Mica CASP Authorisation in Bulgaria Complete Guide for Vasps

Introduction What This Guide Covers and Who Should Read It

Bulgaria has emerged as one of the most compelling jurisdictions for crypto-asset service providers seeking MiCA CASP authorisation within the European Union. This guide is designed for crypto founders, VASP operators and compliance leads who need a clear, actionable roadmap for obtaining a CASP licence through the Bulgarian Financial Supervision Commission (FSC), structuring a Bulgarian entity and leveraging the country’s 10 % corporate tax regime as a cost-effective EU entry point. Whether you are converting an existing pre-registration or applying for the first time, the information below walks you through regulatory requirements, documentation, fees, timelines, and post-authorisation obligations with direct references to primary EU and Bulgarian sources.

Quick Summary: MiCA CASP in Bulgaria

• National Competent Authority: The Financial Supervision Commission (FSC) supervises and authorises CASPs under MiCA in Bulgaria.
• EU Legal Basis: Regulation (EU) 2023/1114 (Markets in Crypto-Assets) harmonises CASP licensing across all Member States.
• Tax Advantage: Bulgaria’s flat 10 % corporate income tax rate is the lowest in the EU.
• Passporting: A Bulgarian CASP authorisation enables cross-border service provision throughout the European Economic Area.

Why 2026 Is Critical

The MiCA transitional period is closing. Member States that elected to grant existing VASPs a temporary operating runway had until 1 July 2026 as the final deadline for conversion to full CASP authorisation under Regulation (EU) 2023/1114. Operators that fail to secure authorisation by that date risk losing their right to provide crypto-asset services within the EU. This urgency makes 2026 the defining year for jurisdictional decisions, and Bulgaria’s efficient regulatory pathway offers a realistic route for firms that need to act quickly.

At-a-Glance Key Facts, Quick Stats and Fast Answers

Snapshot

• FSC = NCA? Yes the Financial Supervision Commission is Bulgaria’s designated National Competent Authority for MiCA.
• Capital Classes: MiCA prescribes minimum own-funds thresholds of €50,000, €125,000 or €150,000 depending on the services offered (Articles 60–62, MiCA Regulation).
• Typical Timeline: Several weeks for the completeness check, followed by a substantive review period overall processing generally ranges from three to six months.
• Estimated Fees: Application and annual supervisory fees are set by the FSC; applicants should consult the FSC’s fee schedule for the latest figures.
• Passporting: Full EU/EEA passporting rights once authorised.

Why Choose Bulgaria as Your EU MiCA Entry Point?

Cost Profile and Value Proposition Low Operating Costs + 10 % Corporate Tax Regime

Bulgaria offers the lowest corporate income tax rate in the EU at a flat 10 %, combined with significantly lower office rents, salaries and professional-services fees compared to hubs such as Luxembourg, Ireland or Malta. For early-stage crypto businesses managing burn rate, this cost differential can be substantial making Bulgaria a genuinely competitive EU MiCA entry point for CASPs of all sizes.

Market Access and Passporting Potential Across the EU

Under MiCA, a CASP authorised in any Member State may notify its NCA and provide services cross-border throughout the EEA. Choosing Bulgaria does not limit your market: it opens 30+ jurisdictions from a single licence, with the same regulatory passport available to a firm licensed in Frankfurt or Paris.

Practical Considerations

• Banking: Establishing local banking relationships requires early engagement; industry observers note that Bulgarian banks are progressively improving their approach to fintech and crypto clients, though lead times remain longer than in traditional sectors.
• Legal and Compliance Support: A growing ecosystem of Bulgarian law firms, compliance consultancies and accounting practices service crypto businesses.
• Language: Regulatory filings are typically in Bulgarian; professional translation and local counsel are essential for non-Bulgarian applicants.

Regulatory Overview FSC as Bulgaria’s MiCA National Competent Authority

FSC Responsibilities for CASPs and Supervision Scope

The Financial Supervision Commission (FSC) is responsible for receiving and assessing CASP applications, granting or refusing authorisation, maintaining the public register of authorised CASPs, and conducting ongoing supervision including enforcement actions where providers breach MiCA requirements. The FSC Bulgaria MiCA mandate covers the full lifecycle from initial application through to withdrawal of authorisation.

