VASP license in Bulgaria: Reporting Duties

Operating in the cryptocurrency sector in Europe requires a solid regulatory foundation and a compliant business structure. In this context, company registration in Bulgaria represents one of the strategic steps to access the crypto market with relatively low costs and a regulatory framework that is comparatively accessible.

Unlike other European countries, Bulgaria does not provide a traditional licensing regime for many activities related to virtual assets, but rather a system based on registration and strict compliance with anti-money laundering regulations. This approach makes the country particularly attractive for startups and established operators, provided that precise requirements in terms of compliance, governance and transparency are met.

Regulatory framework and competent authorities for VASPs in Bulgaria

The Bulgarian system is mainly based on anti-money laundering legislation, which implements EU directives on combating money laundering and terrorist financing. Crypto activities are therefore regulated through specific laws that impose obligations of registration, monitoring and control.

The main activities subject to registration include:

• conversion between cryptocurrencies and fiat currency
• exchange between digital assets
• custody and wallet services
• transfer of virtual assets
• ICO or IEO operations not classified as financial instruments

From a regulatory perspective, supervision is distributed among several authorities:

• the National Revenue Agency (NRA), responsible for registration and general supervision
• the Financial Intelligence Directorate (FID), overseeing AML compliance under SANS
• the Financial Supervision Commission (FSC), competent for tokens classified as financial instruments

Companies must also comply with AMLD5 standards and prepare for the introduction of the MiCA regulation, which will establish a harmonised licensing framework across the EU.

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VASP license in Bulgaria: operational, financial and documentation requirements

To start a VASP activity in Bulgaria, it is necessary to establish a local company, typically an OOD, which can be created with a very low minimum capital. However, this formal requirement can be misleading: authorities require concrete proof of the financial sustainability of the project.

The company must demonstrate:

• availability of sufficient funds for at least 12 months of operation
• transparency of financial flows and bank accounts
• accounting systems capable of tracking all transactions

From a tax perspective, the environment remains competitive: corporate profits are taxed at 10%, and in many cases, crypto services are not subject to VAT.

Documentation plays a central role. The required dossier includes:

• full corporate documentation
• identification of directors and ultimate beneficial owners
• AML/CFT policies and advanced KYC procedures
• a detailed business plan
• IT systems and security protocols
• internal controls and organisational structure

Particular attention is given to the MLRO (Money Laundering Reporting Officer), who must demonstrate specific expertise and operational independence.

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Compliance, controls and future developments with MiCA

Regulatory compliance represents the core pillar for operating as a VASP in Bulgaria. Companies must implement a continuous risk-based control system that includes:

• customer identity verification
• transaction monitoring
• sanctions and PEP screening
• analysis of the source of funds

Additionally, companies are required to report suspicious activities promptly to the competent authorities and maintain detailed records of operations.

Authorities may conduct audits, request additional documentation or impose sanctions in case of irregularities. In more serious cases, suspension or removal from the VASP register may occur.

Looking ahead, the introduction of the MiCA regulation represents a crucial milestone. This new framework will bring:

• a single license valid across the European Union
• stricter requirements on governance and capital
• greater user protection and operational transparency

Companies currently operating in Bulgaria must adopt a proactive approach, updating their procedures and gradually aligning with evolving European standards.

Bulgaria remains an attractive jurisdiction for crypto businesses thanks to low operating costs, competitive taxation and direct access to the EU market. However, this advantage is closely linked to the ability to comply with an evolving regulatory system, where compliance is not just an obligation, but a strategic factor for growth.

To properly structure a VASP activity and manage every phase of the process—from company formation to regulatory compliance—it is essential to rely on experienced professionals such as Accountancy Bulgaria, accountancy company in Bulgaria.