Regulated United Europe OÜ
Registration number: 14153440
Anno: 16.11.2016
Phone: +372 56 966 260
Email: info@rue.ee
Address: Laeva 2, Tallinn, 10111, Estonia
MiCA license in Bulgaria
Bulgaria MiCA license in 2026 means CASP authorisation under EU rules, not a generic local crypto permit. RUE maps the correct perimeter, regulator path and compliance build-out.
Discuss Bulgaria MiCA scope
Regulator
FSC
Timeframe
3-6+ months
Cost
case-based
Capital
EUR 50k+
Capital, timing and scope depend on the exact MiCA service mix
Bulgaria MiCA license in 2026 at a glance
A “crypto license in Bulgaria” in 2026 is usually shorthand for a CASP authorisation under Regulation (EU) 2023/1114. That shorthand is useful commercially, but it is not legally precise. The real question is whether the business model falls within MiCA crypto-asset services, into the EMT or payment perimeter, or partly into another regime such as MiFID II.
Bulgaria is relevant for founders who want an EU base with a clear company law framework, access to the single market through MiCA notification mechanics, and a cost structure that is often more manageable than in some higher-cost EU jurisdictions. Passporting is not “automatic EEA access”; it depends on the authorised scope, home-state procedures and compliant cross-border rollout.
RUE structures Bulgaria MiCA projects around four workstreams: legal perimeter analysis, Bulgarian entity setup, authorisation file preparation, and post-licensing AML/Travel Rule/DORA operating model. For related topics, see MiCA license in Europe, CASP license and crypto regulations in Bulgaria.
RUE starts with a regulatory decision tree, not with marketing labels. We determine whether the model needs a Bulgaria MiCA license, falls into a BNB-sensitive EMT or payment perimeter, or requires a mixed legal analysis. We then align incorporation, governance, AML/KYC, Travel Rule, ICT resilience and banking readiness into one filing strategy.
EU MiCA framework rather than fragmented local logic
The core licensing frame is MiCA, supported by ESMA, EBA and directly applicable EU rules on conduct, prudential safeguards and authorisation scope.
Useful for founders who need perimeter clarity
Bulgaria can work well where the main challenge is to separate CASP services from EMT/e-money, payment services or MiFID activities before launch.
Straightforward company formation layer
A Bulgarian entity can usually be incorporated relatively quickly, but company-law capital must not be confused with MiCA prudential capital and governance readiness.
Known tax environment for operating companies
Founders often look at Bulgaria because of the generally known 10% corporate income tax and 5% dividend withholding framework, subject to the actual tax facts and service mix.
MiCA license in Bulgaria
22,900 EUR
Package includes (8)
- Preparation of necessary documents for registration of a new company in Bulgaria
- Translation of a certificate of no criminal record through a sworn translator
- Payment of state fees related to company registration
- Payment of notary fees related to company registration
- Preparation of compliance documents for MiCA application
- Preparation of a business plan
- Submission of the necessary documents to FSC
- Recruitment of local MLRO/Compliance officer
Timeframe: From 6 months
Additional Services
Updating policies in line with ESMA / EBA guidelines
from 1,900 EUR
MiCA structuring & jurisdiction selection advisory within the EU
from 2,900 EUR
Regulatory risk memo for business model validation
from 2,900 EUR
Assistance with opening crypto-friendly bank accounts / EMIs
from 2,900 EUR
Legal qualification of tokens (utility vs EMT vs ART vs financial instrument under MiFID II)
from 3,900 EUR
Pre-application gap analysis and readiness assessment
from 4,900 EUR
Annual compliance reviews and internal audits
from 4,900 EUR/year
Cross-border structuring for non-EU founders entering the EU market
from 5,900 EUR
MiCA Class Comparison for MiCA license in Bulgaria
Compare MiCA Class 1, Class 2 and Class 3 by permitted activities and baseline requirements.
