# Banks in Bulgaria: Accounts for Companies, Licensed Firms and Non-Residents

> Bank accounts in Bulgaria for an EOOD, EMI or CASP: BNB bank register, capital-deposit account, KYC, safeguarding, deposit guarantee, euro/TARGET, sanctions.

Author: Gordey Bolotko — Partner, Corporate & Commercial (https://wiki.private.law/en/authors/bolotko)
Last modified: 2026-09-27T17:01:00.000Z
Canonical: https://wiki.private.law/en/bulgaria-banks
Publisher: wiki.private.law (https://wiki.private.law)
Version: b04879d934281cb27a66f536291bfaeaa7f1aff94d5269e43ca97f64ba2fb508
Cite as: Banks in Bulgaria: Accounts for Companies, Licensed Firms and Non-Residents. wiki.private.law. https://wiki.private.law/en/bulgaria-banks. Version b04879d934281cb27a66f536291bfaeaa7f1aff94d5269e43ca97f64ba2fb508.
Topics: banking
Jurisdictions: bulgaria, eu, russia
Functional tags: corporate-banking, personal-banking
Product tags: banking, bank, compliance, license-emi-eu, personal-banking
Semantic tags: corporate-banking, personal-banking, banking, bank, compliance, license-emi-eu

---

A company in Bulgaria meets its bank three times, and each meeting rests on a different rule. Before the company or a financial licence exists, a bank receives the founders' capital and certifies it. After registration, a bank opens the operating account once it has identified the company, its managers and its beneficial owners. A payment institution, an e-money institution or a crypto-asset service provider then needs a further account in which its clients' money is kept apart from its own.

Which bank will open the account, what it will ask for and how long it will take depend on those three rules and on the people behind the company. Bank conditions are stated as the banks published them on 24 September 2026, and banks appear in the order of the [register kept by the Bulgarian National Bank (BNB)](https://www.bnb.bg/RegistersAndServices/RSCIRegisters/BS_CI_REG_BANKSLIST_BG).

## Concept: three accounts, three legal results

Each account has its own legal basis and its own legal result.

**Capital or escrow account**

Holds the founders' contributions before registration or licensing. Its legal result is the bank's confirmation of paid-in capital, on which the registry and, for a PI or EMI, the BNB rely.

**Operating current account**

The company's everyday payment account after registration. It rests on the bank's customer due diligence under the AML Act; no statute gives a company a right to one.

**Safeguarding account**

A separate account in which a PI, EMI or crypto-asset service provider places client money. Its legal result is ring-fencing from the firm's own creditors.

### The capital account comes first

Bulgarian company law ties registration to money actually paid. An OOD or EOOD is registered only once the statutory minimum capital is paid in and, where the registered capital is higher, at least 70% of it ([Commerce Act art. 119(1)](https://www.mi.government.bg/file/2011/08/targovski_zakon_31.07.2026.pdf)); the minimum is €1 since 1 January 2026. A joint-stock company (AD) needs capital of at least €25,000, and before registration at least a quarter of each share's value is paid in ([art. 174(1)](https://www.mi.government.bg/file/2011/08/targovski_zakon_31.07.2026.pdf)) through an escrow account. The bank's note of paid-in capital is among the documents the [Registry Agency](https://www.registryagency.bg/bg/registri/targovski-registar/kak-da-registriram-firma/) lists for registration, and for a payment institution (PI) or e-money institution (EMI) the bank's certificate on the escrow account also enters the licence file the BNB reviews.

### What follows from the model

Four features set Bulgarian business banking apart.

The bank is the first gatekeeper. Because the capital certificate precedes registration and licensing, no company or licence application can proceed until some bank has accepted and certified the capital, and the origin of the founders' money is first examined there.

The people behind the company decide the channel. Where banks offer remote onboarding, it is built around a Bulgarian-citizen manager, at DSK Bank also Bulgarian-citizen beneficial owners, and at United Bulgarian Bank holders of a Bulgarian personal number (EGN). A company outside those conditions opens its account through a branch, on paper, often with apostilled documents.

Protection depends on who holds the money. The [Bulgarian Deposit Insurance Fund (BDIF)](https://www.dif.bg/web/files/documents/34/files/bank-deposit-guarantee-act.pdf) guarantees up to €100,000 per depositor per bank, but PIs and EMIs are excluded from repayment as financial institutions, and branches of banks from other EU states sit under their home schemes.

> 🍓 Access rights depend on the client. A consumer lawfully resident in the EU has a statutory right to a basic payment account. A PI or EMI benefits from a duty on banks not to discriminate, with every refusal explained to the BNB. An ordinary EOOD has no statutory right to an account at all, so its route to a bank runs entirely through the bank's own due diligence.

Since 1 January 2026 all three accounts run in euro: lev balances were converted, IBANs kept, and settlement moved to TARGET and SEPA.

