How to start a vending machine business in Bulgaria - requirements and permission

A detailed guide to starting a vending machine business in Bulgaria - accounting, taxation, patent tax, do you need a cash register, requirements, pavement law, sale of medicines and much more!
updated on
15/4/2024
How to start a vending machine business in Bulgaria - requirements and permission
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Starting a business with vending machines in Bulgaria represents an interesting and potentially profitable venture that can bring you good income with proper management and organization. IN Elan Consulting, with our deep knowledge and experience in the field of accounting and business consulting, we are focused on providing valuable support and guidance to those who wish to embark on this type of entrepreneurship. It is important to emphasize that success in business with vending machines requires careful planning, as well as an understanding of a number legal requirements and regulations.

One of the key steps in starting this business is getting permission to place a vending machine. This process can involve different types of permits, depending on the type of products to be offered - from drinks and snacks to medicines, the latter requiring a specific license for vending machines for medicines.

Also, an important aspect is the arrangement of pavement law about vending machines, as well as familiarization with patent tax for vending machines and the relevant regulations for vending machines. These elements are essential for determining the location of your machines and for calculating the expected vending machine profit.

When renting places for your vending machines, it is important to be aware of the conditions and requirements for contract for placing a coffee machineor another type of vending machine. This includes both location and the requirements for the placement of vending machines, which may vary depending on local municipal ordinances.

In addition, effective management of the vending machine business requires the implementation of program for accounting of vending machinesto help track sales and optimize inventory.

IN Elan ConsultingWe understand that behind every successful business there is strong financial and accounting management. We are here to provide you with expert support and help you navigate the complex web of legal requirements and administrative procedures related to starting a vending machine businessin Bulgaria. Our team is committed to offering customized solutions to meet your unique needs and help grow your business.

What are the legal requirements for placing a vending machine in Bulgaria?

Starting a business with vending machinesin Bulgaria represents an exciting enterprise with the potential for good profits. IN Elan Consulting, with our expertise in accounting and business consulting, we are here to support you in this endeavor by providing all the necessary information and advice for the successful start and management of your vending business.

Do I need to register a company?

Starting a vending business requires advance planning and attention to detail, especially in terms of legal formof your operation. It is important to determine if you are going to register Ltd. (Sole proprietorship with limited liability), ET, or Ltd. (limited liability company), each of these forms has its own specifics and advantages. Sole proprietors (ET)are responsible with all their personal property for the activities of the company, while in LTD.there is a division between personal property and that of the company. The choice between these forms depends on your individual needs and preferences, and we at Elan Consulting are on hand to advise you and help you make the best decision for your business. In addition, income from vending machines can be taxed patent tax, which is applicable to natural persons or sole traders under certain conditions.

What license and permit from BABH to install a vending machine do I need?

To start a vending business, it is necessary to be aware of the legal requirements for obtaining license and permitfor the operation of vending machines. Depending on the type of products you will be offering, you may need to obtain a permit from Bulgarian Food Safety Agency (BABH), especially if your vending machine will offer food or drinks. This process requires detailed familiarization with the regulations and standards of safety and hygiene established by the BACH.

Authorization from the Bulgarian Academy for the installation of a vending machine for the sale of foodstuffs

To start a food vending machine business, it is a must the registration of the objectfor the production or marketing of food in Regional Directorate for Food Safety (ODBH))at the location of the object to the Bulgarian Food Safety Agency. This includes the submission of a sample application and documentation certifying compliance with hygiene and veterinary requirements, as well as the existence of good practices in the production and marketing of food.

It is important to emphasize that the registration process also includes an on-site inspection by the relevant authority for the compliance of the site with the established requirements. Upon successful passing of this check, it is issued certificate of registration, which is the final step to start the business with a food vending machine.

According to §1, item 14 of the Supplementary Provisions of The Food Law, it is necessary to apply “Good practice”, which includes a system of basic hygienic and technological rules. These rules are aimed at minimizing the risk of food contamination and apply to all stages of the production and commercial process - from the design of buildings and the maintenance of equipment to hygiene and training of personnel.