Mica Class 1 - 50 000 EUR
CapitalFrom EUR 50,000
TimeCountry-specific
Swipe left/right to switch license type
Reception and transmission of client orders
Execution of orders on behalf of clients
Placement and advisory services
Portfolio management
No custody of client crypto-assets
Target Models
Advisory firms
Introducing brokers
Portfolio advisory setups
Mica Class 2 - 125 000 EUR
CapitalFrom EUR 125,000
TimeCountry-specific
Swipe left/right to switch license type
All Class 1 services
Crypto-fiat and crypto-crypto exchange
Custody and administration of client assets
Transfer services for crypto-assets
Higher organizational and AML requirements
Target Models
Exchanges
Custody providers
Broker-dealer operations
Mica Class 3 - 150 000 EUR
CapitalFrom EUR 150,000
TimeCountry-specific
Swipe left/right to switch license type
All Class 2 services
Operation of crypto-asset trading platform
Enhanced governance and internal controls
Advanced risk management and reporting
Typical for full-scale marketplace operators
Target Models
Trading venues
Multi-service CASP groups
Institutional-grade operators
MiCA Class Comparison (Class 1, Class 2, Class 3)
| Activity / Option | Mica Class 1 - 50 000 EUR | Mica Class 2 - 125 000 EUR | Mica Class 3 - 150 000 EUR |
|---|---|---|---|
| Reception and transmission of orders | V | V | V |
| Execution of orders on behalf of clients | V | V | V |
| Advisory and portfolio management | V | V | V |
| Crypto-fiat and crypto-crypto exchange | X | V | V |
| Custody and administration of crypto-assets | X | V | V |
| Operation of a trading platform | X | X | V |
Core requirements for a Bulgaria MiCA license
A Bulgaria MiCA license requires more than a registered company. The Bulgarian applicant must show a credible operating model, transparent ownership, fit-and-proper management, prudential readiness and a control framework that works in practice. In 2026, regulators and counterparties focus less on brochure statements and more on whether the applicant can evidence governance, outsourcing oversight, customer protection and incident response.
The minimum baseline usually includes:
- a Bulgarian legal entity with disclosed UBO structure and clean corporate records;
- an identified CASP service perimeter under MiCA rather than a generic “exchange/wallet” description;
- management and key function holders able to pass fit-and-proper assessment;
- documented AML/KYC, sanctions, complaints, conflicts and outsourcing controls;
- documented ICT and security architecture aligned with DORA expectations;
- evidence of required initial capital / own funds for the selected service category.
One practical point founders often miss: the regulator will usually test whether outsourced functions remain under board control. You can outsource screening, transaction monitoring, cloud hosting or parts of custody technology, but you cannot outsource away accountability.
Bulgarian entity and transparent ownership +
Use a properly incorporated Bulgarian company, typically with ownership and UBO disclosure that can be independently verified through the Bulgarian Commercial Register / Registry Agency. Complex nominee chains, unexplained shareholder funding or missing beneficial ownership evidence are common friction points.
Defined MiCA service scope +
The application must map the business model to specific MiCA services. Examples include custody and administration, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, operation of a trading platform, execution of orders, reception and transmission of orders, advice, portfolio management, placing and transfer services.
Fit-and-proper management body +
Directors and senior managers must be suitable for the role. Regulators typically look at professional background, integrity, time commitment, conflicts of interest and whether the team collectively understands AML, operational risk, ICT and the actual product flow.
AML/KYC and Travel Rule framework +
A CASP needs a real AML operating model under the Bulgarian anti-money laundering framework, the EU AML package context and Regulation (EU) 2023/1113 on the Travel Rule. A generic template without risk scoring logic, escalation paths and vendor oversight is usually insufficient.
ICT resilience and security controls +
DORA matters in practice. Applicants should be ready to evidence access control, incident handling, backup and recovery, vendor risk management, logging, encryption, change management and business continuity. Custody models usually require deeper evidence on key management and segregation.
