YARD Law Co. · Reviewed 19 August 2026 · YARD Law Legal Team
On 1 July 2026 the transitional regime that let roughly two hundred Bulgarian companies trade crypto-assets without a licence came to an end. What replaced it is not a lighter version of the old NRA registration. It is a full authorisation regime administered by the Financial Supervision Commission, and in its first weeks it added two further licensed providers - taking the register to four - while refusing four applications.
This article explains what the regime now requires, what it costs, and what an unlicensed provider's options actually are. For the commercial side of the work - preparing and filing an application - see our crypto and blockchain practice page.
Nothing good, and the position is stated bluntly by the regulator itself.
Under § 3(1) of the transitional provisions of the Markets in Crypto-Assets Act (ЗПКА, promulgated in ДВ issue 54 of 4 July 2025, in force 8 July 2025), persons falling under Art. 4, items 38 and 39 of the Anti-Money Laundering Measures Act who were entered in the NRA electronic public register before 30 December 2024 could continue the registered activity in Bulgaria without a licence until 1 July 2026, or until a licence under Art. 63 of Regulation (EU) 2023/1114 was granted or refused, whichever came first. Bulgaria took the maximum transitional period MiCA allows.
That register did not survive the Act. Under § 5, the NRA stopped maintaining it on the date the ЗПКА entered into force and handed the current version to the FSC, which publishes it. The register still sits on the FSC website, and it now carries a notice stating that the persons entered in it do not hold a MiCA licence and have no right to provide crypto-asset services.
Companies registered between 30 December 2024 and the entry into force of the Act were in a different position again: under § 3(2) they had three months from entry into force to file a licence application and to bring their operations into line with the Act and the Regulation.
Four companies, as at 19 August 2026, on the FSC register of licensed crypto-asset service providers:
| Company | ЕИК | Decision | Authorised services |
|---|---|---|---|
| Alaric Securities OOD (investment firm) | 201482151 | 783-ДУКА / 22.12.2025 | Custody and administration, exchange for funds, exchange for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management |
| Belayer OOD | 204792388 | 276-ДУКА / 28.04.2026 | Custody and administration, execution of orders, portfolio management |
| Altcoins BG EOOD | 205491943 | 499-ДУКА / 21.07.2026 | Custody and administration, exchange for funds, exchange for other crypto-assets, transfer services |
| Digital Assist OOD | 206079266 | 500-ДУКА / 21.07.2026 | Exchange of crypto-assets for funds |
Two of those were licensed before the deadline and two three weeks after it. In the same July sitting the FSC refused four other applications. Against a transitional register that ran to roughly two hundred entities, that is the number worth holding on to: the transition closed with a two-company licensed market, and the funnel from registration to authorisation is very narrow.
This figure moves. Check the FSC register of licensed providers, the list of providers notified into Bulgaria from other Member States, and ESMA's Union-wide register before relying on it.
The authorisation requirement in Art. 59 MiCA catches anyone providing crypto-asset services in the Union. Reverse solicitation is a narrow exemption and not a market-access strategy: active marketing into the EEA pulls a non-EU entity into scope regardless of where it is incorporated.
But not every provider needs a full FSC licence. Art. 59(1)(b) MiCA allows certain already-regulated entities to provide crypto-asset services on the basis of a notification. Under Art. 14(3) ЗПКА those persons may operate once they have filed the notification with the information required by Art. 60(7) MiCA and the FSC has confirmed it is complete. Bulgarian law spells two cases out:
This is not a technicality. The first company on the Bulgarian register is an investment firm, and the notification route is materially faster than a first-time licence. If a client already holds a Bulgarian investment-firm licence, the notification question should be asked before anyone starts drafting an Art. 62 application.
Note also who is not under the FSC. Asset-referenced tokens are licensed and supervised by the FSC under Chapter Three ЗПКА, except where the issuer is a credit institution. Electronic money tokens are different: the ЗПКА does not apply to EMT issuers at all except for Title VI of MiCA, and the Bulgarian National Bank is the competent authority for Title IV obligations of EMT issuers seated in Bulgaria, under the new Chapter Ten "a", Art. 182a of the Payment Services and Payment Systems Act. Where a credit institution is an ART issuer or a CASP, the BNB exercises the banking-supervision powers under Art. 33, Art. 34(2), (4) and (12), Art. 68(1) to (3) and Art. 69 MiCA. Getting this split wrong sends an application to the wrong regulator.
A provider must hold, at all times, safeguards at least equal to the higher of the Annex IV permanent minimum capital for its class and one quarter of the preceding year's fixed overheads, reviewed annually. The Annex IV classes are cumulative:
Where a provider holds services across classes, ESMA has confirmed the requirement is the one attaching to the highest class engaged. Several comparison sites have classes 2 and 3 the wrong way round; the trading platform is the EUR 150,000 tier.
Two points are routinely missed. First, the safeguards need not be own funds at all: Art. 67(4) permits CET1 own funds, an insurance policy covering the Union territories served, a comparable guarantee, or a combination. Where it is insurance, Art. 67(5) requires an initial term of at least a year, a cancellation notice period of at least 90 days, an authorised third-party insurer, and publication of the policy on the provider's website, with Art. 67(6) setting the risks that must be covered.
In February 2026 ESMA clarified that the fixed-overheads limb is calculated from the total of all overhead expenses, fixed and variable, under the applicable accounting framework, with only the deductions in Art. 67(3)(a) to (d) permitted, exhaustively. Applicants who modelled "fixed overheads" as rent and salaries have understated the requirement.
