We advise fintech companies and financial institutions on licensing, regulatory compliance and ongoing services — from the BNB application to day-to-day operational consulting.
Deposits and servicing of payment accounts
Cash withdrawals and related operations
Execution of payment transactions (direct debit, card payments, credit transfers)
Payment transactions with credit line
Issuance of payment instruments and acceptance of payments
Money remittance
Payment initiation (PISP) and account information (AISP) — PSD2
| Feature | EMI | Payment Inst. | Bank |
|---|---|---|---|
| Regime | BNB Licence | BNB Licence | BNB + ECB Licence |
| E-money issuance | ✓ Yes | ✗ No | ✓ Yes |
| Payment services | All 7 | All 7 | ✓ Yes |
| Taking deposits | ✗ No | ✗ No | ✓ Yes |
| Lending | Limited | ✗ No | ✓ Yes |
| Min. capital | BGN 700K | BGN 40–250K | EUR 5M |
| EU Passporting | ✓ Full | ✓ Full | ✓ Full |
| Supervisory intensity | Medium | Medium | Highest (SSM) |
Client identification, enhanced due diligence (EDD), monitoring, SANS reporting, UBO verification, staff training.
Quarterly and annual financial reports, payment operations volume reports, own funds, audited annual reports.
Segregation of client funds in separate accounts or insurance coverage. Ring-fencing by end of business day.
ICT risk management, incident reporting, resilience testing, third-party management, information sharing.
Strong customer authentication — two-factor verification for electronic payment transactions (3D Secure).
Registration of agents under LPSA with the BNB, ICT outsourcing agreements, regulatory requirements.
Bulgaria has two main types: a payment institution (PI) licence for providing payment services and an electronic money institution (EMI) licence for issuing electronic money. Both are granted by the Bulgarian National Bank and allow passporting throughout the EU.
The BNB has a statutory 3-month decision period, but in practice the entire process (documentation preparation + review) takes between 9 and 14 months. Preparing the application and internal policies typically requires 3-6 months.
The minimum initial capital for a payment institution ranges from EUR 20,000 to EUR 125,000 depending on the type of payment services. For an EMI, the minimum capital is EUR 350,000. Capital must be paid up before filing the application.
A financial institution under Art. 3a of the Credit Institutions Act is a company that carries out certain activities (e.g. lending, factoring, leasing, guarantees) without a banking licence. Registration is with the BNB and requires a minimum initial capital of BGN 1,000,000.
The DORA Regulation (Digital Operational Resilience Act) has applied since 17 January 2025 and introduces obligations for ICT risk management, digital resilience testing, incident reporting, and third-party risk management for all licensed payment institutions and EMIs.
Contact us for a confidential consultation — we assess your options and prepare a licensing roadmap.