CASP Authorisation in Bulgaria
Bulgaria is an EU/MiCA CASP route for teams that want a more practical cost profile than premium EU jurisdictions, while still accepting full CASP substance, governance, AML, audit and banking-readiness obligations.
Confirm current Bulgarian FSC CASP/MiCA application requirements, fee schedule, forms and supervisory practice before using this page for client advice.
Regulatory status should be confirmed by local counsel before relying on this route.
What is Bulgaria CASP authorisation?
Bulgaria CASP authorisation is the Bulgarian EU route for crypto-asset service providers under MiCA, supervised by the Financial Supervision Commission. It is useful when the business needs an EU-regulated CASP base with a more practical cost profile than premium EU routes.
- Jurisdiction
- Bulgaria
- Regulator
- Financial Supervision Commission (FSC)
- Regime
- CASP
- Legal basis
- Legal basis: MiCA CASP authorisation under the Bulgarian/FSC supervisory framework, subject to current local implementation.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
CASP service scope in Bulgaria
The Bulgarian application should start with a precise CASP service perimeter. Exchange, custody, brokerage, wallet, advisory, staking-adjacent and payment-related models can be possible, but each changes the evidence needed for governance, AML, safeguarding and technology controls.
Exchange
ConditionalExchange activity may require additional scope or separate licensing.
Exchange
Exchange activity may require additional scope or separate licensing.
ConditionalCustody
ConditionalCustody may require separate review or additional controls.
Custody
Custody may require separate review or additional controls.
ConditionalBrokerage
ConditionalBrokerage or OTC activity typically fits within scope.
Brokerage
Brokerage or OTC activity typically fits within scope.
ConditionalWallet provider
ConditionalExchange activity may require additional scope or separate licensing.
Wallet provider
Exchange activity may require additional scope or separate licensing.
ConditionalEU market
IncludedEU/EEA passporting available.
EU market
EU/EEA passporting available.
IncludedStartups
ExcludedHigh setup complexity means significant budget is needed.
Startups
High setup complexity means significant budget is needed.
Excluded
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
EU/EEA passporting from Bulgaria
Bulgaria can be used as an EU home member state route for MiCA CASP authorisation. The passporting case should be connected to the approved activities, target countries, distribution model and operational readiness rather than used as a generic sales claim.
Define target EU/EEA markets, client categories and service channels before filing.
Map each intended passporting market to the exact CASP services requested in Bulgaria.
Avoid language suggesting that one Bulgarian approval automatically covers future services, tokens, branches or markets.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
Capital, governance and audit expectations
Bulgaria may be more practical on cost than premium EU routes, but it remains a full MiCA/CASP authorisation. The CSV snapshot indicates share capital from 50,000 EUR, state fee from 5,000 EUR, no annual supervision fee, local staff, physical office and audit.
- Board, senior management, compliance, AML and technology responsibility should be named and credible.highBoard, senior management, compliance, AML and technology responsibility should be named and credible.high
- Capital planning should match the selected CASP services, especially for exchange, custody or fiat-heavy operations.highCapital planning should match the selected CASP services, especially for exchange, custody or fiat-heavy operations.high
- Audit, outsourcing oversight, reporting, incident management and AML operations should be budgeted as recurring obligations.highAudit, outsourcing oversight, reporting, incident management and AML operations should be budgeted as recurring obligations.high
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Bulgaria CASP application bottlenecks
The main blockers are operating-model issues, not form filling. Bulgaria works best when the team resolves service scope, local substance, governance, AML, audit and banking before treating the application as a simple cost comparison.
- High
Unclear CASP service perimeter or passporting plan
- High
Weak local governance, staffing or board accountability
- High
Custody, safeguarding, wallet or technology-control evidence that does not match the product
- High
Generic AML policies that do not reflect client geography, tokens and fiat flows
- High
Banking or PSP package prepared after the application strategy
- High
Route selection driven only by price rather than a maintainable EU operating model
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Activity fit for this route
Review which crypto activities fit within the scope of this route.
Exchange activity may require additional scope or separate licensing.
Custody may require separate review or additional controls.
Brokerage or OTC activity typically fits within scope.
Exchange activity may require additional scope or separate licensing.
EU/EEA passporting available.
High setup complexity means significant budget is needed.
