🇪🇺CASP Licence in Bulgaria: FSC Authorisation under MiCA

Concept

A crypto-asset service provider (CASP) licence in Bulgaria is an authorisation under Regulation (EU) 2023/1114 (MiCA), granted by the Financial Supervision Commission (FSC). Bulgarian law adds a national layer to the regulation: it designates the supervisors, sets fees and the decision-making procedure, extends national fit-and-proper restrictions to beneficial owners, makes licensees obliged entities under anti-money-laundering law and closes the former registration regime. The requirements on capital, management, the application file and timelines are European, and a licensee may serve other EU Member States under a passport. Where this authorisation sits among the other Bulgarian financial regimes is set out in financial licences in Bulgaria.

The regime exists because MiCA has required an authorisation for crypto-asset services since 30 December 2024; in Bulgaria the transitional period for providers registered before that date ended on 1 July 2026. Before MiCA, the Bulgarian market ran on an AML registration with the National Revenue Agency (NRA). The Law on Markets in Crypto-Assets (Zakon za pazarite na kriptoaktivi, LMCA), promulgated in State Gazette No. 54 of 4 July 2025 and in force since 8 July 2025, replaced that registration with a licence and moved supervision to the FSC.

Three features set the Bulgarian route apart from neighbouring jurisdictions:

• Split competence: the FSC licenses service providers and issuers of asset-referenced tokens (ART), while issuers of e-money tokens (EMT) are supervised by the Bulgarian National Bank (BNB).
• Scale: the FSC register lists five providers, four licensed under Art. 63 MiCA and one investment firm under an Art. 60 notification, against 123 inbound passport notifications.
• State fees: both the licence fee and the annual fee depend on the class and the list of services.

Capital and timelines are set by MiCA; fees and the register are Bulgarian.

Who does what: the FSC and the BNB

The law builds supervision around the FSC. Under Art. 3 of the law, as amended in August 2026, the Commission is the competent authority under Art. 93 MiCA in every case except those expressly assigned to the BNB as supervisor of credit institutions and of EMT issuers. Every notification and every piece of information addressed to a competent authority under MiCA goes to the FSC (Art. 3(5)), as do white papers for crypto-assets other than ARTs and EMTs and applications from ART issuers.

Inside the FSC, the Commission itself grants, extends, refuses and withdraws licences, handles passport notifications and assesses qualifying holdings, acting on a proposal from the Deputy Chair heading the Investment Activity Supervision Division; every other competent-authority power belongs to that Deputy Chair directly.

The BNB keeps two sets of powers. For EMT issuers with their seat in Bulgaria it is the competent authority under Title IV MiCA: the rule sits in a new Chapter 10a of the Payment Services and Payment Systems Act (Art. 182a), and the LMCA itself does not apply to EMT issuers except for the Title VI MiCA market-abuse rules. The logic is that only a bank or an electronic money institution (EMI) may issue EMTs, and both are already supervised by the BNB.

For a bank that provides crypto-asset services or issues ARTs, the BNB exercises the MiCA powers over governance and the management body under Arts 33, 34(2), (4) and (12), 68(1)–(3) and 69 (Art. 1(2), item 9, of the Credit Institutions Act). The bank's Art. 60 notification is still filed with the FSC, and the BNB must withdraw the bank's permission to provide crypto-asset services if the FSC asks for it in a reasoned proposal (Art. 103(10) of that Act).

The allocation by type of entity looks like this.

For a project combining a stablecoin with an exchange service, this means two supervisors from day one.

The last row concerns the transfer rule. The FSC and its Deputy Chair supervise compliance with Regulation 2023/1113 on information accompanying crypto-asset transfers, and a provider licensed under the LMCA becomes an obliged entity under the Measures Against Money Laundering Act (MAMLA), except for its crypto-asset advice activity. New Art. 20a MAMLA requires providers to assess the risk of transfers to or from self-hosted addresses and to apply risk-based measures: identifying the address holder, requesting information on the origin and destination of the assets, and enhanced monitoring.

