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AML Compliance for Accountants in Bulgaria — Complete Guide (2026)

Published: March 25, 2026 | Last updated: March 25, 2026

Accountants and tax advisors operating in Bulgaria are obligated entities under the AML Act (ZMIP). This guide covers all obligations: Art. 9b registry, internal rules, customer due diligence, annual training, and penalties for non-compliance.

What you will learn in this article

  • Which accountants and tax advisors fall within the scope of the AML Act
  • How to register in the Art. 9b registry and what the fee is
  • The nine core obligations, explained step by step
  • How to carry out customer due diligence (CDD) on your clients
  • How to identify beneficial owners (UBOs)
  • What your internal AML rules must contain
  • How to organize annual AML training
  • What penalties apply for non-compliance

Which accountants are obligated entities under the AML Act

The AML Act defines the scope of obligated entities in its Art. 4. For the accounting and tax advisory profession, three provisions are relevant.

Art. 4, item 15 of the AMLA covers persons who professionally provide accounting services. This includes accounting firms, accounting enterprises, self-employed accountants, and anyone whose primary or secondary business activity is maintaining accounting records for third parties.

Art. 4, item 16 of the AMLA covers persons who professionally provide tax advisory services. If you advise clients on tax planning, tax optimization, preparation of tax returns, or representation before the National Revenue Agency (NRA), you fall within this category.

Art. 4, item 18 of the AMLA covers persons who professionally provide services related to the formation, management, or direction of companies, as well as provision of a registered address or correspondence address.

A key point is that the obligation is linked to the activity performed, not the legal form of the business. Freelance accountants, sole traders (ET), single-member limited liability companies (EOOD), limited liability companies (OOD), and any other legal form are all covered.

The Art. 9b Registry

Since 2020, persons under Art. 4, items 15, 16, and 18 of the AMLA must be entered in a dedicated public register maintained by the Financial Intelligence Directorate (FID) of DANS.

When you must register

Registration must take place before commencing the activity. If you are already providing accounting or tax advisory services and have not registered, the obligation is immediate.

How to submit the application

The application is submitted to the Director of the FID at DANS using the approved form. The following documents must be attached:

  1. Copy of the registration certificate or UIC for legal entities.
  2. Data on the persons managing and representing the obligated entity.
  3. Description of the types of activities to be carried out.
  4. Declaration confirming adoption of internal AML rules.
  5. Proof of paid fee.

Registration fee

The fee for entry in the Art. 9b registry is EUR 25.56 according to the DANS tariff. Payment is made by bank transfer.

Consequences of failure to register

Carrying out activities under Art. 4, items 15, 16, or 18 without registration constitutes an administrative violation. Under Art. 124 of the AMLA, the penalty is EUR 1,023 to EUR 5,113.

9 AML obligations step by step

  1. Register in the Art. 9b registry — submit an application to DANS before commencing the activity.
  2. Adopt internal AML rules and procedures — under Art. 101 of the AMLA, within 4 months of registration.
  3. Appoint a compliance officer — Art. 106 of the AMLA requires a person in a senior management position.
  4. Conduct a risk assessment — under Art. 98 of the AMLA, updated periodically.
  5. Carry out customer due diligence (CDD) — when entering into a business relationship or for transactions over EUR 7,669.50.
  6. Identify beneficial owners (UBOs) — if the client is a legal entity.
  7. Ongoing monitoring — under Art. 59, verify that transactions are consistent with the client's profile.
  8. Annual training — Art. 101, para. 11, at least once a year.
  9. Report suspicious operations — immediately notify DANS under Art. 72 of the AMLA.

Customer due diligence (CDD)

CDD is the central element of AML obligations. It applies in the following situations:

  • When establishing a business relationship (a new client).
  • When carrying out an occasional transaction valued at EUR 7,669.50 or more.
  • When there is a suspicion of money laundering, regardless of the value.
  • When there are doubts about the client's identification data.

Standard CDD

Client identification. For natural persons: names, date and place of birth, address, identity document number, personal identification number (EGN/LNCh). For legal entities: name, legal form, registered office, UIC, data on managing persons.

Verification of identification. Data must be verified from a reliable and independent source.

Identification of the beneficial owner (UBO). If the client is a legal entity, establish the ultimate beneficial owner.

Establishing the purpose and nature of the business relationship. Understand the client's business and expected volume of operations.

Ongoing monitoring. After initial CDD, monitor whether the client's transactions are consistent with the information you hold.

Enhanced due diligence

Required in situations of higher risk: client from a high-risk country; a Politically Exposed Person (PEP); complex or unusually large transactions; unusual transaction patterns with no apparent economic purpose.

Simplified due diligence

Under Art. 46 of the AMLA, simplified CDD is permissible for low-risk clients: public authorities, listed companies, and other low-risk categories. Even under simplified CDD, client identification is required in a lighter form.

