MiCA and Jurisdiction Choice in CEE — Why Bulgaria Is the Best Option for Crypto Business (2026)

In this article you will learn:

• What MiCA is and how crypto licence passporting works in the EU
• A detailed comparison of Bulgaria, Lithuania, Czech Republic, Estonia and Poland
• How much a CASP licence costs in Bulgaria by class (1, 2 and 3)
• What tax advantages Bulgaria offers compared to other CEE countries
• What the licensing timelines and transitional periods are
• Practical steps for obtaining a MiCA licence in Bulgaria

What Is MiCA and Why Jurisdiction Matters

Regulation (EU) 2023/1114 — known as MiCA (Markets in Crypto-Assets Regulation) — introduces a unified regulatory framework for crypto-asset markets across the entire European Union. The Regulation is directly applicable in all 27 Member States and does not require transposition.

MiCA covers three categories of crypto-assets:

• Asset-referenced tokens (ART) — stablecoins pegged to a basket of assets
• E-money tokens (EMT) — stablecoins pegged to a single fiat currency
• Other crypto-assets — including utility tokens and cryptocurrencies such as Bitcoin and Ethereum

Passporting — one licence for the entire EU

The key advantage of MiCA is the passporting principle: a CASP licensed in one Member State may provide services across all 27 EU countries without additional national licences. The procedure is straightforward — notification of the competent authority in the home state, which forwards the information to the host state within 15 working days.

In practice this means: choose the jurisdiction with the lowest costs and fastest process — and gain access to a market of 450 million consumers.

Comparison of CEE Jurisdictions for MiCA Licensing

Summary comparison table

Criterion	Bulgaria	Lithuania	Czech Republic	Estonia	Poland
Competent authority	FSC	Bank of Lithuania	CNB	FSA	KNF
State fee	EUR 2,556 – 15,339	~EUR 8,500+	~EUR 4,900	EUR 10,000	~EUR 4,500
Min. capital (CASP)	EUR 50,000 – 150,000	EUR 50,000 – 150,000	EUR 50,000 – 8,000,000	EUR 100,000 – 350,000	EUR 50,000 – 150,000
Decision period	40 working days	~65 working days	2–5 months	~3 months	3–6 months
Corporate tax	10%	16%	21%	20% (0% reinvested)	19%
Transitional period until	01.07.2026	01.01.2026	01.07.2026	01.07.2026	01.07.2026

Bulgaria — the lowest costs in the EU

Bulgaria adopted the Markets in Crypto-Assets Act (promulgated in State Gazette No. 54/04.07.2025), which designates the Financial Supervision Commission (FSC) as the competent authority for CASP licensing, and the Bulgarian National Bank (BNB) for supervision of EMT issuers.

CASP licences by class:

Class	Services	Min. capital	State fee
Class 1	Execution of orders, placement, transfer, reception/transmission of orders, advice, portfolio management	EUR 50,000	EUR 2,556
Class 2	All Class 1 services + custody and administration, crypto/fiat exchange, crypto/crypto exchange	EUR 125,000	EUR 5,113
Class 3	All Class 2 services + operation of a trading platform	EUR 150,000	EUR 15,339

Important: The Class 1 fee of EUR 2,556 is the lowest in the entire European Union for a CASP licence.

The FSC has already issued the first MiCA licence in Bulgaria — to the company Alaric Securities Ltd — confirming that the process is operational and functioning.

Lithuania — no longer the cheapest option

Lithuania was historically the favourite jurisdiction for crypto businesses in the EU thanks to its free VASP registration and fast process (under 1 month). With the introduction of MiCA, this has changed fundamentally:

• The Bank of Lithuania now requires full CASP licensing with capital of EUR 50,000–150,000
• State fees are higher than Bulgaria’s
• Corporate tax is 16% — 60% higher than Bulgaria’s
• A physical office in Lithuania is required with at least partial provision of services within the country
• The transitional period expired on 01.01.2026 — earlier than most CEE countries

Conclusion: Lithuania remains a viable option, but no longer offers the price advantage for which it was known.

Czech Republic — the strictest capital requirements

The Czech Republic adopted the Digital Finance Act (Zákon o digitálních financích, Act No. 31/2025), which entered into force on 15 February 2025. The Czech National Bank (CNB) applies one of the most demanding regimes in the EU:

• Capital requirements reach up to EUR 8,000,000 for trading platform operators — many times above the MiCA minimum
• The state fee is ~EUR 4,900
• Corporate tax is 21%
• Applicants had to submit applications by 31 July 2025 to maintain their activities

Conclusion: The Czech Republic is suitable for large, already established crypto companies, but the excessive capital requirements make it unattractive for start-ups and medium-sized enterprises.

Estonia — from the easiest to one of the most difficult

Estonia was one of the first EU countries to offer crypto licences, but in recent years has significantly tightened regulation:

• Minimum capital is EUR 100,000–350,000 — higher than MiCA requirements
• The state fee is EUR 10,000 — four times higher than Bulgaria’s for Class 1
• At least one member of the management body must be resident in Estonia
• All old VASP licences were annulled — no automatic conversion
• Corporate tax is 20% (0% on reinvested profits)

Conclusion: The unique tax system (0% on reinvested profits) is attractive for growing companies, but the high fees and capital requirements make Estonia an expensive choice.

