MiCA (Markets in Crypto Assets Regulation — EU Regulation 2023/1114) is the EU’s comprehensive regulatory framework for crypto asset markets. It creates a single EU-wide regulatory regime for crypto asset service providers (CASPs) and crypto asset issuers. MiCA became fully applicable on 30 December 2024 for CASPs providing services across the EU. Titles III and IV (covering ARTs and EMTs) applied from 30 June 2024. CASPs that were operating before MiCA’s full application may benefit from transitional provisions in their home member state.
Crypto Licence in Bulgaria
EU MiCA CASP Authorisation — Operate Crypto Asset Services Across the Entire European Union
EU MiCA Regulation
FSC Regulated
Full EU Passporting
From €50,000 Capital
KEY FIGURES
€50K Min. capital — Class 1 CASP
€125K Min. capital — Class 2 CASP
€150K Min. capital — Class 3 CASP
27 EU member states — single licence coverage
Crypto licence in Bulgaria — MiCA and what it means for your business
The EU Markets in Crypto Assets Regulation (MiCA — Regulation 2023/1114) entered into full effect on 30 December 2024, creating the world’s first comprehensive, harmonised regulatory framework for crypto asset service providers (CASPs) across all 27 EU member states. For crypto businesses operating in or targeting the EU market, MiCA fundamentally changes the compliance landscape — making an EU CASP authorisation both a legal necessity and a significant commercial opportunity.
A Bulgarian CASP authorisation under MiCA is issued by the Financial Supervision Commission (FSC) and provides a single EU-wide licence — enabling the holder to provide authorised crypto asset services across all 27 EU member states through the MiCA passporting mechanism, without obtaining separate national licences in each country. Bulgaria offers a cost-competitive environment for establishing the required substance, combined with a 10% flat corporate tax rate and an established financial services regulatory framework.
MiCA IN BULGARIA: The EU MiCA Regulation is directly applicable in Bulgaria as an EU member state — it does not require national transposition legislation. The FSC is designated as the National Competent Authority (NCA) for MiCA in Bulgaria and is responsible for processing CASP authorisation applications, supervising authorised CASPs, and coordinating with ESMA and other EU NCAs. ESMA provides binding technical standards and guidelines that supplement MiCA and apply uniformly across all EU member states.
MiCA crypto asset types — what is covered
MiCA covers three categories of crypto assets, each subject to a different regulatory regime. Understanding which category your tokens or assets fall into is the essential first step in any MiCA compliance analysis.
| Crypto asset type | Description | MiCA treatment & requirements |
|---|---|---|
| Asset-referenced tokens (ARTs) | Crypto assets that maintain a stable value by referencing multiple currencies, commodities, or other crypto assets. Similar to multi-currency stablecoins. | Most stringent MiCA requirements — significant capital, reserve, and governance obligations. Issuers must be authorised credit institutions or obtain specific MiCA authorisation. |
| E-money tokens (EMTs) | Crypto assets that reference a single official currency — essentially electronic money issued on a blockchain (e.g. EUR stablecoins). | Must be issued by a credit institution or an e-money institution. The EMT regime largely follows existing e-money regulation under PSD2. |
| Other crypto assets (CASP scope) | All other crypto assets not qualifying as ARTs or EMTs — including utility tokens, payment tokens, and most major cryptocurrencies (Bitcoin, Ethereum, etc.). | Issuers subject to whitepaper requirements. Service providers (CASPs) require authorisation for any of the 10 services listed above. |
The ten MiCA crypto asset services — what requires CASP authorisation
MiCA defines ten specific crypto asset services that require CASP authorisation. A CASP authorisation must specify which services the entity is authorised to provide — the scope is service-specific and cannot be exceeded without a variation of authorisation. The minimum capital requirement depends on the highest-class service the CASP is authorised to provide.