MiCA Regulatory Framework and Interaction with Bulgarian Law

MiCA is an EU regulation with direct effect across all Member States. The European Commission’s MiCA framework sets harmonised rules for licensing, conduct, prudential requirements and consumer protection. Bulgarian national legislation supplements MiCA with procedural and administrative provisions including the designation of the FSC as NCA, fee schedules, and local enforcement powers but the core substantive requirements (capital, governance, conduct) derive from the EU regulation itself.

Where to Find FSC Guidance and Submission Channels

Applicants should monitor the FSC’s official website (English-language pages where available) for application forms, fee schedules, published guidance notes and submission instructions. The FSC also references ESMA’s technical standards and guidelines, which provide supplementary detail on application content, templates and reporting formats.

Process How to Obtain MiCA CASP Authorisation in Bulgaria

The following numbered steps outline the expected pathway from initial eligibility assessment to post-authorisation obligations. Each step should be supported by the documentation referenced in the checklist section below.

Step 1 Pre-Application and Eligibility Check

Determine which crypto-asset services you intend to offer (e.g., custody, exchange, order execution, transfer, advisory, portfolio management) and identify the corresponding MiCA licence class. Confirm that your proposed business model falls within scope and review any ESMA Q&A guidance on borderline cases. Applicants already holding a temporary VASP MiCA Bulgaria pre-registration should verify their conversion pathway and timeline with the FSC.

Step 2 Corporate Structure and Substance: Bulgarian Company Formation

CASPs must be legal entities. Non-Bulgarian applicants will typically need to incorporate a Bulgarian limited-liability company (OOD) or joint-stock company (AD) through the Bulgarian Registry Agency. Ensure the entity’s articles of association explicitly cover crypto-asset service activities. Substance meaning genuine local management, employees and operational infrastructure is critical both for regulatory approval and for sustaining the 10 % tax position.

Step 3 Governance, Personnel and Key Function Holders

Appoint qualified individuals to the roles of compliance officer, AML/CFT officer (MLRO), and senior management. All key function holders must pass fit-and-proper assessments covering professional experience, criminal background, financial soundness and reputation. The FSC will evaluate whether the management body collectively possesses sufficient knowledge of crypto-asset markets and relevant technologies.

Step 4 Capital Proof, Treasury and Client Asset Segregation

Provide evidence that the entity holds the required minimum own funds (€50,000, €125,000 or €150,000, depending on service class see Articles 60–62 of MiCA). Capital must be freely available, not encumbered, and maintained on an ongoing basis. Demonstrate robust client-asset segregation arrangements, including custody and safekeeping procedures for crypto-assets held on behalf of clients.

Step 5 Preparing the FSC Application File

Compile the full application dossier. This will include corporate documents, business plan, governance policies, AML/CFT programme, IT security documentation, outsourcing register, financial projections and proof of capital. Reference the downloadable checklist (GLE‑Bulgaria‑CASP‑Checklist.pdf) for a category-by-category breakdown of required documentation.

Step 6 Submission, Fees Payment and Processing

Submit the completed application to the FSC via the designated channel (typically electronic submission plus hard-copy filings where required). Pay the applicable application fee as published by the FSC. The regulator will conduct an administrative completeness check; if documents are missing, the clock pauses until the file is complete. Once deemed complete, the FSC proceeds to substantive review.

Step 7 Post-Authorisation Requirements, Reporting and Passporting

After receiving CASP authorisation in Bulgaria, the entity must comply with ongoing obligations: periodic reporting to the FSC, maintenance of minimum capital, annual audited accounts, AML/CFT transaction monitoring, and notification of material changes (new services, management changes, outsourcing arrangements). To passport services into other EU/EEA states, notify the FSC, which will transmit the relevant information to the host NCA typically within a prescribed period under MiCA.

