Dear BNB, I Have Shares at Interactive Brokers

When you file Form SPB-8 (and why your company will be writing to the BNB every month). Up to date as of 5 October 2026.

Since 1 January 2026 the lev has lived only in coin collectors’ albums, and one of my favourite thresholds has finally been rounded off: EUR 25,000. We are talking about reporting to the Bulgarian National Bank (BNB).

One clarification before anyone panics: the BNB is not the National Revenue Agency (NRA). It does not want tax. It wants statistics. Bulgaria’s balance of payments needs to reflect your seven Nvidia shares too. The BNB is not reaching into your pocket, just peeking into it.

The report costs nothing, unless you forget it. Then it starts costing. More on that below.

A note on names: the forms are officially called СПБ-1, СПБ-2 and so on. Below they are written as SPB-1, SPB-2, etc.

The legal basis we stand on:

• Currency Act (CA): Art. 7(5); Art. 10(1) and (2); Art. 12(1); Art. 19.
• BNB Ordinance No. 27 of 13 March 2014 on balance of payments, international investment position and securities statistics, last amended in State Gazette No. 30 of 2026, in force from 1 April 2026.
• The Guidelines to Ordinance No. 27, in force from 1 April 2026. They contain the form templates and the rules for filling them in.

1. In short: an individual with Interactive Brokers

• Opening the brokerage account is not declared. The 15-day deadline in Art. 7(5) CA and Art. 6(1) of the Ordinance applies to legal entities and sole traders. You are a free spirit.
• You file an annual Form SPB-8 by 31 March of the following year (Art. 10(2) CA; Art. 13(1) of the Ordinance) if, as at 31 December, at least one of the following is true:
  • your assets are EUR 25,000 or more (Art. 13(2)(1)). Three things count: securities bought without a Bulgarian investment intermediary; balances on accounts abroad; claims on financial loans you have granted to foreign persons;
  • your liabilities on financial loans to foreign persons are EUR 25,000 or more (Art. 13(2)(2)).
• For 2026, the report is due by 31 March 2027.

💡 About 2025
The report for 2025 (due by 31 March 2026) still used the old threshold of BGN 50,000. The new EUR 25,000 threshold applies to reporting periods from 1 January 2026 (§ 3 of the Guidelines).

1.1. What counts and what doesn’t

What matters is the value as at 31 December. What does not matter:

• how much you deposited during the year;
• the peak your portfolio reached in November (feel free to remember it fondly);
• your profit;
• the value on the day you file.

Foreign currencies are converted into euro at the market rate at the end of the period (Art. 5(11) of the Guidelines). The Currency Act states that for statistical purposes the euro reference rates published by the BNB are used (Art. 12(1) CA). So take the rate for 31 December from the BNB website.

Securities are valued at market value or close to it, as the Guidelines recommend (Art. 5(13)). You need this value to check whether you have reached the threshold.

1.2. A pedantic difference for exactly EUR 25,000.00

The Currency Act says a report is due if the total “exceeds EUR 25,000” (Art. 10(2) CA). The Ordinance and the Guidelines say “equal to or exceeding” (Art. 13(2) of the Ordinance).

If at midnight on 31 December your portfolio is worth exactly EUR 25,000.00, first: congratulations on your precision. Second: file the report. You will avoid an argument nobody wants to have.

1.3. Assets and liabilities are not netted

The two thresholds are separate. EUR 30,000 in shares and a EUR 20,000 margin loan do not make “a net EUR 10,000, so I file nothing”. You file because of the EUR 30,000 in assets.

🧮 Example
As at 31 December you hold shares and ETFs at Interactive Brokers worth EUR 22,000, free cash at the broker of EUR 4,000 and an account with a German bank holding EUR 3,000.

Total: EUR 29,000. That is above the threshold, so SPB-8 by 31 March.

One “but” about cash at the broker. Check your agreement to see what it actually is: a client cash account with the broker, a deposit with a specific bank, a claim against the broker, or part of a cash sweep programme. The IBAN you use to send money to Interactive Brokers usually belongs to the broker and is not your own bank account.

2. What actually goes into SPB-8

The form is simple once you know what it is asking. Here is what people get wrong most often.

Personal details. Name and personal ID number (EGN/LNCh). Address, phone and email are filled in only at your first registration with the BNB or when they change.