In addition, it is extremely important for the company that operates the vending machine to prepare a special Hazard Analysis and Critical Control Point System (HACCP), unique to each site, which is a standard for ensuring food safety throughout the food chain. This system requires the identification and control of potential food hazards, the definition of critical control points and the introduction of effective monitoring procedures.

IN Elan Consultingwe are on hand to provide you with all the necessary advice and assistance in navigating this process. We understand the complexity of regulations and are here to facilitate your journey to a successful food vending machine business.

License for vending machines for medicines

In the context of the developing pharmaceutical market and the growing demand for convenience on the part of consumers, the possibility of offering medicines in a pharmacy through a vending machine appears as an innovative solution. However, this practice is strictly regulated by The Law on Medicinal Products in Human Medicineand requires specific permits and compliance with imposed regulationsto ensure the safety and efficacy of medicines.

According to the law, retail trade in medicinal productsIt can only be done in pharmacies and drugstores, which have received the appropriate authorization from the Executive Agency for Medicines (IAL). This agency, as a specialized body to the Minister of Health, plays a key role in the supervision of the quality, safety and efficacy of medicines on the territory of the Republic of Bulgaria.

In addition to obtaining a retail license, pharmacies wishing to offer medicines through vending machines must comply with and specific requirements for the location, device and organization of workdefined in Ordinance No. 28from the Minister of Health. This regulation regulates in detail aspects such as the external and internal layout of pharmacies, the requirements for the premises and specific products that can be sold through vending machines.

Pharmacies must also ensure that all medicinal products offered through vending machines are authorised for use in the Republic of Bulgariaand that they meet all regulatory requirements for quality and safety. It is also important to ensure that any dispensing of a medicinal product through a vending machine is accompanied by an appropriate advice and instructions for useto protect the health and well-being of patients.

At Elan Consulting, we understand the importance of these regulations and are here to help pharmacies in the process of obtaining the necessary permits and adapting to the regulatory framework. Our team of experts provides professional assistance and advice that ensures that your pharmacy can successfully implement innovative solutions while complying with all legal requirements for the safety and quality of medicinal products.

The so-called “sidewalk right” for placing a vending machine - how is it obtained?

The receipt of pavement right for vending machine placementimplies the passage through a procedure regulated by regulations of the respective municipality, in our case - the Municipality of Burgas. This process includes several key steps that must be followed by applicants to ensure the legal deployment of a movable object as a vending machine on public territory.

Let us examine in detail the requirements for placing a vending machine on the territory of the municipality of Burgas, bearing in mind that the procedures in other cities in Bulgaria are similar.

According to The Ordinance on Movable Objects for Commercial and Other Service Activities and the Elements of Urban Furniture on the Territory of the Municipality of Burgas,last amended by a decision of the Municipal Council-Burgas under item 1, Protocol No 35/22.04.2014, in force from 30.12.2014, the movable objects (which also include vending machines) and the information and decorative-monumental elements on the territory of the Municipality of Burgas are located after a permit for placement has been issued in accordance with the order established by the ordinance, and for state and municipal properties - and on the basis of a scheme approved by the chief architect of the municipality. For state properties, the scheme is approved after consultation with the relevant central administration, which manages the property, and in other cases - with the district governor.

It is important to know that permissions to place moveable objects in real estate - monuments of culture, are issued on the basis of a scheme approved by the Chief Architect, after coordination with the Immovable Cultural Heritage.Schemes for placement of short-term objects are prepared by the interested persons and are submitted by the chief experts of the AS at the Directorate “Spatial Planning” of the Municipality of Burgas to the Chief Architect of the Municipality of Burgas for approval. The technical rules for placing movable objects are described in Appendix No. 1 to the Ordinance. In addition, in private land estates, state-owned properties and concession areas, the placement of movable objects is allowed subject to the observance of distances from neighboring land properties.

All vacancies for placement of movable object are announced on the official website of the Municipality of Burgas not later than 14 days after their release.

How do I apply for a pavement right?

So, the first step to get a sidewalk right to place a vending machine is the submission of an applicationto the relevant Directorate “Center for Administrative Services” in the Municipality of Burgas. The application must conform to the established template and be accompanied by all necessary documents, including a certificate of right of business activity, a document of ownership or lease of the land, a sketch of the layout of the site and other required declarations and documents related to the absence of obligations and certificates of categorization if necessary.

