DIY bookkeeping — mistakes, fines and liability
The risk is not black and white
This guide sets out realistically what you can get wrong, what the consequences are and when it is worth paying a professional. For the legal framework, see Can an EOOD owner do the bookkeeping themselves?, and for a cost comparison — DIY or an accountant: what each one costs.
Who is liable
| Model | Who is liable to the NRA |
|---|---|
| You do it yourself | The manager/owner — full liability |
| Accountant at a firm | Still the manager, but the firm bears professional liability for its work and can be held liable under the contract |
| In-house accountant (employee) | The manager is liable to the NRA; the employee — under employment and disciplinary rules |
Key rule: the signature on the declarations and the GFO is yours (as the company's representative), no matter who prepared the documents. A good accountant reduces the risk of mistakes, but does not shift the tax liability onto themselves.
The most common DIY mistakes
- A missed invoice — the most common cause of an incorrect VAT return and of "unexplained" balance differences
- The wrong tax treatment — an intra-Community supply, reverse charge or export recorded as an ordinary 20% sale
- A missing VAT period — issuing an invoice when the month is not open, and therefore recording it late
- An unfiled zero return — "I had no activity" does not mean "I don't file"
- Payroll mistakes — social insurance income above the ceiling, incorrect contributions, late D1/D6 declarations
- Missed depreciation — fixed assets with no depreciation recorded distort the result and the tax base
- Closing a period with drafts — years are closed with unfinished documents and then reopened
Firmify catches most of these mistakes early — for example, it won't let you issue an invoice without an open period or post an unbalanced entry. The rest is process: a monthly checklist and a check before filing.
Fines and consequences
| Mistake | Typical consequence |
|---|---|
| VAT return not filed | Fine under Art. 179 of the VAT Act + late-payment interest |
| VAT not charged (e.g. an invoice issued without VAT) | Penalty under Art. 180 of the VAT Act, interest and possibly a tax audit |
| GFO not prepared | Fine under Art. 72 of the Accountancy Act |
| GFO not published in the Commercial Register | Fine under Art. 74 of the Accountancy Act |
| Overdue social insurance contributions and D1/D6 declarations | Fines under the Social Insurance Code and interest |
| Overdue taxes | Interest for every day of delay (Tax and Social Insurance Procedure Code) |
When the risk becomes unacceptable
DIY is a reasonable choice, but there are profiles where a mistake costs far more than the fee:
- Employees and payroll — sick leave, holidays, civil contracts, D1/D6 declarations
- Heavy EU trade — intra-Community acquisitions, exports, triangular transactions, OSS
- High document volume — 100+ invoices per month
- The first year after registration — when internal processes have not settled yet
- A tax audit, inspection or dispute with the NRA
- A medium or large enterprise — statutory audit and a GFO from a qualified accountant
If your company falls into any of these groups, rely on a professional at least for that area (for example, payroll only or the year-end closing only).
How to reduce the risk
- Work with a monthly checklist — Monthly accounting checklist for an EOOD
- Don't miss deadlines — enable the deadlines calendar in the accounting module
- Check before filing — open the VAT ledgers and confirm that all invoices are included
- Close periods on time — How to close an accounting period
- Plan an annual review — even with full DIY, one review by an accountant before filing the GFO is cheap insurance
- Keep an audit trail — reversing entries instead of deletions, credit notes instead of edits; Firmify does this by default
💡 Rule of thumb: if you cannot briefly explain why a transaction was recorded this way, that is a signal to ask an accountant — before filing, not after an audit.
All guides
- How to Register a Company in Bulgaria (2026 Guide)
- EOOD vs OOD in Bulgaria — Which to Choose?
