# Ordinance N-18 for online stores: NRA, receipts and the XML file Ordinance N-18 for online stores in Bulgaria: NRA registration, when you need a receipt, the monthly XML audit file and how to set it all up in CloudCart. Source: https://cloudcart.com/en/blog/n18-online-store-nap · CloudCart · 2026-11-06 In short: under Ordinance N-18 (Bulgaria's reporting rules for online sales), every online store is registered with the NRA before its first sale, and the document for each sale depends on how the customer pays. Card payments on the website need no cash register: you issue a sales document and upload a monthly XML file by the 15th. For cash on delivery collected as a postal money order and for bank transfers, you issue no receipt yourself. This guide is for online stores in Bulgaria that sell to consumers, including foreign founders and companies selling in or from Bulgaria. It follows the consolidated text of Ordinance N-18 with the amendments of State Gazette No. 42 of 2025, in force from Jan 1, 2026, and shows how you meet each rule in CloudCart, the Bulgarian ecommerce platform. It is not legal or tax advice: your accountant confirms what applies to your company. ## What is Ordinance N-18 and what does it mean for an online store? [Ordinance No. N-18 of December 13, 2006 (in Bulgarian)](https://lex.bg/laws/ldoc/2135540645) (often searched as "Naredba N-18") is the Bulgarian regulation on how sales are recorded and reported: with cash registers, with sales software in physical shops (SUPTO) and, for e-shops, with a chapter on registration and an alternative regime for card payments. Its basic rule is in Art. 3: every sale is recorded with a fiscal receipt, except in the cases the ordinance lists. Those exceptions decide whether an online store needs a cash register, and they depend on how the customer pays: - Bank transfer to your account: no receipt. - Cash on delivery collected as a postal money order by a courier licensed as a postal operator, such as Econt or Speedy (DPD Bulgaria), Bulgaria's largest couriers: no receipt from you. - Card on the website (bank virtual POS, payment provider, CloudCart Pay ): a fiscal receipt, or the alternative regime of Chapter Seven "g" (Art. 52o to 52u) with a sales document and a monthly XML file. - Cash paid to you in person , at a warehouse pickup or in your own shop: a fiscal receipt from a cash register. ## Which document do you issue for each payment method? The last column is the payment method code (paym) the order gets in the XML file under Annex 38, taken from the official NRA XSD schema. | How the customer pays | Document for the customer | Cash register | Code in the XML file | | Card on the website through CloudCart Pay or another payment provider | Sales document under Art. 52o (or an invoice with the same details) | No, under the alternative regime | 4 (payment service provider) | | Card through a bank's virtual POS | Sales document under Art. 52o | No, under the alternative regime | 2 (virtual POS, with the terminal number) | | Cash on delivery through Econt, Speedy and other couriers with postal money orders | Document from the courier under your contract, with a packing list or invoice in the parcel | No | 3 (cash on delivery with a postal money order) | | Bank transfer | Invoice, if the customer asks for one | No | 1 (exempt under Art. 3) | | Cash in person or in a shop | Fiscal receipt | Yes | 6 (recorded with a fiscal receipt) | | Another payment that needs no fiscal receipt | Depends on the payment | No | 5 (other payment) | Important: the alternative regime is a choice. If you issue fiscal receipts for card payments from a cash register, the monthly XML file does not apply to you. Once you choose the regime, Art. 52o to 52t apply in full. ## Does an online store have to register with the NRA? Yes. Art. 52m(1) requires everyone who sells through an e-shop to file its details with the NRA (National Revenue Agency, Bulgaria's tax authority) under Annex 33 before the first sale, whether the domain is your own, rented or on a platform, and also when you accept only bank transfers and cash on delivery. The filing is made on the [NRA e-services portal](https://portal.nra.bg/), signed with a qualified electronic signature (QES), and registered stores appear in the NRA's public list (Art. 52m(5)). For the alternative regime, the filing also lists the payment methods, the payment service providers, the receiving accounts and any virtual POS terminal numbers (Art. 52r). With CloudCart Pay these details are on the "Status" step of the CloudCart Pay settings, with a PDF for you or your accountant. The NRA then assigns a unique e-shop number starting with RF (Art. 52t(1)), which goes into the QR code of every sales document, into every monthly file and into the N18 Audit app. The form is in Bulgarian, so many foreign owners let a local accountant file it; the full walkthrough is in the guide to [the NRA for online