The figures most often needed at the outset, as at 24 September 2026:

- Licensed banks · 17 banks licensed in Bulgaria and 6 branches of foreign banks (BNB register dated 23 March 2026)
- Deposit guarantee · €100,000 per depositor per bank (BDIF); PIs and EMIs excluded as payees
- Minimum capital · €1 for an OOD or EOOD; €25,000 for an AD; €350,000 for an EMI
- Capital evidence · capital account for an OOD or EOOD; escrow account for an AD and for a PI or EMI applicant
- Deadline to open a business account · none in statute; the 10-day decision period applies to consumer basic accounts only
- Settlement · euro since 1 January 2026; TARGET, SEPA through BISERA, instant payments through TIPS
- Sanctions cap · Reg. 833/2014 art. 5b(1): €100,000 per credit institution for Russian nationals and residents, Russia-established entities and non-EU entities over 50% owned by them; exemptions in art. 5b(3)

Most rows turn on who the client is, which is why the rules that follow are arranged by account and by client.

## Licensed banks and branches

The [BNB register of licensed banks](https://www.bnb.bg/RegistersAndServices/RSCIRegisters/BS_CI_REG_BANKSLIST_BG), in its edition of 23 March 2026, current on 24 September 2026, lists 17 banks licensed in Bulgaria and 6 branches of foreign banks, 23 in total. Country pages for [Serbia](https://wiki.private.law/en/serbia-banks) and [Spain](https://wiki.private.law/en/spain-banks) answer the same questions for those markets, and the [banks hub](https://wiki.private.law/en/banks) maps the rest.

The split between a Bulgarian licence and a branch matters mostly for deposit protection. Banks licensed in Bulgaria belong to BDIF, while [branches of banks from other EU member states](https://www.dif.bg/en/for-depositors/banks) do not: their deposits are covered by the scheme of the home country. The one branch from outside the EU is on the BDIF list of insured banks.

| Branch of a foreign bank | Deposit guarantee |
| --- | --- |
| ING Bank N.V. Sofia Branch | home-state scheme |
| Citibank Europe (Bulgaria Branch) | home-state scheme |
| BNP Paribas S.A. Sofia Branch | home-state scheme |
| Ascory Bank AG Sofia Branch | home-state scheme |
| T.C. Ziraat Bankasi Sofia Branch | BDIF |
| Bigbank AS Bulgaria Branch | home-state scheme |

For a depositor the dividing line is the legal form of the bank's presence: a deposit at an EU branch is protected, but under another country's scheme and procedure.

### Banks licensed in Bulgaria: 17

In the order of the BNB register (edition of 23 March 2026):

  1. DSK Bank
  2. UniCredit Bulbank
  3. Eurobank Bulgaria (Postbank)
  4. United Bulgarian Bank
  5. Investbank
  6. First Investment Bank
  7. Texim Bank
  8. Central Cooperative Bank
  9. Allianz Bank Bulgaria
  10. Bulgarian-American Credit Bank
  11. TBI Bank
  12. ProCredit Bank (Bulgaria)
  13. International Asset Bank
  14. D Commerce Bank
  15. Bulgarian Development Bank
  16. Tokuda Bank
  17. Municipal Bank
Banks licensed elsewhere in the EEA may also serve Bulgarian clients without a local presence, under the EU passport. The [BNB list of such notifications](https://www.bnb.bg/RegistersAndServices/RSCIRegisters/BS_CI_REG_CRBORDACTIV_BG), dated 10 September 2026, runs to 385 entries, a number of them marked as having ceased activity. The list measures the reach of the passport; the mechanics are set out in [EU passporting](https://wiki.private.law/en/eu-passporting).

## Capital account: from founders' money to registration

The account the founders open first depends on the legal form of the future company and on whether it will apply for a licence. The table compares the three cases on the rule that governs payment.

| Future entity | Minimum capital | How capital is paid |
| --- | --- | --- |
| OOD or EOOD | €1 | capital account; the minimum and at least 70% of any higher registered capital paid before registration (Commerce Act art. 119(1)) |
| AD or EAD | €25,000 | escrow account opened by the board; contributions returnable if no filing is certified within three months (art. 166) |
| PI or EMI applicant | €350,000 for an EMI | escrow account; bank certificate plus declarations and documents on the origin of funds (Ordinance No 16) |

The third row adds a licensing layer to the first two: the company form still decides the account, but the BNB also asks where the money came from. The payment-institution capital tiers and the rest of the licensing file are set out in [EMI and payment institution licences in Bulgaria](https://wiki.private.law/en/bulgaria-emi-license), and the Lithuanian alternative is compared in [EMI in Lithuania or Bulgaria](https://wiki.private.law/en/emi-lithuania-vs-bulgaria); tax and formation of the company itself are in [company in Bulgaria](https://wiki.private.law/en/company-bulgaria).

For an AD the Act names the instrument. Cash contributions go into an escrow (collection) account opened in the company's name by its board, with each contributor indicated, and if the board does not certify to the bank within three months that the company has been filed for registration, the contributors may take their money back in full ([Commerce Act art. 166](https://www.mi.government.bg/file/2011/08/targovski_zakon_31.07.2026.pdf)).