Poland — a slow start

Poland’s Financial Supervision Authority (KNF) started later with MiCA implementation:

• State fees are ~EUR 4,500
• Capital requirements follow MiCA minimums (EUR 50,000–150,000)
• The process is slower — 3 to 6 months
• Corporate tax is 19%
• Poland attracts with its large domestic market (38 million people)

Conclusion: Poland is a reasonable choice for companies targeting the Polish market, but for EU-wide access via passporting — Bulgaria offers significantly lower costs.

Tax Advantages of Bulgaria for Crypto Companies

Bulgaria offers the lowest corporate tax rate in the EU — 10%. Combined with a dividend tax of 5%, the effective tax burden for owners is 15% — significantly below the CEE regional average.

Country	Corporate tax	Dividend tax	Combined rate
Bulgaria	10%	5%	15%
Lithuania	16%	15%	28.6%
Poland	19%	19%	34.4%
Estonia	20% (on distribution)	0% (included)	20%
Czech Republic	21%	15%	32.9%

Advice from our practice: For crypto companies that distribute profits to their owners, Bulgaria is undeniably the most advantageous CEE jurisdiction. Only Estonia competes in a scenario of full reinvestment — but upon profit distribution, the rate jumps to 20%.

Process for Obtaining a CASP Licence in Bulgaria

Step by step

1. Company registration — incorporation of an LLC (OOD) or joint-stock company (AD) in the Commercial Register. Minimum capital for an LLC: EUR 1. For a CASP licence, the capital will need to be increased to EUR 50,000–150,000 depending on the class.
2. Documentation preparation — business plan, description of IT infrastructure, AML/CFT policies, description of internal controls, proof of origin of capital, CVs and criminal record certificates of directors.
3. Application to the FSC — the application is submitted to the Financial Supervision Commission, together with the state fee.
4. Assessment by the FSC — the Commission has 40 working days to assess a complete application. If deficiencies are identified, the deadline is suspended until they are remedied.
5. Decision — the FSC issues a reasoned decision (approval or refusal) and notifies the applicant within 5 working days.

Important: The legislator has abolished the principle of “tacit refusal” — the FSC is obliged to issue an express reasoned decision on every application.

Required documents

• Business plan with financial projections for 3 years
• Description of proposed crypto-asset services
• Description of IT systems and cybersecurity (in accordance with DORA)
• AML/CFT policies (in accordance with TFR — Regulation 2023/1113)
• Risk management programme
• Documents evidencing the origin of capital
• CVs, diplomas and criminal record certificates of directors and qualifying shareholders

Transitional Period and Deadlines

The transitional provisions are of critical importance for existing crypto businesses:

• Companies registered before 30.12.2024 with the NRA as virtual currency service providers — may continue their activities until 01.07.2026 (or until receipt of a refusal, if earlier). Activities are limited to the territory of Bulgaria only.
• Companies registered between 30.12.2024 and 08.07.2025 — must submit a licence application within 3 months of the Act entering into force.
• Pending NRA registrations — automatically terminated; a new application to the FSC is required.

Important: After 01.07.2026, no CASP will be permitted to operate without a MiCA-compliant licence from the FSC.

Sanctions for Violations

The Markets in Crypto-Assets Act provides for serious sanctions for unlicensed activities and violations:

Violation	Sanction
First violation	The greater of EUR 2,556,000 (BGN 5,000,000) or 6.25% of global annual turnover
Repeat violation	The greater of EUR 5,113,000 (BGN 10,000,000) or 12.5% of global turnover
Specific violations (repeat)	Up to 15% of global turnover

Why Bulgaria — the Practical Advantage

In summary, Bulgaria offers a unique combination of advantages for crypto companies seeking a MiCA licence:

1. Lowest licensing fee in the EU — EUR 2,556 for Class 1
2. Lowest corporate tax in the EU — 10%
3. Lowest combined tax burden — 15% (corporate tax + dividend)
4. Fast process — 40 working days for FSC decision
5. Full EU passporting — one licence for 27 countries
6. Low operating costs — office rent, salaries and legal services in Sofia are significantly lower than in Vilnius, Prague or Warsaw
7. Proven process — the FSC has already issued the first MiCA licence, demonstrating the system’s operability

Conclusion

With the harmonisation of crypto regulation in the EU through MiCA, the choice of licensing jurisdiction acquires strategic significance. Bulgaria stands out as the most competitive CEE option thanks to the lowest fees in the EU, 10% corporate tax, a fast licensing process and full access to the European market via passporting.

With the deadline of 01.07.2026 approaching, time for preparation is limited. Starting the process early is essential.

Need assistance with MiCA licensing? The Innovires Legal team can help you with a comprehensive legal analysis, documentation preparation and representation before the FSC. Contact us for a free initial consultation.

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