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Bulgaria
BGschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 27 sourced
findings · 24 sources in the cumulative register
8Categoriesbaseline.
27Findings.claims[]
8Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix(sums to 8 rendered categories; click to filter)
No categories moved this cycle.
Jurisdiction lead brief
Lead Signal
Bulgaria's transitional grandfathering period for National Revenue Agency-registered virtual-asset providers expired on 1 July 2026, closing the dual-track regime that had allowed pre-existing providers to continue operating alongside the new Crypto-Asset Markets Act (MICAL) licensing framework. From that date, a Financial Supervision Commission (FSC) MiCA licence is the sole lawful basis for crypto-asset service provider (CASP) operation in Bulgaria, and unlicensed operation now exposes a provider to FSC sanctions of up to 6.25 percent of annual turnover for a first violation.
Other Developments
Token classification moved onto a clear statutory footing this cycle: MICAL sorts crypto-assets into asset-referenced tokens, electronic-money tokens, and other crypto-assets, mirroring the EU MiCA taxonomy and replacing Bulgaria's prior undifferentiated treatment of virtual currencies.
Stablecoin supervision remains split between two authorities, with the framework only partially settled: the Bulgarian National Bank, rather than the FSC, is the competent authority for electronic-money-token issuers, but as of the most recent source located this cycle the BNB had not yet finalised its EMT-specific secondary legislation, leaving implementing detail pending even though the primary supervisory allocation is already in force.
Consumer protection enforcement powers are strong on paper: the FSC may block websites or apps offering unlicensed crypto services without prior court approval in urgent cases. No enforcement track record exercising this power was located this cycle, so the practical consumer-protection posture remains unobserved even as the statutory authority is confirmed.
Cross-Monitor Connections
This cycle's crypto-licensing tightening in Bulgaria intersects with the broader EU AML architecture being tracked by financial-integrity monitoring, given MiCA-aligned CASP supervision typically carries harmonised customer-due-diligence expectations; that AML-specific analysis is not repeated here. Similarly, the electronic-money-token supervisory split between the FSC and the Bulgarian National Bank has direct relevance to payments-sector monitoring of stablecoin and digital-money frameworks, where BNB's EMT-supervisor role is the key structural fact to carry forward without re-analysis here.
Outlook
The clearest gap to close next cycle is evidence of the FSC's actual enforcement posture against CASPs that failed to secure a licence by the 1 July 2026 deadline. The BNB's still-pending EMT secondary legislation is the second item to watch, since it determines how concretely Bulgaria's stablecoin-supervision framework will operate in practice.
8 of 8 categories
Signal
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Bulgaria's Crypto-Asset Markets Act (MICAL) transposes MiCA; the transitional grandfathering period for NRA-registered virtual-asset providers expired 1 July 2026, making MiCA licensing via the FSC the sole lawful basis for CASP operation in Bulgaria.
Standing sub-brief87 words · last cycle 2026-09-02
Crypto Licensing
All crypto-asset service providers must hold an FSC MiCA licence to operate lawfully in Bulgaria. The transitional grandfathering period for NRA-registered virtual-asset providers expired 1 July 2026, and unlicensed operation now exposes a provider to FSC sanctions of up to 6.25 percent of annual turnover (12.5 percent for repeat violations). No enforcement track record against providers that failed to obtain a licence by the deadline was located this cycle.
Outlook
The next observable milestone is evidence of actual FSC enforcement against unlicensed post-deadline CASP activity.
Periodic update · new data 2026-09-21
Crypto Licensing
Bulgaria's crypto-asset licensing regime completed its structural transition this cycle. CASP authorisation from the Financial Supervision Commission is now required to lawfully provide crypto-asset services in Bulgaria, following the closure of the legacy National Revenue Agency Article 9a AML-register transitional pathway on 1 July 2026. This is a Confirmed finding, anchored by Tier-3 law-firm commentary corroborating the underlying Bulgarian Markets in Crypto-Assets Act, though the FSC's own primary page was not directly retrieved this pass.