Four rows of claims and liabilities:

Row	What it is	What you fill in
01	Financial loans granted	maturity, country, currency, amount
02	Financial loans received (e.g. a margin loan, if the agreement makes it a loan)	maturity, country, currency, amount
03	Accounts opened abroad	maturity, country, currency, amount
04	Securities acquired	ISIN and quantity

For rows 01–03:

• Maturity: code L (over one year, including open-ended) or S (up to and including one year).
• Country: that of the foreign person. For accounts, it is the country of the bank or institution where the account is held.
• Currency: the original currency, not euro.
• Amount: in thousands of currency units, rounded to a whole number, at the beginning and at the end of the year. Several accounts in the same currency with the same maturity may go on one row.

For row 04 (securities):

• One ISIN per row. The principle is “security by security”.
• Country of the issuer, not of the broker and not of the exchange. Apple shares are from the US. Many ETFs whose ISIN starts with IE are Irish, even though they track the S&P 500.
• Quantity, not value: the number of units for shares, ETFs and other equity instruments; the nominal amount for bonds. It is given in the original currency of the issue, at the beginning and at the end of the year.

⚠️ The most common mistake
Row 04 takes the number of units, not the market value in euro. You need the market value only to check whether you have reached EUR 25,000.

Not included in the form: derivatives (options, futures, CFDs) and repo transactions.

The signature. At the bottom of the form you declare that you are liable under Art. 313 of the Criminal Code for false information. The BNB is not joking, although I am trying to.

Documents worth keeping (they are not attached to the report, but they back up your numbers):

• the broker’s annual statement as at 31 December;
• the Positions/Portfolio and Cash reports;
• a list of instruments with ISIN and quantity;
• the market value per instrument as at 31 December;
• a document showing which entity of the broker is party to your agreement;
• annual statements from foreign banks and payment institutions.

2.1. How to file

• Electronically through the BNB’s ISIS portal, with a qualified electronic signature (QES);
• on paper at the BNB registry or by post (1 Knyaz Alexander I Sq., Sofia 1000, Statistics Directorate);
• in person or through a proxy (Art. 13(3) of the Ordinance).

With more than five records, the report can only be filed electronically (Art. 14(5) of the Ordinance). Each ISIN is a separate record. Six ETFs in your portfolio and you are officially a person with a QES. 🙂

3. Companies (legal entities and sole traders): no entry threshold here

If you invest through a company, the BNB wants to get to know you from the very first trade.

3.1. Securities through a foreign broker

SPB-10: a one-off declaration, no minimum threshold

• Filed on the first purchase of securities without a Bulgarian investment intermediary (Art. 7(5) CA; Art. 6(1)(5) of the Ordinance).
• Deadline. The Currency Act says 15 days from the transaction. The Ordinance says 15 working days. My advice: count 15 calendar days and sleep well.
• Filed once. Later purchases do not need a new declaration; they go into the periodic reports.
• What it contains: the company’s name and UIC; type of investment; how it was acquired (code BOUGHT for a market purchase, OTHER for another event); the name and country of the foreign intermediary; the date from which you start investing without a local intermediary; details of the declarant.

SPB-10A: monthly report on securities

• Legal basis: Art. 9(11)(1) of the Ordinance.
• Deadline: by the end of the 7th working day of the following month (Art. 12(7)).
• Reported per ISIN: opening and closing positions, purchases, sales, other changes, plus dividends and interest received.
• Filed electronically only (Art. 14(2)).
• Filed for as long as there are securities in the portfolio. Yes, every month. Yes, in August too.

SPB-10B: quarterly report on foreign equity funds

• Legal basis: Art. 9(11)(2) of the Ordinance.
• Deadline: within 55 calendar days after the end of the quarter (Art. 12(6)).

Exception
Companies in the “financial corporations” sector do not file SPB-10 (Art. 6(5)). They report their securities under a separate regime (Art. 9(9)).

3.2. An account with a foreign bank, payment institution or e-money institution

SPB-2: on opening the account, no threshold

• Legal basis: Art. 7(5) CA; Art. 6(1)(2) of the Ordinance.
• Deadline: 15 working days from opening (here too the Act says 15 days, so the same advice applies).
• It also covers accounts with a virtual bank, a payment institution, an e-money institution, and cash-pool/treasury accounts.
• Changes or closure: a corrective SPB-2 or a change request in ISIS within 15 working days (Art. 8(1) and (2)).

