Cryptoassets Regulatory Intelligence

Bulgaria Crypto & Digital Asset Regulation

BG schema crypto-v2.0.0 trajectory: not yet assessed regulated overlaps: Sentinel (AML/CFT), World Payments

Last updated · 9 categories · 40 sourced findings · 34 sources in the cumulative register

Evidence re-verified: ·Position last changed: ·
Record history & provenance ▾

Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

Open in Co-Pilot ↗Build ReportCompare
Framework postureRegulated8 of 9 modules populated · AI-synthesised · Tier-1/2 verified
Lead supervisory authorityEuropean Securities and Markets Authority (ESMA)Primary statutory & supervisory perimeter
Next milestone (> 2026-10-26)2027-09-30DAC8/CARF first EU-wide crypto-asset reporting exchange
Module coverage & confidence8 / 9 modules assessed0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

Law made at European Economic Area (Bloc) level that applies in Bulgaria is covered once, on the European Economic Area (Bloc) page. This page covers Bulgaria’s own layer: implementation, national authorities, national options and local enforcement.

Jurisdiction lead brief

Latest update · 25 October 2026

Lead Signal

Bulgaria's transition into the EU's harmonised crypto-asset regime reached full effect on 1 July 2026. Firms that had continued operating under the prior national registration regime for crypto-asset activities, registered under the national anti-money-laundering statute's Article 9a, could only keep operating past that date without a new authorisation if the national Financial Supervision Commission had not yet decided their application; the grandfathering window itself closed on 1 July 2026 or on an authorisation or refusal decision, whichever came first. From that date, provision of crypto-asset services in Bulgaria requires an authorisation from the Financial Supervision Commission under the Markets in Crypto-Assets Regulation, and firms without that authorisation or a pending application must cease activity. This closes out what had been a live transitional uncertainty and leaves Bulgaria's crypto-asset licensing architecture now fully anchored to the harmonised EU authorisation route rather than any residual national registration.

Key regulatory facts for Bulgaria
Regulatory DimensionBulgaria Standing Position
JurisdictionBulgaria (BG)
Regulatory ScopeCrypto & Digital Asset Regulation (9 modules, 40 sourced findings)
Crypto LicensingBulgaria's Crypto-Asset Markets Act (MICAL) transposes MiCA; the transitional grandfathering period for NRA-registered virtual-asset providers expired 1 July 2026, making MiCA licensing via the FSC the sole lawful...
Token ClassificationBulgaria transposes MiCA's tripartite crypto-asset taxonomy (asset-referenced tokens, e-money tokens, and other crypto-assets) without a distinct national classification scheme.
On-Chain Activity RegimeNeither MiCA nor Bulgaria's national implementing legislation establishes a dedicated licensing or prudential regime for on-chain activities such as staking, DeFi lending, mining, node operation, or validator...
Stablecoin RegimeMiCA Titles III and IV impose a comprehensive stablecoin regime directly applicable in Bulgaria.
Primary Instruments CitedEuropean Securities and Markets Authority (ESMA), European Securities and Markets Authority (ESMA), European Securities and Markets Authority (ESMA), Financial Supervision Commission (FSC), Financial Supervision Commission
Last Confirmed / Updated2026-10-25 (34 sources in cumulative register)

#

Bulgaria's Crypto-Asset Markets Act (MICAL) transposes MiCA; the transitional grandfathering period for NRA-registered virtual-asset providers expired 1 July 2026, making MiCA licensing via the FSC the sole lawful basis for CASP operation in Bulgaria.

