MiCA CASP authorisation in Bulgaria (FSC)

Why teams look at Bulgaria

Bulgaria offers a lower-cost EU base with a single passportable authorisation. Under MiCA’s crypto-asset service provider regime, applying from 30 December 2024, the Financial Supervision Commission (FSC) is the authorising authority, with the Bulgarian National Bank involved on prudential matters. Bulgaria suits cost-sensitive teams that still want full EU market access.

This page is informational and does not replace legal, regulatory, or tax advice. Confirm current requirements, forms, fees, and timelines directly with the FSC before acting.

The authorisation route

A firm that is not already an EU-authorised financial entity applies to the FSC for authorisation as a CASP under Article 62. A firm already authorised under EU financial law can use the lighter Article 60 notification.

Under Article 63 the FSC has 25 working days to confirm completeness and then 40 working days to decide once the file is complete.

What the FSC expects

Local substance

A registered office in Bulgaria and management effectively based there under Article 59(2).

Governance and fit-and-proper

Collective crypto-asset competence and sufficient time under Article 68, with assessment of directors and qualifying shareholders.

Custody and client assets

Segregation, reconciliation, a custody policy, and strict liability for loss under Article 75 where you hold client crypto-assets or the means of access.

Prudential safeguards

Own funds, an insurance policy, a comparable guarantee, or a mix under Article 67, at the higher of the class minimum or one quarter of fixed overheads.

Capital and the Article 67 question

The minimum is 50,000 euro, 125,000 euro, or 150,000 euro depending on the services you are authorised for, or one quarter of the previous year’s fixed overheads if higher. If you are weighing insurance against capital, build the evidence first: see the CASP insurance evidence pack and own funds vs insurance.

Transitional path

Firms operating under Bulgaria’s pre-MiCA regime transition onto MiCA through a process the FSC manages within a national transitional window. Confirm the current cut-off date and the exact transition steps with the FSC.

Transitional dates have moved at the member-state level. Confirm any date against current FSC guidance before planning around it.

FAQ

Is a Bulgaria CASP licence valid across the EU?

Yes. A CASP authorisation passports to all 27 member states under Article 65. You authorise in Bulgaria and notify the host states before providing services there.

How long does it really take?

The legal decision clock is 40 working days after the file is complete, plus a 25 working day completeness check. Preparing a complete file usually takes several months.