stores](https://cloudcart.com/en/blog/nra-bulgaria-online-store). A change of domain, payment method or account is filed within 7 days (Art. 52m(3)), and so is closing the store (Art. 52m(4)). A typical case is a move from WooCommerce or OpenCart: the domain stays and the card provider changes. With a [migration to CloudCart](https://cloudcart.com/en/migration), the old orders are carried over and kept separately, so the sales history stays at hand. ## What does Ordinance N-18 require from a store that takes cards? The alternative regime has five conditions, also listed on the [NRA page on the alternative regime (in Bulgarian)](https://nra.bg/wps/portal/nra/fiskalni-ustroystva-supto-i-e-magazini/page.turgovia-v-internet-i-e-magazini/page.lternativen-rejim-za-registrirane-i-otchitane-na-prodajbite/alternativen-rejim-za-registrirane-i-otchitane-na-prodajbite). Miss one and you lose the right to issue a sales document in place of a fiscal receipt (Art. 52u). - A sales document for every card payment (Art. 52o). This is the receipt Ordinance N-18 requires instead of a fiscal receipt: a 10-digit number that grows by 1, the seller, the order number, the transaction reference, items with tax group, quantity and price, the total, the payment method and a QR code. The customer receives it electronically at payment. - The money arrives in your company's account (Art. 52p). It may pass first through the payment provider's account, as long as it is then transferred to yours. - The store is registered with the NRA with its payment methods, providers and accounts (Art. 52r and 52t(1)). - The store software gives every order a unique number (Art. 52s) and keeps full admin access for NRA inspections. - A monthly audit file (Art. 52t(2)) in XML under Annex 38, by the 15th of the following month. ### Ordinance N-18 deadlines and numbers in one place | What | Deadline or number | Legal basis | | Register the store with the NRA | Before the first sale | Art. 52m(1) | | Change of domain, payments or accounts; closing the store | Within 7 days | Art. 52m(3) and (4) | | Sales document number | 10 digits, grows by 1 | Art. 52o | | Monthly XML file | From the 1st to the 15th of the following month | Art. 52t(2) | | Currency of the amounts in the file | Euro from Jan 1, 2026 | Annex 38 | | Penalty for not issuing a document (company or sole trader) | €511.29 to €2,045.17 | VAT Act, Art. 185(1) (in Bulgarian) | When you issue an [invoice](https://cloudcart.com/en/blog/invoices-n18) with the details of the sales document (order number, transaction reference, items and QR code), a separate sales document is not needed (Art. 52o(3)), which suits business customers. > CloudCart Pay 0% transaction fee through Dec 31, 2026 Cards, Apple Pay and Google Pay are paid in your store's own checkout form, and payouts arrive by SEPA, usually in 2 to 5 business days. For the N-18 regime, enter an account held by the company, as Art. 52p requires. How CloudCart Pay works → ## What is the standardised audit file (XML) and when is it due? The audit file is one XML file per calendar month, built to the dec_audit.xsd schema of Annex 38. It holds your company number (UIC), the unique e-shop number, the domain and the month, then every order: number and date, sales document number, value without VAT, discount, VAT, total, payment method and transaction reference. Returned orders follow with negative amounts and the refund method. It is filed on the NRA portal with your QES between the 1st and the 15th of the next month, so the October file is due by November 15. From Jan 1, 2026 the amounts are in euro, after Bulgaria adopted the euro at the [fixed rate of 1.95583 leva per euro](https://www.ecb.europa.eu/euro/changeover/bulgaria/html/index.en.html); for orders dated before 2026, CloudCart writes leva. More in the guide to [euro prices in an online store](https://cloudcart.com/en/blog/euro-prices-online-store). ### How CloudCart builds the file - A sale is an order that became paid, completed or fulfilled during the month. An order placed on April 28 and paid on May 2 goes into the May file. - A reversal is an order already sold that was cancelled, refunded, returned or disputed during the month. A partial return is a reversal in the month of the return. - Each order goes into one monthly file only. Once included, it is marked and cannot land in another month. - Cash on delivery has its own code and is not merged with bank transfer. - The file is in Windows-1251 encoding , as the NRA validator expects, and characters such as "&", "" in product names are replaced so the file is not rejected. > Invoices and Ordinance N-18 The NRA file comes out of your orders The sales document and the invoice are issued from the order itself, and the N18 Audit app builds the monthly file with the sales and reversals. You only upload it to the NRA portal. How invoices and N-18 work → ## How to set up Ordinance N-18 in CloudCart: steps in the admin You