Open gap — crypto-int-1Exact national pinpoint provision (article number) of MICAL (SG No. 54/2025) for the 1 July 2026 grandfathering cut-off was not confirmed beyond secondary commentary.no under-indexing note recorded
Open gap — crypto-int-2Whether any Bulgarian CASP has yet received full FSC authorisation versus still being mid-process was not confirmed from an FSC primary register.no under-indexing note recorded
Horizon · 2026-07-01 (± a quarter)MiCA grandfathering window closes for legacy NRA-registered VASPsIn force · Tier 3 source
Standing sub-brief · as of 25 August 2026 87 words · last cycle 2026-10-25

Crypto Licensing

All crypto-asset service providers must hold an FSC MiCA licence to operate lawfully in Bulgaria. The transitional grandfathering period for NRA-registered virtual-asset providers expired 1 July 2026, and unlicensed operation now exposes a provider to FSC sanctions of up to 6.25 percent of annual turnover (12.5 percent for repeat violations). No enforcement track record against providers that failed to obtain a licence by the deadline was located this cycle.

Periodic update · new data 2026-10-25

Crypto Licensing

Bulgaria's crypto-asset licensing framework completed its transition to the EU's harmonised Markets in Crypto-Assets Regulation on 1 July 2026. Before that date, persons already registered under Article 9a of the national anti-money-laundering statute could continue crypto-asset activities on that legacy registration, but only until 1 July 2026 or until the Financial Supervision Commission issued an authorisation or refusal decision on their application, whichever occurred first. That transitional provision is now closed as a matter of law: no crypto-asset service provider may rely on the old national registration going forward.

From 1 July 2026, provision of crypto-asset services in Bulgaria requires authorisation from the Financial Supervision Commission under the Markets in Crypto-Assets Regulation. A firm without that authorisation, and without an application still pending before the Commission, must cease activity. This is confirmed directly from the Commission's own published guidance rather than secondary commentary, and represents the single clearest primary-source statement of the current licensing perimeter for Bulgaria.

What is not yet confirmed from a primary register is the operational state of the market under this new regime: whether any applicant has actually completed authorisation, as opposed to still being mid-process with the Commission, and the precise pinpoint statutory provision within the national implementing act (MICAL, State Gazette No. 54/2025) that fixes the 1 July 2026 cut-off date, both remain open points for a future cycle to confirm against the Commission's own text or register.

Outlook

The near-term question for this module is less about the legal architecture, which is now settled and confirmed by the regulator's own publication, and more about observable market completion: how many firms have moved from pending-application status to full authorisation, and whether the Commission has published or will publish a public authorisation register that would let this be verified directly rather than inferred from the closure of the transitional window alone.

3 earlier distinct update(s)
Periodic update · new data 2026-10-18

Crypto Licensing

Bulgaria's crypto-asset licensing framework reached a structural milestone on 1 July 2026, when the transitional provision under Article 4(38) and 4(39) of the Measures Against Money Laundering Act expired. That provision had allowed persons registered under Article 9a MAMLA to continue crypto-asset activities temporarily without MiCA authorisation, either until 1 July 2026 or until the date of issuance or refusal of a MiCA authorisation, whichever occurred first. With that window closed, the Financial Supervision Commission is now the sole authority issuing MiCA authorisations for crypto-asset services in Bulgaria, and firms with applications still pending as of the cutover were required to submit a suspension plan rather than continuing to operate on the strength of the old registration.

This is a national-level implementation of the directly applicable EU Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114, and the obligation to hold FSC authorisation from 1 July 2026 is confirmed by the regulator's own published guidance. Enforcement exposure under this framework is turnover-calibrated: reported penalty ceilings run to the higher of BGN 15 million or 7.5 percent of global annual turnover for a first offence, and up to the higher of BGN 30 million or 15 percent of global annual turnover for a repeat breach. Beyond financial penalties, the Financial Supervision Commission holds power to suspend a crypto-asset service for up to 30 working days, to impose a permanent ban, or to compel amendment or withdrawal of a white paper. A further local-substance condition applies alongside authorisation: crypto-asset service providers must maintain a registered office in Bulgaria, with part of their crypto-asset-related activities actually carried out within the country, rather than relying on a nominal Bulgarian presence layered over genuinely foreign operations.

Token classification under this licensing framework follows MiCA's structure directly, with the Financial Supervision Commission holding competence for asset-referenced tokens and other crypto-assets, while the Bulgarian National Bank is the competent authority specifically for e-money tokens. This split means an entity offering both a general crypto-asset service and an e-money-token-denominated product may need to engage with both regulators depending on the token type involved, though no Bulgaria-specific dispute over this division has been identified.