The FSC issued its first MiCA CASP licence, to Alaric Securities, in April 2026, confirming the regime is operationally live. This finding is rated Probable, resting on a single Tier-4 vendor-blog source without independent corroboration.
The module tracker for crypto_licensing carries an amber traffic light this cycle: the regime is fully in force and operational, but the legacy-registrant transition has only just closed, and residual transition risk, entities that may not have completed authorisation in time, remains an open question. The primary framework is Regulation (EU) 2023/1114 (MiCA) together with the Bulgarian Markets in Crypto-Assets Act, with the Financial Supervision Commission as supervisory authority.
Outlook
The outlook for this module centres on how the FSC handles any legacy registrant that did not complete authorisation before the 1 July 2026 deadline. Watch for enforcement or licence-refusal action against such entities as the clearest signal of how strictly the closed transitional pathway is being enforced.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (3)
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Crypto-asset service providers must obtain authorisation under Article 63 of MiCA from the Financial Supervision Commission (or the Bulgarian National Bank for relevant credit institutions) before providing crypto-asset services in Bulgaria.retrieved M5bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Entities listed in Bulgaria's VASP register between 30 December 2024 and 8 July 2025 (entry into force of the Bulgarian MiCA implementing Act) were required to submit a MiCA Article 63 authorisation application by 8 October 2025 to benefit from the national 18-month grandfathering period.retrieved M4bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Since the EU-wide MiCA transitional period ended on 1 July 2026, any entity providing crypto-asset services in Bulgaria without MiCA authorisation is in breach of EU law and must cease such services.retrieved M5bindingin force
Bulgaria transposes MiCA's tripartite crypto-asset taxonomy (asset-referenced tokens, e-money tokens, and other crypto-assets) without a distinct national classification scheme. The FSC applies ESMA's Guidelines on the qualification of crypto-assets as financial instruments to delineate MiCA-scope tokens from MiFID II-scope securities, implementing them through the national MiCA-transposing legislation rather than separate guidance.
Standing sub-brief63 words · last cycle 2026-08-21
Token Classification
MICAL classifies crypto-assets into asset-referenced tokens, electronic-money tokens, and other crypto-assets, mirroring the taxonomy of the EU MiCA Regulation. This statutory taxonomy is now in force and replaces Bulgaria's prior undifferentiated treatment of virtual currencies.
Outlook
No change to this taxonomy is expected absent an EU-level MiCA amendment; no BG-specific delta was identified this cycle beyond the taxonomy's entry into force.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (4)
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — MiCA defines asset-referenced tokens (ARTs) as crypto-assets purporting to maintain a stable value by referencing another value, right, or combination thereof (including fiat currencies), distinct from e-money tokens, with issuance subject to Title III authorisation.retrieved M4bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — MiCA defines e-money tokens (EMTs) as crypto-assets purporting to maintain a stable value by referencing a single official currency; only credit institutions or authorised e-money institutions may issue them, supervised in Bulgaria by the Bulgarian National Bank.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Crypto-assets other than asset-referenced tokens and e-money tokens (e.g. utility-type tokens) are subject to Title II MiCA offeror/admission-to-trading obligations, including white paper publication, unless a specific exemption applies.retrieved M3bindingin force
T2 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — The Bulgarian FSC applies ESMA's Guidelines on the conditions and criteria for qualifying crypto-assets as financial instruments through Bulgarian national legislation transposing MiCA, delineating MiCA-scope crypto-assets from MiFID II financial instruments.retrieved M3bindingin force
