.
A useful way to think about it is this. If the change alters the information that identified the store when it was notified, the filing may need to be updated. If the business stops using the store altogether, the cessation notice must be filed within the same 7-day period. The compliance duty belongs to the operator of the online sales channel, not to the payment provider, marketplace, or developer.
Where the store is within the notification obligation, a platform migration or new checkout provider should trigger a review before the change goes live. Compare the new domain, software, hosting, seller identity, merchant account and payment methods with the submitted data. Decide whether an update or a separate store submission is required, then retain the electronic acknowledgement. Your developer can supply technical details, but the seller needs a named person responsible for the tax notification. This avoids a working checkout being launched with an outdated compliance record.
This is especially relevant where the business runs several channels at once. A store may move from one platform to another, or it may add or drop a domain while keeping the same legal entity and payment accounts. Even then, the notification duty is not eliminated. The question is whether the filed e-store data still matches the operating facts. If it does not, the file must be updated.
Before deciding what to file, ARG would normally verify three things.
That review matters because it prevents two common mistakes. The first is failing to file a new or changed store in time. The second is assuming that a platform migration or domain change is purely technical when it may already be a compliance event. For Bulgarian e-commerce clients, the filing rule under the VAT Act [ЗДДС] and Nar-18 is therefore part of live bookkeeping, not a one-off registration afterthought.
Tell us where you live, how your business works and what you want to change. We will help you identify the questions to resolve and the next steps to consider.
From 1 January 2026, a Bulgarian-established person’s Article 96(1) registration test uses annual domestic turnover exceeding EUR 51, 130. The application is due within seven days of exceeding the threshold, and registration takes effect from the following day. This is not the old rolling twelve-month BGN 100, 000 test. Monitor the relevant calendar-year supplies, rather than net payment-provider payouts. Foreign-established sellers have separate rules, including registration before the first relevant Bulgarian taxable supply where required, with statutory reverse-charge, special-scheme and SME exceptions. Record establishment, stock locations, customer type and supply dates before selecting the registration ground. A small online store can also trigger a separate obligation through foreign services, even without reaching the domestic threshold.
That timing matters because VAT registration is not only about crossing a number. It is about identifying the point at which the seller’s cross-border model creates a Bulgarian VAT filing duty. For an Amazon seller, a Shopify store owner, or a business that sells through a marketplace and its own site at the same time, ARG would first separate the supply types. Domestic sales, cross-border B2C sales into the EU, non-EU imports, and recipient-charged transactions do not all follow the same registration route. The legal question is not whether the business is online. It is whether the taxable supply is chargeable in Bulgaria and whether a simplification regime can lawfully take that supply out of local registration.
The Bulgarian NRA guidance confirms that OSS and IOSS are the main e-commerce simplification regimes and that they are available for online traders, including operators of electronic interfaces, for eligible cross-border B2C sales. The practical point is that these regimes can replace multiple local VAT registrations for the supplies they cover, but only inside their own scope. They do not erase the seller’s other Bulgarian obligations, and they do not automatically cover domestic stock movements, services outside the regime, or supplies that are excluded by the VAT Act itself. NRA e-commerce VAT guidance
For a client, the decision usually turns on three questions.
Foreign advertising, subscription software or platform services can require Article 97a registration where Bulgarian reverse-charge VAT is due. The filing deadline can arise seven days before the tax becomes chargeable, including on an advance payment. Limited registration on that ground does not give the same general input-tax rights as ordinary registration. Obtain supplier invoices and contracts before paying for the next campaign, identify the actual provider and place of supply, then confirm whether the company needs limited or ordinary VAT registration. Domestic turnover alone does not answer this question.
The commercial consequence is straightforward. Choosing the wrong route can create duplicate filings, missed filings, or a mismatch between the sales platform and the VAT regime. ARG’s role within this service is to map the sales flow against the legal route before a filing is made, so the business does not register in the wrong place or too late. In practice, that means reviewing the store setup, the customer geography, the shipping pattern, the payment flow, and the exact supply character before deciding whether to use local VAT registration, OSS, IOSS, or a combination of routes.