| Crypto asset service (MiCA Art. 3) | Description | Capital class |
|---|---|---|
| Custody & administration of crypto assets on behalf of clients | Safekeeping private keys or otherwise holding crypto assets on behalf of third parties. Includes operation of wallets, vaults, and similar custody infrastructure. | Class 1 — €50,000 |
| Operation of a crypto asset trading platform | Operating a multilateral system (exchange) where multiple third-party parties buy and sell crypto assets — order books, matching engines, or quote-driven platforms. | Class 2 — €125,000 |
| Exchange of crypto assets for fiat currency | Buying and selling crypto assets against fiat currencies (EUR, USD, GBP etc.) using own capital — acting as a dealer or market maker in crypto/fiat pairs. | Class 2 — €125,000 |
| Exchange of crypto assets for other crypto assets | Buying and selling crypto assets against other crypto assets using own capital — crypto-to-crypto swap and exchange operations. | Class 2 — €125,000 |
| Execution of orders in crypto assets on behalf of clients | Executing client orders to buy or sell crypto assets — acting as a broker rather than a principal. | Class 2 — €125,000 |
| Placing of crypto assets | Offering crypto assets to third parties on behalf of the issuer (underwriting or best efforts distribution) — relevant for token issuers and advisors. | Class 2 — €125,000 |
| Reception and transmission of orders in crypto assets (RTO) | Receiving a client order in crypto assets and transmitting it to another CASP for execution — an introducing or referral model. | Class 2 — €125,000 |
| Providing advice on crypto assets | Providing personalised recommendations to clients on specific crypto assets or crypto asset services. | Class 2 — €125,000 |
| Providing portfolio management of crypto assets | Managing portfolios of crypto assets on a discretionary basis on behalf of clients. | Class 3 — €150,000 |
| Providing transfer services for crypto assets on behalf of clients | Transferring crypto assets from one DLT address or account to another on behalf of clients. | Class 1 — €50,000 |
IMPORTANT — CASP AUTHORISATION SCOPE: A CASP authorisation is not a blanket licence to provide all crypto asset services. The FSC authorises specific services from the list above. If a CASP wishes to add services after authorisation, it must apply for a variation of its authorisation. Bulgaria for Business VCC advises on the optimal service scope to include in the initial application — balancing current business needs with anticipated growth.
MiCA CASP authorisation requirements
The MiCA CASP authorisation application requires a comprehensive package of documentation demonstrating that the applicant meets all regulatory requirements. The FSC reviews applications against the MiCA Regulation directly and against ESMA’s regulatory technical standards. A well-prepared application is essential to avoid delays from supplementary questions.
- Registered Bulgarian legal entity — A Bulgarian OOD or AD — the legal form depends on the specific services and capital class. Bulgaria for Business VCC advises on the optimal entity type for the intended CASP services.
- Minimum own funds / capital — Paid-up capital meeting the class requirement: €50,000 (Class 1), €125,000 (Class 2), or €150,000 (Class 3). Must be held in a Bulgarian bank account. May also be maintained as professional indemnity insurance of equivalent coverage.
- Management — fit & proper — Management body members must demonstrate honesty, integrity, sufficient knowledge and experience of crypto asset services (or financial services more broadly). Criminal record clearance required. FSC assesses fitness and propriety of each proposed manager.
- Business plan & whitepaper — Detailed business plan describing the CASP’s services, target markets, technology infrastructure, financial projections, and compliance approach. Where the CASP is also a crypto asset issuer, a MiCA-compliant whitepaper is required.
- Policies & procedures — Documented policies covering: conflicts of interest, market abuse prevention, complaints handling, client asset segregation (where applicable), business continuity, and outsourcing arrangements.
- AML/CFT compliance programme — Fully documented AML/CFT programme — mandatory for all CASPs under the EU Travel Rule and AML Directives as applied to crypto asset service providers. PEP screening, transaction monitoring, and suspicious transaction reporting.
- Technology & cybersecurity assessment — Description of the technology infrastructure, custody arrangements (where applicable), cybersecurity framework, wallet management, key management, and resilience/recovery procedures.
- Client asset segregation — For CASPs holding client crypto assets or fiat money — documented procedures for segregating client assets from own assets and maintaining accurate client position records.
- Physical presence in Bulgaria — A genuine operational presence — physical office in Bulgaria with appropriate infrastructure. The FSC expects real substance, not a letterbox.
AML FOR CRYPTO: CASPs are obliged entities under EU AML Directives and face some of the most demanding AML requirements in the financial sector — including blockchain transaction monitoring, Travel Rule compliance, enhanced due diligence for high-risk wallets, and screening against sanctions lists including OFAC, EU, and UN sanctions. A crypto-specific AML programme — not a generic financial services AML policy — is required. Bulgaria for Business VCC designs crypto-specific AML programmes including blockchain analytics tool integration from €2,000.
The application process — step by step
From initial assessment to authorised CASP operations, Bulgaria for Business VCC manages the full MiCA application process. The typical timeline from engagement to authorisation is 3–12 months depending on application readiness and FSC processing.
1
MiCA scope & services assessment
We assess your business model against MiCA’s 10 service definitions and three asset type categories. We confirm which services require CASP authorisation, which capital class applies, and whether any activities fall outside MiCA’s scope (NFTs, DeFi, pure spot transactions).
