MiCA authorisation, CASP licensing, token structuring and crypto tax - for exchanges, funds, Web3 startups and investors in Bulgaria and across the EU. One firm, the whole file, in-house.
From first-day structuring to full CASP authorisation and ongoing compliance - the complete legal stack for a regulated crypto venture.
Full Crypto-Asset Service Provider licensing before the FSC and BNB - scope assessment, application file, capital and governance.
White papers, ART / EMT analysis, and legal review of ICO, IEO, airdrop and utility-token offerings under MiCA.
Article 33 treatment, corporate and holding structures, off-ramp planning and the source-of-funds story your bank will ask for.
Anti-money-laundering programmes, the crypto travel rule, and operational-resilience documentation to supervisory standard.
Smart-contract and platform terms, fraud and hack recovery, and counterparty or cross-jurisdiction dispute strategy.
EU passporting, cross-border transaction structuring, and legal support for crypto funds, investors and Web3 treasuries.
Holding cryptoassets raises custody, AML, succession and evidentiary issues, while selling, exchanging, earning or using them may trigger tax and reporting consequences. The EU's Markets in Crypto-Assets Regulation (MiCA) and Bulgaria's national implementing legislation have created a clearer framework, but significant uncertainty remains in cross-border operations, on unregulated platforms, and in decentralised finance protocols.
In Bulgaria, income of individuals from the sale or exchange of virtual currencies is generally calculated under Article 33 of the Personal Income Tax Act - annual realised gains offset against annual realised losses, then a 10% statutory expense allowance, with the remainder taxed at 10%. Organised, continuous activity may be reclassified as business activity. Incorrect or missing declarations can result in administrative penalties, additional tax obligations and interest. For companies, crypto operations also create accounting challenges around asset valuation.
The decentralised nature of crypto often limits legal recourse. In cases of fraud, hacks, or counterparty default - especially on decentralised platforms or via smart contracts - identifying the responsible party or jurisdiction can be extremely difficult.
MiCA is directly applicable in Bulgaria and is supplemented by the Bulgarian Markets in Crypto-Assets Act, which governs national authorisation, supervision and sanctions. The Financial Supervision Commission (FSC) is the principal competent authority; the Bulgarian National Bank (BNB) has competence for e-money tokens and certain BNB-supervised entities.
Transition deadline: the national grandfathering period for previously registered Bulgarian providers expires on 1 July 2026, or earlier upon a decision on the provider's authorisation application - whichever occurs first. After that point, cryptoasset services generally require MiCA authorisation, subject to the specific exceptions for already-regulated entities.
We advise on:
In most cases, yes. Since MiCA became applicable to service providers on 30 December 2024, providing crypto-asset services on a professional basis generally requires authorisation as a Crypto-Asset Service Provider (CASP) - a real financial licence that replaced the old, lighter registration. Whether a specific activity is caught is a fact-specific legal question.
The Financial Supervision Commission (FSC) is the designated competent authority for authorising and supervising crypto-asset service providers and most issuers under MiCA. The Bulgarian National Bank (BNB) has competence for e-money tokens and asset-referenced tokens.
MiCA sets the minimum by service class: EUR 50,000 for reception/transmission, advice, execution, placing and transfer; EUR 125,000 for custody or exchange; and EUR 150,000 for operating a trading platform - being the higher of the fixed minimum or a quarter of the prior year's fixed overheads.
Yes. Once authorised in Bulgaria, a CASP can passport its services across the entire EU/EEA by notifying host-state authorities through the FSC - no separate licence in each country.
For individuals outside a business capacity, gains on virtual currencies are generally calculated under Article 33 of the Personal Income Tax Act: annual realised gains less annual realised losses, then a 10% statutory expense allowance, with the remainder taxed at 10%. Organised, continuous activity may be treated as business activity instead.
The grandfathering period for previously registered Bulgarian providers runs until 1 July 2026, or earlier upon a decision on the authorisation application - whichever comes first. The realistic planning horizon is now, since an application takes months to prepare.
Planning a crypto venture in Bulgaria?
From CASP authorisation to AML, DORA, tax and token structuring - we handle the whole file in-house.