Procedure, capital and fees

The application path

The application is filed with the FSC under Art. 62 MiCA; from there the Art. 63 calendar applies, the same across the EU. Bulgarian law adds only a registration step, so the sequence is fixed by statute:

1. Within 5 working days the FSC acknowledges receipt.
2. Within 25 working days it checks completeness and, if needed, sets a deadline for missing information.
3. Within 40 working days of a complete application it adopts a reasoned decision.
4. Within 5 working days it notifies the applicant of the decision.
5. Within 7 days of receiving the licence the company applies to the Registry Agency to enter the activity in the Commercial Register.

If the FSC requests further information, the Art. 63(12) clock stops once only and for no more than 20 working days. The register dates give a practical measure. The first Art. 63 licence, decision 276-DUKA for Belayer, is dated 28 April 2026, almost ten months after the law entered into force.

A bank, investment firm, EMI or other institution listed in Art. 60 MiCA takes the short route: a notification with the Art. 60(7) information, FSC confirmation that it is complete, and activity starts without a separate licence. This is how the investment firm Alaric Securities entered the FSC register in December 2025.

Capital and fees by class

The licence class is set by the most demanding service applied for; it drives both the capital under Annex IV MiCA and the FSC fee under the current tariff.

The Annex IV amounts are a floor. Art. 67 MiCA requires the higher of that amount and one quarter of the previous year's fixed overheads, so for a class 1 provider with annual fixed costs above €200,000 the second figure sets the capital; how that base is computed after ESMA's Q&A 2349 is covered in the CASP licence guide. The same overheads base recurs across EU licence types, and the comparison between them is in regulatory capital.

The tariff prices the rest of a licence's life as well. Widening the scope later is charged separately: €6,135.50 from class 1 to class 2 and €18,917.80 from class 2 to class 3. Climbing in two steps therefore costs €30,166.22 against €30,677.51 for filing at class 3 at the outset, so an applicant who starts narrow and grows pays no premium for it. Surrender at the holder's own request is charged too, at €3,067.75, €5,112.92 and €10,225.84 by class. An Art. 60 notification is not free either: the FSC charges the same amount for examining it as for a licence of the corresponding class, and the same class-change fees apply; after that the notifying institution pays the annual supervision fee for each service it has notified.

The annual general supervision fee has two parts. The fixed part depends on the services in the licence and is due by 31 January; the variable part equals 0.03% of annual revenue, subject to a cap, and is due by 31 July.

Fees add up service by service: a licence covering transfers and exchange costs more to supervise than one covering advice and portfolio management, even within the same class.

Substance and fitness requirements

Art. 59(2) MiCA requires a registered office in a Member State where the provider carries out at least part of its services, a place of effective management in the EU and at least one EU-resident director. Substance is tested at those three points: where the company is registered, where it is actually managed from and where at least one director lives.

Bulgarian law adds its own list of restrictions to the European fit and proper test under Art. 68 MiCA. Art. 17 LMCA applies it to management body members, managers and holders of qualifying holdings, and also to beneficial owners: no conviction for an intentional crime of a general nature unless rehabilitated, no recent board seat in insolvent companies or in companies whose licence was withdrawn by the FSC, the BNB or a corresponding authority of another state, and the MAMLA restrictions on senior managers. These national requirements do not apply to institutions operating under an Art. 60 notification (Art. 17(4)).

Acquisitions of qualifying holdings are assessed by the FSC on the Art. 84 MiCA criteria — the acquirer's reputation and financial soundness, the repute and experience of the people who will direct the business, the provider's continuing ability to comply, and whether there are reasonable grounds to suspect money laundering or terrorist financing in connection with the acquisition. That closed list is the MiCA form of a test common to every EU financial licence, set out in qualifying holdings and fit and proper. The crypto section of the tariff prices that assessment separately: €1,500 for each direct acquirer of a holding below 50%, €2,900 for each direct acquirer of 50% or more, and €800 for each indirect acquirer and for each later increase of a holding.

What happened to NRA registrations

Before the law, crypto businesses registered in the NRA public electronic register under Art. 9a MAMLA. When the LMCA entered into force, the NRA stopped keeping the register and handed it to the FSC, which published it on 10 July 2025 as the register under § 5(3) of the law; Art. 9a MAMLA itself was repealed.

The transitional provisions split registrants into two groups. The dividing line is 30 December 2024, the date from which Title V MiCA applies.