Members of the management body, persons who direct the business and holders of qualifying holdings must satisfy Art. 68 MiCA at all times, plus nine domestic criteria: no conviction for an intentional public-prosecution offence unless rehabilitated; no recent management role in an insolvent company with unsatisfied creditors; not bankrupt; not disqualified from a materially accountable position; outside the senior-management restrictions in Art. 124 AMLA; no management role in the last two years at a company whose licence was withdrawn by the FSC, the BNB or a foreign counterpart; no administrative penalties in the last five years for gross or systematic breaches of a long list of financial statutes and EU regulations; not removed from office under an enforcement measure; and nothing in the collected data on the person and their connected persons casting doubt on reliability, suitability or conflicts of interest.
Critically, Art. 17(3) extends these requirements to beneficial owners and to the natural persons designated to represent a legal person sitting on the management body. Diligence on the ownership chain needs to happen before filing, not during review.
Under Art. 4 ЗПКА, white papers and their summaries, marketing communications and trading-platform rules offered in Bulgaria must be produced in Bulgarian or in a language customary in international finance.
Under Art. 15(3) ЗПКА, a provider that receives a licence - or the confirmation in the notification route - must apply to the Registry Agency within 7 days to enter the activity in its subject of activity in the commercial register. The Registry Agency enters it on presentation of the licence or confirmation.
The ЗПКА inserted a dedicated tariff section into the schedule to the Financial Supervision Commission Act. As promulgated in ДВ issue 54 of 2025 the figures are in leva:
| Item | Amount as promulgated |
|---|---|
| CASP licence, class 1 | 5,000 лв. |
| CASP licence, class 2 | 10,000 лв. |
| CASP licence, class 3 | 30,000 лв. |
| Scope extension, class 1 to class 2 | 8,000 лв. |
| Scope extension, class 2 to class 3 | 25,000 лв. |
| ART licence for public offering or admission to trading | 25,000 лв. |
| Approval of an amended ART white paper | 2,000 лв. |
| Review of an ART issuer's recovery plan | 15,000 лв. |
| Annual supervisory fee, CASP class 1 / 2 / 3 | 2,000 / 4,000 / 20,000 лв. |
| Annual supervisory fee, ART issuer | 3,000 лв. |
Bulgaria adopted the euro on 1 January 2026. These are the amounts in the Act as promulgated, before redenomination. Confirm the current euro figures against the consolidated tariff before quoting them to a client; do not convert them yourself and present the result as the text of the law.
To these add the substantive costs, which dwarf the state fees: the Art. 62 application file itself, the prudential safeguards, ICT and operational resilience work under Regulation (EU) 2022/2554, AML systems and the travel-rule obligations under Regulation (EU) 2023/1113, and an EU bank account, which for most applicants is the slowest item in the project.
There is no statutory grace period, and it is worth being precise about this because a good deal of published commentary is not.
The Act contains no general permission to keep transacting in order to wind down. What it contains is the opposite. Under Art. 32(1) ЗПКА, where there are reasonable grounds to suspect that a person is providing crypto-asset services without a licence, the FSC may order immediate cessation of the activity with no end date - and Art. 32(3) expressly disapplies Art. 26 of the Administrative Procedure Code, so the person is not first invited to be heard. Under Art. 36, where no other effective means exist, the FSC may order hosting providers to block an online interface or app, order registrars to delete a domain name, and order platforms to remove accounts advertising unlicensed services; the decision operates as an order under Art. 9(1) of the Digital Services Act.
There is a transfer mechanism, but it is a supervisory power rather than a right. Art. 28(1), item 6 lets the FSC order existing contracts to be transferred to another provider where a licence has been withdrawn under Art. 64 MiCA, provided the clients and the receiving provider agree.
That leaves three realistic routes, none of which involves continuing to serve clients in the meantime:
Worth knowing for anyone assessing counterparty risk. Under Art. 13 ЗПКА, no enforcement may be levied against assets in an ART reserve for the issuer's own debts, except debts owed to holders of that token. The point is reinforced twice over: Art. 614(8) of the Commerce Act excludes the reserve from the insolvency estate, and the Bank Insolvency Act carries a matching amendment. This is a genuine structural protection and it is one of the clearest arguments for dealing with a licensed issuer.
Yes. Under § 3(1) of the transitional provisions of the ЗПКА, entities on the old NRA register could operate without a licence only until 1 July 2026 or until their licence was granted or refused, whichever came first.
Four, as at 19 August 2026, on the FSC register. The figure changes; check the register.
The higher of the Annex IV class minimum (EUR 50,000, 125,000 or 150,000) and one quarter of the preceding year's fixed overheads.
Yes, by notification under Art. 60(3) MiCA and Art. 9(9) of the Markets in Financial Instruments Act, for services equivalent to those it is already licensed for.
Asset-referenced tokens sit with the FSC unless the issuer is a credit institution. E-money tokens sit with the Bulgarian National Bank under Art. 182a of the Payment Services and Payment Systems Act.
See also our guides to MiCA in Bulgaria after 1 July 2026 and crypto taxation in Bulgaria, and our crypto and blockchain practice.
This article states the position as at 19 August 2026. Licence numbers and register entries change; verify against the FSC register before acting. It is general information and not legal advice. Prepared by the legal team at YARD Law Co., a law firm based in Sofia, Bulgaria.
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