For a PI or EMI the same account becomes licensing evidence. The applicant must be an OOD or AD, registered or in formation, with its capital paid in, of transparent and lawful origin, and with its seat where management actually sits ([Payment Services and Payment Systems Act (ZPUPS) art. 10(4)](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_payment_services_bg.pdf), applied to EMIs by art. 37(2)); an EMI needs at least €350,000 (art. 38). [BNB Ordinance No 16](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/au_lf_ordinance_16_bg.pdf) asks an applicant in formation for a bank certificate that the cash contributions sit in an escrow account, together with the shareholders' declarations and documents on the origin of the money (arts 3(1) and 23(1)).

### One bank's procedure and prices

UniCredit Bulbank publishes both sides of the process. For an OOD or EOOD in formation, the [special capital account](https://www.unicreditbulbank.bg/bg/individualni-klienti/bankirane/dokumenti-za-klienta/yuridicheski-lica/) is opened by the founders or the elected manager, or by a proxy holding an explicit notarised power of attorney. For an AD, a single-member EAD or a partnership limited by shares (KDA) the escrow account is opened by the members of the management or directors' board, or their proxy.

The bank's [tariff for legal entities in force from 1 January 2026](https://www.unicreditbulbank.bg/media/filer_public/49/2a/492a4e46-b3e6-446e-aeb5-ad59f9d81f4a/tariff-le-01-01-2026-bg.pdf) prices the accounts as follows.

| Item (tariff section I) | Fee |
| --- | --- |
| Special capital account: opening and monthly maintenance (4.1) | €10.23 |
| Escrow account: opening (5.1) | €15.34 |
| Current account: opening and monthly maintenance, electronic channel (1.1–1.2) | €12.78 |
| Current account: opening and monthly maintenance, at a branch (1.1–1.2) | €23.01 |

No fee is charged for closing the capital or escrow account and opening a current account when the client moves on to a current account at the same bank (note 3), so the capital account is usually the first step of an ongoing relationship with the same bank.

## Operating account: identification and the choice of channel

### The statutory core

Whatever the bank, the identification core comes from the [Measures Against Money Laundering Act (ZMIP)](https://www.fsc.bg/wp-content/uploads/2026/06/zmip_dv_51_2026.pdf). The Act sets out what the bank collects for each person it must identify.

| Who | What the bank collects | ZMIP |
| --- | --- | --- |
| Natural person (manager, owner, proxy) | names, date and place of birth, ID number, every citizenship held, country of permanent residence and address | art. 53(2) |
| Company | original or notarised register extract and certified constitutional documents, or a check of an official EU or equivalent register; ownership, management and control structure | art. 54(1)–(3) |
| Beneficial owner | beneficial-ownership register, ownership and control documents, and a declaration by the legal representative where these are insufficient or contradictory | art. 59(1) |

The citizenship line matters later: it is the data point on which remote channels and sanctions rules both turn.

The bank's wider review of the company, its owners and its money is described in [corporate KYC](https://wiki.private.law/en/corporate-kyc) and [source of funds](https://wiki.private.law/en/source-of-funds); the Bulgarian AML regime itself, with the Financial Intelligence Directorate and the duties of obliged entities, is the subject of [AML in Bulgaria](https://wiki.private.law/en/bulgaria-aml-framework).

### AML calendar and FATF status

Three developments frame the AML side of account opening. As of September 2026, Bulgaria remains on the FATF list of jurisdictions under increased monitoring, where it has been since October 2023; in June 2026 the FATF made an [initial determination that the action plan is substantially completed](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) and that an on-site assessment is warranted, and no delisting has been decided.

The EU AML Regulation (EU) 2024/1624 [applies from 10 July 2027](https://eur-lex.europa.eu/eli/reg/2024/1624/oj), so until then customer due diligence follows the Bulgarian ZMIP. PSD3 and the Payment Services Regulation are [not adopted and not in force](https://oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=2023%2F0209\(COD\)): the agreed texts were approved in committee on 5 May 2026 and, as of September 2026, a plenary vote is forecast for 14 December 2026.

### Remote or branch

Where a bank offers remote onboarding, the conditions turn on the citizenship or Bulgarian personal number of the people behind the company, and each bank draws the line differently.

