Bulgaria: New relieved procedure for the publication of annual financial statements

With the latest amendments to Ordinance No. 1 for the Administration, Maintenance and Access to the Commercial Register and the Register for Non-Profit Legal Entities (Наредба № 1 за водене, съхраняване и достъп до търговския регистър и до регистъра на юридическите лица с нестопанска цел) in force from 14 March 2020, a new relieved procedure for the publication of the financial statements of micro, small and medium-sized enterprises was adopted.

What's new?

Micro, small and medium-sized enterprises are no longer obliged to file with the Commercial Register and the Register for Non-Profit Legal Entities (the "Commercial Register") any documents proving the adoption of their annual financial statements and annual activity reports, such as invitations to convene a general meeting, minutes of general meetings, etc. Instead, it will suffice to file a sample form declaration in simple written form by the company's representative(s) stating that the company is micro, small or medium-sized and that the annual financial statements and the annual activity report have been duly adopted through a resolution of the shareholders' meeting of limited liability companies or the general meeting of joint-stock companies.

Which companies are concerned?

The relieved procedure for the publication of financial statements applies only to micro, small and medium-sized enterprises within the meaning of Article 19 (2), (3) and (4) of the Accountancy Act (Закона за счетоводството). The categorisation criteria for companies are shown in the table below. In order to be classified in one of the categories below, the company must do not exceed at least two of the criteria as at 31 December of the reporting period.

What is the publication deadline for financial statements for 2019?

Due to the COVID-19 outbreak the deadline to publish annual financial statements for 2019 in the Commercial Register has been extended to 30 September 2020.

What to expect in the future?

From 1 January 2020, the state fee for the publication of financial statements will be cancelled. Currently, state fees of BGN 20 (approx. EUR 10) are applied to financial statements filed electronically and BGN 40 (approx. EUR 20) to statements filed in hard copy.