After that, the submitted applications are examined by a specially appointed committee, which includes representatives of the municipal administration and municipal councilors. This committee assesses the proposals andmay conduct an investment bidding procedure in the presence of competition for the same position according to the sketch of the possible locations of the movable sites.

What are the necessary documents for issuing a permit for the placement of a movable object?

The interested persons personally or with their expressly authorized representatives submit an application for issuing a permit for the placement of movable objects according to a model approved by the Mayor of the Municipality of Burgas, to the relevant Directorate “Center for Administrative Services” at the location of the object. The following documents are attached to the application:

  • Document on the current status of the company or certificate of registration as a Sole trader
  • Copy of document of ownership of the property, in which the location of the movable object is requested - in cases where the placement of a movable object in a property is requested, not owned by Burgas Municipality
  • Sketch of the land plot with a proposal for the placement of the movable object — in cases where the placement of a movable object in a private land property is requested
  • Explicit written consent from the owner of the land plot or a written lease agreement for the area occupied by the movable object, respectively a concession contract or a lease agreement — in cases where the placement of a movable object is requestedin public, private or concessionary property
  • Declaration of lack of obligations of the applicant to the Municipality of Burgas;
  • Declaration of lack of obligations of the applicant to the Republican budget;
  • Declaration that no administrative act has entered into force in respect of the applicant for the removal of a movable object placed by him
  • Document of paid fee for consideration of the application;
  • Certificate ofapproved category or temporary certificate for an open procedure for categorizing a tourist siteand under the Tourism Act.
  • Photos and collages showing the adaptation of the movable object to the urban environment

If the application is approved, permission is issuedfor the placement of the movable object, which describes in detail the conditions and term of the permit, the fees payable, as well as the requirements for the appearance and operation of the object. It is important to note that the owner of a vending machine must strictly comply with the requirements of safety, aesthetics, and last but not least - not to hinder the accessibility and passability of the urban environment.

Does a vending machine have to have a cash register?

Answer to the question “should a vending machine have a cash register?” gives Ordinance No H-18 of 13 December 2006 of the Minister of Finance. According to art. 2, para. 2, item. 5by the Ordinance, any person who carries out sales of goods or services through a self-service vending machine with electric power is obliged to register and account for each sale through fiscal device built into a self-service vending machine (FUVAS). This requirement means that the vending machine must be equipped with a cash registerwhich meets the definitions and functions of FUVAS.

FUVAS aims to ensure that each sale is accounted for correctly and that fiscal information is transmitted on time to the National Revenue Agency. This is achieved by recording sales in real time and issuing a fiscal voucher,which can be displayed on a display or issued as a paper document, depending on the configuration of the vending machine.

The requirement to equip vending machines with FUVAS is in line with the desire to increase transparency in trade and to facilitate tax control. In addition, art. 7bof the same ordinance stipulates that sales by means of a self-service vending machine with electric power are not allowed to be carried out when the connection between the vending machine and the FUVAS/fiscal printer is interrupted, stressing the importance of the permanent relationship with the National Revenue Agency to guarantee the legality of the sales.

How is the accounting of a vending machine carried out?

Vending machine accounting is an important element of managing your business, ensuring accurate and timely accounting of all financial operations. Includes registration of sales, expenses, patent tax and other related financial activities. As we said above, Ordinance №N-18/2006 of the Ministry of Foreign Affairsdetermines the rules for registration and accounting of sales through fiscal devices, including for self-service vending machines. It is important to comply with all deadlines for submitting accounting and tax documents to the relevant authorities in order to avoid possible penalties.

IN Elan Consultingwe understand the challenges of starting a new business and are here to offer our expert help and support. Our goal is to provide you with the necessary information and resources to make an informed choice and successfully manage your vending business in Bulgaria.

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What are the options for taxing a vending machine business?

The options for taxing a business with vending machinesin Bulgaria vary depending on the status of the entity carrying out the activity, including when placing a coffee machine in a guest room by an individual. Taxation with patent taxand the declaration of incomebefore the National Revenue Agency (NRA) are key aspects that must be taken into account.

