Bulgaria's Markets in Crypto-Assets Act: what you need to know

It is important to note that the new law is aimed at regulating businesses and intermediaries: it does not apply to ordinary users who buy, hold and sell cryptocurrency. Thus, ordinary users may buy, hold and sell crypto-assets, use the services of licensed exchanges and transfer cryptocurrency through licensed providers.

Nevertheless, ordinary users are expected to face a greater number of checks and identification requirements for transfers once the law is adopted. On the other hand, when using legal services, users’ rights will be better protected than before.

Changes for intermediaries

The objectives of the new law:

• protecting the interests of crypto-asset holders and of the clients of service providers in this field;
• developing a transparent, stable and efficient crypto-asset market;
• creating conditions to support innovation and fair competition in the crypto-asset market.

The main supervisory authority is the Financial Supervision Commission (Комисия за финансов надзор), which monitors compliance with EU regulations, issues and withdraws licences of crypto-asset service providers, and takes decisions on DORA requirements.

Before the law was adopted, the register of persons providing exchange services between virtual currencies and recognised means of payment, as well as wallet custody services (публичен електронен регистър на лицата, които предоставят услуги по обмяна между виртуални валути и признати валути без златно покритие, и на доставчиците на услуги за съхранение на портфейли), was maintained by the National Revenue Agency (NAP) on the basis of the anti-money laundering law. Since the law entered into force, the register has been maintained by the Financial Supervision Commission.

Companies registered in the NAP register may continue operating without a licence until 01.07.2026. After that, operating without a licence will be prohibited. Thus, a CASP licence must be obtained by the end of June 2026. In addition, if a company’s details change, the Financial Supervision Commission must be notified within 14 days (a fee of 200 leva is charged for this).

Those who are only planning to start a business in this field must obtain a licence and register with the Financial Supervision Commission from the outset.

Prohibitions and fines

The law prohibits:

• the public offering of “other” crypto-assets without the MiCA procedure;
• issuing ART without a MiCA licence;
• providing crypto-asset services without a CASP licence;
• transfers of crypto-assets without the details of the sender and the recipient;
• failure to comply with operational resilience requirements (DORA).

In the event of violations, the Financial Supervision Commission may prohibit certain operations, suspend or withdraw a licence, and require the removal or blocking of interfaces or content. Fines for individuals may range from 1000 to several million leva. For legal entities and CASPs, sanctions of up to tens of millions of leva or up to 15% of turnover are also possible.