FinTech Licensing in Bulgaria — Payment Institutions & E-Money (2026)

Regulatory Framework

The main regulatory framework includes:

• Payment Services and Payment Systems Act (PSPSA) — published SG 79/17.09.2024, transposing Directive (EU) 2015/2366 (PSD2).
• BNB Ordinance No. 16 — licensing and operational conditions for payment institutions and e-money companies.
• Credit Institutions Act — for banking licenses (outside the scope of this article).
• Markets in Financial Instruments Act — for investment intermediaries.

At the European level:

• PSD2 (Directive 2015/2366) — transposed into the PSPSA.
• EMD2 (Directive 2009/110) — for electronic money.
• PSD3 and PSR — the forthcoming reform (see below).

Types of Licenses and Registrations

Payment Institution — BNB License

A payment institution is a legal entity licensed by the BNB to provide payment services, including deposits and withdrawals, credit transfers, direct debits, card issuance, money remittance, and payment initiation.

License Requirements

The applicant must be registered as an LLC or JSC in Bulgaria, possess the required initial capital under Art. 8 of the PSPSA, have adequate organizational structure, risk management systems and internal controls, meet good reputation requirements for managing persons, and implement measures for safeguarding user funds.

E-Money Company

An e-money company issues electronic money — monetary value stored electronically and accepted as a means of payment by persons other than the issuer. It may also provide payment services.

Capital Requirement

The minimum initial capital is BGN 700,000. Additionally, own capital must equal at least 2% of the average value of electronic money in circulation over the previous 6 months.

Difference from Payment Institution

Payment institutions do not issue electronic money. E-money companies issue electronic money and may additionally provide payment services. Capital requirements for e-money companies are higher.

AISP — Account Information Service Provider

The Account Information Service Provider (AISP) provides users with consolidated information about their payment accounts at various banks or payment institutions.

AISP requires registration (not a license) with the BNB register. No minimum capital is required, but AISP must hold professional indemnity insurance or equivalent guarantee, ensure data security, and comply with strong customer authentication (SCA) requirements.

PISP — Payment Initiation Service Provider

The Payment Initiation Service Provider (PISP) initiates payment transactions on behalf of the user, without holding the funds. Unlike AISP, PISP requires a license as a payment institution or inclusion in an existing institution’s license.

Upon initiating a payment, the PISP must immediately provide the payer with confirmation of successful initiation, a transaction reference number, and the transaction amount.

Investment Intermediaries — FSC

FinTech companies providing investment services — trading in financial instruments, portfolio management, investment advice — need a license from the Financial Supervision Commission (FSC), not the BNB. The FSC oversees capital markets, insurance, and supplementary pension insurance.

Capital Requirements

The BNB may require up to 20% higher own capital or allow up to 20% lower, depending on risk management assessment.

BNB Licensing Procedure

Steps for obtaining a BNB license:

1. Establish the company — LLC or JSC with the required capital.
2. Prepare documentation — per BNB Ordinance No. 16 requirements.
3. Submit application — to the BNB Banking Supervision Department.
4. BNB review — of documents, organizational structure, management systems, and capital.
5. BNB decision — license issuance or refusal.
6. Register entry — in the register of licensed payment institutions and e-money companies.

Required documents include a 3-year business plan, organizational structure description, capital documentation with proof of origin, data on managing persons, measures for safeguarding user funds, and AML compliance measures (internal rules, risk assessment).

In practice, the procedure takes 3 to 6 months.

PSD2, PSD3, and Future Regulation

PSD2

The Second Payment Services Directive is transposed through the PSPSA. It introduced strong customer authentication (SCA), Open Banking obligations, and new provider categories (AISP, PISP).

PSD3 and PSR

The European Commission proposed reforming PSD2 through:

• PSD3 (directive) — focused on licensing and supervision.
• PSR (regulation) — directly applicable, governing user rights, SCA, and Open Banking.

Member states, including Bulgaria, will have 18 months to transpose PSD3 after its entry into force. The PSR will be directly applicable.

Passporting — Operating Across the EU

A payment institution or e-money company licensed in one EU member state can provide services in another through notification (passporting), without a new license. This includes freedom of establishment (opening a branch) and freedom to provide services (without physical presence).

For Bulgaria, this means that a FinTech company licensed in Lithuania or Ireland, for example, can operate in Bulgaria, and vice versa — a Bulgarian licensed company can provide services across the entire EU.

Frequently Asked Questions

Conclusion

The FinTech licensing landscape in Bulgaria is governed primarily by the PSPSA and BNB regulations. Whether you are establishing a payment institution, an e-money company, or registering as an AISP, understanding the regulatory requirements, capital thresholds, and procedural steps is essential for a successful market entry.

If you are planning to launch a FinTech company in Bulgaria, the team at Innovires Legal can guide you through the licensing process — from company formation to BNB application and beyond. Contact us for a consultation.

This article is for informational purposes only and does not constitute legal advice. For specific questions about licensing your FinTech company, please consult a qualified lawyer.