| Bank | Remote channel open to | Outside the remote channel |
| --- | --- | --- |
| [DSK Bank](https://dskbank.bg/%D0%B1%D0%B8%D0%B7%D0%BD%D0%B5%D1%81-%D0%BA%D0%BB%D0%B8%D0%B5%D0%BD%D1%82%D0%B8/%D0%BC%D0%BE%D1%8F%D1%82-%D0%B1%D0%B8%D0%B7%D0%BD%D0%B5%D1%81/%D1%81%D0%BC%D0%B5%D1%82%D0%BA%D0%B8-%D0%B8-%D1%80%D0%B0%D0%B7%D0%BF%D0%BB%D0%B0%D1%89%D0%B0%D0%BD%D0%B8%D1%8F/%D0%BE%D1%82%D0%BA%D1%80%D0%B8%D0%B2%D0%B0%D0%BD%D0%B5-%D0%BD%D0%B0-%D0%B1%D0%B8%D0%B7%D0%BD%D0%B5%D1%81-%D1%81%D0%BC%D0%B5%D1%82%D0%BA%D0%B0) | new sole trader (ET), EOOD or OOD, or a liberal profession in the BULSTAT register; Bulgarian-citizen representative, not a politically exposed person (PEP); Bulgarian-citizen beneficial owners | any foreign representative or beneficial owner |
| [UniCredit Bulbank](https://www.unicreditbulbank.bg/bg/malak-biznes/bankirane/smetki/distancionno-otkrivane-smetka/) | Bulgarian entity, registered or in registration, whose legal representative with sole representation rights is a Bulgarian citizen; owners' nationality not a stated condition; qualified electronic signature | foreign representatives and filings by proxy |
| [United Bulgarian Bank](https://ubb.bg/business-digital-onboarding) | company in the Commercial Register whose beneficial owners and/or legal representatives hold an EGN, owner identifiable from the register, current Bulgarian address | representatives of foreign companies; offshore-owned companies |

DSK states that its online channel opens a business account in up to 20 minutes. Companies outside these conditions open their accounts in person, at a branch.

**Bulgarian-citizen manager**

Remote opening without a branch visit: with a qualified electronic signature at UniCredit Bulbank whoever owns the company; fully online in up to 20 minutes at DSK if the beneficial owners are Bulgarian citizens too.

**Foreign manager, or foreign owners at DSK**

Branch visit with identity documents, beneficial-owner evidence and the bank's questionnaire; for a company registered abroad, a full corporate file with apostille or legalisation.

For a company registered outside Bulgaria, UniCredit Bulbank [asks for](https://www.unicreditbulbank.bg/bg/individualni-klienti/bankirane/dokumenti-za-klienta/yuridicheski-lica/) a certified copy of the current constitutional document and an original official document on registration and current particulars, including the ownership and control structure and the representatives. It also asks for identity documents of legal representatives and beneficial owners, signature specimens, licences where applicable and its KYC questionnaire. Foreign public or notarised documents need an apostille or legalisation, and documents in a foreign language need an official Bulgarian translation.

### How long it takes

No statute sets a deadline for opening a business account. The two published figures belong to other situations: DSK's 20 minutes for its online channel, open only to eligible clients, and the 10-day decision period that ZPUPS sets for a consumer's basic payment account. A bank may also end an account relationship later, under the rules set out in [bank account closure](https://wiki.private.law/en/bank-account-closure).

### Published business-account prices: 4 plans

DSK Bank's [small-business plans](https://dskbank.bg/%D0%B1%D0%B8%D0%B7%D0%BD%D0%B5%D1%81-%D0%BA%D0%BB%D0%B8%D0%B5%D0%BD%D1%82%D0%B8/%D0%BC%D0%BE%D1%8F%D1%82-%D0%B1%D0%B8%D0%B7%D0%BD%D0%B5%D1%81/%D1%81%D0%BC%D0%B5%D1%82%D0%BA%D0%B8-%D0%B8-%D1%80%D0%B0%D0%B7%D0%BF%D0%BB%D0%B0%D1%89%D0%B0%D0%BD%D0%B8%D1%8F/%D0%BE%D1%82%D0%BA%D1%80%D0%B8%D0%B2%D0%B0%D0%BD%D0%B5-%D0%BD%D0%B0-%D0%B1%D0%B8%D0%B7%D0%BD%D0%B5%D1%81-%D1%81%D0%BC%D0%B5%D1%82%D0%BA%D0%B0), monthly price as shown on 24 September 2026; the lower figure applies when the plan's discount conditions are met. The plan's euro current account carries no opening or monthly fee.

| Plan | With discount | Without discount |
| --- | --- | --- |
| DSK Nachalo | €10.22 | €12.27 |
| DSK Progres | €18.40 | €20.45 |
| DSK Razvitie | €34.77 | €38.35 |
| DSK Horizont | €61.35 | €69.02 |

## Licensed firms: safeguarding and client-money accounts

A [licensed payment firm](https://wiki.private.law/en/bulgaria-financial-licenses) needs a bank for a different reason than an ordinary company: the law requires it to keep client money outside its own balance sheet.

A PI keeps client funds apart from its own and, if they have not been passed on by the end of the business day after receipt, deposits them in a [separate safeguarding account](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_payment_services_bg.pdf) with a bank licensed in a member state or with a member state's central bank. Those funds cannot be attached or enforced against for the PI's debts to anyone other than its payment-service users (ZPUPS art. 23(2)). If the PI becomes insolvent, users' funds are excluded from the insolvency estate and returned by the trustee pro rata (art. 23(3)).