Capital and financial runway +
MiCA capital thresholds start at EUR 50,000 and can rise to EUR 125,000 or EUR 150,000 depending on the service mix. That is separate from Bulgarian company-law capital. In practice, the regulator will also care whether the business can fund operations beyond the bare minimum.
Jurisdiction Comparison
Compare Bulgaria with other jurisdictions by key conditions for obtaining and operating a MiCA/CASP license: regulator, review period, fees, capital, local substance, and passporting.
6 jurisdictions in this table
* This table focuses on MiCA/CASP authorization conditions. Use the settings icon to customize countries and parameters.
💰 Licensing Cost Estimator
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Taxation of crypto companies in Bulgaria
Bulgaria is often selected partly because of its known corporate tax environment, but tax should be treated as a structuring variable, not as the reason to ignore licensing substance. For an operating CASP, the main questions are corporate income tax, dividend taxation, VAT treatment of specific services, payroll costs and cross-border reporting discipline.
At a high level, founders usually assess the following:
- corporate income tax: 10% on taxable profits under the general Bulgarian corporate tax framework;
- dividend tax: 5% in the commonly cited domestic framework, subject to the shareholder profile and treaty or EU-law analysis where relevant;
- standard VAT rate: 20%, with the important caveat that not every crypto-related service is taxed the same way;
- employment and social contribution costs for local staff and management.
The critical VAT nuance is this: exchange-type services may need to be analysed in light of the CJEU Hedqvist line of reasoning, while advisory, software, support, licensing, white-label or ancillary B2B services may remain taxable. A founder who assumes that “all crypto services are VAT exempt” is usually oversimplifying the issue.
For accounting setup and ongoing reporting, see accounting services in Bulgaria and Bulgaria crypto tax.
Corporate income tax
General Bulgarian corporate tax on taxable profits
10%
Corporate income tax
General Bulgarian corporate tax on taxable profits
The generally cited Bulgarian corporate income tax rate is 10%. This is relevant for CASPs operating through a Bulgarian company, but the effective tax outcome still depends on transfer pricing, deductible expenses, related-party arrangements and whether functions are actually performed in Bulgaria.
Dividend taxation
Domestic dividend framework commonly referenced by founders
5%
Dividend taxation
Domestic dividend framework commonly referenced by founders
The commonly referenced domestic dividend rate is 5%. The actual result may differ depending on the shareholder type, residence, treaty position and applicable EU-law exemptions. Dividend planning should be coordinated with substance and beneficial ownership analysis.
Value added tax
Standard VAT rate with service-by-service analysis required
20%
Value added tax
Standard VAT rate with service-by-service analysis required
The standard Bulgarian VAT rate is 20%. Not all crypto-related services are treated identically. Exchange activity may need separate analysis from consulting, software licensing, SaaS, onboarding support, token design, technical integration or compliance outsourcing. VAT classification should be documented before launch.
Payroll and social costs
Employment cost layer for local substance and operations
variable
Payroll and social costs
Employment cost layer for local substance and operations
Payroll costs are not a fixed headline number. They depend on employment structure, management contracts, local hiring, social security treatment and whether some functions are outsourced. For MiCA projects, payroll planning is part of the substance discussion, not only an HR issue.
Ongoing compliance after authorisation
A Bulgaria MiCA license is an operating regime, not a one-off filing. The real workload starts after authorisation: governance, AML, Travel Rule, DORA, complaints, reporting and outsourcing oversight.
