Fiscal rules

Do I need a fiscal device for an online shop in Bulgaria

It depends on how you get paid, not on selling online. The full matrix by payment method and by courier, with the evidence.

A stationery online shop storefront with a notification reading "Cash on delivery · ППП - the receipt replaces the fiscal bon"

What decides whether you need a fiscal device

The most common confusion is that an online shop by itself requires a fiscal device. It does not. The obligation comes from article 118 of the VAT Act and Ordinance H-18, and it attaches not to the sales channel but to how the money reaches you. The same shop can owe a receipt for some orders and not for others, on the same day.

The rule in one sentence: a payment in cash, or in something treated as cash, requires a fiscal receipt from a registered device. Everything else - a bank transfer, and under certain conditions cash on delivery - falls outside it. The rest of this article is just that sentence unpacked.

It matters just as much what a fiscal receipt is not. An invoice is not one. An order confirmation email is not one. A Stripe receipt is not one. A courier waybill is not one. The only substitute that matters for an online shop is the postal money transfer receipt, and it only works under specific conditions.

The matrix by payment method

Here is the whole obligation in one table. Verified in September 2026 against public sources; Ordinance H-18 changes often, so confirm with your accountant before configuring your shop around it.

The practical upshot: if you take only bank transfer and cash on delivery as a ППП, today you owe a fiscal receipt on no order at all. The by-courier table below shows that, through ZweiHost, no courier collects it that way today. The problem starts the moment you add card payments or a courier whose cash on delivery is not a ППП - Econt since 25 September 2026, unless you sign Econt’s agreement for it to issue the receipt for you, and Speedy and Sameday, whose waybills in ZweiHost request ordinary cash on delivery.

Payment methodReceipt owedWhy
Bank transferNoA credit transfer to a payment account is outside the requirement. The bank statement is the record.
Cash on delivery as a postal money transfer (ППП)NoThe postal money transfer receipt plays the role of the fiscal receipt. This is the only exception for a cash payment.
Cash on delivery collected any other wayYesA courier without a ППП licence, cash on delivery without the ППП contract or on a waybill for ordinary cash on delivery, and cash taken in hand, are ordinary cash payments.
Card paymentYes, by defaultA card payment counts as cash-like, and neither Stripe nor Borica issues Bulgarian fiscal receipts. The alternative is the article 3(17) regime.

Which couriers cover the receipt and which do not

The cash-on-delivery exception does not apply to cash on delivery in general. It applies to the postal money transfer, a service a courier may only offer while holding an individual licence under article 39(3) of the Postal Services Act. The receipt the customer gets when paying then plays the role of the fiscal receipt.

Three things matter - the licence, the contract AND the waybill. Cash on delivery through the same courier but without a ППП agreement in place is ordinary cash collection and needs a receipt. So is a waybill that requests ordinary cash on delivery: with Speedy, for example, cash on delivery and cash on delivery via ППП are separate services, and ZweiHost’s Speedy waybills request the first. If you are not sure what you signed, that is the first question to put to your courier.

And one date you need to know. From 25 September 2026 Econt no longer collects cash on delivery as a postal money transfer - the last ППП parcels went out on 24 September, as part of Econt’s announced exit from postal services. So cash on delivery through Econt no longer substitutes for the fiscal receipt, and Econt is the default courier for a large share of Bulgarian shops. In place of ППП, Econt offers its “Online sales without a cash register” service: under a separate agreement Econt issues the fiscal receipt in your name, but only for parcels prepared electronically with an item list or with your invoice number and date. ZweiHost is adding support for the service; without such an agreement, the receipt for cash on delivery through Econt is your obligation.

CourierППП coverEvidence
ЕконтNot coveredEnded postal money transfers (ППП) and cash on delivery via ППП on 25 September 2026 - by its own notice of 20 September 2026 the last ППП parcels went out on 24 September, and ППП licence no. 3-002-006 carries an early-termination application in the КРС article 39 register. In place of ППП, Econt offers its “Online sales without a cash register” service, under which a separate agreement has Econt issue the fiscal receipt in the merchant’s name.
СпидиNot coveredA licensed ППП operator (licence no. 3-013-001 in the КРС article 39 register, to 6 June 2032), but cash on delivery is a ППП only when the waybill requests it under a contract that allows it. ZweiHost’s Speedy waybills request ordinary cash on delivery. Speedy also offers a “Касов бон за наложен платеж” service, where it issues the receipt for the merchant - ZweiHost does not support it.
SamedayNot coveredA licensed ППП operator (Delivery Solutions EOOD, licence no. 3-041 in the КРС article 39 register, to 18 August 2042), but cash on delivery is a ППП only when the waybill requests it. ZweiHost’s Sameday waybills request ordinary cash on delivery - Sameday has no waybill field that makes it a ППП, and its general terms describe cash on delivery as an ordinary courier service. At easybox lockers cash on delivery is paid by card only.
BOX NOWNot coveredThe lockers take no cash. What BOX NOW calls cash on delivery in Bulgaria is a card payment link sent to the customer after dispatch.
Pigeon ExpressNot coveredAbsent from the КРС article 39 register (the one carrying ППП licences) and present only in the article 38 register - certificate no. 0334/13.08.2025, which cannot include ППП. Their own general terms never mention a postal money transfer.