An EMI applies the same measures to funds received in exchange for e-money. Funds paid by card or another payment instrument must be safeguarded once credited and in any case no later than five working days after the e-money is issued (art. 41(1)–(2)).

The account itself is backed by an access rule. Banks and bank branches operating in Bulgaria must open and maintain [payment accounts for PIs and EMIs](https://wiki.private.law/en/banking-for-msb) on an objective, non-discriminatory and proportionate basis, and must give the BNB a reasoned opinion on every refusal ([ZPUPS arts 27 and 45](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_payment_services_bg.pdf)). The duty does not force a particular bank to say yes, but a refusal leaves a record with the supervisor.

> ⚠️ A PI or EMI is not a BDIF payee. The [Credit Institutions Act (ZKI)](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_creditinstitutions_bg.pdf) classifies PIs and EMIs as financial institutions (art. 3(2)), and the [Bank Deposit Guarantee Act (BDGA)](https://www.dif.bg/web/files/documents/34/files/bank-deposit-guarantee-act.pdf) excludes financial institutions from repayment of guaranteed amounts (art. 11(1)). Client-money protection under ZPUPS is a [separate mechanism](https://wiki.private.law/en/correspondent-banking-safeguarding) built on segregation, immunity from attachment and exclusion from the insolvency estate.

A [crypto-asset service provider (CASP)](https://wiki.private.law/en/bulgaria-casp-license) works under MiCA rather than ZPUPS. A CASP that holds clients' funds other than e-money tokens must place them with a credit institution or a central bank by the end of the business day after receipt, in an account separately identifiable from its own ([MiCA art. 70(2)–(3)](https://eur-lex.europa.eu/eli/reg/2023/1114/oj)). The rule does not apply to CASPs that are themselves EMIs, PIs or credit institutions (art. 70(5)), which follow their own safeguarding regimes.

## Deposit protection: what BDIF covers

Deposit-taking is reserved to banks. An EMI may not accept deposits, and funds a PI receives for payment services are not deposits ([ZPUPS arts 40(1) and 22(3)](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_payment_services_bg.pdf)), so the guarantee attaches only to money held at a bank. BDIF's own rules then decide how much of it is protected.

| Rule | What it means |
| --- | --- |
| Standard limit | full repayment up to €100,000 of all deposits of one person at one bank ([BDGA art. 9(1)](https://www.dif.bg/web/files/documents/34/files/bank-deposit-guarantee-act.pdf)) |
| Temporary higher limit | €125,000 for three months from crediting, for listed life events such as a residential property sale (art. 10(1)) |
| Payout | starts no later than seven working days after the triggering act, through banks BDIF designates ([BDIF](https://www.dif.bg/en/for-depositors/when)) |
| Company and owner | guaranteed separately, €100,000 each; only a sole trader's deposits are added to personal ones ([BDIF](https://www.dif.bg/en/for-depositors/how-much)) |
| Excluded payees | other banks, financial institutions under ZKI art. 3, insurers, pension funds, investment firms, investment funds, budget bodies, guarantee funds (art. 11(1)) |
| EU branches | outside BDIF; covered by the home-state scheme ([BDIF list](https://www.dif.bg/en/for-depositors/banks)) |

For an EOOD this produces two separate guarantees at the same bank: €100,000 for the company and €100,000 for its owner personally.

The temporary €125,000 limit covers deposits of natural persons from residential real-estate transactions, from marriage or divorce, termination of employment, disability or death, and from insurance or social-security payments or crime-damage compensation. It matters mainly to a seller of a flat, a situation described in [buying property in Bulgaria](https://wiki.private.law/en/bulgaria-property-purchase).

## Euro, TARGET and instant payments since 1 January 2026

Bulgaria adopted the euro on 1 January 2026 at the conversion rate of 1.95583 levs to the euro fixed by [Council Regulation (EU) 2025/1409](https://eur-lex.europa.eu/eli/reg/2025/1409/oj). The changeover altered the rails under every account; the [BNB's euro questions and answers](https://www.bnb.bg/AboutUs/AUEurosystem/AUAccessionToTheEuroArea/AUAEFIQuestionsAndAnswers/POAEFI_QUESTIONSANDANSWERS7_BG) describe the switch for each type of payment.

| Payment type | Before 2026 | Since 2026 |
| --- | --- | --- |
| Large-value payments | RINGS, real-time gross settlement in levs, now closed | TARGET in euro, in which banks in Bulgaria and some foreign-bank branches already participated |
| Customer credit transfers | BISERA6 in levs | SEPA in euro through BISERA, operated by BORICA AD, with full SEPA reachability since July 2024 via EBA Clearing STEP2 |
| Instant payments | TIPS in euro from 3 December 2024, for the first participants | TIPS in euro |

Only the instant rail predates the euro. On [3 December 2024](https://www.bnb.bg/AboutUs/PressOffice/POPressReleases/POPRDate/PR_20241203_1_BG) the BNB, the BISERA system, two banks and one e-money institution joined the Eurosystem's TIPS service for SEPA instant credit transfers in euro, and the BNB announced that further payment service providers in Bulgaria would continue joining during 2025.