OrdinanceH-18 allows an optional alternative for qualifying remote credit or debit card payments, subject to its software, notification, account and documentation conditions. It is not a blanket replacement for fiscal receipts whenever Stripe or PayPal is used. Under this route, the seller issues and electronically provides the prescribed sales document, linking the order and financial transaction, seller details, items, values, payment method and QR data. A qualifying invoice can fulfil the role only when it meets the applicable requirements. Review a sample checkout and document before choosing this setup; merely emailing a normal invoice does not establish compliance.
The numbering rule is unusually strict. The document number for that remote-card-sales record must be 10 digits, numeric only, strictly ascending by one for each sale, and unique across the entire e-store and trader activity. That means the accounting setup and the sales software cannot treat numbering as a cosmetic feature. It is a control mechanism. If the numbering is fragmented across channels, duplicated after a platform migration, or broken by an external plugin, the file can stop matching the rule even if the cash later reconciles in the bank.
The alternative route also requires payment-provider and merchant-account information, the store’s assigned identifier and a standard audit file under Annex 38 for each relevant calendar month, submitted by the fifteenth day of the following month. This H-18 file concerns the special online-sales route and should not be confused with the broader SAF-T tax reporting programme. Confirm that the store can export the required logically and arithmetically consistent data, that the account belongs to the liable seller, and that someone checks acceptance each month.
That is the point where Stripe and PayPal reconciliation becomes more than bookkeeping arithmetic. ARG would not just match payouts to orders. It would check whether the merchant account structure, the platform settlement data and the store records point to the same liable seller. If the account is in another name, if settlements are pooled in a way that obscures the seller, or if the platform exports do not show the transaction reference needed to link the payment to the sale, the reconciliation chain becomes weak.
The underlying store data also has to be preserved. The e-store software database, including current data and archived copies, must be retained for the tax-procedure-law retention period, and the tax authority must be given access with export and copy functions on request. Nar-18 art. 52k and 52l That matters because a clean month-end reconciliation is not enough if the business cannot reproduce the source trail later. For e-commerce, the source trail is part of the accounting evidence.
A practical working set for this service therefore includes the following.
If one of those layers is missing, ARG would usually identify whether the gap is recoverable from the platform, whether a corrected document is needed, or whether the accounting records need a different control structure going forward. The useful result is not only that the books balance. It is that the Bulgarian VAT and Nar-18 evidence chain remains usable if the National Revenue Agency asks how a payment reached the ledger.
Article 38 of the Accountancy Act sets the ordinary annual financial-statement publication deadline at 30 September of the following year. The relevant corporate body must first approve the statements; an audit is required where the statutory conditions apply. The annual corporate tax return and tax payment generally have a separate 30 June deadline. Reconcile inventory, supplier balances, platform receivables, refunds, payment reserves and tax accounts before closing the year. A store with no recent sales is not automatically inactive: the statutory inactivity test considers the company’s other transactions and activities as well.
For a small online store, the important distinction is that the annual publication duty does not disappear just because the business is light on staff or uses outsourced fulfilment. Live sales bookkeeping covers the current orders, payouts, refunds, taxes and reconciliations. Year-end accounting covers the annual close, the financial statements, and the statutory publication step. A business can be fully up to date on monthly bookkeeping and still be late on the annual filing if nobody has planned the close in time.
Plan the annual close around evidence that is difficult to reconstruct later. Obtain warehouse counts and ownership records, separate damaged or returned stock, confirm goods in transit and list amounts withheld by marketplaces. Reconcile platform balances at the year-end date even if settlement occurs in January. Check that owner-funded purchases are supported and that expenses belong to the company. Agree the preparation, audit if required, approval and publication dates so the 30 September publication deadline is met without treating it as an extension of the separate tax-return deadline.
If the business also had VAT registration or OSS or IOSS reporting during the year, the annual close should be checked against those filings so the published accounts do not conflict with the live tax position. The point is not only formal compliance. It is to avoid a year-end file that is technically published but commercially inconsistent with the store activity that created it.
For a prospective client, the decision is simple. If the store is active, the accounting job does not end when the monthly reconciliations are done. It ends when the annual close, the publication duty and the VAT position all agree. That is the stage where ARG adds the most value, because it turns fragmented marketplace data into a year-end position that can actually be filed and defended.
Compare the related procedures in this category, including their requirements and the stage at which you need them.
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