Outlook

The immediate open question is how the Financial Supervision Commission treats the residual population of firms that were mid-application at the 1 July 2026 cutover and filed suspension plans rather than securing authorisation outright. No Bulgaria-specific enforcement precedent under the post-cutover regime has yet emerged, so the practical rigor of the turnover-calibrated penalty framework remains, for now, a stated rather than tested feature of the regime.

Periodic update · new data 2026-10-11

Crypto Licensing

Bulgaria's crypto-asset licensing regime is built on Regulation (EU) 2023/1114 (MiCA) as implemented through the Bulgarian Crypto-Asset Markets Act, with the Financial Supervision Commission (FSC) as the supervisory authority. A transitional regime under Article 4(38)-(39) of the Measures Against Money Laundering Act (MAMLA) allowed persons already registered in the National Revenue Agency's AML register before 30 December 2024 to continue crypto-asset activity without a MiCA licence, but that window closed on 1 July 2026, or on the date of an FSC licence grant or refusal if that came first. The transitional regime is now expired and the FSC's own public notice frames 1 July 2026 as the hard line after which only licensed companies may offer crypto-assets within the EU from Bulgaria.

The FSC has moved to enforce that line. On 8 October 2026 it publicly named six websites offering crypto-asset services without authorisation and one site offering unauthorised investment services, ordering cessation within three days. The secondary reporting attributing this action to the FSC was not corroborated against a primary FSC enforcement notice this period, so the action is treated as probable rather than confirmed, though the FSC's own CASP register independently shows active licensing activity in the same window: Belayer OOD was authorised under decision 276-DUKA on 28 April 2026 for portfolio management and custody services, Bulgaria's first fully crypto-focused MiCA licensee.

Fee and capital figures circulating in secondary commentary cite a Class 1 CASP licensing fee of EUR 2,556 and minimum own-funds requirements of EUR 50,000 to 150,000 depending on licence class under MiCA Article 67 and Annex IV, and an asset-referenced-token licensing fee of EUR 12,782 (BGN 25,000) alongside a white-paper, capital and reserve requirement. Both figure sets rest on secondary commentary; the FSC's own Ordinance No. 76 fee schedule was not directly retrieved this period, so these numbers should be treated as indicative pending primary confirmation.

Outlook

The licensing picture is tightening in substance even though no new primary instrument has issued: the transitional population has run out its clock, the FSC is now naming and ordering cessation against unauthorised providers, and the licensed roster continues to add entrants. Whether the 8 October sweep repeats, and whether the FSC publishes the Ordinance No. 76 fee schedule in a form that resolves the current secondary-sourced fee and capital figures, are the two developments most likely to move this module from probable to confirmed in the next reporting period.

Periodic update · new data 2026-09-28

Crypto Licensing

Bulgaria's crypto-asset licensing regime completed its structural transition this cycle. CASP authorisation from the Financial Supervision Commission is now required to lawfully provide crypto-asset services in Bulgaria, following the closure of the legacy National Revenue Agency Article 9a AML-register transitional pathway on 1 July 2026. This is a Confirmed finding, anchored by Tier-3 law-firm commentary corroborating the underlying Bulgarian Markets in Crypto-Assets Act, though the FSC's own primary page was not directly retrieved this pass.

The FSC issued its first MiCA CASP licence, to Alaric Securities, in April 2026, confirming the regime is operationally live. This finding is rated Probable, resting on a single Tier-4 vendor-blog source without independent corroboration.

The module tracker for crypto_licensing carries an amber traffic light this cycle: the regime is fully in force and operational, but the legacy-registrant transition has only just closed, and residual transition risk, entities that may not have completed authorisation in time, remains an open question. The primary framework is Regulation (EU) 2023/1114 (MiCA) together with the Bulgarian Markets in Crypto-Assets Act, with the Financial Supervision Commission as supervisory authority.

