Crypto-assets licensing in Bulgaria
- адв. Светослав Григоров
- Jul 9
- 5 min read
Introduction
On July 4, 2025, the Law on Crypto-Asset Markets came into effect in Bulgaria. This law introduces a regulatory framework for obtaining crypto-assets licensing in Bulgaria in accordance with Regulation (EU) 2023/1114, known as MiCA (Markets in Crypto-Assets Regulation). It regulates the public offering of crypto-assets, their admission to trading on platforms, the licensing and state supervision of issuers and providers of services related to crypto-assets. The law is crucial for businesses, particularly companies in the financial and technological sectors, as it establishes clear rules and encourages innovation while protecting clients and the market.
Main Provisions of the Law
Scope and Objectives
The law governs:
The public offering of crypto-assets.
The admission to trading on crypto-asset platforms.
The licensing of crypto-asset service providers (CASPs) and issuers of asset-referenced tokens.
State supervision of these activities.
It does not apply to issuers of electronic money tokens, except for the requirements provided in Part VI of Regulation (EU) 2023/1114.
Objectives of the law:
Protection of the interests of crypto-asset holders and clients of service providers.
Ensuring a transparent and efficient crypto-asset market.
Maintaining stability, transparency, and trust in the market.
Supporting innovation and fair competition.
Supervisory Authority
The Financial Supervision Commission (FSC) is the primary regulatory body responsible for compliance with the law, Regulation (EU) 2023/1114, and related implementing acts (Article 3). The FSC:
Issues, refuses, or revokes licenses.
Cooperates with the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) in accordance with Article 96 of Regulation (EU) 2023/1114.
Specific powers are exercised by the Deputy Chairman of the FSC, who heads the "Investment Activity Supervision" department.
Crypto-assets licensing in Bulgaria
Companies offering crypto-assets or services related to crypto-assets must obtain a license from the FSC. The law provides for different classes of licenses for crypto-asset service providers (CASPs):
License Type | Issuance Fee (BGN) | Annual Fee (BGN) |
Class 1 | 5,000 | 2,000 |
Class 2 | 10,000 | 4,000 |
Class 3 | 30,000 | 20,000 |
Expansion from Class 1 to Class 2 | 8,000 | - |
Expansion from Class 2 to Class 3 | 25,000 | - |
License Revocation (Class 1) | 3,000 | - |
License Revocation (Class 2) | 5,000 | - |
License Revocation (Class 3) | 10,000 | - |
For issuers of asset-referenced tokens:
Fee for public offering or admission to trading: 25,000 BGN
Approval of an amended white paper: 2,000 BGN
Review of a recovery plan: 15,000 BGN
Annual fee: 3,000 BGN
Licensed entities or those under Article 14, paragraph 3 must register their activity in the Commercial Register within 7 days, providing the license or confirmation from the FSC. The fee for changes or deletion from the register is 200 BGN.
Credit institutions offering asset-referenced tokens must obtain approval of the white paper from the FSC and confirmation of the completeness of the notification in accordance with Regulation (EU) 2023/1114.
Language Requirements
The white paper for crypto-assets offered in Bulgaria, including the summary, marketing communications, and rules of trading platforms, must be in Bulgarian or in a language commonly used in international finance.
Sanctions for Violations
Violations of the law and Regulation (EU) 2023/1114 can lead to significant sanctions:
Individuals: Fines ranging from 1,400 to 1,400,000 BGN.
Legal entities: Fines up to 12.5% of annual turnover, depending on the severity of the violation.
Additional financial penalties for financial institutions: For example, 20,000 to 2,000,000 BGN or 10% of annual turnover for administrators of critical benchmark interest rates.
Sanctions are determined considering the circumstances specified in Article 51, paragraph 2 of Regulation (EU) 2022/2554 and Article 112, paragraph 1 of Regulation (EU) 2023/1114.
Entry into Force
The law came into effect on July 4, 2025, with some provisions applying from July 1, 2026, and others related to the adoption of the euro in Bulgaria, whose entry into force depends on a decision by the Council of the EU.
Impact on Business
Crypto-Asset Service Providers
Companies providing services such as custody, management of trading platforms, exchange of crypto-assets for fiat currencies or other crypto-assets, order execution, consulting, or management of crypto-asset portfolios must obtain a license from the FSC. The different classes of licenses likely reflect varying levels of complexity or risk of services, with Class 3 implying the highest requirements and fees.
Issuers of Crypto-Assets
Issuers of asset-referenced tokens must obtain approval from the FSC for public offerings or admission to trading. This includes submitting a white paper and complying with transparency and client protection requirements. Credit institutions have simplified requirements but still need to obtain white paper approval.
EU Passporting
One of the most significant advantages of the law is that licensed crypto-asset service providers can offer their services throughout the European Union through the MiCA passporting regime. This allows Bulgarian companies to access the EU market of nearly 450 million people without needing additional licensing in each member state.
Risks of Non-Compliance
Non-compliance can result in significant financial penalties and reputational damage. For example, violations such as operating without a license or failing to meet transparency requirements can lead to fines that significantly impact a company’s financial standing.
Growth Opportunities
Attracting Investments: A clear regulatory framework can increase investor confidence, particularly from international investors, potentially leading to increased investments in the Bulgarian crypto-asset market.
Innovation: The law supports innovation by providing legal certainty, which can stimulate the development of new products and services in the sector.
Cross-Border Operations: The passporting regime facilitates business expansion into other EU countries, reducing regulatory barriers.
Comparison with Other Countries
The law aligns Bulgaria with European standards established by MiCA, making it competitive within the EU. Other member states, such as Latvia, have also adopted national laws complementing MiCA, designating local supervisory authorities and fees. For example, in Latvia, supervision is carried out by Latvijas Banka, while in Bulgaria, it is by the FSC. The MiCA passporting regime allows companies licensed in Bulgaria to operate in countries like Poland or Luxembourg without additional licenses, which is a significant advantage.
How to Prepare?
Company leaders operating or planning to enter the crypto-asset market should take the following steps:
Activity Assessment: Determine if your activity falls within the scope of the law (e.g., offering crypto-assets or services like trading or custody).
Consult Experts: Engage legal and financial consultants to understand specific licensing and compliance requirements.
Apply for a License: Prepare the necessary documentation and submit an application to the FSC for the appropriate class of license.
Registration: Register your activity in the Commercial Register within 7 days of receiving the license.
Monitor Guidelines: Follow the guidelines of ESMA and EBA, as well as decisions of the FSC, to ensure full compliance.
Conclusion
The Law on Crypto-Asset Markets is an important step towards regulating the rapidly evolving crypto-asset sector in Bulgaria. It provides legal certainty, encourages innovation, and facilitates access to the EU market through passporting. Company leaders should familiarize themselves with the law’s requirements, ensure compliance, and seize growth opportunities while avoiding the risks of non-compliance. For more information, see the official text of the law and Regulation (EU) 2023/1114.
For inquiries about crypto-asset markets, please contact me via the contact page.
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