Ordinance Н-18 and СУПТО for Restaurants: A Plain Guide
If you run a restaurant in Bulgaria you will hear about Ordinance Н-18 and СУПТО (sales management software) sooner or later. This guide explains in plain language what that software is, how it relates to the fiscal device, and what online ordering, QR menus and a self-service kiosk do and do not change. It is an orientation, not advice: your accountant or НАП (the National Revenue Agency) gives the answers for your venue.
In short
- The fiscal device (ФУ) prints the fiscal receipt. СУПТО is the software that manages sales and commands the ФУ.
- In the VAT Act text we read, a person obliged to issue fiscal receipts “may choose” to use software from the НАП list (art. 118, para. 18). If you choose, the rules are strict.
- Annex 29 requires the software to produce a unique sale number (УНП) that appears on the fiscal receipt. A closed sale is not deleted, it is reversed (storno).
- A common setup for online orders: every order and payment is registered immediately in the venue’s till software, which alone controls the fiscal device.
- This is not legal advice. Check with your accountant or НАП before you change anything.
The basic terms: ФУ, fiscal receipt, УНП, СУПТО, storno
The VAT Act requires every person to register and report sales in a retail site by issuing a fiscal receipt from a fiscal device, or a system receipt from an integrated automated system (VAT Act, art. 118, para. 1). The details sit in Ordinance No. Н-18, whose full title also covers the requirements for sales management software.
Fiscal device (ФУ)Hardware
A cash register or fiscal printer with fiscal memory. It prints the fiscal receipt and sends data to НАП.
Fiscal receiptDocument
The slip the guest gets when paying in cash or by card. It is issued by the ФУ.
СУПТОSoftware
Sales management software: the till program that opens bills and commands the ФУ.
УНПNumber
Unique sale number. The СУПТО generates it and it is printed on the fiscal receipt.
StornoCorrection
A reversing entry for a closed sale. The data is kept, never erased.
НАП listRegister
A public list of software whose makers declared compliance with Н-18 (VAT Act, art. 118, para. 16).
An important distinction: the ФУ is a device, the СУПТО is a program. Most venues today have both: a program on the till tablet or computer that writes the bills, and a printer that makes them fiscal.
Is СУПТО mandatory? What the text says
This is the most common question, and we have to be careful. In the consolidated VAT Act text we opened, a person who must issue a fiscal receipt and wishes to use sales management software “may choose” software from the para. 16 list (art. 118, para. 18). If they chose it for a site, they must use “only that software” there.
НАП describes the same on its submission page: it concerns “persons who have chosen to use” such software, and the information is submitted for each site separately. In the latest VAT Act text we read (amended up to State Gazette no. 69 of 2026) the wording is still “may choose”. A move to a mandatory regime has been discussed, but we did not find it in the text we read.
- 2018
The list rules and Annex 29
The VAT Act gets art. 118, paras. 14–16 (SG 24/2018): makers may declare compliance and НАП keeps a public list. Annex 29 is new (SG 80/2018).
- 12.12.2020
The “by choice” regime
Art. 118, para. 18 gets its current form (SG 104/2020): the person may choose software from the list.
- 26.02.2021
Changes to Н-18
New wording for the choice and filing procedure (SG 17/2021). НАП: those who had already filed under Annex 32 before this date are treated as having chosen СУПТО.
- 01.01.2026
Euro in Annex 29
Amounts in the software’s reports are shown in euro (SG 42/2025).
- 22.10.2026
As of this article
The VAT Act text we opened includes amendments up to SG 69/2026 and still says “may choose”. Laws change: check the current text.
What “every order is a sale” means
Annex 29 to Н-18 holds the requirements for the software. Several of them explain why online orders are not a “separate world”. Once the information about a sale enters the software (point 9.1: when an item is entered in the screen form or saved to the database), the software generates the УНП (point 9). When a payment that needs a fiscal receipt is entered, the software sends a command to the ФУ and the УНП is printed on the receipt (point 10).
The practical takeaway: if an order (from the till, a QR menu, a kiosk or a website) is treated as a sale, it must go through the same controlled path. The УНП is the shape of that control: numbers run upward without gaps and each starts with a ФУ number. Cancelled (unclosed) sales are stored with full detail (point 12), and closed ones are reversed, not deleted (point 13).
These are requirements for the software, not for you as a restaurateur. You pick software whose maker has declared compliance and use it as intended. Do not add external modules without the maker’s authorisation (Н-18, art. 52з, para. 5).
Does this concern me? A decision tree
The chart below does not hand you a verdict, it gives an order of questions. Every path ends with a conversation with your accountant or НАП, because the answer depends on your exact venue, software and payment methods.
If you cannot answer question 2, start there: ask your till vendor whether the software is on the НАП public list and who filed the information for your site.
Online orders, QR menus and kiosks: what changes
A QR menu used only for browsing dishes and allergens is not a sale, so it changes nothing in your fiscal routine. It starts to matter when guests order through it: own online ordering, table orders or a self-service kiosk. Then every order is a potential sale.