set it up once, after the NRA registration, and then download one file a month. - Turn on invoicing. Settings → Invoicing → General settings: turn on "Activate invoicing", choose automatic issuing and fill in the company details. The document number in the file comes from here, so invoicing has to be on during every month you report. - Install the app. Apps → N18 Audit. It has no on or off switch: it works once you save the unique e-shop number. - Enter the NRA details. On the app's Settings tab: the unique e-shop number, the domain (by default the store's main address) and how refunds are paid back. Virtual POS methods get a terminal number field, filled in already if the method's own settings have it. - Set up the payments. Settings → Payments: CloudCart Pay for cards, Apple Pay and Google Pay, plus "Cash on delivery" and "Bank transfer", matching your NRA filing. - Connect the courier. For Econt: Apps → Econt → Settings, turn on the packing list and, if you signed the "online sales without a cash register" contract, its own switch. The packing list is built from the order lines when the shipping label is created. - Download the file every month. Apps → N18 Audit → List: add the month, wait for the file, download the XML and upload it to the NRA portal by the 15th. If the [store is connected to an AI assistant](https://cloudcart.com/en/offer/ai) such as Claude Code or ChatGPT Codex with a read-only PAT token, one sentence like "List the orders from October with number, date, total, payment method and payment status" gives you the list to compare with the file. Important: generating the same month again creates a second file next to the first. File the correct one and delete the other. ## Does an online store need a cash register? For most online stores, no. Many Bulgarian stores accept cash on delivery and cards: with cash on delivery collected as a postal money order the receipt is the courier's job, and for cards you use the alternative regime. You need a cash register when customers pay you cash directly, on handover, at a warehouse pickup or in your own shop, and a physical shop's register is separate from your online sales. Econt offers an "online sales without a cash register" contract: the courier issues the receipt to the recipient at delivery, and each parcel carries a packing list (name, unit price, quantity) or the invoice number and date. The packing list total has to equal the cash on delivery amount. > Shipping Econt, Speedy and BOX NOW, built into the admin The shipping label and the packing list are created from the order. With cash on delivery sync turned on (depending on the plan), the order is completed on its own once the courier reports the money collected, so the statuses the XML file is built from are correct. Couriers in CloudCart → ## Do you issue a receipt for cash on delivery? Not yourself, if the money is collected as a postal money order by a licensed postal operator (Art. 3(1)). The customer gets a document with the main details of the sale under the courier contract, and the money arrives in your bank account. Check the terms with each courier, Speedy included. If you deliver yourself and take cash, the receipt is yours. Cash on delivery has a cost (courier fee, later payout, refused parcels), so some stores add a fee for it or a discount for cards. In CloudCart the fee or discount is set on the "Cash on delivery" method and shown as a separate line in checkout. The numbers are in the guide to [cash on delivery or card payments](https://cloudcart.com/en/blog/cash-on-delivery-vs-card-payments). ## A worked example: one store's month An illustrative example with round numbers: a store registered with the NRA ships 412 orders in September. | Orders | Payment | Document | In the September file | | 236 | CloudCart Pay (card, Apple Pay, Google Pay) | Sales document issued from the order | Sales with code 4 | | 158 | Cash on delivery with Econt and Speedy | Receipt from the courier | Sales with code 3, in the month the order became paid or fulfilled | | 18 | Bank transfer (business customers) | Invoice | Sales with code 1 | | 9 | Returned orders | Credit note where an invoice was issued | Reversals with a negative amount | On October 3 the owner generates September in N18 Audit, checks the count of sales and reversals and files the XML. There is no cash register, and no document was written by hand. ## Can you run an online store without a company? Only in narrow cases. Regular sales of goods usually need a sole trader (ET) or a company (EOOD, a single-owner limited company, or OOD). Some individuals, such as freelancers, craftspeople and farmers, record sales without a company and have the same document obligations. Decide it with an accountant before launch. The options are compared in the guide to [company registration in Bulgaria](https://cloudcart.com/en/blog/company-registration-online-store). CloudCart Pay accepts companies, sole traders