Outlook

The outlook for this module centres on how the FSC handles any legacy registrant that did not complete authorisation before the 1 July 2026 deadline. Watch for enforcement or licence-refusal action against such entities as the clearest signal of how strictly the closed transitional pathway is being enforced.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (7)
  1. T1European Securities and Markets Authority (ESMA) — Crypto-asset service providers must obtain authorisation under Article 63 of MiCA from the Financial Supervision Commission (or the Bulgarian National Bank for relevant credit institutions) before providing crypto-asset services in Bulgaria. retrieved M5 binding in force
  2. T1European Securities and Markets Authority (ESMA) — Entities listed in Bulgaria's VASP register between 30 December 2024 and 8 July 2025 (entry into force of the Bulgarian MiCA implementing Act) were required to submit a MiCA Article 63 authorisation application by 8 October 2025 to benefit from the national 18-month grandfathering period. retrieved M4 binding in force
  3. T1European Securities and Markets Authority (ESMA) — Since the EU-wide MiCA transitional period ended on 1 July 2026, any entity providing crypto-asset services in Bulgaria without MiCA authorisation is in breach of EU law and must cease such services. retrieved M5 binding in force
  4. T3Financial Supervision Commission (FSC) — CASP authorisation under MiCA Title V is issued by the FSC; the national transitional period for firms previously registered with the NRA under AML rules ended 1 July 2026, after which unauthorised CASPs must cease offering crypto-asset services. M4 binding in force
  5. T3Financial Supervision Commission — up to the higher of BGN 30 million or 15% of global annual turnover for a repeat breach retrieved M4 binding in force
  6. T1FSC (Financial Supervision Commission) — Persons registered under Art. 9a MAMLA could continue crypto-asset activities without MiCA authorisation only until 1 July 2026 or an FSC authorisation/refusal decision, whichever occurred first retrieved M5 binding in force
  7. T1FSC (Financial Supervision Commission) — From 1 July 2026, provision of crypto-asset services in Bulgaria is permitted only with FSC authorisation under MiCA retrieved M5 binding in force

#

Bulgaria transposes MiCA's tripartite crypto-asset taxonomy (asset-referenced tokens, e-money tokens, and other crypto-assets) without a distinct national classification scheme. The FSC applies ESMA's Guidelines on the qualification of crypto-assets as financial instruments to delineate MiCA-scope tokens from MiFID II-scope securities, implementing them through the national MiCA-transposing legislation rather than separate guidance.

C2 · Token Classification — Full Module Record0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

Unlock with Free Pass / Sign In View Pro & Firm Plans (£39 / £199)View Open Exemplar (Gibraltar)

#

Neither MiCA nor Bulgaria's national implementing legislation establishes a dedicated licensing or prudential regime for on-chain activities such as staking, DeFi lending, mining, node operation, or validator services as distinct categories. These activities are only indirectly captured where they fall within MiCA's existing CASP service categories (e.g., custody and administration, or portfolio management of crypto-assets); genuinely decentralised, non-intermediated activity generally falls outside MiCA's scope by recital exclusion. This is a jurisdiction-wide (EU-level) gap rather than a Bulgaria-specific omission.

C3 · On-Chain Activity — Full Module Record0 sub-modules · 180 words · 3 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

Unlock with Free Pass / Sign InView Pro & Firm Plans (£39 / £199)View Open Exemplar (Gibraltar)

#

MiCA Titles III and IV impose a comprehensive stablecoin regime directly applicable in Bulgaria. Asset-referenced token (ART) issuers require FSC authorisation; e-money token (EMT) issuance is restricted to credit institutions or authorised e-money institutions supervised by the Bulgarian National Bank. Both token types carry reserve-of-assets, redemption-right, and disclosure obligations.

C4 · Stablecoins & EMTs — Full Module Record0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

Unlock with Free Pass / Sign InView Pro & Firm Plans (£39 / £199)View Open Exemplar (Gibraltar)

#

Consumer protection for crypto-asset holders and CASP clients in Bulgaria runs through directly-applicable MiCA obligations: mandatory white paper disclosure (now in machine-readable iXBRL format since 23 December 2025), restrictions on marketing communications, custody segregation duties for CASPs, and mandatory complaint-handling procedures. ESMA and NCAs, including the FSC, also issue public verification guidance directing consumers to the Interim MiCA Register.