- Company Registration Costs in Bulgaria (2026)
- VAT Registration in Bulgaria — When & How
- Corporate Tax in Bulgaria — 10% Flat Rate Guide
- How to Register an EOOD in Bulgaria — Full Guide
- How to Register an OOD in Bulgaria — Full Guide
- Check & Reserve a Company Name in Bulgaria
- Documents for Company Registration in Bulgaria
- Signing Documents for Company Registration — QES, Specimen, Firmify
- Signing Help — Evrotrust, PDF, B-Trust
- Sign PDF with QES Outside Firmify — Adobe Reader, Steps
- Signing with Evrotrust in Firmify — Steps
- B-Trust, Smart Card, and BISS for Signing
- Capital Escrow Account & Company Banking in Bulgaria
- Annual Financial Report (AFR) in Bulgaria — Filing & Deadlines
- Company Registration & Maintenance Costs in Bulgaria
- Online Company Registration in Bulgaria
- Dissolving an EOOD/OOD in Bulgaria — Procedure & Timeline
- Share Transfer in EOOD/OOD — Procedure & Documents
- Company Amendments in the Commercial Register (A4)
- Euro Capital Conversion — EOOD and OOD
- GDPR Policy & Legal Documents for Your Business
- Employment Contract & HR Documents in Bulgaria
- How to Find an Accountant or Lawyer for Your Company in Bulgaria
- Firmify Partner Program — How to Earn
- Business Documents — Quotes, Proforma Invoices, Contracts
- Do I Need a Lawyer to Register a Company in Bulgaria?
- Firmify vs Lawyer vs DIY Company Registration
- Registering a Company with Firmify — How It Works Step by Step
- How Long Does Company Registration Take in Bulgaria?
- What to Do After Receiving Your EIK?
- Do I Need a Notary for Company Registration?
- EOOD vs Freelance in Bulgaria — Which Is More Profitable?
- Manager Social Insurance for EOOD — Types & Obligations
- Public procurement radar: CPV codes and your Firmify profile
- What “AI assistance” means for TED notices
- End-to-end Firmify tenders flow: TED radar, case workspace, Stripe document pack
- Paid TED document pack for Firmify tenders: Stripe, statuses, filenames
- How to find the CPV code for your business
- Requirements for participating in public procurement in Bulgaria
- Art. 97a VAT Filing in Bulgaria — Monthly Guide (2026)
- VIES Declaration in Bulgaria — Guide 2026
- How to use the Firmify accounting module
- Monthly accounting checklist for EOOD
- How to file a VAT return with Firmify
- How to record a purchase invoice in Firmify
- How to issue an invoice with Firmify
- How to close an accounting period in Firmify
- Annual financial report (GFO) with Firmify
- Accounting glossary — Bulgaria
- Can an EOOD owner do their own bookkeeping in Bulgaria?
- DIY bookkeeping vs an accountant in Bulgaria: what each costs
- DIY bookkeeping risks in Bulgaria: mistakes, fines, liability
- The hybrid bookkeeping model: DIY monthly, accountant at year-end
- Switching from an accountant to DIY bookkeeping (and back)
- Bank statement import & reconciliation in Firmify
- Payroll and salaries in Firmify — EOOD guide
- Fixed assets and depreciation in Firmify
- Freelance Profession in Bulgaria — Complete Guide 2026
- BULSTAT Registration for Freelancers — Step by Step 2026
- Taxes and Social Security for Freelancers in Bulgaria 2026
- Freelance vs EOOD Tax Calculator — How to Use
- Freelance Accounting in Bulgaria — Self-Service with Firmify
- Freelance vs EOOD in Bulgaria — When to Incorporate?
- Digital Nomad Tax Guide: Working as a Freelancer in Bulgaria 2026
- How to Register as Self-Employed in Bulgaria as a Foreigner 2026
- VAT for Freelancers in Bulgaria 2026 — When to Register
- OKD-5 Declaration — Registering as Self-Employed in Bulgaria
- Choosing Insurance Income for Freelancers in Bulgaria 2026
- Annual Tax Return (Art. 50) for Freelancers in Bulgaria
- Public API v1 — Developer Documentation
- Using the Firmify Public API — Developer's Guide
- Public API Changelog
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