Is Crypto Legal in Bulgaria?

Crypto exchanges and custodians in Bulgaria need authorisation from the Financial Supervision Commission under MiCA (Markets in Crypto-Assets Act Art 3(1)); the National Revenue Agency only ran an AML registration under MAMLA Art 9a, closed on 8 July 2025 (§ 5(1)).

In Bulgaria the Financial Supervision Commission is the competent authority for offerors and persons seeking admission to trading of crypto-assets, issuers of asset-referenced tokens and crypto-asset service providers (Markets in Crypto-Assets Act Arts 1(1), 3(1)); e-money token issuers fall under the BNB.

Since 8 July 2025 crypto-asset service providers authorised under Bulgaria's Markets in Crypto-Assets Act are obliged entities under the Measures Against Money Laundering Act (Art 4 item 19), which now cites the crypto travel rule Regulation (EU) 2023/1113 and adds risk measures for transfers to or from self-hosted addresses (Art 20a).

Under Art 37 of Bulgaria's Markets in Crypto-Assets Act, FSC penalties for MiCA breaches reach BGN 700,000 for natural persons and, for legal persons, the higher of BGN 5,000,000 or 1.5%, 6.25% or 2.5% of annual turnover depending on the MiCA provision; amounts are written in BGN in the FSC translation.

Individuals' income from crypto-assets is taxed under Article 33(3) of Bulgaria's Income Taxes on Natural Persons Act, which since § 20 of the Markets in Crypto-Assets Act (SG No. 54/2025) refers to 'crypto-assets' instead of 'virtual currencies', with 'crypto-assets' defined by reference to that Act.

The Measures Against Money Laundering Act (SG No. 27/2018) remains Bulgaria's AML/CFT statute for crypto businesses: the Markets in Crypto-Assets Act (SG No. 54/2025), in force since 8 July 2025, amended it in § 18 to add FSC-authorised crypto-asset service providers as obliged entities (Article 4, item 19), repeal the NRA register (Article 9a) and repeal the former VASP items 38 and 39 from 1 July 2026.

The Measures Against Money Laundering Act covered virtual-asset providers through Article 4, items 38 and 39; the Markets in Crypto-Assets Act repealed those items from 1 July 2026, replaced them with item 19 (FSC-authorised crypto-asset service providers) and added definitions of crypto-asset, crypto-asset service provider and self-hosted address (Supplementary Provisions § 1, items 33–35).

SANS does not supervise crypto-asset service providers: under the Markets in Crypto-Assets Act the Financial Supervision Commission authorises and supervises them (Art 3(1)) and monitors their crypto-transfer compliance under Regulation (EU) 2023/1113 (Art 20), and only notifies SANS when it starts enforcing a coercive administrative measure (Art 24).

The National Revenue Agency no longer registers or supervises VASPs: on 8 July 2025 it discontinued its MAMLA Art 9a register and handed it to the FSC (Markets in Crypto-Assets Act § 5(1)–(2)), and firms on that list are under FSC supervision during the transition (§ 3(4)).

Until 8 July 2025 Bulgarian VASPs had to register with the National Revenue Agency under Article 9a of the Measures Against Money Laundering Act; the Markets in Crypto-Assets Act repealed Article 9a, the NRA discontinued the register on the Act's entry into force (§ 5(1)) and pending registration proceedings were terminated (§ 4).

Since 1 July 2026 the Measures Against Money Laundering Act no longer has a separate virtual-asset provider category: items 38 and 39 of Article 4 were repealed, and custody and administration of crypto-assets makes a firm an obliged entity only as a crypto-asset service provider authorised under the Markets in Crypto-Assets Act (Article 4, item 19).

Registration with the National Revenue Agency (НАП) under the Measures Against Money Laundering Act was an AML registration, not a licence; under § 3(1) of the Markets in Crypto-Assets Act, firms registered before 30 December 2024 could continue without MiCA authorisation only until 1 July 2026.

Registration of crypto businesses with the National Revenue Agency under Article 9a of the Measures Against Money Laundering Act ended when the Markets in Crypto-Assets Act entered into force on 8 July 2025 (§ 5(1)); crypto-asset service providers now need FSC authorisation under MiCA Article 63, and providers registered after 30 December 2024 had to apply within three months (§ 3(2)).

The Measures Against Money Laundering Act was promulgated in the State Gazette (Държавен вестник) No. 27 of 2018 and has been amended many times, including by the Markets in Crypto-Assets Act (SG No. 54/2025, § 18).