What ZweiHost does, and what it does not

It pays to be specific here, because this is where expensive misunderstandings start. The platform shows you the consequence at configuration time: for each courier you see which payment methods are allowed and what follows fiscally from that choice, and every order whose receipt stays with you carries an explicit note in the admin. There is also a page that computes whether you qualify for the no-fiscal-device regime.

What ZweiHost does not do matters just as much:

Where to start

First check what you actually accept. Open your courier settings and look at which payment methods are enabled for each - it often turns out a method nobody uses has been left switched on, and creates an obligation all by itself.

Then decide what you want to offer. If card payments bring you enough orders to justify a fiscal device or the article 3(17) regime, switch them on deliberately. If not, turning them off is a perfectly legitimate decision and makes your life considerably simpler.

And finally, take this conversation to your accountant with the specifics: which couriers, which payment methods, whether you have a physical location. This article exists so you arrive prepared, not so you can skip the meeting.

Frequently asked questions

Do I need a fiscal device for an online shop?

It depends on how you get paid, not on selling online. If you take only bank transfer and cash on delivery as a postal money transfer (ППП), you owe a fiscal receipt on no order and need no device - but through ZweiHost no courier collects cash on delivery as a ППП today. If you take card payments or cash on delivery that is not a ППП, you owe one by default - either from your own fiscal device or through the article 3(17) regime.

Does cash on delivery need a fiscal receipt?

Only if the courier does not collect the amount as a postal money transfer. When a licensed ППП operator collects it as a ППП, the receipt the customer gets replaces the fiscal receipt and you issue nothing. With a courier without that licence - including BOX NOW and Pigeon Express - and with ordinary cash on delivery, which ZweiHost’s Speedy and Sameday waybills request, it is ordinary cash collection and the receipt is your obligation.

Is a fiscal receipt needed for an online card payment?

By default yes. A card payment is treated as cash-like, and Stripe and Borica issue payment confirmations, not Bulgarian fiscal receipts. The alternative is the article 3(17) regime, where instead of a receipt you issue a sale registration document under Appendix 18a and file a monthly audit file under Appendix 38.

Does ZweiHost issue fiscal receipts for me?

No. ZweiHost is not a fiscal device and is not registered fiscalisation software, so it cannot issue fiscal receipts for any payment method. What we do is show you clearly which orders leave the obligation with you, and generate the documents we can - including the Appendix 18a document and the Appendix 38 audit file if you work under the alternative regime.

What changes with Econt in September 2026?

From 25 September 2026 Econt replaced postal money transfers and cash on delivery via ППП with its “Online sales without a cash register” service. Cash on delivery through Econt no longer substitutes for the fiscal receipt: without the new agreement, those sales move to your own fiscalisation. With it, Econt issues the fiscal receipt in your name, provided the parcel is prepared electronically with an item list or with your invoice number and date. Parcels sent with ППП up to and including 24 September stay covered.

Do I need to file the Appendix 33 declaration?

Yes, if you sell through an e-shop. Ordinance H-18 (article 52m(1)) requires the Appendix 33 information for every e-shop, whatever payments it takes - including a shop taking only bank transfer and ППП cash on delivery. It is filed before sales begin, separately for each shop, through the tax authority portal with an electronic signature or PIN. Changes are declared within 7 days.

Verified as of 8 October 2026. This article is general information, not legal or tax advice. Ordinance H-18 changes often, and the rules that apply depend on your activity, VAT registration and courier contracts. The verification behind the date above was done against public sources - the КРС registers, the revenue agency and the couriers’ own general terms. Confirm anything here with your accountant before relying on it.

A shop that tells you what you owe

ZweiHost shows the fiscal consequence while you configure your couriers, and flags every order whose receipt stays with you. We will not file anything on your behalf, but we will not leave you guessing either.

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Do I need a fiscal device for an online shop · ZweiHost