Bulgaria’s Council of Ministers has submitted draft legislation to the National Assembly to transpose EU DAC8 and DAC9 directives, introducing new crypto-asset reporting obligations, expanded automatic exchange of financial information, Pillar Two Top-up Tax reporting rules, and refinements to the transfer pricing framework.
Bulgaria’s Council of Ministers has approved and submitted a draft bill to the National Assembly on 7 May 2026 to transpose two European Union directives into national law: Council Directive (EU) 2023/2226 (DAC8) and Council Directive (EU) 2025/872 (DAC9). The legislation also introduces amendments to the country’s transfer pricing framework.
DAC8: Crypto-asset reporting requirements
The draft bill introduces a new Section IIIb establishing rules for the automatic exchange of information on crypto-assets.
Under the proposed rules, “crypto-asset service providers” — including both licensed and certain non-licensed operators — will be required to carry out due diligence and report transaction data to the National Revenue Agency (NRA).
The scope of reportable information includes user identification details such as name, address and tax number, as well as the type of crypto-asset and total gross amounts and units relating to exchanges into fiat currency or other crypto-assets.
The National Revenue Agency will exchange this information with other EU Member States and partner jurisdictions where the user is a tax resident.
Reporting entities must submit the required information by 30 June of the year following the relevant reporting period.
Expansion of financial and tax reporting
The draft law significantly expands the scope of automatic exchange of information beyond crypto-assets.
It brings electronic money and Central Bank Digital Currencies (CBDCs) within the scope of financial account information exchange. It also extends reporting to new income categories, including dividends not held in custodial accounts and tax rulings issued to high-net-worth individuals.
In addition, the legislation introduces rules for exchanging data under the Global Anti-Base Erosion (GloBE) framework. This includes GloBE Information Returns aimed at ensuring large multinational groups pay a minimum tax level of 15% across jurisdictions.
Compliance, enforcement and penalties
The Executive Director of the National Revenue Agency (NRA) is required to conduct periodic reviews of administrative practices to ensure effective use of exchanged data.
The bill also introduces enforcement measures, including the ability for the NRA to request court orders to block access within Bulgaria to a crypto-asset operator’s website or application where the operator fails to register or comply with reporting obligations.
The proposed penalty regime includes:
- Failure to report: fines between EUR 3,000 and EUR 5,000 for individuals and up to EUR 10,000 for legal entities
- Incomplete or incorrect data: EUR 100–EUR 150 per affected user
- User violations: fines between EUR 1,000 and EUR 4,000 for users providing false information in declarations
DAC9: Top-up tax information return framework
The bill also implements DAC9, which establishes the framework for the automatic exchange of Top-up Tax Information Returns (TTIRs) between EU competent authorities. This applies to in-scope groups under Article 260я23 of the Corporate Income Tax Act, which transposes the Minimum Taxation Directive (EU) 2022/2523, also known as the Pillar Two Global Minimum Tax (GMT) Directive.
Under DAC9, ultimate parent entities or designated filing entities of a multinational enterprise (MNE) group may submit a central TTIR. This removes the obligation for other constituent entities located in different EU Member States to file separate Top-up Tax Information Returns.
The first exchange of information under DAC9 must take place no earlier than 1 December 2026 and within six months of the applicable TTIR filing deadline.
Broader reporting scope under DAC8 and DAC9 framework
The bill further broadens automatic exchange of information on financial accounts to include:
- Electronic money and central bank digital currencies
- E-money institutions, added to the definition of “financial institution”
- Non-custodial dividends
- Cross-border tax rulings issued to high-net-worth individuals
Transfer pricing refinements
The draft law also revises the definition of “market price” (arm’s length price) in the Additional Provisions of the TSSPC. The updated definition aligns with the latest OECD Transfer Pricing Guidelines, defining it as the price that would be agreed in a transaction with comparable terms between independent persons under comparable circumstances.
In addition, the bill explicitly introduces a sixth transfer pricing method, which may be used where the existing five standard methods are not adequate or cannot be applied with sufficient reliability, in line with OECD recommendations.
Implementation timeline
The first exchange of information on crypto-assets for users who are EU tax residents will apply to reporting periods starting from 1 January 2026.
Crypto-asset service providers must complete due diligence for existing users by 1 January 2027.
Earlier, the European Commission issued formal notices to 12 Member States for not fully implementing Directive (EU) 2023/2226 (DAC8) on crypto-asset information exchange, and to 10 Member States for incomplete transposition of Directive (EU) 2025/872 (DAC9) on GloBE information returns in its January 2025 infringements package issued on 30 January 2026.
