LPSA · PSD2 · CIA · AMLA · DORA · Updated 2026

Payment Services & Fintech

We advise fintech companies and financial institutions on licensing, regulatory compliance and ongoing services — from the BNB application to day-to-day operational consulting.

Licensing & Registration
We assist with obtaining all types of licences and registrations for providing payment services in Bulgaria and the EU
7 Categories of Payment Services under LPSA
Licensed institutions may provide one or more of these service types
01

Deposits and servicing of payment accounts

02

Cash withdrawals and related operations

03

Execution of payment transactions (direct debit, card payments, credit transfers)

04

Payment transactions with credit line

05

Issuance of payment instruments and acceptance of payments

06

Money remittance

07

Payment initiation (PISP) and account information (AISP) — PSD2

Comparison of Regimes
FeatureEMIPayment Inst.Bank
RegimeBNB LicenceBNB LicenceBNB + ECB Licence
E-money issuance✓ Yes✗ No✓ Yes
Payment servicesAll 7All 7✓ Yes
Taking deposits✗ No✗ No✓ Yes
LendingLimited✗ No✓ Yes
Min. capitalBGN 700KBGN 40–250KEUR 5M
EU Passporting✓ Full✓ Full✓ Full
Supervisory intensityMediumMediumHighest (SSM)
Regulatory Compliance
We provide ongoing legal services for licensed institutions across all regulatory requirements

AML/KYC (AMLA)

Client identification, enhanced due diligence (EDD), monitoring, SANS reporting, UBO verification, staff training.

BNB Reporting

Quarterly and annual financial reports, payment operations volume reports, own funds, audited annual reports.

Fund Safeguarding

Segregation of client funds in separate accounts or insurance coverage. Ring-fencing by end of business day.

DORA (from 2025)

ICT risk management, incident reporting, resilience testing, third-party management, information sharing.

SCA (PSD2)

Strong customer authentication — two-factor verification for electronic payment transactions (3D Secure).

Agents & Outsourcing

Registration of agents under LPSA with the BNB, ICT outsourcing agreements, regulatory requirements.

Coming Soon: PSD3/PSR and MiCA

PSD3 unifies the EMI and PI regimes into a single framework. MiCA regulates crypto-assets from July 2025. NIS 2 takes effect in February 2026. Follow our insights for the latest updates.

Launching a fintech project and need help obtaining a licence?

Contact us for a confidential consultation — we assess your options and prepare a licensing roadmap.