MiCA Crypto Regulation in Bulgaria — What You Need to Know (2026)

What You Will Learn

• What MiCA is and how it applies in Bulgaria
• The three types of tokens and how each is regulated differently
• The CASP licensing procedure before the FSC
• The role of the Bulgarian National Bank (BNB) for stablecoins
• The transition period deadlines
• How crypto gains are taxed for individuals and companies
• What steps you need to take before 01.07.2026

What Is MiCA — Regulation (EU) 2023/1114

The Markets in Crypto-Assets Regulation (MiCA) is the first comprehensive regulatory framework for crypto-assets in the European Union.

Key Characteristics

• Directly applicable — as an EU regulation, MiCA does not need to be transposed; it applies directly in all 27 Member States
• Single licence — a licence obtained in one EU Member State entitles the holder to operate across the entire EU (passporting)
• Consumer protection — mandatory white papers, governance rules, and capital requirements
• Anti-money laundering — integration with the AML/CFT framework (Bulgaria's Anti-Money Laundering Act)

Phased Implementation

MiCA took effect in stages:

• 30.06.2024 — rules for stablecoins (EMTs and ARTs)
• 30.12.2024 — full application for all crypto-assets and CASPs

Bulgarian Crypto-Assets Markets Act

Although the Regulation is directly applicable, the Bulgarian Crypto-Assets Markets Act (published State Gazette No. 54/04.07.2025, effective from 08.07.2025) designates:

• The FSC (Financial Supervision Commission) as the competent authority for licensing CASPs and supervising ARTs
• The BNB (Bulgarian National Bank) as the competent authority for EMTs (stablecoins)
• Licensing fees
• Transitional rules for companies that operated under the old registration regime
• Repeal of the NRA register under Art. 9a of the Anti-Money Laundering Act

Related Regulations

MiCA operates alongside two additional regulations:

• Regulation (EU) 2022/2554 (DORA) — Digital Operational Resilience Act — requirements for operational resilience and cybersecurity
• Regulation (EU) 2023/1113 (TFR) — Transfer of Funds Regulation — the “travel rule” for crypto transfers, requiring identification of sender and recipient

Three Types of Tokens — ARTs, EMTs, and Others

MiCA introduces a clear classification of crypto-assets into three categories, each with a different regulatory regime.

1. Asset-Referenced Tokens (ARTs)

What they are: Crypto-assets whose value is stabilised by pegging to a basket of assets — fiat currencies, commodities (gold, silver), other crypto-assets, or a combination.

Regulator: FSC (Financial Supervision Commission)

Requirements:

• Licence from the FSC for issuance
• White paper approved by the FSC
• Capital requirements and reserve of assets
• Governance rules and conflict of interest management
• Regular reporting

Licensing fee: EUR 12,782 (BGN 25,000)

2. E-Money Tokens (EMTs)

What they are: Crypto-assets whose value is pegged to a single official (fiat) currency. These are stablecoins — USDT (Tether), USDC (USD Coin), EURC, and others.

Regulator: BNB (Bulgarian National Bank)

Requirements:

• The issuer must be a licensed credit institution (bank) or electronic money institution
• The token is treated as electronic money under the Payment Services Act
• Mandatory reserve at a 1:1 ratio with the base currency
• Holders have the right to redemption at par value at any time
• Prohibition on paying interest on EMTs

Practical significance: Most European stablecoin issuers already hold licences in other EU countries (e.g. Circle — USDC — licensed in France). For a Bulgarian EMT issuer, licensing goes through the BNB.

3. Other Crypto-Assets

What they are: All crypto-assets that are neither ARTs nor EMTs. This includes Bitcoin, Ethereum, utility tokens, and most altcoins.

