Bulgaria Crypto License Requirements in 2026

A Bulgaria crypto (CASP) licence requires a Bulgarian company with genuine local substance and the class-based MiCA capital — €50,000, €125,000 or €150,000 by service class. Bulgaria is the EU’s value option for a full crypto licence — the lowest official fees in the union and a flat 10% corporate tax — but the requirements file behind a CASP authorisation is the same full MiCA file every member state demands. The cheap state fee buys you a place in the queue, not a lighter standard. The Financial Supervision Commission (FSC) still asks for a real Bulgarian business: a company with substance, funded capital, vetted people and a working AML and ICT-resilience programme.

This guide is the requirements checklist we work from on our own desk. It covers exactly what the 2026 Bulgaria CASP regime demands — a Bulgarian company with genuine presence, initial capital by service class, fit-and-proper management assessed by the regulator, an MLRO, and a DORA-compliant ICT framework — so you can price the licence on what it actually takes rather than on the headline fee. This is a full EU financial-services regime, and we scope it as one.

The company and local substance

Everything starts with a Bulgarian company. The FSC licenses a Bulgarian legal entity with genuine substance behind it — there is no remote-only route. The applicant is incorporated in Bulgaria, keeps a registered office there, and runs a real operating presence, not a virtual mailbox. This is the first hard requirement operators pricing Bulgaria on the €2,556 Class 1 fee tend to skip past, and it is the one that separates a serious file from a rejected one.

Substance is assessed in the round. The regulator wants to see that the business is directed and administered from Bulgaria, with the right people performing the core functions locally. A company that exists only on paper, with management and operations sitting elsewhere, does not clear the substance test — the low cost base is a genuine advantage, but it is not permission to run a nameplate. For the full picture of what a CASP authorisation buys and how it sits within MiCA, our flagship Bulgaria crypto licence overview maps the regime end to end.

Capital by service class

This is the requirement that catches operators reading Bulgaria as “the cheap one.” MiCA sets a minimum capital floor by the service class you run, and Bulgaria applies it directly — the low state fee does not reduce it. At application you must fund the initial capital and hold it in a bank or e-money account within the EEA. It is working capital of the business, not a fee.

These figures are identical in every EU member state — they come from MiCA, not from Bulgarian law — so the capital tier is not something you optimise by choosing Bulgaria over another jurisdiction. What Bulgaria offers is the lowest official application fees in the EU and a flat 10% corporate tax sitting behind the same capital requirement. Costs sit outside scope here; for the full year-one build, the state fee and running costs, see the Bulgaria crypto licence cost guide, and for the capital rules across all three classes our CASP capital requirements primer breaks each one down.

People, governance and fit-and-proper vetting

Under MiCA, the people behind the company are assessed as rigorously as the business itself, and the FSC runs the vetting. This is not a formality — an unresolved file on any one person holds the whole application.

Fit-and-proper management. The people running the CASP are assessed for competence, integrity and relevant experience. The FSC expects a board and senior management with genuine financial-services or crypto backgrounds — not a founder team with no regulated-industry track record. Directors must demonstrate they can actually run a licensed EU financial-services business, and that expectation does not soften because Bulgaria is the cheaper base.

A dedicated MLRO and governance structure. A money-laundering reporting officer is a condition of the licence, backed by a clear governance structure with defined responsibilities and board-level compliance oversight. The MLRO is accountable for the AML programme, transaction monitoring and reporting — and must be a real, appointable person, not a name on an org chart.

Suitability and source-of-funds on shareholders and UBOs. Every ultimate beneficial owner and significant shareholder faces suitability checks and a source-of-funds assessment. You must show not only that the business is funded, but where the money comes from and how the beneficial owners built their wealth. Vague or undocumented wealth is one of the most common reasons a file stalls — the same standard a tier-1 bank applies.

Because these checks take the longest to assemble, especially source-of-funds evidence and documents from multiple jurisdictions, start them on day one rather than treating them as a closing step.

The documents and programme

Alongside people and capital, the FSC reviews a defined set of documents and policies. Filing with any of these missing, or written for a different business model, is what stops the statutory 40-working-day clock and turns a two-month approval into a longer one. The core pack is:

Three elements deserve emphasis. The AML/CFT policies must be operable documents aligned to the EU’s anti-money-laundering directives and the Travel Rule — the EU Transfer of Funds Regulation obligation to attach originator and beneficiary data to crypto transfers — because the MLRO is expected to actually run them. The DORA ICT framework covers ICT risk management, incident reporting, resilience testing and third-party ICT oversight, and it applies to every CASP. And where you issue or admit tokens to trading, a MiCA white paper meeting the regulation’s disclosure standard is required on top of the service authorisation. Custody, safeguarding and complaints-handling policies round out the pack, with strict client-asset segregation for any class that touches custody.

Transition, passporting and the statutory clock

Two dates frame the requirements. First, the VASP-to-CASP transition: Bulgaria adopted the full grandfathering window to 1 July 2026 and issued its first MiCA licence in April 2026, so the regime is operational and the legacy window has now closed. New entrants apply directly to the FSC for a CASP authorisation — there is no VASP registration shortcut left. Bulgaria’s low tax base is a natural home for teams weighing where profits land; our Bulgaria crypto tax guide covers the flat 10% corporate rate and how crypto activity is treated alongside it.

Second, the reward for meeting the full requirements: passporting. Once the FSC grants the CASP licence, it lets you offer crypto services across all 27 EU member states on a notification basis under MiCA Article 65 — one licence, the single largest regulated crypto market in the world, without applying jurisdiction by jurisdiction. That EU-wide reach is exactly what the substance, capital and DORA requirements are the price of. And unlike heavier EU regulators, the FSC runs a defined 40-working-day statutory assessment of a complete file, which keeps a well-prepared timeline predictable.

Assembling the file in the right order

Requirements are one thing; sequence is another. The order that avoids rework is: fix your CASP service classes and the matching capital tier first, then incorporate the Bulgarian company, fund the capital in an EEA account and stand up the local office and roles. Assemble every UBO and management fit-and-proper file — source of funds, suitability, experience evidence — in parallel, because they take the longest. Draft the programme of operations, AML/CFT and DORA policies against your actual operating model, not off a template. Only then does the FSC application go in, because the statutory clock only rewards a complete file.

None of this is a light-touch registration — and the low cost does not make it one. The Bulgarian CASP regime asks for a real company, real capital, vetted people and operable AML and ICT programmes, and in exchange gives you a full EU financial-services credential that passports across 27 markets and carries weight with banks, PSPs and institutional partners, all on the lowest fee base and one of the lowest tax rates in the union. Get the file complete and internally consistent the first time and the statutory window works in your favour; file with gaps and the clock stops.

Ready to assemble your CASP requirements pack, or want a second opinion on a file you have already started? Our team handles the full Bulgarian substance, fit-and-proper, AML and DORA build end to end and will review any application against the FSC’s expectations before you submit. Book a free consultation and we will tell you exactly what is missing.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.