BULGARIA Trends and Developments Contributed by: George Chisuse, Ivelin Vassilev and Stephany Valcheva, VC Law
Vassilev and Chisuse Law Firm 256A build., Mladost 2 District Sofia Bulgaria 1799
Tel: +359 89 913 7682 Email: office@vclaw.eu Web: www.vclaw.eu
Bulgaria’s new crypto framework is no longer a registration exercise The most important change for crypto businesses in Bulgaria is the move from a lighter, registration-based environment to full authorisation under MiCA. Existing providers that were active before the MiCA regime benefit from transitional arrangements, but this should not be treated as a permanent safe harbour. Bulgaria has opted for the full MiCA transitional period until 1 July 2026, meaning that existing providers need to use this time to prepare for authorisation rather than assume that previous registration is enough for long- term operation. The Bulgarian Markets in Crypto-Assets Act entered into force in 2025 and has since been supplemented by more detailed local rules. A particularly impor- tant development is Ordinance No 77 of 12 March 2026, which regulates the conditions and procedure for licensing and operation of issuers of asset-refer- enced tokens and crypto-asset service providers. It also covers internal organisation requirements and requirements for natural persons providing advice on crypto-assets. This matters because the licensing file is no longer just a corporate pack. The FSC will need to under- stand what the applicant will actually do, how it will do it, who will be responsible, which functions are outsourced, how risks are controlled and whether the business is capable of operating as a regulated financial-sector participant.
Building a Crypto Exchange in Bulgaria in 2026: What Founders Should Get Right Before Applying for a CASP Licence In 2026, the question “Can we launch a crypto exchange in Bulgaria?” no longer starts with the tech- nology. It starts with the operating model. A few years ago, many crypto projects were built first and legally reviewed later. That approach is now risky. The Market in Crypto Assets Regulation (MiCA) has changed the way crypto businesses are assessed across the EU, and Bulgaria has now adopted its own Markets in Crypto-Assets Act to support the local application of the Regulation. The Bulgarian Act governs, among other things, public offers of crypto- assets, admission to trading and the authorisation and supervision of crypto-asset service providers. The Financial Supervision Commission, or FSC, is the main authority for CASP authorisation and supervision in Bulgaria. This does not mean that Bulgaria has become closed to crypto business. Quite the opposite. Bulgaria can be a workable EU entry point for serious crypto- asset service providers, especially those that want access to the MiCA passport. But the new framework rewards preparation. A company that can explain its services, governance, outsourcing, custody model, ICT arrangements and client protection measures will be in a much better position than a company that approaches the licensing process with a broad pitch and a set of generic policies.
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