The periodic reports after that:

• SPB-5 for accounts under a cash management agreement (cash pool). Filed quarterly, whatever the balance (Art. 9(1)(2)), by the 20th of the month after the quarter. For the fourth quarter the deadline is 25 January (Art. 12(2) and (3)).
• SPB-5A for all other accounts. Filed once a year if the total balance at year-end is EUR 25,000 or more (Art. 9(4)(3)), by 25 January (Art. 12(4)).

4. Cheat sheet: broker vs. bank

Individual

Situation	Form	Threshold	Deadline
Securities through a foreign broker	SPB-8	total assets ≥ €25,000 at 31 Dec	by 31 March
Account with a foreign bank	SPB-8	counts towards the same total threshold	by 31 March
Margin or other loan from a foreign person	SPB-8	liabilities ≥ €25,000 (separate threshold)	by 31 March
Just opening an account with a broker or bank	nothing	—	—

Company

Situation	Initially	Threshold	Afterwards
Securities through a foreign broker	SPB-10 within 15 working days	none	SPB-10A monthly / SPB-10B quarterly
Account with a foreign bank or payment institution	SPB-2 within 15 working days	none	SPB-5A annually if ≥ €25,000
Cash pool / cash management	SPB-2 within 15 working days	none	SPB-5 quarterly, whatever the balance
Transfer to the broker’s IBAN (the account is the broker’s)	usually not your account	—	check the agreement

The last row is my practical conclusion, not an explicit rule. What decides it is whether your company is the holder of the account or just transfers money to the broker’s account.

5. More thresholds for companies, so there are no surprises

• Financial loans from/to foreign persons of EUR 25,000 or more: SPB-1 within 15 working days (Art. 6(1)(1)).
  • from EUR 25,000 to EUR 250,000: then SPB-4A annually by 25 January (Art. 9(4)(1); Art. 12(4));
  • EUR 250,000 or more: SPB-4 quarterly, by the 20th after the quarter and by 25 January for the fourth (Art. 9(1)(1); Art. 12(2) and (3)).
• Trade receivables from foreign persons of EUR 100,000 or more: SPB-6A quarterly (Art. 9(1)(3)).
• Trade payables to foreign persons of EUR 100,000 or more: SPB-6B quarterly (Art. 9(1)(4)).
• Direct investment abroad: SPB-3 within 15 working days (Art. 6(1)(3)). Then SPB-7 quarterly, or SPB-7B annually for real estate (Art. 10 of the Ordinance).
• Services, fees and unrequited payments (SPB-11) and foreign direct investment in your company (SPB-12): filed only if the BNB writes to you (Art. 9(1)(5) and (6)). No letter, no worries.

6. Interactive Brokers: three traps

1. “Interactive Brokers” is not enough. The group has several entities in different countries. Many EU clients, for example, are with Interactive Brokers Ireland Limited, but check your own agreement. You need the exact entity from the Client Agreement, the Account Confirmation or the annual statement.

• In the company’s SPB-10, you enter the name and country of that entity.
• In an individual’s SPB-8, the country is that of the issuer for securities and that of the institution holding the account for cash balances.

2. Margin: is it a loan?

Short answer: almost always yes, if you have actually borrowed money. Ordinance No. 27 and the Guidelines do not define “financial loan”, and the word “margin” appears nowhere in them. So this is an interpretation, but a well-founded one. The broker gives you money you owe, you pay interest, you repay on demand, and your shares are the collateral. That is a classic credit line. And the BNB’s forms know exactly this kind of loan: the loan types in SPB-1 include “Revolving loan (credit line)” and “Overdraft”.

How negative cash goes into SPB-8:

• row 02 “Financial loans received”;
• maturity S, because it is repayable on demand;
• country: that of the broker’s entity that lends to you (from the agreement);
• currency: that of the negative balance, e.g. USD;
• amount: the balance at the beginning and at the end of the year, in thousands, rounded;
• a separate threshold: liabilities of EUR 25,000 or more as at 31 December (Art. 13(2)(2) of the Ordinance).

What is not a loan:

• Unused buying power. If nothing has been borrowed, nothing is reported. Only the actual negative balance at 31 December counts.
• Margin as collateral for futures and options. That is a guarantee, not a loan, and derivatives are outside SPB-8 altogether.
• Short selling. There you have borrowed shares, not money, and the form has no row for a negative securities position. A grey zone worth clarifying with the BNB.

