Bulgaria crypto license 2026 — FSC CASP authorisation
Bulgaria runs CASP authorisation through the Financial Supervision Commission (FSC) under MiCA and the Markets in Crypto-Assets Act (SG 54/2025). The FSC applies EU-standard supervision at a low operating cost, with a 10% corporate tax, the EU's second-lowest after Hungary, and DANS receiving STRs.
Last reviewed by the Crypto Law Index editorial desk
Sofia as the low-cost EU alternative
Bulgaria is one of the EU's lowest-cost operating jurisdictions. Corporate income tax is 10%, the second-lowest standard rate in the bloc after Hungary's 9%. 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 implemented MiCA through a standalone Markets in Crypto-Assets Act (SG No. 54/2025), which makes the FSC the competent authority within the meaning of MiCA Article 93 (Art 3(1)). The FSC handles CASP authorisation under Article 63, prudential supervision under Article 67, conduct supervision under Articles 66-73, and consumer-protection and marketing-communications oversight; the Bulgarian National Bank covers e-money tokens.
The DANS Financial Intelligence Directorate receives suspicious-transaction reports, and the MiCA Act amended the Measures against Money Laundering Act to add CASPs to the entities subject to sectoral AML inspections, 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. The Markets in Crypto-Assets Act let registered firms continue until 1 July 2026 (§ 3(1) of its transitional provisions); firms registered after 30 December 2024 had to apply by 8 October 2025. That gave operational continuity, never a presumption of authorisation, and the period is now over.
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 and effective management in Bulgaria, with a locally present senior manager and compliance function expected in practice — 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 should be in Bulgarian and must be fair, clear and not misleading under MiCA Article 66(2), with Bulgarian consumer-law overlays.
Bulgaria's CASP authorisation is the licence granted by the Financial Supervision Commission (FSC) under MiCA Regulation (EU) 2023/1114 Articles 59 and 63, and the Bulgarian Markets in Crypto-Assets Act (SG No. 54/2025), which designates the FSC as competent authority (Art 3(1)), 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 + Markets in Crypto-Assets Act (SG No. 54/2025, amended by SG 67/2025 and SG 25/2026) |
| 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 | 40 working days from a complete file to decision under MiCA Article 63(9); one information request can suspend it for up to 20 working days |
| Corporate income tax | 10% flat — the EU's second-lowest standard rate after Hungary's 9% |
| 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 competent authority for CASP authorisation, prudential and conduct supervision under the Markets in Crypto-Assets Act. The DANS Financial Intelligence Directorate receives STRs, and CASPs are subject to sectoral AML inspections.
How long does FSC CASP authorisation take?
Practitioners estimate five to eight months end-to-end for a clean first-time file. The statutory decision period is 40 working days from a complete file under MiCA Article 63(9).
What makes Bulgaria attractive for a MiCA passport-hub strategy?
Low operating costs: a 10% corporate income tax, the second-lowest in the EU, lower salaries and professional fees than in Western Europe, and an English-friendly legal market. 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 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 standards. Applicants who expect a paper-only application file face information requests on matters. The cost advantage of Bulgaria is in operating costs, not in regulatory leniency.
2 Underestimating Bulgarian-language file requirements
Advisers expect the formal application and core documents in Bulgarian; confirm with the FSC which annexes may be filed in English. Allow several weeks for translation of a substantial file.
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 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 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, implemented in Bulgaria by the Markets in Crypto-Assets Act (State Gazette No. 54 of 4 July 2025). Visit www.fsc.bg/en/markets-in-crypto-assets-regulation-mica for the regulator's official guidance, application forms, and supervisory expectations.
For where every EU and EEA state stands — its authority, its national act and when its transitional period ended — see the MiCA implementation tracker.