Neither MiCA nor Bulgaria's national implementing legislation establishes a dedicated licensing or prudential regime for on-chain activities such as staking, DeFi lending, mining, node operation, or validator services as distinct categories. These activities are only indirectly captured where they fall within MiCA's existing CASP service categories (e.g., custody and administration, or portfolio management of crypto-assets); genuinely decentralised, non-intermediated activity generally falls outside MiCA's scope by recital exclusion. This is a jurisdiction-wide (EU-level) gap rather than a Bulgaria-specific omission.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (3)
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Bulgaria has not enacted, and MiCA does not include, a dedicated licensing or prudential regime specific to crypto-asset staking; staking service providers fall under general CASP categories only where they constitute 'custody and administration' or portfolio management services under MiCA.retrieved M2non-bindinga fact about the regime
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — No Bulgaria-specific or MiCA-level licensing regime exists for crypto-asset mining activity; mining is not treated as a regulated crypto-asset service under the national or EU framework.retrieved M2non-bindinga fact about the regime
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Fully decentralised finance (DeFi) activity without an identifiable intermediary generally falls outside MiCA's scope, leaving DeFi lending largely unregulated at both the Bulgarian and EU level pending future rulemaking.retrieved M2non-bindinga fact about the regime
MiCA Titles III and IV impose a comprehensive stablecoin regime directly applicable in Bulgaria. Asset-referenced token (ART) issuers require FSC authorisation; e-money token (EMT) issuance is restricted to credit institutions or authorised e-money institutions supervised by the Bulgarian National Bank. Both token types carry reserve-of-assets, redemption-right, and disclosure obligations.
Standing sub-brief74 words · last cycle 2026-08-21
Stablecoin Regime
The Bulgarian National Bank (BNB), rather than the FSC, is the competent authority for issuers of electronic-money tokens (EMTs) under MICAL. This supervisory allocation is settled in statute, but as of the most recent source located this cycle the BNB had not yet updated its EMT-specific secondary legislation, leaving implementing detail pending.
Outlook
Whether the BNB finalises its EMT secondary legislation is the key item to track for this domain next cycle.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (5)
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Issuers of asset-referenced tokens must obtain prior authorisation from the competent authority (the FSC in Bulgaria) before offering ARTs to the public or seeking admission to trading, per Title III MiCA.retrieved M5bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Only credit institutions or authorised electronic money institutions may issue e-money tokens in Bulgaria, subject to supervision by the Bulgarian National Bank under MiCA Title IV.retrieved M5bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — MiCA Article 36 obliges issuers of asset-referenced tokens to constitute and manage a reserve of assets matching the claims of token holders at all times.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — MiCA grants holders of asset-referenced and e-money tokens a permanent right of redemption at par value against the issuer.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Issuers of e-money tokens are liable for the information given in the mandatory crypto-asset white paper under MiCA Article 52.retrieved M3bindingin force
Consumer protection for crypto-asset holders and CASP clients in Bulgaria runs through directly-applicable MiCA obligations: mandatory white paper disclosure (now in machine-readable iXBRL format since 23 December 2025), restrictions on marketing communications, custody segregation duties for CASPs, and mandatory complaint-handling procedures. ESMA and NCAs, including the FSC, also issue public verification guidance directing consumers to the Interim MiCA Register.
Standing sub-brief58 words · last cycle 2026-08-21
Consumer Protection
The FSC may block websites or apps offering unlicensed crypto-asset services without prior court approval in urgent cases, a strong statutory enforcement power under MICAL. No enforcement track record exercising this power was located this cycle.