Bulgaria gave the first group the maximum period Art. 143(3) MiCA allowed and closed it to the second: a registration obtained after MiCA started gave only three months to file an application.

The outcome shows in two registers. In November 2025 the § 5(3) register held just over 210 entries, about two dozen of them already marked as deleted. Today the FSC states on that register's page that entry in it confers no MiCA licence and no right to provide crypto-asset services. Four companies have received an FSC licence; three of them are former NRA registrants: Belayer, Digital Assist and Altcoins BG, which was entered in the NRA register in 2024 under its former name Lendix.

Companies sold with an NRA registration

Licensees and the passport

The FSC register of licensed providers held five entries as at 24 September 2026: four licences under Art. 63 MiCA and one investment firm entered on an Art. 60 notification. Each entry carries its decision number, the company's UIC and the exact list of services, so the scope of a Bulgarian counterparty's permission can be read off the register rather than off its website.

Only FF Digital holds the right to operate a trading platform, that is, class 3. The same five entries with home Member State BG appear in the ESMA interim register, which listed 362 providers in total in its file of 24 September 2026.

The passport works both ways. A Bulgarian licensee notifies the FSC of the countries and services under Art. 65 MiCA; within 10 working days the Commission forwards the information to the host regulators, and services may start on receipt of that communication or, at the latest, from the 15th calendar day after filing.

The inbound flow is far larger: the FSC's Art. 65 list as at 23 September 2026 shows 123 notifications from 117 providers in other Member States, the largest numbers from providers based in France (20) and Cyprus (17). Most regulated providers available to residents of Bulgaria are therefore licensed and supervised in other Member States.

EMT issuer: pairing an EMI (BNB) with a CASP (FSC)

For a single-currency stablecoin, Bulgaria's split competence becomes a structure with two permissions. Under Art. 48 MiCA only a bank or an EMI may issue EMTs, and anyone else may offer the token to the public or seek its admission to trading only with the issuer's written consent; in Bulgaria that means an EMI licence from the BNB, and the BNB also supervises the token issuer under Title IV MiCA. EMI status gives little on the crypto-services side: under Art. 60(4) MiCA an electronic money institution may, after a notification 40 working days in advance, only provide custody, administration and transfers of the EMTs it issues itself.

An issuer that wants to exchange tokens for money itself or run a venue prepares a second file, for the FSC, and meets two capital requirements. The issuer regime as a whole is covered in the article on ART and EMT issuance.

EU sanctions perimeter (Regulation 833/2014)

An applicant whose ultimate beneficial owners (UBOs) are connected to a sanctioned jurisdiction meets a constraint that sits outside both MiCA and Bulgarian law and that the FSC cannot waive. EU restrictive measures bear on a crypto-asset licence from two directions — who may be served and who may own the provider — and the operative text is Regulation 833/2014.

Regulation 2026/1848 also added Art. 5bc, which extends the same prohibition on transactions to providers and crypto platforms in third countries that the Council enters in Annex LVII as systematically failing to prevent sanctions circumvention through crypto services; in the consolidated text of 24 July 2026 that annex is empty.

For ownership and control there is one exception: Art. 5b(3) disapplies paragraphs 1, 2 and 2a for nationals of EU, EEA and Swiss states and for persons holding a temporary or permanent residence permit in those states. A Russian national without such status may not own or sit on the management of a Bulgarian provider of wallet, account or custody services since 18 January 2024 and, after Regulation 2026/1848, of a provider of any class from 25 August 2026. An owner holding an EU residence permit falls within the exception, but it does not replace the FSC assessment under Art. 68 MiCA and Art. 17 LMCA.

The client-side ban of Art. 5b(2) admits case-by-case authorisations by the competent authority under Art. 5c, for instance for basic needs, legal fees, diplomatic purposes or non-prohibited cross-border trade; these derogations do not extend to the ownership ban of Art. 5b(2a). Art. 5bb carries its own exemptions and allows authorisations strictly necessary for divestment from Russia or for winding down business there.

The Art. 5b(3) exception does not reach Art. 5r either: an EU company more than 40% owned, directly or indirectly, by Russian nationals, residents of Russia or Russian entities reports to its competent authority, within two weeks after each quarter, every transfer of funds out of the Union above €100,000 made in that quarter.