Dear Prime Minister,

Following the meeting held on the 26th of February 2019 at your invitation, I hereby inform you that the branch organizations, which are represented and coordinated by the Bulgarian Industrial Association have:

  1. Participated actively in all expert meetings with the National Revenue Agency (NRA);
  2. Submitted a package of specific proposals for amendments to Ordinance H- 18 within the time limit for public consultation;
  3. Have made six improvement propositions to the NRA, concerning the revision of Regulation H- 18:

1). Card payments and electronic payment systems;  

2). Electronic fiscal notes and electronic fiscal documents;

3). Electronic systems with fiscal memory – ESFP;

4). Duplicate functionality / A clear boundary to where STUDO ends and business management software begins (data duplication);

5). Unlawful texts, over-regulation and control of access to data, collected under Ordinance H-18;

6). Operational issues, incl. sealing objects.

  1. They thereby insisted:

1). To prepare a negotiation schedule for the six thematic areas;

2). To prepare a bilateral protocol, which includes the specific arrangements made within negotiations

3). To make these bilateral protocols public.

  1. They have committed to:

1). Present specific changes in the texts of the Ordinance (revision of existing and/ or addition of missing ones);

2). Enable representatives to participate in the negotiations on the different strands.

Unfortunately, the NRA did not appreciate this good-will partnership behavior and so far there has been little to no understanding towards the six strategic directions for improvements in Ordinance H-18. No relevant working groups have been set up, thus there has been no progress on any of the proposed changes.

  1. The arrangement to resolve the essential issues by the 30th of September will not be held. The extension of some of the terms in the Ordinance will only delay the chaos, which will be inevitable if there are no changes in the substance of the Ordinance. This does not display the NRA’s and the Ministry of Finance’s declared willingness to step into a productive dialogue.
  2. There were minor and small business proposals, which have had no significant contribution to overcoming the global defects in the Ordinance;
  3. Despite our repeated demands, the minutes of meetings with organizations have not been made public and people have not had open access to them;
  4. We are still waiting for feedback to over 60 of our proposals, which have been officially presented in the public consultation and have been published on the public consultation website.

The changes in Ordinance H- 18 of autumn last year are not aimed at lightening the economy and guaranteeing a good business environment but rather generate public tension in a year of European and local elections. The Bulgarian business should not become a hostage of political interests. Economic stability does not require acts that aggravate the business environment.

Such actions (the publication of vague texts, predicting unreasonably short and unenforceable deadlines, and promulgation of changes in the improvements- hence- changes) create tremendous tension, uncertainty and even anger among businesses and citizens, and this undermines the long-standing trust in the administration. The Ordinance has a direct impact on the society. The business will have to pay a five-times- higher price when it applies the new requirements of the Ordinance compared to its preliminary impact assessment. This will also affect the value of end-user goods and services.

I turn to you with the expectation that you will put to use the necessary institutional control and thus overcome the accumulated problems in the shortest possible time. I am convinced that the preservation of economic and fiscal stability in the country depend on the quick and effective decisions.




Chairman of the Management Board of BIA


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