Free initial assessment — 1–3 business days
2
Entity formation
Formation of the Bulgarian company — OOD or AD depending on the services and capital class. Articles of Association, director appointment, share capital deposit, and Commercial Register registration.
2–4 weeks
3
Application documentation preparation
Preparation of the full MiCA application package: business plan, financial projections, compliance manual, AML programme (including blockchain analytics and Travel Rule solution), technology assessment, management CVs, policies and procedures, and whitepaper (if applicable).
4–8 weeks
4
FSC pre-application engagement
Where appropriate, we engage with the FSC in a pre-application meeting to confirm the application approach, discuss any novel aspects of the business model, and clarify FSC expectations before formal submission.
Optional but recommended for novel business models
5
Application submission to FSC
The complete MiCA CASP authorisation application is submitted to the FSC. The FSC has 25 working days to confirm completeness, and then a statutory review period (currently being established under MiCA Level 2 standards) to assess the application.
Submitted within 1 week of final package
6
FSC review & supplementary questions
The FSC reviews the application and typically issues supplementary questions. We manage all FSC correspondence — preparing well-framed responses that address the regulator’s concerns concisely and completely.
3–10 months from submission
7
CASP authorisation issued
The FSC grants the CASP authorisation and publishes the firm in ESMA’s EU-wide public register of authorised CASPs. The authorisation specifies the services the CASP is authorised to provide.
Published in ESMA’s CASP register upon authorisation
8
Passporting & launch
EU passporting notifications to target member states, final compliance systems testing, and launch of authorised operations. Transition from application mode to full ongoing compliance regime.
1–2 months post-authorisation
Ongoing obligations after CASP authorisation
MiCA CASP authorisation carries substantial ongoing obligations. These are not administrative formalities — regulators actively supervise CASPs and have powers to suspend or revoke authorisation for non-compliance. Bulgaria for Business VCC provides ongoing compliance support for all CASP clients.
| Ongoing obligation | Details |
|---|---|
| Own funds maintenance | Ongoing maintenance of minimum own funds. Immediate notification to FSC if own funds fall below the required minimum. Regular own funds calculations and reporting. |
| Prudential reporting to FSC | Periodic prudential reports to the FSC covering own funds, risk exposures, and compliance with MiCA requirements. |
| AML ongoing compliance | Continuous customer due diligence, transaction monitoring using blockchain analytics tools, Travel Rule compliance for crypto transfers, suspicious activity reporting to DANS. |
| Travel Rule compliance | Under FATF Travel Rule (implemented in EU via TFR Regulation), CASPs must transmit originator and beneficiary information with crypto asset transfers above €1,000. Requires Travel Rule solution integration. |
| Market abuse prevention | Monitoring and prevention of market manipulation and insider dealing in crypto asset markets — obligations similar to MAR for traditional financial instruments. |
| Client disclosure obligations | Pre-contractual and ongoing disclosure to clients on fees, conflicts of interest, risks, and complaint procedures. Complaints handling with defined response timeframes. |
| Annual statutory audit | Annual statutory audit by a licensed Bulgarian auditor — audited financial statements submitted to the FSC. |
| Regulatory change monitoring | Ongoing monitoring of ESMA MiCA guidance, FSC regulatory developments, and EU AML Directive changes affecting CASPs — implementing required policy updates. |
Cost overview
The total cost of obtaining and maintaining a Bulgarian MiCA CASP authorisation involves one-off application costs, a minimum capital commitment, and ongoing annual compliance costs. All professional fees exclude Bulgarian VAT (20%).
| Item | Description | Cost (excl. VAT) |
|---|---|---|
| Company formation (OOD or AD) | Formation of the Bulgarian entity — Articles of Association, director, share capital deposit, and Commercial Register filing. | From €300 |
| FSC application fee (state fee) | Official application fee payable to the FSC upon submission of the CASP authorisation application. | ~BGN 1,000–3,000 (~€500–1,500) |
| Bulgaria for Business VCC — application preparation | Full application package: business plan, organisational policies, AML programme, technology assessment, management CVs, compliance manual, and all supporting documentation. | From €4,000 |
| AML compliance programme (crypto-specific) | Crypto-focused AML/CFT programme including blockchain analytics tool integration, Travel Rule solution, and transaction monitoring procedures. | From €2,000 |
| Legal address & physical office setup | Physical presence in Bulgaria — legal address and office arrangement advisory. | From €400/yr |
| Minimum own funds — Class 1 (custody/transfer) | Paid-up capital or equivalent professional indemnity insurance — regulatory capital commitment. | €50,000 |
| Minimum own funds — Class 2 (exchange/trading) | Paid-up capital for exchange, trading platform, order execution, and related services. | €125,000 |
| Minimum own funds — Class 3 (portfolio management) | Paid-up capital for portfolio management services. | €150,000 |
| Ongoing compliance support (annual) | Post-licence compliance: FSC reporting, AML review, Travel Rule monitoring, policy updates, regulatory change management. | From €1,500/mo |
| Annual statutory audit | Annual statutory audit by a licensed Bulgarian auditor. | From €2,500/yr |
Minimum own funds are a regulatory capital commitment — a balance sheet item, not a fee. They must be maintained at all times. Professional indemnity insurance of equivalent value may substitute for paid-up capital in some cases — we advise on this option at the assessment stage. Official FSC fees are paid directly to the regulator and are not included in Bulgaria for Business VCC service fees.