Fees, Timelines and What to Expect from the FSC

Typical Fee Categories

• Application fee: A one-off fee payable upon submission. The exact amount is published by the FSC and may vary by licence class.
• Annual supervisory fee: Ongoing fees levied on authorised CASPs to fund FSC oversight.
• Company registration costs: Separate fees apply for incorporation at the Registry Agency and tax registration at the NRA.

Expected FSC Timelines

Timelines are indicative. Applicants should confirm current processing periods on the FSC website. Complex applications or information requests may extend the review.

Tips to Reduce Review Time

• Complete applications only: The single most common cause of delay is incomplete filings. Use the documentation checklist to ensure every item is addressed before submission.
• Pre-engagement: Where available, take advantage of any FSC pre-application meeting or guidance window.
• Responsive communication: Reply promptly and comprehensively to FSC information requests during the review process.

Key Requirements and Eligibility Capital Classes and Licence Classes Under MiCA

CASP Licence Classes Covered by MiCA Scope and Permitted Activities

Under the MiCA framework, a CASP may be authorised to provide one or more of the following services: custody and administration of crypto-assets on behalf of clients; operation of a trading platform; exchange of crypto-assets for funds or other crypto-assets; execution of orders; placing of crypto-assets; reception and transmission of orders; advice on crypto-assets; portfolio management of crypto-assets; and transfer services. Each combination of services maps to a specific capital and governance requirement.

Capital Requirements: How Classes Map to Required Own Funds

Providers must also maintain own funds equal to at least one quarter of their fixed overheads of the preceding year, where that amount exceeds the minimum thresholds above ensuring that the capital requirement scales with operational size.

Fit and Proper Tests, Governance and Prudential Expectations

All members of the management body and shareholders with qualifying holdings must satisfy fit-and-proper requirements. The FSC evaluates professional competence, personal integrity, financial soundness and absence of criminal records. Governance frameworks must include clear organisational structures, effective internal controls, documented decision-making procedures and conflict-of-interest policies.

Documentation Checklist What the FSC Expects

Documentation Categories

• Corporate documents: Certificate of incorporation, articles of association, shareholder register, organisational chart.
• Governance: Board composition, CVs and fit-and-proper questionnaires for key function holders, internal rules of procedure.
• Policies: AML/CFT programme, conflict-of-interest policy, complaints-handling procedure, outsourcing policy, business continuity plan.
• Technical and security: IT architecture documentation, cybersecurity framework, custody and safekeeping procedures, incident response plan.
• AML/CFT specifics: Customer due diligence procedures, transaction monitoring methodology, suspicious activity reporting protocol.
• Financial: Audited accounts (or opening balance sheet for new entities), capital adequacy evidence, financial projections (3-year business plan).

Downloadable Checklist

A detailed, category-by-category checklist is available for download: GLE‑Bulgaria‑CASP‑Checklist.pdf (PDF) and GLE‑FSC‑Application‑Template.docx (editable Word template). These resources map every FSC documentation requirement to the corresponding MiCA article, ensuring nothing is overlooked during application preparation.

Risk and Compliance Controls the FSC Will Scrutinise

AML/CFT and Transaction Monitoring Expectations

The FSC expects CASPs to implement risk-based customer due diligence, real-time or near-real-time transaction monitoring, sanctions screening and suspicious transaction reporting aligned with both MiCA and Bulgaria’s national AML legislation. Documented procedures and evidence of staff training are essential.

Operational Resilience, IT Security, Custody and Crypto Asset Safekeeping

Applicants must demonstrate robust ICT risk management, including penetration testing, disaster recovery planning, and clear custody arrangements that ensure client crypto-assets are segregated from the CASP’s own holdings. Industry observers note that the FSC, in line with ESMA guidance, places significant weight on operational resilience documentation.

Outsourcing and Third-Party Vendor Controls

Where critical functions are outsourced for example, IT infrastructure, KYC screening or custody technology the CASP must maintain a register of outsourcing arrangements, conduct due diligence on service providers, and retain ultimate regulatory responsibility. Outsourcing must not impair the FSC’s ability to supervise the CASP.

