Bulgaria Compliance Report

Generated 2026-10-23

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Crypto-Assets Act the Financial Supervision Commission, National Revenue Agency, State Agency for National Security, Financial Intelligence Directorate, In Bulgaria the Financial Supervision Commission, European Central Bank
Primary Legislation: Markets in Crypto-Assets Act Art 3(1, Under Art 37 of Bulgaria's Markets in Crypto-Assets Act, FSC penalties for MiCA, Compliance with the Regulation on Digital Asset Service Providers (DASP), which, s personal income tax is governed by the Income Taxes on Natural Persons Act (SG No. 95/2006), not a, Bulgarian crypto regulation combines directly applicable MiCA with the national, Bulgaria's Markets in Crypto-Assets Act, in force 8 July 2025, regulates public
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: National Revenue Agency (NAP/NRA): The official body for tax administration in Bulgaria.. Website: https://nra.bg/ (Bulgarian). 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.. For U.S. tax purposes, a taxable crypto event includes selling or exchanging cryptocurrency for fiat or other crypto when a gain or loss is realized, and it also includes other taxable receipts such as mining, staking, airdrops, and payment for services at fair market value when received.. 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).

Key Facts

aml 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. Exchange between one or more forms of virtual assets. Transfer of virtual assets. Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets. Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset are subject to AML/CFT regulation and are treated as financial activities for regulated virtual asset and stablecoin issuers. 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).
enforcement 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. Legal Basis: EU sanctions are typically imposed through Council Decisions and implemented via Council Regulations. These Regulations are directly applicable in all EU Member States without the need for national transposition.
general The Measures Against Money Laundering Act (ЗМИП, SG No. 27/2018) is Bulgaria's principal AML/CFT statute; as amended by the Markets in Crypto-Assets Act (§ 18) it covers FSC-authorised crypto-asset service providers (Article 4, item 19) and requires them to assess and mitigate the risk of transfers to or from self-hosted addresses (Article 20a). Obligations: The ZMSIP mandates obliged entities (including VASPs) to: Apply CDD measures, including identification and verification of customers, and identify and verify beneficial owners in line with FinCEN’s CDD Rule and any applicable exceptive relief (i.e., not necessarily for every account opening or in all cases where relief applies). Monitor transactions for suspicious activity. In Bulgaria, suspicious transactions must be reported to the Financial Intelligence Directorate within the State Agency for National Security (SANS), in accordance with local AML/CTF law, not to U.S. authorities such as FinCEN. Implement internal policies, controls, and training related to AML/CFT and sanctions. Freeze assets of designated persons/entities and report these freezes. The Financial Supervision Commission now keeps both Bulgarian crypto registers: its register of MiCA-licensed CASPs (five entries) and the § 5(3) register of former NRA-registered VASPs, which the NRA closed on 8 July 2025 and which lists firms that hold no MiCA licence.
licensing 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)). The application process includes submitting detailed business plans, AML/KYC policies, and compliance with Bulgarian tax laws on digital asset transactions. 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. Compliance includes risk management frameworks, consumer protection measures, and transparent reporting of market activities. 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). Regular audits and continuous monitoring are necessary to ensure ongoing compliance. 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. Recent enforcement actions include penalties for a local exchange lacking proper AML controls, highlighting the importance of preemptive licensing compliance.