Frequently asked questions — crypto licence
Key questions answered for foreign entrepreneurs considering a Bulgarian MiCA CASP licence.
Yes. Under MiCA, a CASP authorisation granted by the FSC in Bulgaria can be passported across all EU member states — allowing the CASP to provide its authorised services to clients in other member states either on a cross-border basis or through a branch, without obtaining separate national licences. The passporting notification process involves informing the FSC, which notifies the host state’s competent authority.
Bitcoin, Ethereum, and the vast majority of cryptocurrencies fall into MiCA’s ‘other crypto assets’ category — they are neither ARTs nor EMTs. Providing services in relation to these assets requires CASP authorisation under MiCA. NFTs (non-fungible tokens) are generally outside MiCA’s scope unless they are fungible in practice. DeFi protocols and fully decentralised systems without an identifiable service provider are also generally outside MiCA’s scope.
MiCA includes transitional provisions allowing CASPs that were lawfully providing crypto asset services before MiCA’s full application date to continue operating during a transition period — which varies by member state (up to 18 months for some). During this period, the CASP must submit a full MiCA authorisation application. Bulgaria for Business VCC assists existing operators with MiCA transition planning, application preparation, and FSC liaison during the transition period.
The FATF Travel Rule, implemented in the EU through the Transfer of Funds Regulation (TFR), requires CASPs to obtain, hold, and transmit originator and beneficiary information with every crypto asset transfer of €1,000 or more. This applies to transfers between CASPs and to unhosted wallets (private wallets). Compliance requires implementation of a Travel Rule solution — technology that enables structured data exchange between CASPs. Bulgaria for Business VCC advises on Travel Rule compliance and technology provider selection as part of the AML programme.
A CASP is an entity providing services in relation to crypto assets — exchanges, custodians, brokers, portfolio managers. A crypto asset issuer is an entity that creates and offers crypto assets to the public (via a whitepaper). The same entity can be both an issuer and a CASP. Issuers of ‘other crypto assets’ must publish a MiCA-compliant whitepaper and comply with issuer conduct obligations — but do not require separate CASP authorisation for the issuance itself.
Under MiCA, all CASP authorisations are issued under the same EU-level regulatory framework — so the substantive requirements are identical regardless of which EU member state issues the licence. The key differences between jurisdictions are: the regulator’s processing speed and communication approach, the cost of establishing genuine substance, and the broader business environment. Bulgaria offers competitive operational costs and a 10% corporate tax rate. Lithuania has been a popular early-mover jurisdiction. Germany’s BaFin has a more intensive supervisory approach. Bulgaria for Business VCC advises on jurisdiction selection as part of the regulatory assessment service.
Non-fungible tokens (NFTs) are generally outside the scope of MiCA — the regulation explicitly excludes crypto assets that are unique and not fungible with other crypto assets. However, if NFTs are issued in a large series where individual tokens are effectively interchangeable, or if they are used as payment instruments or investment vehicles, they may fall within MiCA’s scope. Bulgaria for Business VCC provides specific advice on the MiCA classification of NFTs and related token structures on a case-by-case basis.
Start your MiCA CASP application in Bulgaria
Free regulatory assessment — we confirm the right service class for your business model, outline MiCA requirements, and provide a fixed-fee proposal for the full application process.
Class 1 from €50,000
Class 2 from €125,000
Class 3 from €150,000
Application support from €4,000
Class 2 from €125,000
Class 3 from €150,000
Application support from €4,000
Bulgaria for Business VCC — Your Trusted Partner for Business Expansion into Bulgaria and the European Union. MiCA requirements, capital thresholds, and regulatory timelines are correct as of 2024–2025 and are subject to change as ESMA publishes Level 2 technical standards and NCAs develop supervisory practices. This document is for general information only and does not constitute legal or regulatory advice.