Bulgaria Crypto Licence 2026: The CASP Guide
A 2026 guide to the Bulgaria crypto licence — the FSC CASP authorisation under MiCA, capital by class, EU-27 passporting, the 10% flat tax.
Contents
If you want a full EU crypto licence and you want to keep the running cost lean, Bulgaria is the value option most cost-sensitive operators end up shortlisting. A CASP authorisation from the Financial Supervision Commission (FSC) under MiCA passports across all 27 EU member states on a notification basis, the same credential a Frankfurt or Paris licence gives you, but Bulgaria wraps it in a flat 10% corporate tax and a low overall cost base that the EU heavyweights cannot match. With the legacy VASP transition period now over, it is also one of the cheapest ways to re-establish EU-facing authorisation from scratch.
Bulgaria’s VASP-to-CASP window closed on 1 July 2026, so choosing it now means a full MiCA licence, and the case for it is the total cost of staying licensed in Europe over several years. The capital is fixed by MiCA and identical everywhere; the substance and the DORA programme are real work wherever you go. What differs jurisdiction to jurisdiction is tax, running cost and the regulator’s temperament, and on that axis Bulgaria is genuinely hard to beat. This guide explains what a Bulgaria crypto licence actually is in 2026: the regime, the capital, the passport, the 10% tax draw, the substance, and the trade-off.
- The Bulgaria crypto licence is a MiCA CASP authorisation from the Financial Supervision Commission (FSC). It replaced the old national register and passports across all 27 EU states by notification.
- Capital is set by MiCA and identical EU-wide: €50,000 (Class 1), €125,000 (Class 2, adds custody + exchange), €150,000 (Class 3, trading platform).
- The headline draw is a flat 10% corporate tax, the standard rate and among the EU’s lowest for a typical CASP, on top of a low overall cost base.
- It demands real substance: a Bulgarian company, qualified management, an MLRO and a DORA ICT framework. The VASP→CASP window closed on 1 July 2026.
What a Bulgaria CASP licence is and what it replaced
A Bulgaria crypto licence is a Crypto-Asset Service Provider (CASP) authorisation, issued by the Financial Supervision Commission (Комисия за финансов надзор) under the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114). The FSC is the competent authority for CASP licensing in Bulgaria (the Bulgarian National Bank handles the prudential side of e-money tokens). It is the single EU credential for firms that provide crypto services: running an exchange, safeguarding client assets, executing orders, operating a trading platform, or advising on crypto-assets.
The word “replaced” is doing real work here. Before MiCA, Bulgaria, like most of the bloc, ran a light national register for crypto providers with minimal substance behind it. MiCA retired that model across the EU. The CASP licence that took its place is a proper financial-services authorisation, supervised by the FSC, carrying capital, governance, AML and technology obligations the old registration never had. If you have read our VASP, CASP and MiCA explainer, this is the same EU-wide shift landing in Bulgaria. Anyone still marketing a “Bulgarian VASP licence” in 2026 is describing something that is either a CASP or a registration that has already expired, and confusing the two is expensive.
Capital by service class in Bulgaria
MiCA sets minimum capital by the class of service you provide, and those tiers are the same in every EU country, which is the point operators most often miss. You do not pick Bulgaria for cheaper capital; the capital is fixed by the regulation. You pick it for the tax, the cost base and the FSC’s process. What Bulgaria determines is which class (or classes) your business falls into.
| Class | Minimum capital | Typical services |
|---|---|---|
| Class 1 | €50,000 | Reception/transmission of orders, advice, execution, placing, transfers |
| Class 2 | €125,000 | Adds custody and exchange (holding client assets, crypto-to-fiat) |
| Class 3 | €150,000 | Adds operating a trading platform |
Two things matter in planning. First, the capital is not paid as a fee. Held as own funds it stays in the business, an insurance policy can cover it instead, and the requirement rises to a quarter of last year’s fixed overheads if that is higher. Second, the classes are cumulative: an exchange with custody sits in Class 2, and a full order-book trading venue lands you in Class 3 at €150,000. Most exchange and broker projects sit at €125,000. Scoping the right class before you incorporate is the single decision that most affects your budget — our Bulgaria crypto licence cost breakdown models the full year-one number, capital included, and our Bulgaria crypto licence requirements guide sets out the complete document and governance checklist behind it.