Taxation with patent tax - what are the benefits?

The main benefit of taxing vending machines with patent tax is, ha tax is paid, which is a fixed amount, which is pays one timeand has a strictly fixed size. Usually, most often this is point three of Annex No. 4 to the Law on Local Taxes and Fees, according to which in retail trade up to 100 sq.m of net retail area of the object - the tax is determined for 1 sq.m of net retail area according to the location of the object and is from2 to 20 BGN per year per sq.m. In most cases, vending machines occupy no more than 1-2 square meters, that is, the tax burden is minimal!

According to Art. 61h.by the Local Taxes and Charges Act, any natural person, including sole proprietor, who carries out activities specified in Annex No. 4 to the Local Taxes and Fees Act (patent activities), including the operation of vending machines, provided that:

  • Turnoverfor the previous year does not exceed BGN 50,000
  • The face not registered under the VAT Act, except in specific cases under Art. 97a, Art. 99, and Art. 100, para. 2 of the GDPR.

It is important to note that the taxation of patent tax does not excludethe obligation to submit annual tax return.

Important!Taxation withpatent tax is an alternative type taxation from standard taxation, in which a fixed annual amount of tax is paid INSTEAD AND UNLIKE standard taxation in which expenses are subtracted from the income and the balance (tax base) is multiplied by the tax rate (10% for companies under the Corporate Income Tax Act) and 15% for Sole proprietors. If you are wondering “Which is better for starting a vending machine business - to register an ET or register a company, we recommend that you contact us to make the calculation!

It is important to note that regardless of the chosen tax regime, it is mandatory every act of sale, effected by vending machine, to be registered and reportedthrough a fiscal device. This requirement ensures transparency and proper taxation of income received. Fiscal devices must have the technical ability to establish a remote connection with the NRA, which facilitates the tax reporting process.

Finally, in addition to taxation, vending machine business owners must also take into account other regulatory requirements, such as the registration of commercial activity and the need to comply with regulations related to the location and type of goods sold. Specific products, such as medicines or food products, require additional permits and compliance with sanitary and health standards.

For food products, for example, registration or approval by the Bulgarian Food Safety Agency (BAFSA) may be required, in compliance with hygiene and food safety standards. If the vending machine offers medicinal products, this requires the obtaining of specialized authorizations from the Executive Agency for Medicines.

Vending business owners should also be aware of the requirements for fiscal reporting. As mentioned, all sales must be accounted for through fiscal devices, including self-service vending machines. This makes it easier to track sales and ensures accurate and transparent taxation.

From the point of view of insurance contributions, operators of vending machines registered as sole traders or entrepreneurs are obliged to make insurance contributions for themselves in accordance with the Social Insurance Code. This includes pension provision, health care and other social guarantees.

When can I NOT be subject to patent tax if I have a vending machine?

Taxation with patent taxis a specific tax regime in Bulgaria that allows certain categories of entrepreneurs to pay a fixed annual tax based on the type and location of their activity, instead of accounting for their real income and expenses. Although this may be advantageous for many small businesses and sole traders, there are certain conditions under which this tax regime cannot be applied.

When can I NOT be subject to patent tax if I have a vending machine?

  1. Exceeding the maximum annual turnover:According to Art. 61h of the Law on Local Taxes and Fees, if the person's turnover for the previous year Exceeds BGN 100,000, it cannot benefit from patent tax. This means that if your business is expanded and you have generated income above this limit, you must switch to general taxation, which involves filing an annual tax return and reporting all income and expenses.
  2. VAT registration:If you are registered under The Value Added Tax Act(except in specific cases, such as registration for supplies of services in the EU), you can also not be subject to patent tax. VAT registration is mandatory upon reaching a certain annual turnover (as of 2024 - BGN 100,000, and from 01.01.2025 - BGN 166 000) and implies the submission of monthly or quarterly VAT returns.
  3. Change of circumstances in the current year:According to Art. 61i of the Local Taxes and Fees Act, if in the current tax year the person's turnover exceed 100 000 BGNor if you register under the VAT, you automatically switch to taxation in the general order. This also applies to the termination of a patent activity and the launch of a new one, which leads to a total turnover above the limit.
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