MiCA in Bulgaria: current basic rules

MiCA in Bulgaria: current basic rules

On December 18, 2024, the Bulgarian Government approved the draft Bill on Crypto-Assets Markets (BCAM) — a key legislative proposal aimed at aligning national regulation with the Markets in Crypto-Assets Regulation (MiCA) adopted at the EU level. The bill now awaits parliamentary review and formal adoption.

If passed, BCAM will introduce a comprehensive framework for the licensing and supervision of crypto-asset service providers (CASPs) and token issuers, positioning Bulgaria in line with the unified EU regulatory environment for digital assets.

Supervisory Authorities

Under Article 3(1) of the draft bill, regulatory responsibilities will be divided between:

• The Financial Supervision Commission (FSC) – expected to issue licenses to CASPs and token issuers, except in the case of asset-referenced or e-money tokens.
• The Bulgarian National Bank (BNB) – will supervise issuers of electronic money tokens.

Who Can Be a CASP Operator?

Article 16 of the bill outlines strict eligibility requirements for:

• Members of the management body
• Shareholders with qualifying holdings
• Persons responsible for day-to-day operations

These individuals must meet the “fit and proper” criteria of MiCA Article 68, including:

• Good reputation
• Proven knowledge, skills, and experience
• No criminal history related to money laundering, terrorism financing, or corporate misconduct
• No recent disqualification, insolvency involvement, or license revocation
• Compliance with the Bulgarian Anti-Money Laundering Measures Act

Licensing Process and Documentation

The draft law also clarifies the list of documents to be submitted to the Regulator. Additionally, issuers of crypto-assets (other than e-money or asset-backed tokens) must submit a White Paper for any public offering or trading admission, as specified in MiCA.

Transition Rules

The draft legislation provides for two different approaches depending on the company’s current status:

1. VASPs registered before December 30, 2024:
   May continue operations until December 31, 2025, but must apply for a new license under BCAM within that period.
2. New market entrants:
   Will need to go through the full licensing process under the new legal regime once it is enacted.

Fees and Capital Requirements

As outlined in Annex IX of the draft BCAM:

• License Fees:
  • Class 1 – 5,000 BGN
  • Class 2 – 10,000 BGN
  • Class 3 – 30,000 BGN
• License Expansion:
  • From Class 1 to 2 – 8,000 BGN
  • From Class 3 – 25,000 BGN

According to Annex IV of MiCA, the minimum required capital will be:

• Class 1 – €50,000
• Class 2 – €125,000
• Class 3 – €150,000

What’s Next?

The BCAM draft is currently under consideration by four parliamentary committees and must go through two readings in Parliament before it can become law. Amendments may be introduced during the legislative process. Only after final adoption and the President’s signature will the bill be enforceable.

Despite the delay compared to other EU countries, Bulgaria’s approach may give existing VASPs more time to prepare. However, new market entrants should begin aligning their operations with MiCA standards now.

🔎 How Finance IQ Hub Can Help

Finance IQ Hub offers full support for companies preparing to operate under MiCA in Bulgaria:

✔️ Pre-licensing consultation and document preparation
✔️ Legal structuring to meet BCAM/MiCA requirements
✔️ Onboarding of resident directors and AML officers
✔️ Application assistance with FSC
✔️ Strategic advisory on transition planning

📩 Stay ahead of regulatory change.
Contact Finance IQ Hub to prepare your crypto business for Bulgaria’s upcoming MiCA regime