Not sure if your model fits? Request a licensing assessment
Is Bulgaria CASP authorisation right for your project?
Best for
- EU passporting and regulated CASP operations
- EU/EEA market access
Not suitable for
- Low-budget or fast offshore setup
- Projects without a prepared banking strategy
Banking difficulty is high for this route. Prepare a banking strategy before committing to the Bulgaria route.
Core requirements
Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Local substance in Bulgaria
Local staff and a physical office should be treated as real operating requirements. The application needs to explain which decisions, controls and regulator-facing functions sit in Bulgaria and which functions are outsourced or handled by a wider group.
Local staff
RequiredRequired
At least one locally-accountable staff member or director is expected.
Physical office
RequiredRequired
A genuine office presence is expected, not a nominal registered address.
Audit
RequiredRequired
External audit is required for ongoing supervision compliance.
Planning notes
- Plan local compliance ownership and FSC-facing accountability before submission.
- Document outsourced technology, custody, customer support or group functions with oversight controls.
- Budget office, staff, audit and ongoing compliance separately from the application advisory fee.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Cost breakdown
Budget for service price, regulatory fees, share capital and ongoing costs separately.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Cost breakdown — Bulgaria
Budget for service price, regulatory fees, share capital and ongoing costs separately.
| Cost item | Amount |
|---|---|
| Service priceApplication preparation and professional services. | €19,600 |
| State fee | €5,000 |
| Required share capitalMust be held, not an expenditure. | €50,000 |
Summary
- One-off costs
- €74,600
- Annual (year 1)
- €0
- Total year 1
- €74,600
Adjust to convert to your base currency.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Application process
The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Bulgaria — From 6 months.
Pre-assessment and scope review
1–3 weeksDefine the activity scope, governance model and target markets before formal preparation.
Company setup in Bulgaria
2–6 weeksEstablish legal entity, appoint local staff and set up local operating structure.
Documentation and compliance packBottleneck risk
3–8 weeksPrepare AML/CFT policies, governance documents, controls framework and application materials.
Application submission to Financial Supervision Commission
1–2 weeksSubmit complete application with all required documentation.
Regulator reviewBottleneck risk
From 6 monthsRegulator reviews the application. May request clarifications. Incomplete files extend this phase.
Depends on: File quality and completeness
Authorisation or registration confirmation
1–4 weeksRegulator confirms authorisation or registration. Commence operations.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
What can delay or increase cost
These factors are most likely to affect timelines and budgets for this route.
Setup complexity is rated high for Bulgaria. Company setup, governance and documentation take longer than average.
Banking difficulty is rated high. Opening accounts for crypto businesses in Bulgaria requires extensive documentation.
Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.
Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Banking and PSP strategy
Bulgaria has a high regulatory reputation in the CSV profile, but banking difficulty remains medium to high. Bank and PSP readiness should run in parallel with authorisation planning, especially for exchange, custody and fiat-heavy businesses.
Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.
Reflects availability of payment service providers willing to onboard crypto-licensed entities.
A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.
Preparation checklist
- Prepare ownership, source-of-funds, flow-of-funds, client geography and token policy evidence early.
- Explain safeguarding, reconciliation, transaction monitoring and fiat rails before approaching banks or PSPs.
- Do not assume FSC authorisation or EU passporting will automatically solve account opening.
Business model fit — Bulgaria
Assess how well this route covers your planned activities.
Fit score
- Good fit
- 0/6
- Partial fit
- 6/6
- Poor fit
- 0/6
Bulgaria may not cover your primary activities
Consider an alternative route that better matches your activity profile.
FSC application profile
Financial Supervision Commission (FSC)
A Bulgaria CASP application should read like a regulated financial-services file: precise activities, accountable governance, local substance, AML controls, safeguarding, technology resilience and a banking plan that can survive due diligence.
- Bulgaria is strongest for teams that want EU market access with disciplined operating costs, not for teams seeking a light offshore setup.
- Custody, exchange and cross-border fiat flows need deeper controls than narrow brokerage or advisory models.
- AML, sanctions, travel rule, transaction monitoring, outsourcing and cybersecurity materials should be product-specific.
- Bulgarian legal implementation and FSC practice should be checked before relying on filing mechanics, fees or timing.