> ⚙️ For an account that existed on 31 December 2025, the changeover was mechanical: banks and other payment service providers converted every lev balance into euro once, free of charge and on unchanged contract terms, and the IBAN stayed the same ([BNB](https://www.bnb.bg/AboutUs/AUEurosystem/AUAccessionToTheEuroArea/AUAEFIQuestionsAndAnswers/POAEFI_QUESTIONSANDANSWERS7_BG)). Contracts, standing orders and account numbers opened before 2026 therefore continue without re-papering.

## Basic payment account: a consumer right, not a company one

Bulgarian law does contain a right to a bank account, but it belongs to individuals. A basic payment account under ZPUPS arts 117–121 is available to consumers, meaning natural persons acting outside their trade or profession ([ZPUPS § 1 item 40 of the additional provisions](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_payment_services_bg.pdf)). A company account is never a basic payment account.

Every bank licensed in Bulgaria and every branch operating there that provides payment services to consumers must offer the account, in euro since 1 January 2026. It covers opening, use and closing, deposits, cash withdrawals, direct debits, card payments and credit transfers, with no limit on the number of those operations (arts 118 and 119(1)). A bank or branch that serves consumers only exceptionally, and only a limited number and category of them, may be exempt (art. 119(9)).

Consumers lawfully resident in the EU, including those without a fixed address, asylum seekers and persons who cannot be expelled, are entitled to the account. The bank must open it or refuse within 10 days of receiving all required documents (art. 119(2)–(3)), and may not discriminate on grounds of nationality or residence (art. 117(1)). Fees must be nil or reasonable: lower than the BNB-published average for the same services and lower than the bank's own tariff for other consumer accounts (art. 120).

The three access regimes compare as follows.

| Client | Statutory position | Refusal |
| --- | --- | --- |
| Consumer lawfully resident in the EU | right to a basic payment account; decision within 10 days of complete documents | mandatory where AML law would be breached; optional if one is already held; written reasons, free |
| PI or EMI | banks must open and maintain accounts on objective, non-discriminatory, proportionate terms | reasoned opinion to the BNB on every refusal |
| Ordinary company (EOOD, OOD, AD) | no statutory right to an account | no specific statutory rule |

The founder of an EOOD can therefore rely on the basic account personally, if lawfully resident in the EU, but not for the company. Sanctions law applies to this account as to any other: for a Russian national without EU, EEA or Swiss nationality or a residence permit there, the art. 5b limits reach the basic account too, including the ban on issuing a payment card ([Commission FAQ on deposits](https://finance.ec.europa.eu/document/download/a2f66733-09b6-43ec-b8f5-c594a55ca997_en?filename=faqs-sanctions-russia-deposits_en.pdf), question 34), and whether a given document counts as a residence permit is a matter of national law (question 29). Accounts for individuals abroad more generally are described in [personal bank accounts](https://wiki.private.law/en/personal-accounts).

## Non-EU owners and managers

The owner's nationality and residence enter the file in two ways. Through KYC they decide the channel, because the bank records every citizenship and the country of residence. Through EU sanctions law they can cap the deposits and exclude certain services, and here the logic is set by one regulation.

### The deposit cap and its limits

[Art. 5b(1) of Regulation 833/2014](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20260724) prohibits EU credit institutions from accepting deposits from the persons in the left column once that depositor's total deposits at the credit institution exceed €100,000.

**Caught by art. 5b(1)**

Russian nationals; natural persons residing in Russia; legal persons established in Russia; legal persons established outside the EU and more than 50% owned, directly or indirectly, by Russian nationals or natural persons residing in Russia.

**Outside art. 5b(1)**

A registered EU company, such as a Bulgarian EOOD, whoever owns it, provided it is not used to circumvent the cap (art. 12). Also nationals of an EU state, the EEA or Switzerland, and holders of a temporary or permanent residence permit there (art. 5b(3)).

The cap is counted per credit institution, not per account. The art. 5b(3) exemption covers natural persons only; it does not extend to legal persons, but an EU-incorporated company does not need it, because the ownership limb reaches only entities established outside the Union. In the Commission's reading, a company established outside the EU and more than 50% owned by a Russian national who holds EU, EEA or Swiss nationality or a residence permit there is not caught by the ownership limb either; this does not apply to entities established in Russia ([Commission FAQ on deposits](https://finance.ec.europa.eu/document/download/a2f66733-09b6-43ec-b8f5-c594a55ca997_en?filename=faqs-sanctions-russia-deposits_en.pdf), question 43).

The cap bites on new deposits: balances held when it took effect may stay but cannot be increased above €100,000, and interest or dividends are not credited once the cap is exceeded (questions 14, 17 and 26). National authorities may authorise specific deposits under [art. 5c(1)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20260724), for example for basic needs, legal fees or non-prohibited EU–Russia trade. For an EOOD with a Russian owner, the Commission expects banks to apply enhanced due diligence, and money that an owner without the art. 5b(3) status pays into the company's account personally may count as that owner's deposit (questions 27 and 36).

