@janemulberry
Thank you for your thoughts Jane.
I did some additional research, and here is what AI said regarding reporting and filing obligations:
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"Here's the most up-to-date information (as of January 2026) on tax returns and reporting obligations for dormant (inactive / no-activity) companies in Bulgaria.
Current Rules for Dormant Companies (2025–2026)
A dormant company is one that had zero revenue, zero expenses, zero transactions, no salaries, no sales/purchases, no assets acquired/disposed, etc., in the previous calendar year.
1. Corporate Income Tax Return (Form 100 / Art. 92 of the Corporate Income Tax Act)
Companies with no activity during the entire previous year are exempt from submitting the annual corporate income tax return to the National Revenue Agency (НАП).
This exemption has been in force since the 2018 amendments and remains valid in 2025 and 2026.
No need to file Form 100 by 31 March (or June 30).
2. Annual Financial Statements & Publication in the Commercial Register
Normally due by 30 September of the following year.
If you file the Declaration of No Activity (Декларация за липса на дейност), the company is fully exempt from preparing and publishing annual financial statements (balance sheet, profit & loss account, notes, etc.).
3. Declaration of No Activity – Commercial Register (Art. 38, para. 9 of the Accountancy Act)
This is a one-time declaration, filed only in the first year the company becomes inactive.
Once filed, it applies to all subsequent years of continued inactivity (no need to refile every year).
Deadline (for companies inactive in 2024): 30 June 2025.
Deadline (for companies inactive in 2025): expected 30 June 2026.
How to file:
Application G3 + text declaration
Electronically (with qualified electronic signature) via the Registry Agency portal — recommended
Or on paper at any Registry Agency office
Signed by the manager (or lawyer with simple power of attorney)
No state fee.
Effect: Exempts the company from publishing financial statements indefinitely while inactive.
4. NSI Declaration (Appendix No. 11 – Enterprises without activity)
Annual declaration to the National Statistical Institute (НСИ) confirming no activity.
Deadline for 2025 (reporting on 2024): 1 March – 30 June 2025.
Can be submitted:
Online with QES
Via email to the relevant territorial statistical office
Post
In person
5. VAT Obligations
If the company is VAT-registered: You must continue filing monthly zero VAT returns (Декларация по ДДС) + purchase/sales ledgers (by the 14th of the following month) indefinitely.
Recommendation: Voluntarily deregister from VAT (application to НАП) if you do not expect taxable supplies in the future — this removes the ongoing burden.
6. Social Security & Payroll Declarations
No employees → no declarations required.
Any employees (even on unpaid leave or maternity leave) → monthly declarations to НАП and NOI are still required.
7. Penalties for Non-Compliance
Failure to file the Commercial Register Declaration on time → obligation to publish full financial statements + fines starting at 500–2,000 BGN (and possible higher penalties for repeated violations).
Late or missing NSI declaration → fines from several hundred to a few thousand BGN.
Continuing to file zero VAT returns late → penalties apply."