Implemetating MiCA in Bulgaria: the Crypto- Asset Martkets Act effective from 8 July 2025

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At the very end of 2024 the Bulgarian Council of Ministers approved a draft Crypto-Asset Markets Act (CAMA) and introduced it to the Parliament. CAMA was finally voted on 20 June 2025, published in State Gazette # 54 on 4 July 2025 and entered into force on 8 July 2025.

CAMA implements in the national legislation the EU Regulation on Markets in Crypto- Assets (MiCA), as well as the regulations on information accompanying transfers of funds and transfers of certain crypto-assets and on the operational resilience of digital technologies in the financial sector.  Until now, the only requirements, related to the functioning of crypto-asset markets, which are not financial instruments, are those introduced for the purposes of the measures against money laundering and terrorist financing. For this reason and given the significant volume of regulation already introduced at EU level, such new law is of critical significance for the financial markets.

Implemetating MiCA in Bulgaria

CAMA Highlights

The Financial Supervision Commission (FSC) is the national competent authority for the purposes of regulating and supervising the activities of crypto-asset service providers, issuers of asset-backed tokens and issuers of crypto-assets other than asset-backed tokens or electronic money tokens. This will ensure a unified supervision of all activities related to the trading of crypto-assets, which aims to support the effective and lawful functioning of the crypto-asset market and its future development. Using the existing expertise and supervisory practices of FSC, no additional costs are expected to arise, which would result from the creation of a separate new specialized state body. The Bulgarian National Bank (BNB) is designated as the competent authority with respect to the activities of issuers of electronic money tokens. The permissible coercive administrative measures are defined, as well as the procedure for imposing administrative penalties, including the guarantee of the right to judicial appeal.

Licensing Regime

The FSC will issue licenses to persons wishing to conduct a public offering of asset-backed tokens or seeking admission to trading; persons undertaking a public offering of asset-backed tokens or seeking admission to trading; persons operating as crypto-asset service providers. Within 7 days of receiving a license to operate as a crypto-asset service provider, such provider must apply to the Commercial Register for entry of this activity in its scope of business. 

The law also introduces special requirements for members of the management body of crypto-asset service providers and persons managing their activities, shareholders or persons having a direct or indirect qualifying holding in the crypto-asset service provider. These requirements also apply to individuals who are identified as beneficial owners of a crypto-asset service provider, as well as to individuals who are designated as representatives of a legal entity – a member of the management body of the crypto-asset service provider. 

Crypto-asset service providers licensed under CAMA, except for their activities of providing advice on crypto-assets, are also obliged entities under Art. 4, item 19 of the AML Law. Issuers of electronic money tokens will be licensed either as a credit institution or as an electronic money institution. The license will be issued by the Bulgarian National Bank. 

The following fees will be collected for issuing licenses to carry out activities under CAMA: for a license for a crypto-asset service provider: class 1 – BGN 5 000 (approx. EUR 2 500), class 2 – BGN 10 000 (approx. EUR 5 000), class 3 – BGN 30 000 (approx. EUR 15 000), and for issuing a license for a public offering and/or for admission to trading of tokens secured by assets – BGN 25 000 (approx. EUR 12 500).

Transitional Period and Pending Cases 

Crypto- asset service providers registered before 30 December 2024 in the current register under Art. 9a, para. 1 of the Anti-Money Laundering Measures Act at the National Revenue Agency may continue to provide the services registered in the register without a license only on the territory of Bulgaria until 1 July 2026 or until the issuance or refusal to issue a license, depending on which of the two circumstances occurs earlier. 

Those registered in the register between 30 December 2024 and 8 July 2025 (the date of entry into force of CAMA) must apply for a license within three months of the entry into force of the law, i.e. by 8 October 2025. Pending proceedings before the NRA for registration in the register that have not been completed by 8 July 2025 are terminated. This means that companies which proceedings have been terminated must submit a new application for a license to the FSC under the provisions of CAMA.

Conclusion

CAMA will have a positive effect on financial innovation and the financial sector, encouraging the spread of new crypto products and technologies in Bulgaria. The interests of crypto-asset holders and clients of crypto-asset service providers will be most effectively and reliably protected. The exercise of powers by FSC and BNB reduces the risk of consumers being provided with misleading or false information. Given the supervisory experience of both institutions, it will be possible to promptly identify violations and fraud and take the fastest and most effective actions possible to eliminate them. The presence of a clear legal basis for crypto-assets in the EU and Bulgaria would allow companies and issuers of crypto-assets to innovate and compete on equal terms in the single market, as well as to use the advantages of new forms of payment, without reducing the level of consumer protection and financial stability. 

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