Outlook
Whether the FSC begins exercising this blocking power in practice is the key consumer-protection item to watch next cycle.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (5)
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — MiCA requires issuers/offerors of crypto-assets to publish a crypto-asset white paper containing risk disclosures before public offers or admission to trading, with iXBRL machine-readable formatting mandatory since 23 December 2025.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Marketing communications relating to a public offer of crypto-assets must be fair, clear and non-misleading and consistent with the crypto-asset white paper, and may not be disseminated before the white paper's publication.retrieved M3bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — CASPs providing custody and administration of crypto-assets on behalf of clients must safeguard clients' assets and keep them segregated from the CASP's own assets under MiCA Title V custody obligations.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — CASPs must establish and maintain effective and transparent procedures for the prompt handling of client complaints under MiCA Title V.retrieved M3bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — ESMA and national competent authorities advise consumers to verify that a crypto-asset service provider is listed as MiCA-authorised in the ESMA Interim MiCA Register before investing or transferring funds, given that MiCA protections apply only to the specific authorised legal entity.retrieved M3non-binding
Bulgaria has no crypto-specific tax code; digital-asset gains are absorbed into the general flat-rate personal/corporate income tax system based on 2014 National Revenue Agency (NRA) administrative guidance that has not been publicly superseded. Layered on top from 1 January 2026 is the EU-wide DAC8 crypto-asset reporting regime, which is directly binding regardless of any gap in Bulgaria-specific guidance updates.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (4)
T4 · CoinDeskCoinDesk — Bulgaria's National Revenue Agency has guided that gains from the sale of digital currencies such as bitcoin are treated as income from the sale of financial assets and taxed at Bulgaria's flat 10% rate.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Bulgarian tax authorities' 2014 guidance indicated that gains realized on using crypto to purchase goods were not separately taxed as a distinct acquisition-stage gain, with taxable income instead arising from the net sum of gains and losses on realized transactions during the tax year.retrieved M2non-binding
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — From 1 January 2026, Council Directive (EU) 2023/2226 (DAC8) requires crypto-asset service providers, including those established in Bulgaria, to comply with reporting and due-diligence obligations and to have their data automatically exchanged with other EU Member States' tax authorities.retrieved M5bindingin force
T4 · CoinDeskCoinDesk — As of mid-2014, Bulgaria had not settled its VAT treatment of bitcoin-for-fiat exchange transactions, pending the outcome of a Swedish referral to the European Court of Justice on whether such exchange services are VAT-exempt.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
Bulgaria's cross-border crypto-asset framework combines MiCA's single-market passporting regime for authorised CASPs, the crypto-asset 'travel rule' under Regulation (EU) 2023/1113, and DAC8's cross-border tax-data exchange. No Bulgaria-specific outbound capital restriction on crypto-assets was identified.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (3)
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — A CASP authorised in Bulgaria under MiCA benefits from an EU passporting right allowing it to provide crypto-asset services across all EU/EEA Member States without separate host-state authorisation.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Under DAC8, Bulgarian crypto-asset service providers must report user transaction data for automatic cross-border exchange with tax authorities in other EU Member States, with the first exchange occurring within nine months of year-end from 1 January 2026.retrieved M4bindingin force
T1 · EUR-Lex / Publications Office of the European UnionEUR-Lex / Publications Office of the European Union — Regulation (EU) 2023/1113 requires crypto-asset service providers established in Bulgaria to accompany crypto-asset transfers with originator and beneficiary information (the 'travel rule'), applicable since 30 December 2024 alongside MiCA.retrieved M4bindingin force
Crypto AML/CFT obligations are out of scope for this baseline: the crypto consumer subscribes to the FIM aml_ctf module and AML-specific claims are not produced here. For disambiguation context only: Bulgaria's AML framework for virtual-asset service providers runs through the Law on Measures against Money Laundering (LMML), with the Financial Intelligence Directorate (FID-SANS) and, per MONEYVAL's follow-up assessment, some technical deficiencies remain around VASP-specific supervision, new-technology risk assessment, and fit-and-proper checks.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
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Publication gate
Blocking. 1 failing check(s).
schema_valid
FAIL
min_quoted_text_present
waived — floor 0%
egress_verified
pass
every_practical_object_has_source_id
n/a — no subject in this jurisdiction
source_tier_integrity_ok
pass
jurisdiction_source_floor_met
pass
tier_a_b_national_primary_pct
78.57
aggregator_only_jurisdiction_count
0
manual_override
Editorial metadata
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Editorial metadata for Bulgaria
Field
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trust.lawyer_review.status
never_reviewed
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no reviewer on record
trust.content_source
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Provenance and declared absence
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