The NRA's VASP register closed when the Markets in Crypto-Assets Act entered into force on 8 July 2025 (§ 5(1)); the FSC now publishes it as the § 5(3) register, which on 14 October 2026 listed about 210 former NRA-registered firms, roughly 47 of them marked cancelled, none holding a MiCA licence.

Segregation of client crypto-assets and funds by crypto-asset service providers in Bulgaria is governed directly by MiCA (Regulation (EU) 2023/1114, Articles 70 and 75), not transposed; the Markets in Crypto-Assets Act makes the Financial Supervision Commission the competent authority (Art 3(1)) and sets pecuniary sanctions for breaches of MiCA Articles 59–83 (Art 37(4)).

VASP registration under the Measures Against Money Laundering Act ended on 8 July 2025 (Markets in Crypto-Assets Act § 5); crypto-asset service providers now need FSC authorisation under MiCA, whose prudential requirements (Article 67) can be met with own funds, an insurance policy or a combination of both.

The Financial Supervision Commission (Комисия за финансов надзор) is Bulgaria's MiCA competent authority (Markets in Crypto-Assets Act Art 3(1)); its register lists five licensed CASPs, authorised by decisions dated 22 December 2025 to 10 September 2026, the same five ESMA lists with Bulgaria as home state.

Bulgaria implemented MiCA nationally through the Markets in Crypto-Assets Act (Закон за пазарите на криптоактиви), promulgated in State Gazette No. 54 of 4 July 2025 and in force since 8 July 2025, which sets out authorisation, supervision, penalties (Arts 37–47) and transitional rules (§§ 3–6).

Bulgaria's Markets in Crypto-Assets Act entered into force on 8 July 2025; it designates the FSC as competent authority for CASPs (Art 3(1)), with authorisation decisions under MiCA Art 63 and penalty decrees issued by the FSC Deputy Chairperson in charge of investment supervision (Arts 3(3)–(4), 45).

The Markets in Crypto-Assets Act (SG No. 54/2025, in force 8 July 2025) amended the Financial Supervision Commission Act (§ 12), the Payment Services and Payment Systems Act (§ 9) and the Measures Against Money Laundering Act (§ 18) to give the FSC and the BNB their MiCA powers; it took effect after MiCA's 30 December 2024 application date.

The BNB is not Bulgaria's supervisor of crypto service providers: the Markets in Crypto-Assets Act makes the Financial Supervision Commission the MiCA competent authority (Art 3(1)), adds authorised CASPs to the obliged entities of the Measures Against Money Laundering Act (Art 4 item 19) and repeals the NRA's VASP register (Art 9a); the BNB's crypto role covers e-money token issuers (PSPSA Art 182a).

The Bulgarian National Bank supervises anti-money-laundering and counter-terrorist-financing compliance in the banking sector and, under Article 122(1)–(2) of the Measures Against Money Laundering Act (ZMIP), publishes the enforced administrative measures and penalty decrees it has imposed on banks for breaches of that Act.

The Bulgarian National Bank is the competent authority under MiCA Title IV for issuers of e-money tokens with a registered office in Bulgaria, under Article 182a of the Payment Services and Payment Systems Act inserted by § 9 of the Markets in Crypto-Assets Act (SG No. 54/2025).

The Financial Supervision Commission is the Bulgarian competent authority for issuers of asset-referenced tokens: Art 3(3) of the Markets in Crypto-Assets Act assigns it the MiCA powers under Arts 17–25 and 35 (ART authorisation and own funds), and Art 3(1) names it the Article 93 competent authority.

In Bulgaria the Financial Supervision Commission authorises and supervises crypto-asset service providers and issuers of asset-referenced tokens (Markets in Crypto-Assets Act Art 3(1)); the Bulgarian National Bank is competent only for issuers of e-money tokens (Act Art 1(2); PSPSA Art 182a).

Since 1 July 2026 only CASPs licensed by Bulgaria's Financial Supervision Commission, or authorised in another EU state and passported into Bulgaria, may provide crypto-asset services in Bulgaria; ESMA's register on 14 October 2026 showed 5 Bulgarian-authorised CASPs and 175 CASPs passporting into Bulgaria.

The Bulgarian National Bank is the competent authority for e-money token issuers seated in Bulgaria (PSPSA Art 182a, inserted by MCAA § 9) and Bulgaria's Article 96 MiCA cooperation authority with the EBA and ESMA for those issuers (Art 182a(2)).

