Bulgaria

Other Developments

Tax reporting machinery is commencing alongside the licensing cutover. Crypto-asset service providers in Bulgaria face a new DAC8/CARF reporting obligation: an annual XML transaction report to the National Revenue Agency, with the first reporting period running from 1 January 2026 and the first EU-wide exchange of that data due by 30 September 2027. This reporting layer sits alongside, but is distinct from, the licensing authorisation obligation, and represents newly commencing compliance machinery that has not yet been tested by an enforcement cycle. Enforcement exposure under the licensing regime is calibrated by turnover. Reported penalty ceilings for breaches of the MiCA licensing framework in Bulgaria run to the higher of BGN 15 million or 7.5 percent of global annual turnover for a first offence, rising to the higher of BGN 30 million or 15 percent for a repeat breach, alongside powers to suspend a crypto-asset service for up to 30 working days, impose a permanent ban, or compel amendment or withdrawal of a white paper.

Cross-Monitor Connections

The completion of Bulgaria's MiCA transitional cutover and the accompanying DAC8/CARF reporting obligation both sit within a broader EU-level framework that other monitors track from adjacent angles: the licensing cutover is a crypto/digital-asset financial-innovation development with direct relevance to financial-integrity monitoring of CASP authorisation status, and the DAC8/CARF reporting machinery is itself a tax-transparency instrument with AML/CFT-adjacent reporting value, since transaction-level reporting to a national revenue authority can surface patterns otherwise invisible to supervisory authorities. Payment-sector monitors tracking correspondent and settlement access in Bulgaria should note that CASP authorisation status is now a binary determined solely by the Financial Supervision Commission, which simplifies counterparty due diligence relative to the prior dual registration/licensing ambiguity.

Outlook

With the transitional period closed, the near-term question for Bulgaria's crypto sector is less about the licensing framework itself, which has now settled into FSC-sole-authority form, and more about how the DAC8/CARF reporting obligation performs through its first full reporting cycle, running from 1 January 2026 through to the first EU-wide data exchange on 30 September 2027. Firms that did not secure MiCA authorisation before the 1 July 2026 cutover, and did not file a suspension plan, carry the clearest residual exposure under the penalty framework described above.

2 earlier updates not shown here.

Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

Lead Signal

Bulgaria's transitional grandfathering period for National Revenue Agency-registered virtual-asset providers expired on 1 July 2026, closing the dual-track regime that had allowed pre-existing providers to continue operating alongside the new Crypto-Asset Markets Act (MICAL) licensing framework. From that date, a Financial Supervision Commission (FSC) MiCA licence is the sole lawful basis for crypto-asset service provider (CASP) operation in Bulgaria, and unlicensed operation now exposes a provider to FSC sanctions of up to 6.25 percent of annual turnover for a first violation.

Other Developments

Token classification moved onto a clear statutory footing this cycle: MICAL sorts crypto-assets into asset-referenced tokens, electronic-money tokens, and other crypto-assets, mirroring the EU MiCA taxonomy and replacing Bulgaria's prior undifferentiated treatment of virtual currencies.

Stablecoin supervision remains split between two authorities, with the framework only partially settled: the Bulgarian National Bank, rather than the FSC, is the competent authority for electronic-money-token issuers, but as of the most recent source located this cycle the BNB had not yet finalised its EMT-specific secondary legislation, leaving implementing detail pending even though the primary supervisory allocation is already in force.

Consumer protection enforcement powers are strong on paper: the FSC may block websites or apps offering unlicensed crypto services without prior court approval in urgent cases. No enforcement track record exercising this power was located this cycle, so the practical consumer-protection posture remains unobserved even as the statutory authority is confirmed.

Cross-Monitor Connections

This cycle's crypto-licensing tightening in Bulgaria intersects with the broader EU AML architecture being tracked by financial-integrity monitoring, given MiCA-aligned CASP supervision typically carries harmonised customer-due-diligence expectations; that AML-specific analysis is not repeated here. Similarly, the electronic-money-token supervisory split between the FSC and the Bulgarian National Bank has direct relevance to payments-sector monitoring of stablecoin and digital-money frameworks, where BNB's EMT-supervisor role is the key structural fact to carry forward without re-analysis here.

Outlook

The clearest gap to close next cycle is evidence of the FSC's actual enforcement posture against CASPs that failed to secure a licence by the 1 July 2026 deadline. The BNB's still-pending EMT secondary legislation is the second item to watch, since it determines how concretely Bulgaria's stablecoin-supervision framework will operate in practice.