A new group of amendments to Ordinance H-18/2006 , which regulates the recording and reporting of sales at retail outlets through fiscal devices, was promulgated in issue 75 of the State Gazette („Ordinance H-18” / “The Ordinance”).
1. Extended deadlines
A significant part of the new amendments governs the extension of the deadlines for compliance with the requirements of Ordinance H-18 as follows:
- Until January 31st, 2020 – deadline for all SMSPS (sales management software at the point of sale) users – whether or not registered under the VATA – to bring their software and fiscal devices in accordance with the Ordinance and its annexes; this is also the deadline for IABMS (integrated automated business management system) users to align their activities;
- As of February 1st, 2020 all cash receipts issued by an electronic system with fiscal memory should also contain data on the amount of VAT, excise duty, purchase and sale price of fuels;
- Until March 31st, 2020 is the deadline for compliance with all requirements of the Ordinance for persons who sell goods or services through an online store, provided that the software of the online shop is the only one through which the sales of the online store are processed. These persons should submit the information under Annex 32 by May 31st, 2020.
2. Possibility to use an SMSPS that does not meet the requirement for blocking operations
The another part of the amendments, under certain conditions, it is allowed to use an SMSPS that does not meet the requirement to block the initiation and closing of a sale whenever the status of the fiscal device (“FD”) does not allow the issuance of a cash receipt. The software shall only block the payment for a sale for which there is an obligation to issue a cash receipt, and the merchants shall be able to continue to perform sales that do not require the issuance of a cash receipt, which opportunity is not otherwise acceptable. However, this opportunity is only applicable for sales for which there is no obligation to issue a cash receipt – only they could continue to be performed when the FD is blocked and a standardized audit file is used.
The deadline for compliance with the requirements of the Ordinance for persons who choose to use such type of an SMSPS is also March 31st, 2020, as by then they should also submit the information in accordance with Annex 32 of Ordinance H-18.
In addition, when operating in this mode, merchants should electronically notify the National Revenue Agency by January 31st, 2020, as well as submit their standardised audit file once for each calendar year, by the end of January of next year.
The above described opportunity is granted to merchants with up to 5 % income from sales, for which the issuance of a cash receipt is obligatory, during the previous calendar , and if at least two of the following conditions are simultaneously met:
- the book value of the assets as of the end of the previous calendar year exceeds BGN 8 000 000;
- the net sales revenue for the previous calendar year exceeds BGN 16,000,000;
- the average staff number for the previous calendar year exceeds 50 people.
The persons performing sales at/from retail outlets located at areas with permanent insecurity of a remote connection with a mobile operator shall no longer be obliged to register the sales performed at a retail outlet through a FD / IABMS due to lack of mobile coverage.
Also noteworthy is the newly introduced requirement in item 10 of Annex No. 29 to Ordinance H-18/2006, concerning the reporting of sales performed prior to the introduction of the requirements of the Ordinance for which payment has been received with an obligation to issue a cash receipt after the implementation of a SMSPS: “Upon payment concerning a sale performed prior the implementation of the software for which a cash receipt has not been generated, a cash receipt of the following type should be issued: OO000000-0000-0000000, where the first two characters are the Latin capital letters O and the rest are zeros.”