Open gap — crypto-int-4Bulgaria-specific application of MiCA Art. 75 custody/segregation duties was not confirmed against FSC supervisory text.no under-indexing note recorded
Standing sub-brief · as of 25 August 2026 58 words · last cycle 2026-10-25

Consumer Protection

The FSC may block websites or apps offering unlicensed crypto-asset services without prior court approval in urgent cases, a strong statutory enforcement power under MICAL. No enforcement track record exercising this power was located this cycle.

Outlook

Whether the FSC begins exercising this blocking power in practice is the key consumer-protection item to watch next cycle.

Periodic update · new data 2026-10-25

Consumer Protection

The clearest consumer-protection signal to emerge for Bulgaria this period comes from the retail distribution channel itself rather than from a dedicated regulatory statement. Fibank's own announcement of its partnership with Bitpanda, the Austrian crypto-asset platform, to embed crypto-asset trading inside its My Fibank mobile banking app discloses that the crypto-asset services distributed through that channel carry no deposit guarantee and are not covered by any compensation scheme, a protection boundary distinct from the one attached to the bank's ordinary deposit products held through the same institution and, potentially, the same app.

This disclosure is significant less for its content, which follows directly from the general principle that crypto-assets are not deposits under the EU's harmonised framework, and more for the fact that it is now being communicated to retail customers at the point of product access inside a mainstream banking channel rather than only inside the terms of a standalone crypto exchange. As embedded bank distribution of crypto-asset services becomes a live model in the Bulgarian market, the clarity of this kind of at-point-of-sale disclosure becomes the practical mechanism by which the regulatory boundary between deposit protection and crypto-asset risk actually reaches the customer.

Broader custody and segregation duties that would apply to a crypto-asset service provider distributing through such a channel, under the Markets in Crypto-Assets Regulation's custody provisions, have not been independently confirmed against the Financial Supervision Commission's own supervisory text this period; the disclosure reported here is the one concrete, source-confirmed consumer-protection fact for Bulgaria.

Outlook

Watch for whether the Financial Supervision Commission issues its own consumer-facing guidance on bank-distributed crypto-asset products now that this distribution model has entered the market, and for whether other Bulgarian banks adopt comparable at-point-of-sale disclosure language as they consider similar partnerships.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (8)
  1. T1European Securities and Markets Authority (ESMA) — MiCA requires issuers/offerors of crypto-assets to publish a crypto-asset white paper containing risk disclosures before public offers or admission to trading, with iXBRL machine-readable formatting mandatory since 23 December 2025. retrieved M4 binding in force
  2. T1EUR-Lex / Publications Office of the European Union — Marketing communications relating to a public offer of crypto-assets must be fair, clear and non-misleading and consistent with the crypto-asset white paper, and may not be disseminated before the white paper's publication. retrieved M3 binding in force
  3. T1EUR-Lex / Publications Office of the European Union — CASPs providing custody and administration of crypto-assets on behalf of clients must safeguard clients' assets and keep them segregated from the CASP's own assets under MiCA Title V custody obligations. retrieved M4 binding in force
  4. T1EUR-Lex / Publications Office of the European Union — CASPs must establish and maintain effective and transparent procedures for the prompt handling of client complaints under MiCA Title V. retrieved M3 binding in force
  5. T1European Securities and Markets Authority (ESMA) — ESMA and national competent authorities advise consumers to verify that a crypto-asset service provider is listed as MiCA-authorised in the ESMA Interim MiCA Register before investing or transferring funds, given that MiCA protections apply only to the specific authorised legal entity. retrieved M3 non-binding
  6. T3 · CMS LawOpposition parties (Bulgarian National Assembly) — Called for a ban on using cryptocurrency for gambling transactions; not contained in the government's TRIS-notified draft Gambling Act amendment as of 2 October 2026. retrieved M2 non-binding in force
  7. T2Fibank / Bitpanda crypto distribution — Crypto-asset services distributed through Fibank carry no deposit guarantee or compensation-scheme protection, distinct from traditional deposits retrieved M3 non-binding in force
  8. T1Crypto-asset service providers (Bulgaria) — registered office in Bulgaria and part of crypto-asset-related activities carried out within the country M4 binding in force

