We at BESCO – the Bulgarian Startup Association, firmly oppose the controversial Ordinance No. 18. In the following lines, we will explain more about the ordinance itself, its motivations, implementation, and the numerous issues that directly affect innovative businesses in Bulgaria. Our position aligns with that of other institutions and private companies, but we also present our perspective based on the startup ecosystem in Bulgaria.
“In September 2018, an amendment and supplement to Ordinance No. N-18 of December 13, 2006, on the registration and reporting of sales in commercial establishments through fiscal devices was promulgated. The changes relate to the reporting of sales (including reversal operations), the introduction of requirements for software used to manage them, as well as requirements for developers/distributors and users of such software, and for persons conducting sales through online stores.”
“The goal is to eliminate the possibility of manipulation of fiscal devices currently in use by introducing a requirement to transmit information for every fiscal/system receipt for the sale of goods/services to the servers of the National Revenue Agency (NRA) within up to five minutes.”
In simple terms, the NRA is attempting to regulate the gray economy, mainly in sectors such as hospitality and tourism. So far, so good, but…
Ordinance N-18 primarily concerns the fiscal reporting of payments in commercial establishments made:
It introduces the concept of SUTTO (Sales Management Software in Commercial Establishments). These systems must be registered and licensed with the NRA and meet numerous technical and organizational requirements.
To a large extent, the SUTTO regime is not compatible with e-commerce due to the requirement for automatic issuance of a receipt upon payment, necessitating a constant connection to a fiscal device (cash register or fiscal printer).
It also introduces electronic receipts—merchants may send receipts by email, but they must still be generated by a fiscal device and contain all required attributes. At the time of writing, only one device supports this functionality.
Constant connection to fiscal devices
Fiscal devices are typically located in physical stores, while e-commerce platforms operate in data centers. This requires a continuous and reliable connection, which is often not guaranteed. Result: online stores may fail whenever there is no power or internet at the office.
Dependence on device operation
Due to limited availability of electronic receipt devices, merchants must manage paper rolls and daily resets, requiring staff presence—even on weekends.
Dependence on state institutions (NRA)
Any change in SUTTO must be pre-approved by the NRA. Security vulnerabilities may remain unresolved for long periods, creating risks including GDPR violations.
Leadership & Advocacy Academy doesn’t only develop individual participants. For BESCO, it is a long-term investment in a stronger ecosystem - building capacity where it matters most: within the organizations, institutions, and communities that shape the public environment.
.png%3F2026-05-02T12%3A49%3A40.449Z&w=2560&q=75)
POSITION of the Association for Innovation, Business Services and Technologies (AIBEST) Regarding Draft Concept for Building a School STEM Environment
4 min read
Read article
In this opinion, BESCO objects to the proposed requirement that insurance contracts be signed mandatorily with a qualified electronic signature (QES), as this raises costs and hinders access to insurance services and duplicates the framework already in place in the LEDETS (Law on Electronic Document and Electronic Trust Services).
4 min read
Read articleThe proposal constitutes a substantial departure from the current legal framework. At present, the maximum pecuniary sanction under Article 210b of the Consumer Protection Act is BGN 70,000.
4 min read
Read article