Regulator: FSC (for the white paper and admission to trading)

Requirements:

• White paper — mandatory for public offering or admission to trading; notified to the FSC (not approved, only registered)
• The white paper must contain: project description, holder rights, technology, risks, and issuer information

Exemptions from the white paper:

• Crypto-assets offered for free (airdrops)
• Mining and staking rewards
• Unique and non-fungible tokens (NFTs)
• Offerings to fewer than 150 persons per country
• Offerings with a total value below EUR 1,000,000 over 12 months

CASP Licensing — Procedure, Fees, FSC

Who Is a CASP

A Crypto-Asset Service Provider (CASP) is any person that professionally provides one or more of the following services:

1. Custody and administration of crypto-assets on behalf of clients
2. Operation of a trading platform for crypto-assets (exchange)
3. Exchange of crypto-assets for fiat funds
4. Exchange of crypto-assets for other crypto-assets
5. Execution of orders for crypto-assets on behalf of clients
6. Placing of crypto-assets
7. Reception and transmission of orders for crypto-assets
8. Providing advice on crypto-assets (investment advisory)
9. Portfolio management of crypto-assets
10. Transfer services for crypto-assets on behalf of clients

Licensing Fees

Capital Requirements

In addition to the fee, a CASP must maintain minimum own capital depending on the type of services:

• Class 1: EUR 50,000
• Class 2: EUR 125,000
• Class 3: EUR 150,000

Or one-quarter of the fixed overheads for the preceding year — whichever is higher.

Licensing Procedure

1. Prepare documentation — business plan, organisational structure, internal rules, AML/KYC policies, operational resilience plan (DORA), proof of capital
2. Submit the application to the FSC with a complete document package
3. FSC review — formal completeness check (up to 25 working days for completeness confirmation)
4. Decision — the FSC issues a decision within 40 working days of confirming the application is complete
5. Licence issuance and entry in the FSC register
6. Passporting — notification to the FSC of the intention to operate in other EU Member States

Passporting — Single Licence for the EU

One of MiCA's core advantages is passporting — an FSC licence entitles the holder to provide services across the entire EU/EEA without an additional licence. The procedure is:

1. The CASP notifies the FSC of its intention to operate in another country
2. The FSC informs the competent authority of the host country within 10 working days
3. The CASP may commence activity in the host country

This mechanism makes Bulgaria an attractive licensing jurisdiction — comparatively low fees (EUR 2,557–15,339) and a corporate tax rate of 10 % attract crypto businesses from across the EU.

First Licence in Bulgaria

In 2025, the FSC issued the first MiCA licence in Bulgaria — to Alaric Securities, marking the start of the licensed crypto market in the country.

Stablecoins — The Role of the BNB

Stablecoins (EMTs) occupy a special place in MiCA's regulatory framework, as they function as a means of payment and are directly linked to financial stability.

Why the BNB, Not the FSC

E-Money Tokens (EMTs) are treated as electronic money under the Payment Services and Payment Systems Act. Consequently, the competent authority is the BNB, not the FSC.

Requirements for EMT Issuers

• The issuer must be a licensed credit institution (bank) or electronic money institution
• A mandatory asset reserve at a 1:1 ratio with the base currency
• Reserve assets must be held in segregated accounts
• EMT holders have the right to redemption at par value at any time
• Prohibition on paying interest on EMTs

Significant EMTs

If an EMT is classified as “significant” — for example, if the value of issued tokens exceeds EUR 5 billion — supervision shifts to the European level (European Banking Authority — EBA).

Practical Significance

Most Bulgarian users and businesses use stablecoins issued by foreign emitters (Tether — USDT, Circle — USDC). These issuers must hold a licence in at least one EU Member State — after which they may operate across the EU through passporting. Circle (USDC) is already licensed in France.

Transition Period — Until 01.07.2026

The transition period is critical for all existing crypto businesses in Bulgaria.

