Crypto-funded debit card in Bulgaria

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Laundering Act covered virtual-asset providers through Article 4, items 38 and 39; the Markets in Crypto-Assets Act repealed those items from 1 July 2026, replaced them with item 19 (FSC-authorised crypto-asset service providers) and added definitions of crypto-asset, crypto-asset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).

Exchange between virtual assets and fiat currencies.

Transfer of virtual assets.

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).

National Revenue Agency (NRA) (Национална агенция за приходите - НАП)

Natural Persons: Name, date and place of birth, nationality, permanent address, unique identification number (e.g., national ID card, passport number). Identity must be verified using reliable, independent source documents or data (e.g., valid official identification document).

Legal Entities: Company name, legal form, registration number, registered address, and the names of the individuals authorized to represent the company. Verification involves obtaining extracts from commercial registers or similar official documents.

For legal entities, VASPs must identify the natural person(s) who ultimately own or control the customer, typically defined as holding 25% plus one share or more of the voting rights or exercising control via other means. This information must also be verified.

Regular scrutiny of transactions undertaken throughout the course of the business relationship to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Politically Exposed Persons (PEPs): Customers who hold or have held prominent public functions, their family members, or close associates.

High-Risk Third Countries: Transactions involving customers or beneficial owners from countries identified by the EU or FATF as having strategic AML/CFT deficiencies.

Complex, Unusual, Large Transactions, or Unusual Patterns: Transactions that have no apparent economic or lawful purpose.

Keeping customer documents, data, and information up-to-date.

MiCA and Bulgaria's Markets in Crypto-Assets Act do not set tax rules; the Act's only income-tax change (§ 20 of its transitional and final provisions) replaces "virtual currencies" with "crypto-assets" in Article 33(3) of the Income Taxes on Natural Persons Act and defines crypto-assets in § 1 item 63 of that Act by reference to the Markets in Crypto-Assets Act.

Tax Rate: 10% flat rate on the positive difference (gain) between the sale price and the acquisition price. This falls under income from the sale of "financial assets" or "other property" under the Personal Income Tax Act (ZDDLF - Закон за данъците върху доходите на физическите лица).

Exchange Services (Fiat-to-Crypto, Crypto-to-Fiat): The exchange of traditional currencies for virtual currencies (and vice-versa) is exempt from VAT (under the ZDDLS - Закон за данък върху добавената стойност). This is because the ECJ ruled that such transactions constitute a supply of services relating to currency, similar to traditional financial transactions, and thus fall under the VAT exemption for certain financial services.

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.

Outcome: Administrative fines, cessation of non-compliant activities, and potential criminal investigations in severe cases of money laundering.