Practical Steps for Non-EU Applicants

Options: Local Subsidiary, Branch and Substance

Non-EU companies cannot directly hold a MiCA CASP authorisation. The standard pathway is to incorporate a Bulgarian subsidiary (OOD or AD) with genuine local substance including at least one resident director, local employees performing compliance and operational functions, and a physical office. Nominee-director arrangements without real substance are unlikely to satisfy either the FSC or Bulgarian tax authorities.

Banking Access and Euro Clearing

Opening a corporate bank account in Bulgaria can take several weeks. Non-EU applicants should begin the banking process in parallel with company formation. While Bulgaria’s national currency remains the Bulgarian lev (BGN), the country’s preparations for euro adoption and access to euro clearing via the Bulgarian National Bank payment systems provide practical infrastructure for EU-wide operations.

Passporting After Bulgarian Authorisation

Once authorised, the CASP notifies the FSC of its intention to provide services in other Member States. The FSC transmits the notification to the relevant host NCA, and the CASP may commence cross-border services within the period prescribed by MiCA enabling a single Bulgarian licence to serve the entire EU/EEA market.

Pairing CASP Authorisation with Bulgarian Company Formation and the 10 % Tax Regime

Bulgaria’s Flat Corporate Tax and Effective Tax Planning

Bulgaria levies a flat 10 % corporate income tax the lowest rate in the EU. Combined with competitive social-security contribution levels, this creates a meaningful after-tax advantage for crypto businesses that establish genuine operations in the country. Dividend withholding tax within the EU is typically reduced to 0 % under the EU Parent-Subsidiary Directive, further enhancing the tax efficiency of Bulgarian holding structures.

Substance Requirements to Support Tax Position

To sustain the Bulgarian tax residency and the associated 10 % rate, the entity must demonstrate economic substance: a local office, employees performing key functions, and management decisions taken in Bulgaria. Transfer pricing rules apply to intra-group transactions, and the NRA may challenge arrangements lacking commercial substance.

Practical Checklist: Company Type, Registration and Payroll

• Company type: OOD (limited liability company) for most CASPs; AD (joint-stock company) for those seeking to issue shares publicly.
• Registration: File at the Registry Agency; typical processing within a few business days.
• Tax registration: Register with the NRA for corporate income tax and, where applicable, VAT.
• Payroll: Register employees with the National Social Security Institute; payroll taxes and social contributions are significantly lower than Western European averages.

Comparison Bulgaria vs Malta vs Lithuania

Key takeaways: Capital requirements are harmonised under MiCA across all EU Member States the competitive differentiation lies in tax rates, operating costs, regulator processing efficiency and banking accessibility. Bulgaria’s 10 % corporate tax rate makes it the most cost-efficient base for profit retention, while its overall operating costs remain below those of Malta and Lithuania. Industry observers expect Bulgaria’s regulatory infrastructure to continue maturing as the FSC processes a growing pipeline of CASP applications through 2026 and beyond.

Appendix and Downloadable Resources

The following resources are available for download to support your MiCA CASP application in Bulgaria:

• GLE‑Bulgaria‑CASP‑Checklist.pdf A comprehensive documentation checklist mapping every FSC requirement to the corresponding MiCA article, organised by category (corporate, governance, compliance, technical, financial).
• GLE‑FSC‑Application‑Template.docx An editable application template covering all required sections of the FSC submission, with guidance notes and placeholder text for each field.

These resources are designed as practical working tools for applicants and their legal advisers. They should be used alongside the primary source materials referenced throughout this guide.

Legal and Sourcing Note

This page summarises the MiCA Regulation and FSC guidance current as of 12 August 2026. Applicants should verify all figures, fees and procedures against the linked primary sources, as regulatory requirements may be updated. Nothing on this page constitutes legal advice.

Sources

• European Commission Markets in Crypto-Assets (MiCA) Overview
• EUR-Lex Regulation (EU) 2023/1114 (MiCA Regulation)
• Financial Supervision Commission (FSC) Bulgaria
• Bulgarian Registry Agency Company Registration
• National Revenue Agency (NRA) Bulgaria
• Bulgarian National Bank (BNB)