From Bulgaria, one licence and 27 markets: the EU passport
The reason a CASP licence is worth the substance is the passport. Under MiCA Article 65, once the FSC authorises you, you can provide your licensed services into every other EU/EEA member state on a notification basis: the regulator in each host country is notified, and you can start serving that market. You license once in Sofia and passport everywhere, instead of applying licence-by-licence across 27 jurisdictions.
An offshore VASP makes you legal where it is issued. A Bulgarian CASP reaches the entire European single market, 27 member states under one rulebook, from one file. It also carries weight with the parties that decide whether you can actually operate: banks that hold your funds, the EMI and PI partners that provide your fiat rails, auditors and institutional counterparties. An FSC licence is an EU credential, and those counterparties treat it very differently from an offshore permit.
A CASP licence passports by notification, but you still honour each market’s local marketing rules and geo-block jurisdictions you are not authorised in, plus the United States, sanctioned and FATF-listed territories. The passport gives you market access while each host country’s conduct rules still apply. The scope of what we build for a Bulgarian file lives on our Bulgaria crypto licence service page.
The 10% tax advantage: the main reason to choose Bulgaria
Here is why cost-sensitive teams keep landing on Bulgaria. The country levies a flat 10% corporate tax, the standard headline rate, applied to almost all businesses, with none of the reduced-band conditions or graduated schedules you have to qualify for elsewhere. For a typical CASP, that is genuinely among the lowest effective corporate tax rates in the European Union. A profitable exchange or brokerage keeps materially more of its margin under a Bulgarian entity than under most EU peers, year after year. Unlike a one-off setup saving, a tax edge compounds for as long as you operate.
Bulgaria’s 10% is the ordinary corporate tax that applies across the board, which is what makes it durable and easy to model. Very large multinational groups in scope of the OECD/EU Pillar Two rules may face a top-up toward the 15% global minimum, but for the vast majority of CASPs the 10% standard rate is exactly what you plan around. We model the full, current tax position, corporate and crypto-specific, in our Bulgaria crypto tax guide.
Tax is the headline, but it sits on top of a broadly low cost base. Office, staff and professional-services costs in Bulgaria run well below the EU average, which matters because the FSC substance requirements recur every year. The combination is the whole pitch: a full MiCA licence with the same passport as anywhere in the bloc, at a tax and running cost that lets a lean team actually afford to keep it.
The real substance requirement in Bulgaria
This is where the modern Bulgaria licence separates hardest from the old register, and where the real work goes. A CASP authorisation requires a Bulgarian company with genuine local substance. That means a registered office and a real operating presence in Bulgaria, MiCA-level own funds or insurance cover, and management the FSC assesses as qualified and fit-and-proper, with relevant financial-services or crypto experience on the board.
On top of the entity, you need a live compliance function. A dedicated MLRO (money-laundering reporting officer) and AML/CFT policies aligned to the EU’s 5th and 6th AML directives, the EU Transfer of Funds Regulation (the Travel Rule) for originator and beneficiary data on transfers, and suitability and source-of-funds checks on shareholders and UBOs. And since 17 January 2025, MiCA firms must run a DORA-compliant ICT programme (operational resilience, incident reporting, resilience testing and third-party ICT oversight), which for a crypto business also means serious custody, key-management and cybersecurity controls. None of this existed under the old register, and it is exactly what gives the CASP licence its standing. Building it properly is a project in itself, and the crypto-friendly banking and EMI/PI partners around it are usually the hardest single piece to line up.