MiCA alignment was enacted by the National Assembly in the Markets in Crypto-Assets Act (SG No. 54/2025), which inserted Article 182a into the Payment Services and Payment Systems Act making the Bulgarian National Bank the competent authority only for e-money token issuers with a registered office in Bulgaria; the Financial Supervision Commission is the competent authority for all other MiCA matters (Art 3(1)).

Bulgaria's Payment Services and Payment Systems Act (SG No. 20/2018) governs payment and e-money institutions; Article 182a, inserted by the Markets in Crypto-Assets Act (§ 9), makes the Bulgarian National Bank the competent authority under MiCA Title IV for e-money token issuers with a registered office in Bulgaria.

Bulgaria has not implemented the EU Anti-Money Laundering Regulation (EU) 2024/1624, which applies directly from 10 July 2027; until then crypto-asset service providers are obliged entities under the Measures Against Money Laundering Act, Article 4, item 19, inserted by the Markets in Crypto-Assets Act (SG No. 54/2025, § 18).

Bulgaria's Markets in Crypto-Assets Act (SG No. 54/2025) governs offers to the public and admission to trading of crypto-assets and the authorisation and supervision of crypto-asset issuers and CASPs (Art 1(1)), and requires white papers and marketing communications offered in Bulgaria to be in Bulgarian or a language customary in international finance (Art 4).

Virtual-asset providers in Bulgaria registered with the National Revenue Agency, not SANS; since 8 July 2025 the Financial Supervision Commission authorises crypto-asset service providers and monitors their compliance with Regulation (EU) 2023/1113 on crypto transfers (Markets in Crypto-Assets Act Art 20), notifying SANS when it starts enforcing a coercive administrative measure (Art 24).

The Financial Supervision Commission is Bulgaria's MiCA competent authority (Markets in Crypto-Assets Act Art 3(1)); most MiCA powers are exercised by the FSC Deputy Chairperson in charge of the Investment Supervision Directorate, with listed decisions taken by the Commission on that Deputy Chairperson's proposal (Art 3(3)–(4)).

Bulgaria's current Measures Against Money Laundering Act was promulgated in State Gazette No. 27 of 2018; the Markets in Crypto-Assets Act (SG No. 54/2025, § 18) amended it to make FSC-authorised crypto-asset service providers obliged entities (Article 4, item 19).

Bulgarian virtual-asset providers registered with the National Revenue Agency under Article 9a of the Measures Against Money Laundering Act, not with SANS; the Markets in Crypto-Assets Act repealed Article 9a and closed that register on 8 July 2025, and FSC-authorised crypto-asset service providers are now obliged entities under Article 4, item 19.

Crypto-asset services are lawful in Bulgaria only with MiCA authorisation: since 1 July 2026 only crypto-asset service providers licensed by the Financial Supervision Commission (or EU CASPs passporting in) may provide them, and the FSC had licensed five Bulgarian CASPs between 22 December 2025 and 10 September 2026.

Bulgarian VASPs (Measures Against Money Laundering Act Art 4 items 38–39) registered with the National Revenue Agency under MAMLA Art 9a, not with the State Agency for National Security; the Markets in Crypto-Assets Act repealed Art 9a (§ 18 item 3) and items 38–39 from 1 July 2026, replacing registration with FSC authorisation under MiCA.

Operating a crypto exchange in Bulgaria requires authorisation as a crypto-asset service provider by the Financial Supervision Commission under MiCA and the Markets in Crypto-Assets Act (Art 3(1)); the former NRA registration under the Measures Against Money Laundering Act gave transitional rights only until 1 July 2026 (§ 3(1)).

Bulgaria used MiCA's transitional period: VASPs registered with the NRA before 30 December 2024 could keep operating without authorisation until 1 July 2026 or an earlier FSC decision (Markets in Crypto-Assets Act § 3(1)); since 1 July 2026 only FSC-licensed CASPs or CASPs passported from another EU state may serve Bulgarian clients.

Since the Markets in Crypto-Assets Act (SG No. 54/2025) the FSC sanctions MiCA breaches under Article 37 (natural persons BGN 1,400 to 700,000; legal persons up to the higher of BGN 5,000,000 or 1.5% to 6.25% of annual turnover, depending on the provision) and travel-rule breaches under Article 39; on its § 5(3) list of former NRA-registered VASPs the FSC has cancelled 47 registrations by decisions dated 12 August 2025 to 24 June 2026. Amounts are stated in BGN as written in the Act; Bulgaria adopted the euro on 1 January 2026 at 1.95583 BGN per EUR.