> ⚠️ Since 24 October 2025 [art. 5b(2)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20260724) also bars providing Russian nationals, residents of Russia and entities established in Russia with crypto-asset services, the issuing of payment instruments, acquiring, payment initiation and the issuing of e-money. Renewing or re-issuing a card counts as issuing. Executing payment transactions and transfers is not covered, and existing accounts need not be closed. The art. 5b(3) exemption for EU, EEA and Swiss nationals and residence-permit holders applies here too.

The carve-out for EU companies starts only at registration. Before that the company does not yet exist ([Commerce Act art. 67](https://www.mi.government.bg/file/2011/08/targovski_zakon_31.07.2026.pdf)), and contributions on an AD's escrow account are recorded against each contributor and returnable to them (art. 166). A founder without the art. 5b(3) status who pays in more than €100,000 at one bank before registration, such as the €350,000 of an EMI, therefore risks meeting the cap.

Ownership of a crypto firm is a separate rule. Art. 5b(2a) bars Russian nationals and residents of Russia without the art. 5b(3) status from owning, controlling or sitting on the governing bodies of an EU legal person providing crypto-asset wallet, account or custody services since 18 January 2024, and any crypto-asset service under MiCA since 25 August 2026. Its effect on a Bulgarian application is set out in the [CASP licence](https://wiki.private.law/en/bulgaria-casp-license), and the wider map in [sanctions](https://wiki.private.law/en/sanctions-map).

### Reporting for Russian-owned EU companies: art. 5r

[Art. 5r](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20260724) reaches legal persons established in the EU that are owned directly or indirectly more than 40% by a Russian-established entity, a Russian national or a natural person residing in Russia. Since 1 May 2024 such a company reports to its national competent authority, within two weeks after each quarter, every transfer of funds out of the Union exceeding €100,000 in that quarter, made in one operation or several. Since 1 July 2024 credit and financial institutions report such transfers they initiated semi-annually. A Bulgarian EOOD above the 40% threshold is therefore outside the deposit cap but inside this reporting duty.

### Documents for a foreign individual

Banks publish their document requirements for individuals by nationality and residence status. UniCredit Bulbank's [account-opening leaflet](https://unicreditbulbank.bg/doc/1723028346/19682/) (last modified 21 October 2025) sets them out in three columns.

| Document | EU, EEA or Swiss citizen, no Bulgarian permit | Other foreign citizen, no Bulgarian permit | Foreign citizen with a Bulgarian permit |
| --- | --- | --- | --- |
| Identity | international passport or national passport or ID card | international passport and national passport or ID card | international passport and Bulgarian residence permit |
| Proof of address | from the country of origin, if the ID shows no permanent address | from the country of origin, if the ID shows no permanent address | not required |
| Reason for the account | required, e.g. employment contract or notarial deed | required, e.g. employment contract or notarial deed | required |
| KYC questionnaire | required | required | required |

A Bulgarian residence permit replaces the second identity document and the proof of address, but not the document explaining why the account is needed. Documents in a foreign language without an English translation need an official Bulgarian translation, and the bank may ask for more.

For a founder moving with the business, [relocation from Russia](https://wiki.private.law/en/relocation-from-russia) covers the personal side, and [money transfers to and from Russia](https://wiki.private.law/en/remittances-from-russia) the payment routes that art. 5b(2) leaves open.

## Typical profiles

The rules above combine differently for each kind of client. The table maps five common profiles to the account route, what the bank asks for and the limits that apply.

| Profile | Account route | What the bank asks | Limits |
| --- | --- | --- | --- |
| EOOD with a Bulgarian-citizen manager | capital account, then remote opening at UniCredit Bulbank, or at DSK Bank if the beneficial owners are Bulgarian citizens too | ZMIP identification of the company, manager and beneficial owners; qualified electronic signature | no statutory right to an account; DSK online in up to 20 minutes |
| EOOD with a foreign manager | capital account, then a branch | identity documents, beneficial-owner evidence, questionnaire; apostilled and translated file if registered abroad | no statutory deadline |
| PI or EMI applicant | escrow account and bank certificate, then a safeguarding account at a bank or central bank | origin-of-funds documents under Ordinance No 16 | €350,000 for an EMI; reasoned refusal to the BNB; not a BDIF payee |
| CASP | account for clients' funds at a credit institution or central bank | identification under ZMIP, as for any company | MiCA art. 70: placed by the end of the next business day, separate from own funds |
| Russian national without EU nationality or residence permit | registered EOOD outside the art. 5b(1) cap; personal accounts inside it | enhanced due diligence on the company's account and on capital paid in before registration | personal deposits up to €100,000 per bank; no new cards, e-money or crypto services (art. 5b(2)) |

The route is set by who stands behind the company and whether it holds client money; the choice of bank follows from that.