#

Bulgaria has no crypto-specific tax code; digital-asset gains are absorbed into the general flat-rate personal/corporate income tax system based on 2014 National Revenue Agency (NRA) administrative guidance that has not been publicly superseded. Layered on top from 1 January 2026 is the EU-wide DAC8 crypto-asset reporting regime, which is directly binding regardless of any gap in Bulgaria-specific guidance updates.

Horizon · 2027-09-30 (± a quarter)DAC8/CARF first EU-wide crypto-asset reporting exchangeAdopted, not yet in force · Tier 3 source
Periodic update · new data 2026-10-18

Tax Treatment

Bulgaria's crypto-asset tax treatment is being reshaped by the commencement of DAC8/CARF reporting machinery, layered onto the existing Personal Income Tax Act and Corporate Income Tax Act framework. Crypto-asset service providers operating in Bulgaria are now subject to an annual XML-format transaction report filed with the National Revenue Agency, with the first reporting period running from 1 January 2026. The first EU-wide exchange of that reported data between tax authorities is due by 30 September 2027, under the DAC8 directive's implementation of the OECD's Crypto-Asset Reporting Framework.

This reporting obligation is distinct from Bulgaria's existing crypto-asset income tax rates, which this cycle's evidence does not revisit; the development is specifically the newly commencing reporting machinery that sits on top of the settled tax-rate framework. Because the first reporting period is already underway and the first cross-border exchange date is more than a year out, this obligation is best understood as enacted and now in its operational run-up phase rather than as a future contingency: crypto-asset service providers should already be capturing the transaction data this reporting cycle requires, even though no enforcement or audit precedent under the new regime has yet been reported.

Outlook

The period between now and the first EU-wide exchange date of 30 September 2027 is the practical test window for this reporting obligation: whether Bulgarian crypto-asset service providers' data capture and XML submission processes are adequate will not be visible until National Revenue Agency compliance activity or the cross-border exchange itself surfaces any gaps. No Bulgaria-specific DAC8/CARF enforcement action has been identified to date.

C6 · Tax Treatment — Full Module Record0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

Unlock with Free Pass / Sign InView Pro & Firm Plans (£39 / £199)View Open Exemplar (Gibraltar)

#

Bulgaria's cross-border crypto-asset framework combines MiCA's single-market passporting regime for authorised CASPs, the crypto-asset 'travel rule' under Regulation (EU) 2023/1113, and DAC8's cross-border tax-data exchange. No Bulgaria-specific outbound capital restriction on crypto-assets was identified.

C7 · Cross-Border & Travel Rule — Full Module Record0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

Unlock with Free Pass / Sign InView Pro & Firm Plans (£39 / £199)View Open Exemplar (Gibraltar)

#

Crypto AML/CFT obligations are out of scope for this baseline: the crypto consumer subscribes to the FIM aml_ctf module and AML-specific claims are not produced here. For disambiguation context only: Bulgaria's AML framework for virtual-asset service providers runs through the Law on Measures against Money Laundering (LMML), with the Financial Intelligence Directorate (FID-SANS) and, per MONEYVAL's follow-up assessment, some technical deficiencies remain around VASP-specific supervision, new-technology risk assessment, and fit-and-proper checks.

C8 · AML/CFT Regime — Full Module Record0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).