Н-18 has a concrete provision here: when a person also sells through an e-shop, orders from the shop may be imported into the sales management software in use; the import covers all new and changed customer orders and follows the requirements of Annex 42 (art. 52з, para. 11). In plain terms, website orders may flow into the till software by the route the ordinance provides.
A common setup (not legal advice)
- #01
The guest orders
Through a QR menu, website, phone or kiosk.
- #02
The order enters the till at once
Through a bridge (integration) to the venue’s till software. There it gets its own number.
- #03
Payment is entered in the same software
Cash at the counter, card at the terminal or online, as you choose.
- #04
The till software commands the ФУ
Only it controls the fiscal device and prints the receipt. Menuto does not issue fiscal receipts.
- #05
The kitchen screen gets the order
Everything else (screen, pickup number) works on an order that is already registered.
E-shop: Annex 33 and the card-only regime
A second topic often mixed up with СУПТО is the e-shop. Under Н-18 a person selling through an e-shop (own, rented or third-party domain) files information before starting, per Annex 33, and within 7 days of any change (art. 52м, paras. 1 and 3). Menuto has a helper for this in its settings (it prepares the data, the filing is yours).
In addition, art. 3, para. 17 allows e-shops with remote card payment to report sales with a sale registration document instead of a fiscal receipt, under conditions. These include software under art. 52с (it generates a unique number for every order and meets at least points 2, 3 and 7 of Annex 29) and a monthly audit file by the 15th of the following month (art. 52т, para. 2). If you take cash on pickup, this regime as written does not cover those sales.
| - | СУПТО (sales software) | E-shop (Annex 33) |
|---|---|---|
| What it is for | Software that manages sales and the ФУ at the site | Sales through a website or online platform |
| What is filed | Annex 32 information, if you choose СУПТО | Annex 33 information before the first sale |
| Deadline for changes | 7 days (НАП) | 7 days (art. 52м, para. 3) |
| Filed with | Qualified e-signature, НАП e-services portal | Qualified e-signature, НАП e-services portal |
| Optional? | Yes, under art. 118(18) VAT Act | No: filed for online sales by a person under art. 3 |
What to do: questions for your accountant
You do not need to read the whole ordinance. You need to know what to ask and to write down the answers. Here is a list for the meeting with your accountant or a call to НАП.
Questions before you launch online orders or a kiosk
- Is my till software on the НАП public list and which version?
- Was Annex 32 information filed for the site, and when?
- Do online orders and payments reach the till software immediately?
- Who issues the fiscal receipt for kiosk or online payments, and at what moment?
- Was Annex 33 information filed for my website?
- What happens with storno and refunds for an online order?
- What do I do if the connection to the ФУ drops during a shift?
Total7 items
Frequently asked questions about Н-18 and СУПТО
What is СУПТО?
Sales management software at a retail site: the program that opens bills, takes payments and commands the fiscal device. НАП keeps a public list of software whose makers declared compliance with Н-18 (VAT Act, art. 118, para. 16).
Do I have to use СУПТО from the НАП list?
In the VAT Act text we read, a person “may choose” such software (art. 118, para. 18). If you choose, you file Annex 32 information and use only that software at the site. The law changes, so check the current position with НАП or your accountant.
What is the УНП and where do I see it?
The unique sale number. The software generates it when the information about a sale enters it, and it is printed on the fiscal receipt. It consists of the ФУ number, the operator code and a running sale number (Annex 29, point 9).
What is storno, and can I delete a sale?
Storno is a reversing entry for a closed sale. Annex 29 requires that the software has no function to delete such records and that it keeps the reversed data (point 13). How a refund is done in practice, ask your till vendor.
Do I need to register my website with НАП if I take online orders?
Under art. 52м of Н-18 a person selling through an e-shop files Annex 33 information before starting. Whether your case falls here, confirm with your accountant.
Does a QR menu change my fiscal routine?
A menu for browsing is not a sale. When guests order and pay through it, the order is a potential sale and should enter the same controlled path as other sales. A common setup is that the order enters the venue’s till software immediately.
Does Menuto issue fiscal receipts?
No. Menuto is a menu and ordering platform; the fiscal receipt is issued by the venue’s fiscal device, managed by your till software. Menuto can pass orders to it through a bridge (Menuto Handler) that is set up individually.
This article is for information only and is not legal or tax advice.
Sources
- НАП: Подаване на информация за използван софтуер за управление на продажбите (СУПТО)
- НАП: Информация за потребителите на СУПТО
- Наредба № Н-18 от 13.12.2006 г., консолидиран текст (lex.bg): чл. 3, чл. 52з, чл. 52м, чл. 52с, чл. 52т, Приложение № 29, Приложение № 33
- Закон за данъка върху добавената стойност, консолидиран текст (lex.bg): чл. 118
- Министерство на финансите за мярката за СУПТО в проекта на бюджет 2026 (отразено от Фокус)