Bulgarian CASP licensing under MiCA. The transition period ended on 1 July 2026, and only a handful of firms hold a KFN licence. We prepare application files, own-funds evidence and passporting notifications.
For firms applying for the first time, firms that lost their transitional position, and non-EU businesses assessing EU entry.
Preparing and filing the authorisation file with KFN: governance, fit-and-proper documentation, own-funds evidence, internal rules, AML/CTF framework, custody and segregation policies, complaints handling, ICT and business continuity.
Assessing what activity can lawfully continue, structuring the wind-down of client relationships, and choosing between a fresh Bulgarian application and licensing in another Member State followed by notification into Bulgaria.
Notifying other Member States on a Bulgarian licence, and notifying KFN on a licence held elsewhere in the EU.
Asset-referenced tokens and e-money tokens sit with the Bulgarian National Bank rather than KFN, so a firm issuing a stablecoin alongside providing services is running two procedures before two regulators.
Transfer-of-funds obligations for crypto-asset service providers, and the AML framework KFN examines as part of the application.
Prudential monitoring, disclosure, market-abuse compliance and reporting once authorised.
The transition period ended on 1 July 2026. Firms that were registered under the old regime and did not obtain a licence cannot lawfully offer crypto-asset services, and may only carry out transactions connected with winding down client relationships.
The bar turned out to be considerably higher than most expected. More than 180 providers sat in the transitional register in August 2025. By the end of the transition, KFN had licensed two. Two further licences followed on 21 July 2026, bringing the register to four. Of the applications KFN had decided by February 2026, half were refused.
Over a hundred foreign firms now serve the Bulgarian market instead, passported in from licences held elsewhere in the EU.
We advise firms applying for a Bulgarian CASP licence, firms that missed the transition and need a route back to market, and non-EU businesses deciding whether Bulgaria is the right entry point into the EU at all. The full regulatory position is set out in our guide to MiCA in Bulgaria after 1 July 2026.
The capital requirement is the part firms prepare for and it is rarely the problem. Minimum own funds run from EUR 50,000 to EUR 150,000 depending on the class of services, and the applicable figure is the higher of the fixed minimum and one quarter of the previous year's fixed overheads.
Refusals cluster elsewhere: governance and the fitness of the management body, the quality of the AML/CTF framework, custody and client-asset segregation, and internal rules that describe an intended business rather than an operating one.
An application is a description of a firm that can already run. Assembling one is not a documentation exercise.
Authorisation by KFN allows a firm to provide crypto-asset services across the EU and EEA by notification to the host Member States, without separate authorisation in each.
That is what the old national registration never provided - it operated only within Bulgaria. Firms that relied on it never held EU access, which is part of why so many are now looking at a full application for the first time.
KFN, the Financial Supervision Commission. Licenses and supervises crypto-asset service providers.
BNB, the Bulgarian National Bank. Competent for asset-referenced tokens and e-money tokens.
No. The transition period ended on 1 July 2026. A provider without a licence cannot offer new services and may only carry out transactions connected with terminating client relationships. Licensed providers are also barred from delegating custody of client assets to unlicensed firms.
Four, on the KFN register as at August 2026 - two at the close of the transition period and two more licensed on 21 July 2026 - against more than 180 registered under the transitional regime. Over a hundred foreign firms operate here on passported licences from other Member States. Check the KFN register for the current figure.
EUR 50,000, EUR 125,000 or EUR 150,000 depending on the class of services, and the applicable figure is the higher of that minimum and one quarter of the prior year's fixed overheads.
A fresh application to KFN, or licensing in another Member State and notifying KFN to serve the Bulgarian market. Which is faster depends on your services, structure and how ready the documentation is. Activity cannot resume in the meantime.
Yes, by notification to host Member States, without separate authorisation in each.
The Bulgarian National Bank, for both asset-referenced tokens and e-money tokens. KFN handles service providers.
Bulgarian CASP licensing, after the transition
Applications, passporting and token issuance. We work with firms applying for the first time, firms that lost their transitional position, and non-EU businesses assessing EU entry.