Insurance Broker and Agent in Bulgaria — Registration, Differences and Requirements (2026)

What Is Insurance Intermediation

Insurance intermediation encompasses activities related to offering, preparing, concluding and performing insurance contracts, carried out by persons other than the insurer itself. The legal framework is set out in the Insurance Code (IC) and Ordinance No. 67 of 04.07.2019 of the Financial Supervision Commission (FSC).

Bulgarian law recognises two main types of insurance intermediaries:

• Insurance broker — an independent professional who acts in the interest of the client (consumer). The broker analyses the market, compares offers from various insurers and recommends the most suitable coverage for the specific case. Registration is filed directly with the FSC.
• Insurance agent — a person tied to a specific insurer (or several insurers), who acts on behalf of and for the account of the insurer. The agent is entered in the FSC register by the insurer itself.

This distinction is of fundamental importance — it determines whose interests the intermediary represents, what liability they bear and which regulatory regime applies.

Broker vs Agent — Comparison Table

The following table summarises the key differences between the two models of insurance intermediation:

Insurance Broker — Who Can Apply and What Are the Requirements

Who can be an insurance broker

An insurance broker may be a commercial company (LLC, sole-member LLC, JSC) or a sole trader, registered in the Commercial Register. EU/EEA persons may carry out brokerage activities under certain conditions for cross-border provision of services or through a branch.

Requirements for management

The persons managing and representing the broker must meet strict requirements for professional qualification and reputation (fit & proper):

• University degree — at least a bachelor's degree.
• Minimum 2 years of professional experience in insurance — in a managerial position or a role directly related to the conclusion or performance of insurance contracts.
• Alternative: successful completion of a professional qualification exam organised by the FSC, if the person does not have the required practical experience.
• No criminal convictions for intentional crimes of a general nature.
• Not declared insolvent and not having been a manager or board member of a company declared insolvent with unsatisfied creditors remaining.

Mandatory professional indemnity insurance

Every insurance broker must maintain valid professional indemnity insurance with minimum limits of:

• EUR 1,250,000 — minimum limit per insurance event.
• EUR 1,850,000 — minimum aggregate limit for all claims per year.

The insurance covers damages caused to clients or third parties as a result of professional errors, omissions or negligence in the course of brokerage activities. Without a valid policy, the broker cannot carry out its business.

Insurance Broker Registration Procedure

Registration is carried out before the Financial Supervision Commission (FSC). The process involves the following steps:

1. Incorporation and registration in the Commercial Register — the company must be registered with the Registry Agency before filing the application with the FSC. The business object must include insurance intermediation.
2. Preparation of documentation — the application to the FSC must be accompanied by:
   • Certificate of current status from the Commercial Register;
   • Documents proving education and professional experience of management;
   • Fit & proper declarations (absence of convictions, insolvency);
   • Professional indemnity insurance policy;
   • Business plan describing the envisaged activities;
   • Internal rules for managing conflicts of interest.
3. Filing the application — the application with all annexes is submitted to the FSC.
4. Review by the FSC — the Commission reviews the application within a one-month period from submission. If irregularities or gaps are identified, the FSC grants the applicant at least 15 days to remedy them.
5. Entry in the public register — upon approval, the FSC enters the broker in the public register and issues a registration certificate.

After registration, the broker may commence operations. Its data is publicly available in the FSC electronic information system (eis.fsc.bg), allowing consumers to verify the legitimacy of any intermediary.

Insurance Agent — Who Can Apply and What Are the Requirements

Who can be an insurance agent

An insurance agent may be:

• A natural person — acting as a self-employed individual or employed under an employment contract;
• A sole trader;
• A commercial company — LLC, sole-member LLC or JSC.

This flexibility makes the agent model significantly more accessible compared to the broker model, which requires a registered trader.

Registration through the insurer

The key feature is that the agent does not file an independent application with the FSC. Instead, the insurer with whom the agent works registers them directly in the FSC register. The agent acts on behalf of and for the account of the specific insurer under a contract concluded between them.

Education and qualifications

• Training by the insurer — the primary path to qualification for agents is completing training conducted by the insurer itself under a programme approved by the FSC. This includes both theoretical and practical preparation.
• Alternative: university degree + 2 years of experience (analogous to broker requirements) — in this case, training by the insurer is not mandatory.
• Continuing education: minimum 15 hours per year — an obligation that applies equally to brokers and agents.

