Cryptocurrency License Bulgaria

Is This the Right Fit?

May Fit
You can establish genuine Bulgarian operations and fund staff, systems and controls.

Separate Perimeter Review
Token issuance, e-money tokens (EMTs), financial instruments and existing regulated entities need distinct analysis.

Outside Ordinary CASP Permission
Banking, payment services and issuing electronic money require their applicable permissions.

Choose the Applicable Route

Eligible entities generally notify their sectoral authority under Article 60 at least 40 working days before starting, incomplete notification prevents starting. An electronic money institution (EMI) is limited to custody and transfers of its own EMTs. EMT issuance follows its separate regime.

Under Article 65, notify your home authority. It transmits the information within 10 working days. You may start upon notice of transmission or from the 15th calendar day after submission.

Regulated Crypto-Asset Services

Class 1 • €50,000 Floor

Execution, placing, transfers, receiving and transmitting orders, advice and portfolio management. Staff, resources and policies must support selected services.

Class 2 • €125,000 Floor

Adds custody and exchange for funds or other crypto-assets. Resources and controls must support custody and exchange where selected.

Class 3 • €150,000 Floor

Adds operating a trading platform. You need actual platform, technology and outsourcing resources proportionate to selected services.

Maintain financial safeguards at whichever is higher: the highest applicable class floor or one-quarter of last year’s fixed running costs (overheads). New businesses use projected overheads for their first 12 months. Recalculate annually.

Safeguards can be Common Equity Tier 1 own funds after required deductions, insurance covering the EU territories where you operate, a comparable guarantee, or a combination, meeting Article 67 conditions. They support resilience and are separate from fees and client assets. They need not all be paid-up share capital. Article 67 does not apply to Article 60 entities.

Bulgaria CASP Application Support

Gofaizen & Sherle can prepare and coordinate:

• Activity mapping, company setup and the operations program, using your ownership, management and financial information
• Governance, anti-money-laundering and counter-terrorist-financing (AML/CFT), technology, safeguarding and prudential documents. You implement working controls
• Bulgarian localization, filing and FSC responses within the engagement. Translation and third-party work depend on agreed inclusions

The regulator decides which services you may provide.

Scope and Costs

We quote for one agreed scope based on your services, operating model and preparation needed.

What We Need from You

To assess your plans and prepare the application, provide:

• Ownership, ultimate beneficial owners and sources of funds
• Management reputation, qualifications, experience and time commitment
• A three-year operations and financial program, staff, systems, outsourcing and client-asset controls
• Evidence of local substance: FSC expects a Bulgarian-resident executive fully engaged in the CASP, real local staff and some Bulgarian clients. No fixed headcount guarantees acceptance
• Bulgarian documents and bilingual declarations for foreign nationals. Electronic submission requires a qualified electronic signature

Preparation and Review Time

Preparation involves your records and operations, consultant work, translators and providers. FSC’s statutory stages are:

• Acknowledgment within 5 working days of receipt
• Completeness assessment within 25 working days of receipt
• Decision within 40 working days of a complete application
• Decision notification within 5 working days of the decision

FSC sets deadlines for missing information. A request by assessment day 20 can pause assessment for up to 20 working days, later requests do not pause it. These clocks do not guarantee a launch date.

Bulgaria Crypto Regulatory Framework

MiCA and Bulgaria’s Markets in Crypto-Assets Act govern authorization. Since August 7, 2026, Article 3(1) refers special banking/EMI cases to competent sectoral authorities. Assess Bulgarian National Bank (BNB) involvement under those rules.

Applicable layers include AML/CFT, the Digital Operational Resilience Act (DORA) for technology resilience, the Transfer of Funds Regulation (TFR) for transfer information, and the General Data Protection Regulation (GDPR).

Current Authorization Status

Duties After Authorization

Management
Maintain governance, complaints, conflicts and outsourcing controls continuously, with records.

Compliance
Monitor transactions and maintain AML/CFT and transfer-information checks and records.

Operations
Maintain client-asset controls and DORA systems, including incident records.

Finance
Maintain safeguards, review annually, and meet applicable reporting and supervisory requirements.

Risks of Unauthorized Operations

Unauthorized services, misleading legacy VASP claims, weak substance or AML/technology control failures create regulatory intervention risks.

Banking and Payment Providers

CASP authorization does not guarantee an account or grant payment/e-money permission. Each provider decides whether to accept you. Prepare for its questions with:

• Ownership and funding information
• Transaction flows and target markets
• Custody arrangements and permission evidence

Business Tax Considerations

Corporate income tax is 10% of profit after tax adjustments. The Hedqvist value-added tax (VAT) exemption covers traditional-currency/bitcoin exchange in that judgment, not all CASP services. VAT treatment, payroll, withholding, permanent establishment, transfer pricing and accounting require individual assessment.

Compare EU Home States

Common MiCA requirements include a registered office and some services in the home state, effective management in the EU and an EU-resident director. Article 65 passporting covers authorized services after notification. Host-state physical presence is unnecessary.