Bulgaria has opened MiCAR licensing and continues to adapt its crypto legislation

Following the enactment of the new Bulgarian law on Markets in Crypto Assets (BG MiCA Act) on 8 July 2025, Bulgarian authorities have continued to adapt and apply Markets in Crypto Assets Regulation (MiCAR) legislation. Government officials have confirmed that, even though not all bylaws have yet been adopted, licensing applications can already be filed and will be processed.

On 7 July, the Bulgarian Financial Supervision Commission (FSC) published the register of persons under § 5, para. 3 of the BG MiCA Act, which targets individuals who provide services for the exchange of virtual currencies and recognised currencies without gold backing, the transfer or exchange of virtual assets, the storage of virtual assets and their control and management, services related to the public offering of virtual assets, and to wallet providers offering custody services. Until the law came into force on 8 July 2025, this register (the electronic public register) was kept by the National Revenue Agency under Article 9a of the Anti-Money Laundering Act.

The list on the FSC website includes issuers and providers of crypto-asset services with the exception of issuers of electronic money tokens. Under the BG MiCA Act, the Commission is the authority empowered to supervise this group of persons.

Under the BG MiCA Act, persons referred to in Article 4(38) and (39) of the Anti-Money Laundering Act who are listed in the electronic public register of the National Revenue Agency before 30 December 2024 can continue to carry out their activities in the territory of the Republic of Bulgaria without a licence until 1 July 2026, or until the issuance or refusal to issue a licence under Article 63 of Regulation (EU) 2023/1114, whichever occurs first. Persons registered after 30 December 2024 until the entry into force of the BG MiCA Act (8 July 2025) must submit an application for the issuance of a licence under Article 63 of Regulation (EU) 2023/1114 within three months of the entry into force of the BG MiCA Act (8 October 2025).

The FSC notified interested parties that, insofar as § 9, item 3 of the State Budget Act of the Republic of Bulgaria for 2025 repeals the Annex to Article 27, paragraph 1 of the Financial Supervision Commission Act, the fees for administrative proceedings under the BG MiCA Act and for general supervision of licensed companies are provided for in Ordinance No. 76 of 12 June 2025 on the fees collected by the Financial Supervision Commission, and not in accordance with the bill for the adoption BG MiCA Act. This was an important clarification as there were deviations in the amounts of the applicable fees.

The FSC also created a special section on its website concerning in formation on the crypto regulation: https://www.fsc.bg/kriptoaktivi/. This section contains useful information on the following:

• Electronic form for inquiries, complaints, and reports;
• List of regulatory documents implementing MiCA Regulation (EU) 2023/1114;
• Link to questions and answers published by the ESMA on the application of the Regulation;
• Interim MiCA Register published by the ESMA, which publishes a central register of white papers for crypto assets, licensed crypto asset service providers, and non-compliant entities providing crypto asset services. National competent authorities (NCAs) and the European Banking Authority (EBA) provide the ESMA with the information in the register;
• ESMA supervisory briefings provide guidance to national competent authorities (NCAs) on the licensing of crypto-asset service providers;
• Link to the ESMA’s interim register, consisting of the following files:
• white paper on crypto assets — for crypto assets other than asset-backed tokens and electronic money tokens;
• issuers of asset-backed tokens;
• issuers of electronic money tokens;
• crypto-asset service providers;
• non-compliant entities providing crypto-asset services.

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