| Fits Bulgaria if you are… | Why |
|---|---|
| A cost-sensitive team wanting an EU base | Full MiCA passport at a flat 10% tax and a low running-cost base |
| An exchange or broker scaling into the EU | One CASP passports to 27 markets; Class 2 at €125k covers exchange + custody |
| A custodian or wallet provider | Custody service class plus MiCA asset-segregation and DORA controls |
| An early-stage EU entrant | A lean, low-tax base with full single-market reach from day one |
Timeline, the deadline, and who it suits
Plan for roughly three to six months end to end on a complete, well-prepared file, covering incorporation, funding, file-building and the FSC’s assessment. The FSC reviews a complete application against a defined statutory clock and issues a reasoned decision, so the variable that decides your timeline is not the regulator’s queue but your own preparation. The classes must be scoped, the Bulgarian company incorporated and capitalised, the programme of operations and the AML, DORA and safeguarding policies drafted to FSC standard, and management genuinely fit-and-proper. Poorly prepared applications stall in review questions, which is where most of the timeline risk sits.
The date that mattered for legacy providers was 1 July 2026, the outer limit of the MiCA transitional window (Article 143(3)). That window has now closed, so new entrants apply directly to the FSC for a full CASP authorisation; there is no lighter interim route to fall back on. So who is it for? Bulgaria suits operators who genuinely need the EU market, can meet the capital and substance bar, and want a low sustainable cost of holding a full EU licence: exchanges, brokers, custodians and early-stage teams building a long-term European base. If your market is global or non-EU, an offshore or Gulf regime is often faster and cheaper, and no single licence covers every market, so many groups run an EU CASP for Europe and a separate licence for the rest of the world.
The Bulgaria trade-off
Bulgaria’s pull is its flat 10% corporate tax, but the FSC still expects MiCA capital, a real Bulgarian company and a DORA programme, and a file takes three to six months to build and clear. What you get for that is EU-wide passporting from one authorisation, with running costs among the lowest of the serious EU options.
If a low-cost EU crypto base is where your project is heading, we run the entire file (the Bulgarian company, the substance and management, the AML and DORA framework, the FSC application and the crypto-friendly banking around it), with our fees and the state costs shown separately. See the scope on our Bulgaria crypto licence page, then book a free consultation and we’ll model the real year-one economics, including the right service class, the capital and the 10% tax position, before you commit a euro.
Frequently asked questions
What is a crypto licence in Bulgaria?
A Bulgaria crypto licence is a Crypto-Asset Service Provider (CASP) authorisation issued by the Financial Supervision Commission (FSC) under the EU's Markets in Crypto-Assets Regulation (MiCA). It replaced Bulgaria's old national crypto register and lets you provide crypto services across all 27 EU member states on a notification basis. It is a full financial-services licence, and the FSC supervises it as one.
How much capital do I need for a Bulgarian CASP?
Capital is set by MiCA by service class and is identical across the EU: €50,000 for Class 1 (reception/transmission, advice, execution, placing), €125,000 for Class 2 (adds custody and exchange), and €150,000 for Class 3 (operating a trading platform). In practice you hold the higher of that tier or a quarter of last year's fixed overheads, as own funds (which remain the company's money), an insurance policy or a mix.
Why is Bulgaria cheaper than other EU crypto jurisdictions?
Bulgaria pairs a flat 10% corporate tax (the standard rate, and among the EU's lowest for a typical CASP) with modest running costs and lean substance. You still fund the same MiCA capital and build the same AML and DORA programme, but the tax and cost base make Bulgaria one of the most efficient full EU crypto bases available.
How long does a Bulgarian crypto licence take?
Plan for roughly three to six months on a complete, well-prepared file, including incorporation and file-building. The FSC assesses a complete application against a defined statutory clock; the timeline risk sits in your own preparation, since poorly built files are what stall in review questions.
Is the old Bulgarian VASP registration still available?
No. Under MiCA the national register is retired and replaced by the CASP licence. The transitional window for previously registered providers closed on 1 July 2026 (MiCA Article 143(3)). New entrants apply directly to the FSC for CASP authorisation — there is no route back to the old regime.
Does a Bulgarian CASP work across the whole EU?
Yes. It is a full MiCA authorisation and passports into all 27 member states on a notification basis under MiCA Article 65. You license once in Bulgaria and serve the entire European single market while still honouring each market's local conduct rules.
Sources
This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.
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