AML and financial crime controls
- Maintain a risk-based AML framework under Bulgarian AML law and EU standards
- Run CDD, EDD, sanctions and PEP screening at onboarding and on an ongoing basis
- Escalate suspicious activity and keep evidence for FIU-facing reporting
- Review customer risk scoring, typologies and alert calibration periodically
Travel Rule and transaction monitoring
- Apply Regulation (EU) 2023/1113 data transmission requirements for transfers
- Implement controls for VASP-to-VASP messaging and exception handling
- Assess self-hosted wallet exposure using ownership or control indicators where required
- Keep audit trails for rejected, returned or manually reviewed transfers
DORA and ICT governance
- Maintain incident response, vulnerability management, backup and recovery procedures
- Control access through least privilege, MFA, logging and periodic access reviews
- Keep an ICT third-party register and monitor critical vendors
- Test BCP/DR, document RTO/RPO and evidence remediation of control gaps
Governance and conduct
- Maintain complaints handling, conflicts management and consumer-facing disclosures
- Keep board oversight over outsourced functions and material incidents
- Update policies when products, channels, geographies or counterparties change
- Preserve records that support supervisory review and internal accountability
RUE handles compliance for you. Our team provides ongoing compliance support, including AML officer services, regulatory reporting, and policy updates. We ensure your license stays in good standing year after year.
Contact us for compliance support →
📝 Check Your Eligibility
Answer a few quick questions to find out if this jurisdiction suits your crypto business
Step 1 of 5
What type of crypto services will you provide?
Exchange (fiat ↔ crypto)
Custody & Wallet Services
Transfer & Payment Services
Advisory / Portfolio Management
Multiple / All of the Above
Step 2 of 5
What is your target market?
European Union only
EU + Global markets
Global (non-EU priority)
Step 3 of 5
Do you already have a registered company in the EU?
Yes, in this jurisdiction
Yes, in another EU country
No, I need to register one
Step 4 of 5
What is your available budget range?
Under €20,000
€20,000 – €50,000
€50,000 – €100,000
Over €100,000
Step 5 of 5
When do you plan to launch?
As soon as possible (1–3 months)
Within 6 months
Within a year
Just exploring options
This Jurisdiction Is a Great Fit!
Based on your answers, this jurisdiction matches your business requirements well. Here's a quick summary:
Recommended License
CASP License
Estimated Budget
€24,000 – €35,000
Estimated Timeframe
4–6 months
EU Passporting
Available
Process for a Bulgaria MiCA license
Step 1
Perimeter analysis
RUE first determines whether the model needs a Bulgaria MiCA license, falls into an EMT or payment perimeter, or requires mixed analysis under MiCA, MiFID II or adjacent rules.
Step 2
Company setup
We incorporate the Bulgarian entity, organise shareholder and UBO disclosures, confirm the registered office layer and align the corporate structure with the planned authorisation scope.
Step 3
Governance design
We map the management body, key functions, outsourcing model, conflicts framework and fit-and-proper evidence so the application reflects a real operating structure.
Step 4
Compliance package
We prepare the programme of operations, AML/KYC, Travel Rule, complaints, ICT, DORA, security, business continuity and financial model documentation required for review.
Step 5
Filing and review
We support submission, regulator questions, clarifications and document updates. The main timing variable is usually the quality and consistency of the initial file.
Step 6
Launch readiness
After authorisation, we help align banking, accounting, reporting, vendor oversight and ongoing compliance so the CASP can operate within its approved scope.
Answers
Frequently Asked Questions
Open the key issues founders, compliance teams and legal leads usually need to confirm before launch.
Is a VASP registration still enough in Bulgaria in 2026? +
Usually no for MiCA-regulated crypto-asset services. In 2026, the main legal frame for crypto-asset service providers in the EU is MiCA. Whether any legacy position remains relevant depends on the exact transitional mechanics and the applicant’s factual status, but new operating models should be assessed primarily against the CASP authorisation perimeter rather than older VASP language.
What is the difference between a crypto license in Bulgaria and a Bulgaria MiCA license? +
The term “crypto license in Bulgaria” is market shorthand. The legally precise concept is usually CASP authorisation under Regulation (EU) 2023/1114. The shorthand becomes misleading when a business actually falls into the EMT, e-money, payment services or MiFID II perimeter.
Who regulates MiCA applications in Bulgaria? +
The key CASP authority is the Financial Supervision Commission. The FSC is central for MiCA authorisation and supervision. The BNB becomes important where the model touches EMT, e-money or payment issues. FID-SANS is relevant for AML reporting logic, and the NRA is relevant for tax registration and ongoing fiscal compliance.