Record-keeping

All CDD data and documents must be retained for 5 years after the termination of the business relationship (Art. 67 of the AMLA).

Beneficial owners (UBOs)

Under paragraph 2 of the Supplementary Provisions of the AMLA, a “beneficial owner” is the natural person who ultimately owns or controls the legal entity. The threshold is 25% of the capital or votes.

How to identify the beneficial owner

  1. Request a Beneficial Owner Declaration from the client.
  2. Search the Commercial Register for the distribution of shares/interests.
  3. If ownership is indirect — trace the chain to the ultimate natural person.
  4. If no natural person can be identified through capital — the person exercising control by other means.
  5. If that is also not possible — the person in a senior management position.

Common mistakes

Many accountants make the mistake of treating the company manager as the beneficial owner. The manager is not necessarily the beneficial owner unless they also hold a sufficient share of the capital. Another common error is failing to trace multi-layered ownership structures, particularly involving foreign legal entities.

Internal AML rules and procedures

Under Art. 101 of the AMLA and Art. 59 of the Regulations for the Implementation of the AMLA (PPZMIP), internal rules must include:

  • Criteria for identifying suspicious operations, transactions, and clients.
  • CDD procedures.
  • Procedures for collecting, processing, and storing information.
  • Rules for reporting suspicious operations to DANS.
  • An internal control system.
  • Description of the procedure for appointing a compliance officer.
  • A staff training program.
  • A risk assessment procedure.
  • Measures for protecting whistleblowers.

Approval by DANS

Internal rules are subject to approval by DANS. They must be sent to the Director of the FID within 4 months of registration in the Art. 9b registry.

Updates

Internal rules must be updated upon changes in the regulatory framework or risk assessment. A review at least once a year is recommended.

Annual training

Under Art. 101, para. 11 of the AMLA, obligated entities must organize staff training programs.

Frequency. At least once a year.

Scope. The regulatory framework (AMLA, PPZMIP, EU directives), internal rules, criteria for recognizing suspicious operations, the reporting procedure, and consequences of non-compliance.

Participants. All employees who have contact with clients or process client-related information. If you work alone, training may be self-study, but it must be documented.

Record-keeping. Maintain a record of each training session: date, attendees, topics, and duration.

New employees. Provide introductory AML training within the first 30 days.

Penalties

Non-compliance with AML obligations carries significant penalties:

Violation Natural person Legal entity
Failure to carry out CDD (Art. 116)EUR 511 – 5,113EUR 1,023 – 10,226
Lack of internal rules (Art. 116)EUR 511 – 5,113EUR 1,023 – 10,226
Failure to register in Art. 9b registry (Art. 124)—EUR 1,023 – 5,113
Failure to notify DANS (Art. 116)EUR 511 – 5,113EUR 1,023 – 10,226
Tipping off (Art. 121)EUR 1,023 – 5,113EUR 2,557 – 10,226
Serious/repeated/systematic violation (Art. 116, para. 3)up to EUR 10,226up to EUR 1,000,000

For a repeat violation within 2 years, the fine is doubled. Liability is cumulative: a fine may be imposed on both the legal entity and the manager or compliance officer.

Frequently asked questions

Which accountants are obligated entities under the AML Act?
Under Art. 4, items 15, 16, and 18 of the AMLA, obligated entities include all persons who professionally provide accounting services, tax advisory, or services related to the formation and management of companies. The legal form of the business is irrelevant.
What is the Art. 9b registry and is registration mandatory?
Yes, registration is mandatory. The Art. 9b registry is a public electronic register maintained by DANS. Providing accounting or tax advisory services without registration is an administrative violation.
What is the registration fee?
The fee is EUR 25.56 and is payable by bank transfer to the DANS account.
Am I required to report suspicious transactions?
Yes. If you suspect money laundering or terrorist financing, you must immediately notify the Financial Intelligence Directorate of DANS. You are prohibited from informing the client about the report.
What are the penalties if I do not register?
A property sanction of EUR 1,023 to EUR 5,113 under Art. 124 of the AMLA.
Do I need to conduct training even if I work alone?
Yes. Even if you have no employees, Art. 101, para. 11 of the AMLA requires a training program. For a self-employed accountant, this can take the form of self-study, but it must be documented.
When is CDD not required?
Simplified CDD is permissible for low-risk clients (Art. 46 of the AMLA). There is no full exemption from CDD. Even for low-risk clients, a minimum level of identification is required.
Where can I find a template for internal AML rules?
DANS publishes guidance and sample elements on its website (dans.bg). However, we recommend adapting the rules to the specifics of your business, as DANS evaluates whether the rules reflect the actual risks and processes of the specific obligated entity.

Need assistance?

If you need help with registration in the Art. 9b registry, preparation of internal rules, risk assessment, or staff training, the team at Innovires Legal can help.