💱 The currency trap
Say you have −USD 30,000 and +EUR 40,000. Interactive Brokers charges you interest on the dollars even though you are “net” positive. For the BNB the balances are not netted. The dollars are a liability, tested against the EUR 25,000 threshold. The euro is an asset and counts towards your total assets. So you may have to file SPB-8 on both grounds. And never deduct the loan from the value of your shares.

For a company, a margin loan of EUR 25,000 or more means a separate SPB-1 declaration within 15 working days of the agreement (Art. 6(1)(1) of the Ordinance). After that comes SPB-4A annually, or SPB-4 quarterly if the loan is EUR 250,000 or more. What is unclear is the “amount” of a loan that keeps changing: the agreed limit or the amount actually drawn. That is a question for the BNB.

Since there is no explicit rule, the safest course when in doubt is to ask the BNB’s Statistics Directorate for a written opinion. Its phone numbers are on the SPB-8 form itself: +359 2 9145 1071 and +359 2 9145 1523. A written answer protects you if someone later reads the rules differently.

3. ETF vs. private fund.

• For an individual, both usually go into row 04 as securities with an ISIN.
• For a company, listed shares, bonds and ETFs go into SPB-10A, and foreign equity funds into SPB-10B.

And if you trade actively through Interactive Brokers, also check when that leads to VAT registration. That one is about the NRA, not statistics.

7. What if I forget?

The BNB does not charge interest, but it does issue penalty notices. The sanctions are under Art. 19 CA:

Who	First violation	Repeat violation (Art. 19(7))
Individual (Art. 19(1))	fine of BGN 200–1,000 (≈ €102.26–511.29)	BGN 500–2,500 (≈ €255.65–1,278.23)
Company or sole trader (Art. 19(2))	pecuniary sanction of BGN 2,000–10,000 (≈ €1,022.58–5,112.92)	BGN 4,000–20,000 (≈ €2,045.17–10,225.84)

The Act still states the amounts in leva. They apply converted at the fixed rate of 1.95583 (Art. 12 and § 5(1) of the Transitional and Final Provisions of the Act on the Introduction of the Euro in the Republic of Bulgaria).

Violations are established by BNB officials, and penalty decrees are issued by the BNB Governor or a person authorised by the Governor (Art. 19(8) CA).

8. The practical takeaway

• Investing personally? On 31 December, look at your portfolio, not just the Christmas tree. At EUR 25,000 or more, file SPB-8 by 31 March. For 2026 the deadline is 31 March 2027.
• Investing through a company? Don’t wait for EUR 25,000. On the first purchase through a foreign broker, file SPB-10 (count 15 calendar days). Then SPB-10A every month. If the company also has its own account with a foreign bank or payment institution, file a separate SPB-2.
• Before you fill in anything for Interactive Brokers, check three things: which entity you contracted with, what the annual statement as at 31 December says, and how the cash or margin is classified. These three things most often change the form and the numbers.

If after all this you are thinking “no thanks, I’d rather someone else dealt with ISIS”, book a meeting and we’ll sort it out together. 😉

This article is general information as of 5 October 2026 and is not a substitute for individual advice. That is especially true for margin accounts, cash held at the broker, or different contracting entities within the Interactive Brokers group.

Legislation and sources

• Currency Act: Art. 7(5); Art. 10(1) and (2); Art. 12(1); Art. 19.
• BNB – Ordinance No. 27 of the BNB of 13 March 2014 (opens in a new tab) (in Bulgarian): Arts. 6, 8, 9, 10, 12, 13 and 14 (last amended State Gazette No. 30/2026, in force from 1 April 2026)
• BNB – Guidelines to Ordinance No. 27 (opens in a new tab) (in Bulgarian), in force from 1 April 2026: Art. 5(11) and (13); § 3; filling-in instructions for SPB-2, SPB-5, SPB-5A, SPB-8, SPB-10, SPB-10A and SPB-10B
• BNB – FAQ on Ordinance No. 27 (opens in a new tab) (in Bulgarian)
• BNB – Act on the Introduction of the Euro in the Republic of Bulgaria (opens in a new tab) (in Bulgarian): Art. 12; § 5(1) of the Transitional and Final Provisions
• Criminal Code: Art. 313