Liability

Under the agent model, liability for the agent's actions is borne by the insurer. If the agent causes damage to a client through error or omission, the liability falls on the insurer that authorised the agent. For this reason, agents are not required to maintain separate professional indemnity insurance.

Insurance Agent Registration Procedure

The procedure for agents is considerably simpler compared to that for brokers:

1. Concluding a contract with an insurer — the agent enters into an insurance agency contract with a specific insurer (or insurers). The contract defines the scope of activities, products and territory.
2. Completing training — the agent completes training organised by the insurer under a programme approved by the FSC (unless they meet the alternative qualification requirements).
3. Registration by the insurer — the insurer submits an application to the FSC for registering the agent in the public register. No independent action by the agent is required.
4. Entry in the register — entry is automatic upon submission of correct documentation by the insurer. There is no one-month review period as with brokers.

An agent may work for more than one insurer, provided their contracts allow it and there is no conflict of interest regarding the products offered.

Mandatory Professional Indemnity Insurance

Professional indemnity insurance is a central element of the regulatory regime, but it applies only to insurance brokers.

Why it is mandatory for brokers

Since the broker acts independently and represents the client, they bear independent liability for their professional actions. The insurance ensures that clients will be compensated in the event of errors, omissions or negligence by the broker — for example, incorrect advice regarding the necessary coverage, delayed conclusion of a policy or inaccurate information passed to the insurer.

Minimum limits

Why agents do not have this obligation

The agent acts on behalf of the insurer, which bears direct liability for the agent's actions. Accordingly, the insurer covers any potential damages caused by the agent through its own insurance and financial resources.

Continuing Education and FSC Examination

Obligation for 15 hours per year

Both brokers and agents are required to complete at least 15 hours per year of specialised training. The training covers changes in legislation, new market products, risk management, consumer protection and ethical standards.

FSC examination

The FSC organises a professional qualification examination that is particularly relevant for persons applying for registration as brokers. The exam is an alternative to the 2-year practical experience requirement and covers:

• Legal framework for insurance intermediation;
• Insurance products and coverage;
• Risk management and client needs analysis;
• Ethical standards and conflicts of interest;
• Consumer protection and information obligations.

Successful completion of the exam entitles the person to be registered as a manager of a brokerage company, even without the required practical experience.

AML Obligations Under the AMLA

Both brokers and agents are obliged entities under the Anti-Money Laundering Act (AMLA). This means they must implement the following measures:

• Client identification (KYC) — before establishing a business relationship or carrying out certain transactions, the intermediary must identify the client and the beneficial owner in accordance with the statutory procedure.
• Enhanced due diligence — in cases of elevated risk (politically exposed persons, complex corporate structures, cross-border operations), enhanced due diligence applies.
• Reporting suspicious transactions — if there is suspicion of money laundering or terrorist financing, the intermediary must notify the State Agency for National Security (SANS).
• Internal rules — every intermediary must have adopted and implemented internal rules for controlling and preventing money laundering.
• Staff training — periodic training of personnel to recognise suspicious transactions.

Additionally, the processing of clients' personal data is subject to GDPR regulation, which requires appropriate technical and organisational measures for data protection.

Sanctions for Violations

The FSC has broad powers to impose sanctions for violations of the Insurance Code and secondary legislation:

Operating without registration

• Fines — carrying out insurance intermediation without registration in the FSC register is a violation that leads to substantial financial sanctions.
• Cessation of activities — the FSC may order the immediate cessation of unregistered activities.

Violations by registered intermediaries

• Warning — for minor or initial violations, the FSC may issue a written warning.
• Financial sanctions — fines in amounts specified by the IC for various types of violations (failure to maintain insurance, non-compliance with information obligations, failure to meet training requirements).
• Deregistration — the most severe measure. The FSC may deregister the intermediary for systematic or serious violations, which constitutes a complete ban on carrying out the activity.

Specific violations

• Non-compliance with continuing education obligations (15 hours per year): warning, followed by deregistration for repeat violations.
• AML violations under the AMLA: separate sanctions under the AMLA, independent of those under the IC.
• Violations of information obligations to clients: fines and compulsory administrative measures.

Which Model Is Right for You

The choice between the broker and agent models depends on your specific business goals, resources and readiness for regulatory obligations:

If you plan to build an independent business with a wide product range and direct responsibility to clients — the broker model is more suitable. If you prefer a lower barrier to entry and the support of an established insurer — the agent model is a sensible starting point.

Frequently Asked Questions