Which services usually require a Bulgaria MiCA license? +
MiCA usually captures ten core crypto-asset services. These include custody and administration, operation of a trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management and transfer services for crypto-assets on behalf of clients.
How much capital do I need for a Bulgaria MiCA license? +
The main MiCA thresholds are EUR 50,000, EUR 125,000 and EUR 150,000. The applicable amount depends on the service category. Advisory-style models may sit at the lower end, while custody and trading platform models are typically at the higher end. Mixed models should usually budget for the higher relevant threshold.
Is Bulgarian company capital the same as MiCA prudential capital? +
No. Bulgarian company-law capital for incorporation and MiCA prudential capital are different concepts. Founders often confuse the two. The first is a corporate formation issue; the second is a licensing and ongoing prudential issue linked to the authorised service profile.
Can a Bulgarian CASP passport across the EU? +
Yes, but not automatically in the simplistic marketing sense. MiCA provides a single-EU framework, yet cross-border activity depends on the authorised scope and the applicable notification mechanics. The practical rollout should also consider host-state consumer-facing rules, marketing approach and operational readiness.
How long does a Bulgaria MiCA license take in 2026? +
A realistic end-to-end range is often around 3 to 6+ months, sometimes longer for complex models. Incorporation may be relatively quick, but preparation of a credible file usually takes weeks, and regulator review depends heavily on the quality of governance, AML and ICT evidence.
Do I need a local office or resident director in Bulgaria? +
You should not rely on blanket yes-or-no answers. The real issue is the difference between a registered office, effective management and credible local substance. A minimal structure may be legally possible in some cases, but for many CASP projects a purely nominal presence weakens both the application and banking onboarding.
Do I need an MLRO for a Bulgarian CASP? +
You should plan for a clearly assigned AML responsible function. Even where local structuring flexibility exists, a CASP without a credible AML owner is a red flag. In practice, regulators and banks expect identified responsibility for AML governance, suspicious activity escalation, training and control testing.
How does the Travel Rule apply to Bulgarian CASPs? +
Bulgarian CASPs must comply with Regulation (EU) 2023/1113. This means collecting and transmitting required originator and beneficiary data for relevant transfers, maintaining auditability, handling exceptions and applying appropriate controls to transfers involving self-hosted wallets.
What ICT controls are expected under DORA? +
DORA expects evidence-based ICT governance. A serious applicant should be able to show access control, MFA, logging, incident response, backup and recovery, vendor risk management, business continuity and periodic testing. Custody models usually need stronger key-management evidence such as HSM, MPC or equivalent control architecture.
Are crypto exchange services VAT exempt in Bulgaria? +
Sometimes, but not as a blanket rule for every crypto-related service. Exchange activity may require analysis in light of CJEU Hedqvist, while consulting, software, support or ancillary services may remain taxable at the standard VAT rate. The classification should be reviewed service by service.
Can I apply for a Bulgaria MiCA license remotely? +
Parts of the project can be handled remotely, but the application still needs a credible Bulgarian and EU operating structure. Remote founders can often complete much of the preparation through counsel and local service providers, yet ownership verification, governance evidence, banking readiness and substance planning still need to be properly documented.
Can I buy a ready-made licensed company in Bulgaria? +
You should treat “ready-made licensed company” offers with caution. Even where an acquisition structure is legally possible, a change in ownership, control, management, business model or outsourcing chain can trigger fresh regulatory scrutiny. In MiCA projects, the quality of the live operating model matters more than the age of the corporate shell.
When is Bulgaria not the best MiCA jurisdiction? +
Bulgaria may be suboptimal if the project depends on immediate high-tier banking, very heavy institutional infrastructure or a business model that is actually closer to EMT or payment services than to a standard CASP. Jurisdiction choice should follow the service perimeter, not only tax or setup cost.
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