After the implementation of MiCA, the Bulgarian crypto market was expected to thrive. It, however, lacked a local law to help with the smooth transition. This was changed in July 2025, with the Bulgarian Markets in Crypto-Assets Act (MCAA), but questions remained unanswered.
“Who can rely on the grandfathering period and how exactly?”
“What are the full local requirements for companies?”
Although much work was done, there are still issues that lead foreign businesses to withhold investments in Bulgaria.
Investors meet difficulties with several topics:
- Procuring a bank account at a Bulgarian bank for their business, which is an archaic regulation;
- Getting documentation and procedures in compliance with MiCA;
- Complying with the numerous requirements of the local regulator in Bulgaria, the Financial Supervision Commission (FSC).
G&P Law, with its extensive corporate and compliance expertise (including providing to Latvian clients), can supply a one-stop-shop resolution to the above issues by:
- Setting up the correct business structure of an enterprise, pushing banking KYC questions to a positive result;
- Support the necessary documentation to be MiCA compliant;
- Be in constant contact with the regulator, so that the process for the client goes smoothly.
A simple case study can show how the process goes with all its expected and unforeseen issues:
A local company must be established at the Commercial Register with a capital as per MiCA’s requirements for the respective class of services. In most operative cases, this is Class 2, with a capital requirement of at least EUR 125,000. This means that all shareholders and managers at the company must comply with KYC banking standards in Bulgaria, which are numerous and can take weeks to clear.
When said and done, your company must create the respective MiCA application set, which includes internal policies, KYC procedures, “whitebook” of assets, and all the rest as per the EU Regulation. All must be provided in the correct form to be received by the FSC.
The FSC itself has several local requirements, both in accordance with MiCA and established good practices. These include local acknowledgment of foreign diplomas, local residency of managing personnel, even more strict KYC than banks, etc., which can be a separate legal case on their own.
Do not hesitate to contact us for the best approach for your business.
Images: Canva
