On 20 June 2025, the Bulgarian Parliament passed the long-awaited Crypto-Asset Markets Act, marking a significant step toward regulatory clarity and legal certainty for participants in the virtual currencies and blockchain technology sector.
The Act introduces rules governing the issuance of crypto-assets, the provision of related services, supervisory measures over market participants, sanctions for violations, and the management of operational and IT risks in the crypto sector. It aligns with three core EU acts: the Markets in Crypto-Assets Regulation (MiCA), which defines types of crypto-assets, requirements for service providers, and licensing and oversight procedures; the Transfer of Funds Regulation (TFR), part of the EU’s anti-money laundering package; and the Digital Operational Resilience Act (DORA), establishing a unified IT risk management framework for the entire EU financial sector.
Supervisory responsibilities are divided between two regulators. The Financial Supervision Commission (FSC) will license crypto service providers, oversee their activities, and impose sanctions or bans in case of violations. The Bulgarian National Bank (BNB) will supervise electronic money tokens.
To foster a predictable business environment, significant amendments were made between the first and second readings of the bill. Notably, the so-called “tacit refusal” principle was removed. Under this rule, the absence of a response from the FSC was deemed a rejection, which created legal uncertainty and contradicted MiCA principles. The licensing procedure and timelines were also clarified, including the introduction of a transitional regime.
Companies listed in the National Revenue Agency’s register as virtual currency service providers under the Anti-Money Laundering Act as of 30 December 2024 may continue operations until 1 July 2026 without holding a full MiCA license. This transitional period allows them time to prepare for the new regulatory framework, including the development of internal policies, meeting capital requirements, and implementing compliance procedures. After 1 July 2026, all crypto businesses wishing to operate legally in Bulgaria—and across the EU under the so-called passporting regime—will be required to obtain a MiCA license.
The Act also sets out specific sanctions for non-compliance. Fines can reach up to 6.25% of the company’s annual turnover, and for repeated violations, up to 12.5%. Additionally, the FSC will have the authority to impose temporary or permanent bans on operations in cases of serious breaches.
Companies in the sector must now assess their readiness for the MiCA licensing process. This includes the implementation of compliant policies, procedures, and technological solutions to meet the new regulatory standards. After 1 July 2026, an FSC license will be mandatory for all market participants operating in Bulgaria and will enable them to offer services across the European Union.
The G&P Law team provides comprehensive legal support for MiCA licensing preparation, internal policy development, risk assessment, and representation before the FSC and BNB. If you operate a business in the crypto-assets sector, contact us for a consultation on the new requirements and deadlines.
Images: Canva