sanctions Legal Basis: EU sanctions are typically imposed through Council Decisions and implemented via Council Regulations. These Regulations are directly applicable in all EU Member States without the need for national transposition. EU sanctions apply in Bulgaria, but Bulgaria has imposed additional national restrictions, such as a temporary ban on fuel exports to other EU members following Lukoil sanctions, modifying the uniform application of EU sanctions within its jurisdiction. All natural and legal persons, entities, or bodies within the territory of the EU. Any legal person, entity, or body incorporated or constituted under the law of a Member State. Any natural or legal person, entity, or body in respect of any business done in whole or in part within the EU. Definition of "Funds" and "Economic Resources": EU sanctions regulations typically prohibit making "funds" and "economic resources" available to designated persons and entities. Post-AMLD5 and the Russia sanctions, cryptocurrencies are widely understood and treated as "funds" or "economic resources" for sanctions compliance purposes. Legal Reference: Council Regulation (EU) No 833/2014 (concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine), Article 5b, explicitly mentions the prohibition of providing crypto-asset wallet, account, or custody services to Russian persons/entities. Similar provisions can be found in other sanctions regimes. Council Regulation (EU) No 833/2014 (See Article 5b for crypto-related restrictions concerning Russia)
securities Bulgaria's Markets in Crypto-Assets Act (SG No. 54/2025), in force since 8 July 2025, supplements the directly applicable MiCA Regulation; virtual-asset providers registered with the NRA before 30 December 2024 could operate without authorisation until 1 July 2026 (§ 3(1)). Bulgarian securities-market infrastructure can offer crypto services: the Markets in Crypto-Assets Act inserted Article 227h1 into the Markets in Financial Instruments Act, allowing a central securities depository to provide custody and administration of crypto-assets for clients after notifying the FSC under MiCA Article 60(2). AML/CFT rules for crypto in Bulgaria come from the Measures Against Money Laundering Act as amended by the Markets in Crypto-Assets Act (§ 18) and from Regulation (EU) 2023/1113, not from MiCA; the Financial Supervision Commission licenses crypto-asset service providers (five licensed by 10 September 2026). MiCA (Regulation (EU) 2023/1114) applies directly in Bulgaria and is supplemented by the Markets in Crypto-Assets Act (SG No. 54/2025), which designates the Financial Supervision Commission as competent authority (Art 3(1)) and amended the Markets in Financial Instruments Act so investment firms may provide equivalent crypto-asset services after notifying the FSC under MiCA Article 60(3) (MiFIA Art 9(9)). Bulgaria's Markets in Crypto-Assets Act designates the Financial Supervision Commission as the MiCA competent authority (Art 3(1)) and, through Article 182a of the Payment Services and Payment Systems Act, the Bulgarian National Bank for e-money token issuers; the FSC authorises crypto-asset service providers under MiCA Article 63. Bulgarian law regulates crypto exchanges and token offerings: the 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 service providers (Art 1(1)), with the Financial Supervision Commission as competent authority (Art 3(1)). Bulgarian investment firms may provide crypto-asset services: the Markets in Crypto-Assets Act amended the Markets in Financial Instruments Act (Art 9(9)) to allow services equivalent to their licence after notifying the FSC under MiCA Article 60(3), and investment firm Alaric Securities was the first FSC-licensed crypto-asset service provider (22 December 2025). Bulgarian AML law is now tailored to crypto-asset service providers: the Markets in Crypto-Assets Act inserted Article 44a (due diligence before crypto correspondent relationships) and Article 50(2) (enhanced due diligence for crypto-asset services and transfers) into the Measures Against Money Laundering Act.
stablecoin Regulatory Landscape Overview: Bulgaria's regulatory environment for cryptocurrencies and digital assets, particularly stablecoins, is evolving under the MiCA (Markets in Crypto-Assets) regulation expected to be formally adopted by the European Commission in early 2023. Full implementation across all EU member states, including Bulgaria, is anticipated by mid-2024, with specific provisions for stablecoin issuance becoming enforceable thereafter. The regulation aims to provide a harmonized framework ensuring consumer protection, market integrity, and financial stability. Stablecoin issuers in Bulgaria do not get a licence from a 'National Bank of Bulgaria': ART issuers are authorised by the Financial Supervision Commission (Markets in Crypto-Assets Act Art 3), and the Bulgarian National Bank is competent authority for e-money token issuers seated in Bulgaria (PSPSA Art 182a). AML/KYC Obligations: Entities issuing or providing services related to stablecoins must adhere to comprehensive AML/KYC regulations. This includes customer due diligence, ongoing monitoring of transactions, and reporting suspicious activities to the Bulgarian Financial Intelligence Unit (FIU). For ART issuers and crypto-asset service providers, enforcement in Bulgaria lies with the Financial Supervision Commission: its Deputy Chairperson can order remedial measures (Markets in Crypto-Assets Act Art 27) and issues penalty decrees (Art 45); e-money token issuers are supervised by the BNB. Tax Implications: Income generated from stablecoin transactions is subject to corporate income tax in Bulgaria. Specific guidance on cryptocurrency taxation is expected post-MiCA implementation, impacting how stablecoin earnings are reported and taxed. Bulgaria's national MiCA act, the Markets in Crypto-Assets Act, entered into force on 8 July 2025; on 14 October 2026 ESMA's interim registers listed no Bulgarian e-money token issuer and no asset-referenced token issuer from any member state. Applications from asset-referenced token issuers seated in Bulgaria go to the Financial Supervision Commission, which exercises the MiCA Art 18 and Art 21 authorisation powers (Markets in Crypto-Assets Act Art 3(3)); e-money token issuers fall under the Bulgarian National Bank (PSPSA Art 182a). There is no 'NBB'. Capital Adequacy Standards: Stablecoin issuers are required to maintain adequate capital buffers to safeguard against market risks and ensure the redeemability of stablecoins. Specific capital requirements will be outlined in MiCA-compliant guidelines from the NBB.