Timeline

What Is Permitted During the Transition Period

• Companies registered under the old regime (Art. 9a AML Act) may continue operating until 01.07.2026
• Activity is restricted to Bulgarian territory only — no right to passport
• Compliance with AML/KYC rules under the Anti-Money Laundering Act is mandatory
• A licence application must be submitted to the FSC within the prescribed deadlines

What Happens After 01.07.2026

• Any CASP without an FSC licence must cease operations
• Operating without a licence is an administrative offence and may result in:
  • Enforcement measures from the FSC
  • Fines for the company and responsible officers
  • Criminal liability for systematic violations
• Client funds must be returned or transferred to a licensed CASP

Crypto Tax in Bulgaria

The tax treatment of crypto-assets is of critical importance for both individual investors and businesses.

For Individuals (Personal Income Tax Act)

Taxable income:

Under Art. 33(3) of the Personal Income Tax Act, taxable income from the sale (disposal) of crypto-assets is calculated as:

Taxable income = (Sum of gains − Sum of losses) − 10 % standard deductible expenses

Tax rate: 10 %

Effective rate: ~9 % (10 % tax on 90 % of net profit)

Example:

• Purchase of Bitcoin: EUR 10,000
• Sale: EUR 15,000
• Gain: EUR 5,000
• Standard deductible expenses (10 %): EUR 500
• Taxable income: EUR 4,500
• Tax (10 %): EUR 450
• Effective rate: 450/5,000 = 9 %

Filing:

• Annex 5, Table 2 of the annual tax return under Art. 50 of the Personal Income Tax Act
• Filing deadline: 30 April of the following year
• Payment deadline: 30 June of the following year

Mining and staking:

• Income from mining and staking is treated as business income
• Declared in Annex 2 (under the rules for sole traders)
• Standard deductible expenses are 25 % (if no accounting records are kept)

For Companies (Corporate Income Tax Act)

• Corporate income tax: 10 % on taxable profit
• Crypto-assets are treated as financial assets
• Subsequent revaluations (unrealised gains/losses) are not recognised for tax purposes under Art. 34 of the Corporate Income Tax Act — they are recognised only upon realisation (sale/exchange)
• Acquisition costs (purchase price, fees) are tax-deductible

VAT

• Transactions involving crypto-assets (purchase and sale) are exempt supplies by analogy with financial services — per the CJEU ruling in Case C-264/14 (Hedqvist) and Art. 46 of the VAT Act
• Mining: may be a taxable supply if there is a direct link between the service and the remuneration (e.g. mining pool fees)
• VAT registration may be required upon reaching a turnover of BGN 166,000 (~EUR 84,895) from supplies with a place of performance in the country

Social Security

• Income from passive trading in crypto-assets (by an unregistered individual) — social security contributions are NOT owed
• If the activity is conducted on a professional basis (systematically, with the intention to profit, as a primary or significant income source) — the person is self-insured and owes contributions on the income

What You Should Do NOW

If You Are an Existing Crypto Business

1. Check your status — are you registered in the old NRA register under Art. 9a of the AML Act
2. Submit a licence application to the FSC if you have not done so — the deadline for companies in the transition period has passed (08.10.2025), but new applications are possible
3. Prepare the documentation — business plan, AML/KYC policies, organisational structure, proof of capital, operational resilience plan (DORA)
4. Secure the minimum capital — EUR 50,000, EUR 125,000, or EUR 150,000 depending on the class
5. Plan for passporting — if you intend to operate in other EU Member States

If You Plan to Start a Crypto Business

1. Determine the type of services — custody, exchange, trading, advisory
2. Choose the jurisdiction — Bulgaria offers competitive fees (from EUR 2,557) and a low corporate tax rate (10 %)
3. Prepare capital and documentation
4. Submit an application to the FSC — the decision period is up to 40 working days
5. Engage legal counsel — the procedure requires specialised legal and regulatory assistance

If You Are an Individual Investor

1. Declare your income — in the annual tax return under Art. 50 of the Personal Income Tax Act, Annex 5
2. Keep records — date, purchase and sale price, platform, fees
3. Check whether your platform is licensed — after 01.07.2026, using an unlicensed CASP creates risks for your funds
4. Seek advice if you have income from mining, staking, or DeFi — the tax treatment may differ

Frequently Asked Questions