## Q/A

### Company and capital

### **Can a foreign-owned EOOD open its bank account online?**

Only if the manager is Bulgarian. UniCredit Bulbank accepts remote onboarding when the legal representative with sole representation rights is a Bulgarian citizen, whoever owns the company. DSK Bank also requires Bulgarian-citizen beneficial owners, and United Bulgarian Bank requires owners or representatives with a Bulgarian personal number and no offshore owners. Otherwise the account is opened at a branch with identity documents, beneficial-owner evidence and the bank's questionnaire.

### **How much capital must an EOOD pay before registration?**

The statutory minimum is €1 since 1 January 2026. If the registered capital is higher, at least 70% of it must be paid in before registration under Commerce Act art. 119(1). An AD needs capital of at least €25,000, of which at least a quarter of each share's value is paid before registration through an escrow account opened by its board.

### **How long does it take to open a business account in Bulgaria?**

No statute sets a deadline. DSK states up to 20 minutes for its online channel, which is open only to eligible companies with a Bulgarian-citizen representative and Bulgarian-citizen beneficial owners. The 10-day decision period in ZPUPS applies to a consumer's basic payment account, not to a company.

### Licensed firms

### **Can a Bulgarian bank refuse a safeguarding account to an EMI?**

It can refuse, but not freely. ZPUPS arts 27 and 45 require banks and branches operating in Bulgaria to open and maintain payment accounts for PIs and EMIs on objective, non-discriminatory and proportionate terms, and to give the BNB a reasoned opinion on every refusal.

### **Where must a CASP keep its clients' money?**

Client funds other than e-money tokens go to a credit institution or a central bank by the end of the business day after receipt, in an account separately identifiable from the CASP's own (MiCA art. 70(3)). A CASP that is also an EMI, PI or credit institution follows its own safeguarding regime instead.

### **Is an EMI's money at a bank covered by BDIF?**

The EMI itself is not a BDIF payee: the Credit Institutions Act classifies PIs and EMIs as financial institutions, and the Bank Deposit Guarantee Act excludes financial institutions from repayment. Client money is protected under ZPUPS by segregation, immunity from attachment and exclusion from the insolvency estate.

### Non-residents and sanctions

### **Does the €100,000 sanctions cap apply to an EOOD owned by a Russian national?**

Not to a registered EOOD. Art. 5b(1) of Regulation 833/2014 reaches Russian nationals, natural persons residing in Russia, entities established in Russia and entities established outside the EU that are more than 50% owned by Russian nationals or residents of Russia. A Bulgarian EOOD is established in the EU, so the cap does not apply to it. The Commission expects banks to apply enhanced due diligence to such accounts, and money that an owner without the art. 5b(3) status pays in personally may count as the owner's deposit (Commission FAQ on deposits, questions 27 and 36). If Russian ownership exceeds 40%, the art. 5r reporting duty on transfers out of the Union applies.

### **Can a Russian citizen with a Bulgarian residence permit get a bank card?**

Yes, as far as sanctions law goes. The art. 5b(3) exemption covers holders of a temporary or permanent residence permit in an EU state, so the art. 5b(2) ban on issuing payment instruments does not apply to them. The [Commission's guidance](https://finance.ec.europa.eu/document/download/8b0e76f4-6a5e-4fd3-a85e-04d7ecdfe340_en?filename=faqs-sanctions-russia-payments-services_en.pdf) expects the permit to stay valid for the whole validity of the card, and the bank still carries out its own KYC.

### **Does a foreign director have a right to a basic payment account?**

Personally, yes, if lawfully resident in the EU: the right belongs to consumers, including asylum seekers and persons who cannot be expelled, and the bank decides within 10 days of complete documents. For a Russian national without EU, EEA or Swiss nationality or a residence permit, the art. 5b limits apply to that account too, including the ban on issuing a card. The company the director manages has no such right.

---

## Factual claims

- Bulgarian company law ties registration to money actually paid.
- Since 1 January 2026 all three accounts run in euro: lev balances were converted, IBANs kept, and settlement moved to TARGET and SEPA.
- The figures most often needed at the outset, as at 24 September 2026:
- The BNB register of licensed banks, in its edition of 23 March 2026, current on 24 September 2026, lists 17 banks licensed in Bulgaria and 6 branches of foreign banks, 23 in total.
- The bank's tariff for legal entities in force from 1 January 2026 prices the accounts as follows.
- The EU AML Regulation (EU) 2024/1624 applies from 10 July 2027, so until then customer due diligence follows the Bulgarian ZMIP.
- DSK states that its online channel opens a business account in up to 20 minutes.
- A licensed payment firm needs a bank for a different reason than an ordinary company: the law requires it to keep client money outside its own balance sheet.

---

Source: wiki.private.law — the private.law legal knowledge base. When quoting, cite the canonical page URL.
Consultation with a lawyer: https://t.me/private_law_bot