included, and non-profit organisations, and under the alternative regime card money has to reach an account held by your company (Art. 52p). ## Ordinance N-18 and SUPTO: what is the difference? SUPTO is sales management software for a physical point of sale with a cash register, and its requirements are a separate part of Ordinance N-18. E-shop software under the alternative regime has shorter rules (Art. 52s): a unique number for every order and points 2, 3 and 7 of Annex 29. ## Mistakes to avoid - Selling before the NRA registration. For cards it is also a condition of the alternative regime. - Invoicing switched off during a reporting month. Sales then go into the file without a document number. - Card money paid into a personal or unregistered account. Art. 52p requires an account held by your company. - Missing the 15th. Set a reminder for the 1st of every month. - Two files for one month. File one and delete the other. - A new payment method without updating the NRA filing. Register it before it goes live in checkout. ## What are the penalties for not following Ordinance N-18? Under the ordinance, a store that stops meeting a condition of the alternative regime loses the right to issue sales documents in place of fiscal receipts and may be removed from the NRA list (Art. 52u). Under the [VAT Act (in Bulgarian)](https://lex.bg/laws/ldoc/2135533201), Art. 185(1) sets a penalty of €511.29 to €2,045.17 for a company or sole trader that does not issue a sales document, and €1,022.58 to €4,090.34 for a repeat (Art. 185(4)). The law still quotes leva (BGN 1,000 to 4,000 and 2,000 to 8,000), converted here at 1.95583. Confirm your own case with your accountant. ## An Ordinance N-18 checklist before Black Friday November brings more orders and, after the holidays, more reversals. Check six things: - The unique NRA number is saved in Apps → N18 Audit → Settings. - Invoicing is on and issues documents automatically. - Every payment method in checkout is registered with the NRA , with terminal numbers. - The courier packing list is on , if you have a contract for online sales without a cash register. - The refund method in the N18 Audit settings matches what you do. - The October file is filed by November 15. > A new store €1/month for the first 3 months Invoices, the sales document and the N18 Audit app are built into the platform, so the store is ready for the NRA from the first order. The offer is for new stores through Dec 31, 2026. Create a store for €1 → Starting out? See [how to create an online store step by step](https://cloudcart.com/en/blog/how-to-create-online-store) and the [CloudCart plan prices](https://cloudcart.com/en/pricing). Switching platforms? The [guide to migrating from WooCommerce](https://cloudcart.com/en/blog/migrate-from-woocommerce-guide) shows how orders are carried over. All payment methods are on the [payment methods](https://cloudcart.com/en/payments) page, and CloudCart takes [0% commission on your sales](https://cloudcart.com/en/offer/zero-commission-ecommerce). Questions about the setup: [support@cloudcart.com](https://cloudcart.commailto:support@cloudcart.com). ## Frequently asked questions **Does an online store in Bulgaria have to register with the NRA?** Yes. Under Art. 52m(1) of Ordinance N-18, every e-shop is registered on the NRA portal with a QES before the first sale, whatever payment methods it accepts. Changes are filed within 7 days, and stores under the alternative regime get a unique e-shop number. **What does Ordinance N-18 require from online stores?** A document for every sale according to the payment method. For cards without a cash register: NRA registration, a sales document with a 10-digit number and QR code, money in the company's account, a unique number per order and a monthly XML file by the 15th. **Do I need a cash register for an online store in Bulgaria?** Usually not. Cards are documented under the alternative regime, cash on delivery as a postal money order under the courier contract, and bank transfers need no receipt. You need a cash register when customers pay you cash in person. **What is the Annex 38 audit file and when is it due?** A monthly XML file with the month's sales and returns, filed on the NRA portal from the 1st to the 15th of the next month, in euro since Jan 1, 2026. In CloudCart the N18 Audit app builds it from your orders. **Do I issue a receipt for cash on delivery?** Not if a licensed postal operator collects the money as a postal money order. The customer gets a document under the courier contract, for example Econt's receipt under its contract for online sales without a cash register. If you deliver and take cash yourself, you need a cash register. **Does CloudCart file the XML with the NRA for me?** No. The filing is signed with your own QES. The N18 Audit app builds the file for the month you choose, keeps it for download and puts each order in one month only; you upload it to the NRA portal.