Bulgaria crypto license 2026 — FSC CASP authorisation
Bulgaria runs CASP authorisation through the Financial Supervision Commission (FSC) under MiCA, transposed via amendments to the Markets in Financial Instruments Act and the AML Measures Act. The FSC applies EU-standard supervision at the EU's lowest operating cost, with a 10% corporate tax and DANS handling AML.
Sofia as the low-cost EU alternative
Bulgaria is the EU's lowest-cost operating jurisdiction. Corporate income tax is 10% — the lowest standard rate in the bloc. Labour costs in Sofia are a fraction of Western European levels, and the legal-services and accounting market is mature for financial-services work while charging materially lower fees than comparable services in Lithuania, Cyprus, or Western EU jurisdictions.
For platforms prioritising capital efficiency without trading away the EU passport, Bulgaria is a credible alternative to Lithuania and Cyprus. The FSC applies professional EU-standard supervision; the cost advantage is in operating costs, not in regulatory leniency. That combination — a serious supervisor plus a low operating cost — is unusual on the EU CASP map.
The supervisory architecture
Bulgaria built its MiCA implementation around the FSC as the primary CASP supervisor. Amendments to the Markets in Financial Instruments Act and the AML Measures Act assigned the FSC CASP authorisation under MiCA Article 63, prudential supervision under Article 67, conduct supervision under Articles 66-73, and consumer-protection and marketing-communications oversight.
The DANS Financial Intelligence Directorate retained AML supervisory authority for crypto-asset entities and continues to receive suspicious-transaction reports, while the Bulgarian National Bank supervises credit-institution CASPs under MiCA Article 60. Bulgaria also operated a pre-MiCA crypto register through the National Revenue Agency under the 5AMLD transposition; it wound down at MiCA application with a 12-month transitional window, granting operational continuity rather than a presumption of authorisation.
What the FSC looks for
The FSC's CASP application standards reflect professional EU-norm supervision. The recurring themes are a management body sized for the planned business with documented fit-and-proper assessments, genuine substance in Bulgaria — a registered office, at least one Bulgaria-resident senior manager, and a locally staffed compliance function — and an Article 67 own-funds calculation reviewed in detail alongside a DORA-consistent ICT risk-management framework.
The AML programme has to be designed for DANS supervisory engagement, with an MLRO appointed, KYC and transaction-monitoring infrastructure in place, and STR reporting to DANS. Client-facing materials and marketing communications for Bulgaria-targeted services need to be in Bulgarian, under MiCA Article 7 with Bulgarian consumer-law overlays. The FSC has been clear that substance arrangements are tested at first supervisory contact.
Bulgaria's CASP authorisation is the licence granted by the Financial Supervision Commission (FSC) under MiCA Regulation (EU) 2023/1114 Articles 59 and 63, transposed into Bulgarian law via amendments to the Markets in Financial Instruments Act and the Measures against Money Laundering Act, to crypto-asset service providers established in Bulgaria.
Fast facts
| Parameter | Value |
|---|---|
| Regulator | Financial Supervision Commission (FSC, Комисия за финансов надзор), Sofia |
| Legal basis | MiCA Regulation (EU) 2023/1114 + amendments to the Markets in Financial Instruments Act and AML Measures Act |
| Initial capital | €50,000 (Class 1) — €150,000 (Class 3), MiCA Annex IV |
| AML supervisor | State Agency for National Security (DANS), Financial Intelligence Directorate — receives STRs and supervises AML for crypto-asset entities |
| Statutory clock | Five months from complete file to decision under MiCA Article 63 |
| Corporate income tax | 10% flat — the lowest standard corporate-income-tax rate in the EU |
| Application language | Bulgarian required for the formal application; English working translations accepted for supporting documentation |
Top counsel for Bulgaria CASP work
Firms below are ranked according to the published CLPAI methodology. Featured selections cover firms with documented Bulgaria engagement, regardless of where they are headquartered.
Frequently asked questions about Bulgaria CASP authorisation
Who supervises CASPs in Bulgaria under MiCA?
The Financial Supervision Commission (FSC) is the national competent authority for CASP authorisation, prudential supervision, and conduct supervision. The DANS Financial Intelligence Directorate supervises AML and receives STRs.
How long does FSC CASP authorisation take?
Five to eight months end-to-end for a clean first-time file. The FSC's substantive review tracks the EU median, with practical supervisor engagement that favours well-prepared applicants.
What makes Bulgaria attractive for a MiCA passport-hub strategy?
The lowest operating costs in the EU — 10% corporate income tax, low compliance overhead, an English-friendly legal market, and established crypto-friendly banking. For capital-efficient pan-EU operations, the cost advantage is material.
Is the FSC a serious supervisor or a light-touch one?
Serious. The FSC applies professional EU-standard CASP supervision and engages substantively with applicants. Bulgaria's cost advantage comes from operating costs, not from regulatory leniency.
Pitfalls and nuances in Bulgaria
1 Reading Bulgaria's low cost as a low compliance standard
The FSC applies professional CASP supervision aligned with EU norms. Governance, ICT, AML, prudential calculations — all assessed against substantive standards. Applicants who expect a paper-only application file face information requests on substantive matters. The cost advantage of Bulgaria is in operating costs, not in regulatory leniency.
2 Underestimating Bulgarian-language file requirements
The FSC requires the formal application in Bulgarian. Articles of association, internal policies, AML manual, ICT framework — all need Bulgarian translations. The Bulgarian legal-translation market is mature for financial services, but lead times for substantial files run 5-7 weeks.
3 Treating the NRA virtual-currency register as a head-start
Bulgarian VASPs on the pre-MiCA NRA register were subject to AML-focused obligations under 5AMLD. The register was not a substantive licence. CASP authorisation file requirements applied in full to transitioning entities — the register granted operational continuity, not authorisation.
4 Overlooking DANS AML supervisory engagement
The DANS Financial Intelligence Directorate is a substantive supervisor with direct engagement on AML compliance. CASPs operating in Bulgaria engage with DANS on STR reporting, compliance reviews, and AML programme assessments. The AML workstream is real even where the FSC is the authorisation counterparty.
Regulator and primary sources
The supervisor of CASP authorisations in Bulgaria is Financial Supervision Commission (FSC, Комисия за финансов надзор). The legal basis is MiCA Regulation (EU) 2023/1114, transposed in Bulgaria via amendments to the Markets in Financial Instruments Act and AML Measures Act. Visit www.fsc.bg/en/markets-in-crypto-assets-regulation-mica for the regulator's official guidance, application forms, and supervisory expectations.