Unlock with Free Pass / Sign InView Pro & Firm Plans (£39 / £199)View Open Exemplar (Gibraltar)

#

## Commercial Activity Bulgaria's crypto-asset commercial landscape is expanding through new FSC authorisations rather than through funding or M&A activity. Belayer OOD became Bulgaria's first fully crypto-focused MiCA licensee, authorised by FSC decision 276-DUKA on 28 April 2026 to provide crypto-asset portfolio management and custody services. The FSC's own register of licensed crypto-asset service providers is the primary source for this authorisation, giving it a reasonably firm evidentiary basis (confidence: Probable, given secondary corroboration gaps on some surrounding detail, though the licensing fact itself is register-sourced). Belayer's entry predates the 1 July 2026 expiry of the MAMLA Article 4(38)-(39) transitional regime by more than two months, indicating that new, fully-licensed market entrants were establishing themselves ahead of, rather than purely in reaction to, the transition deadline. No funding round, acquisition or investment event specific to a Bulgaria-domiciled crypto-native firm was identified this period. This is a negative finding rather than an indication of commercial inactivity: the FSC's licensing register shows continuing new-entrant activity through the year, but the pooled search budget this period did not surface a disclosed investment or M&A transaction involving a Bulgarian crypto-asset firm specifically. Readers should not infer from this silence that the commercial sector is static; it reflects what has been licensed and publicly reported, not a comprehensive transaction census. — Outlook: The commercial signal to watch is whether the pace of new CASP authorisations continues at a rate comparable to Belayer's entry, and whether a funding or acquisition event involving a Bulgaria-domiciled crypto firm surfaces in a future period. The FSC's CASP register remains the most reliable primary source for tracking new licensee activity going forward.

Periodic update · new data 2026-10-25

Commercial Activity

Fibank, First Investment Bank, signed a strategic partnership with Bitpanda GmbH, the Austrian crypto-asset platform authorised as a crypto-asset service provider under the Markets in Crypto-Assets Regulation, on 12 October 2026. The partnership will embed crypto-asset trading access inside Fibank's existing My Fibank mobile banking app, with launch expected in early 2027 according to both companies' own announcements. The arrangement is structured as a distribution and technology partnership rather than a merger, acquisition or capital investment, and neither party disclosed a transaction value.

This is reported as the first arrangement of its kind in the Bulgarian market, confirmed independently by both the issuer's own press release and the crypto-asset platform's own corporate announcement, giving the development a higher degree of confirmation than is typical for a commentary-sourced commercial event. It follows the completion of Bulgaria's transition to the harmonised EU crypto-asset licensing regime on 1 July 2026, which removed the national registration route and left bank-fintech partnerships of this kind operating against a settled authorisation framework rather than a transitional one.

Outlook

The product's actual launch, expected in early 2027, remains the key date to confirm the partnership's translation from signed agreement into a live retail offering. Whether this arrangement prompts comparable bank-distributed crypto partnerships elsewhere in the Bulgarian market is the broader structural question this single event raises but does not yet answer.

Sources and findings (2)
  1. T1Belayer OOD — Became Bulgaria's first fully crypto-focused MiCA licensee (crypto-asset portfolio management and custody services), authorised by FSC decision 276-ДУКА of 28 April 2026 retrieved M3 binding in force new
  2. T2Fibank (First Investment Bank) — Signed strategic partnership with Bitpanda GmbH (Austria, MiCA-authorised CASP) on 12 October 2026 to embed crypto-asset trading in the My Fibank app, launch expected early 2027 retrieved M3 non-binding
No categories match.

Filters combine as OR inside a group and AND across groups.

Provenance and declared absence

Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is.

Sentinel-fed modules receive no special rendering treatment. sentinel_feed is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page.

Family taxonomy is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.

Suppressed by doctrine: derived risk score; per-module RAG traffic light. Not shown on this page.

Band honesty: uncertainty bands are computed against a frozen build clock of 2026-11-04. A year-precision row is never promoted into a tighter band.

Orphan deltas: 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.

Envelope: baseline resolved at jurisdiction_json.baseline; 9 module(s), 40 finding(s), 34 source(s) in the cumulative register.

Audit trail

Machine checkChallenged on 3 Nov 2026: not upheld (8 confirmed against the cited source; 1 contradicted by the cited source; 2 could not be checked). An automated, adversarial test run by a second model; no person has assessed the result.

Think something on this page is wrong? Report an error.