status Progressive rates ranging from 10% up to 10% on the highest income brackets. Specific rates apply to various types of income (e.g., salaries, pensions, capital gains). Tax is levied on worldwide income for tax residents. A resident is defined by the “substantial presence” test or habitual residence within Bulgaria. Includes wages, self‑employment earnings, rental income, and foreign sourced income. Deductions for business expenses, social security contributions, and certain allowances are permitted. Standard deductions and personal allowances reduce taxable income. Special incentives exist for education, child care, and renewable energy investments.
tax National Revenue Agency (NAP/NRA): The official body for tax administration in Bulgaria. Website: https://nra.bg/ (Bulgarian) 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. For U.S. tax purposes, a taxable crypto event includes selling or exchanging cryptocurrency for fiat or other crypto when a gain or loss is realized, and it also includes other taxable receipts such as mining, staking, airdrops, and payment for services at fair market value when received. 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). Taxable Gain = Sale Price - Acquisition Price The acquisition price includes all costs directly related to acquiring the crypto (e.g., purchase price, trading fees). Losses: Losses from the sale of cryptocurrencies can generally offset gains from the sale of other cryptocurrencies within the same tax year. However, losses from cryptocurrency sales typically cannot be offset against other types of income.
travel rule Regulation (EU) 2023/1113 (the recast Transfer of Funds Regulation) has applied directly in Bulgaria since 30 December 2024; under Article 20 of the Markets in Crypto-Assets Act (SG No. 54/2025) the Financial Supervision Commission monitors compliance with its Chapters I, III, V and IX for crypto-asset transfers and receives all notifications under them. Before the Markets in Crypto-Assets Act, virtual-asset service providers were obliged entities under Article 4, items 38 and 39 of the Measures Against Money Laundering Act and registered in the National Revenue Agency's public register under its Article 9a; the Act discontinued that register on its entry into force (§ 5(1)) and repealed Article 9a (§ 18, item 3). The EU Transfer of Funds Regulation as amended by Regulation (EU) 2023/1113 extends the Travel Rule to crypto‑asset transfers, and these requirements have applied in the EU (including Bulgaria) since 30 December 2024. Bulgaria's Measures Against Money Laundering Act (SG No. 27/2018) makes crypto-asset service providers authorised under the Markets in Crypto-Assets Act obliged entities, except for crypto-asset advice (Article 4, item 19, inserted by § 18 of the Markets in Crypto-Assets Act, SG No. 54/2025). For crypto-asset transfers between EU Crypto-Asset Service Providers (CASPs) under Regulation (EU) 2023/1113, there is no de minimis threshold: all such transfers, regardless of amount, must include complete originator and beneficiary information. However, the EU framework now distinguishes these CASP‑to‑CASP transfers from transactions involving self‑hosted wallets, for which additional rules apply above €1,000, so any description of the regime should situate the zero‑threshold rule within this broader, MiCA‑aligned CASP/Transfer of Funds Regulation context rather than as a generic VASP rule. The travel rule for crypto-asset transfers, including transfers to and from self-hosted addresses involving a CASP, has applied in Bulgaria since 30 December 2024 under Regulation (EU) 2023/1113, and § 3(3) of the Markets in Crypto-Assets Act required NRA-registered firms operating under the transition to apply that Regulation as well. CASPs must collect originator and beneficiary information for all transfers. For transfers exceeding €1,000, the CASP must verify that the unhosted wallet is owned or controlled by the originator or beneficiary.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-10-14. View full profile