Strong international recognition and established supervision track record.
Reflects documentation depth, governance requirements and expected review friction.
Reflects likelihood of delays, additional information requests or policy uncertainty.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
Compliance documentation
Most crypto licensing routes require a documented compliance framework before submission, not only after approval.
- RequiredAML/CFT policy and risk assessmentDocument your customer risk model and control framework.
- RequiredCustomer due diligence (CDD) procedures
- RequiredEnhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
- RequiredTransaction monitoring system and rules
- RequiredSanctions screening procedures
- RequiredSuspicious activity reporting (SAR) process
- RequiredMLRO / Compliance officer appointmentLocal accountability may be required.
- RecommendedBoard-approved governance charter
- ConditionalOutsourcing policy and monitoringRequired if functions are outsourced.
- RecommendedICT / cybersecurity policy
- RequiredComplaints handling procedure
- RequiredAnnual external audit engagementRequired for ongoing supervision compliance.
Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.
Documents to prepare
Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.
Corporate documents
AML and compliance
Operational
Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Risk assessment
Main risk dimensions for the Bulgaria route.
Route risk rating — banking difficulty: Medium to high. Authorisation does not guarantee bank account opening.
Mitigation: Start banking outreach and compliance preparation before the application.
Route risk rating — setup complexity: High.
Route risk rating — maintenance cost: High. Budget for ongoing compliance, fees and supervision separately.
Route risk rating — regulatory reputation: High.
Route risk rating — regulatory risk: Low to medium. Weak compliance, vague scope or insufficient controls increase review risk.
Mitigation: Prepare an evidence-based compliance file before submission.
This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.
Bulgaria CASP vs alternatives
Compare Bulgaria with Romania CASP and Greece CASP for regional EU positioning, Cyprus CASP for an established EU financial-services hub, and Malta CASP for a more established EU/MiCA crypto supervision profile.
Bulgaria
CASP
- Price
- 19 600 EUR
- Timeline
- From 6 months
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
Romania (CASP)
CASP
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- Medium to high
+ Comparable EU route for Balkan and Central-Eastern Europe positioning
− Current Romanian CASP process, fees and regulator practice need separate validation
View routeGreece (CASP)
CASP
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ EU route with Mediterranean market logic and strong regional positioning
− Not automatically lighter; local substance and MiCA controls still apply
View routeCyprus (CASP)
CASP
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ Established EU financial-services hub often compared for regulated crypto operations
− Can carry higher operating and compliance expectations than budget-led routes assume
View routeMalta (CASP)
CASP
- Price
- 20 700 EUR
- Timeline
- From 6 months
- Passporting
- EU/EEA
- Banking
- Medium to high
- Reputation
- High
+ Established EU/MiCA crypto supervision profile
− Not a low-cost alternative; MFSA substance and compliance burden remain material
View routeFees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.
Bulgaria vs other CASP routes
Compare key parameters across CASP authorisation routes.
Check your readiness for Bulgaria CASP authorisation
Documented AML/CFT policies, risk assessment, compliance officer.
From 50 000 EUR minimum capital required.
Documented AML/CFT policies, risk assessment, compliance officer.
Board, management, accountability chain defined.
Banking strategy and identified partners.
Local staff and office in Bulgaria.
Readiness status
Answer the criteria on the left to see your readiness status.
Frequently asked questions
Bulgaria CASP authorisation under MiCA can support EU/EEA passporting for approved services, but it should not be described as automatic access. The passporting plan must match the authorised service scope and required notification process.
Bulgaria can be attractive when the business wants an EU-regulated CASP route with a more practical cost profile than premium EU jurisdictions, while still maintaining full MiCA substance, governance, AML, audit and banking readiness.
Usually no. Bulgaria may be more cost-practical than some premium EU routes, but it is still a high-complexity CASP authorisation with local staff, office, audit, capital, governance and ongoing compliance obligations.
A credible file should define the CASP services, management and compliance ownership, local substance, AML and sanctions controls, safeguarding, technology resilience, outsourcing oversight and banking or PSP strategy.
Compare Romania and Greece for regional EU options, Cyprus for an established EU financial-services hub, and Malta for a more established EU/MiCA crypto supervision profile. Each still requires a separate legal review of current CASP process, fees and regulator practice.
The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.
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