Bulgaria’s MiCA transition ended on 1 July 2026 with two licensed firms, and its law does not mention crypto ATMs
Bulgaria’s Crypto-Asset Markets Act, published on 4 July 2025, names the Financial Supervision Commission as the licensing authority. The transition for registered firms ended on 1 July 2026, and the Commission reported two licensed Bulgarian firms. The law and the licence decisions reviewed do not mention crypto ATMs.
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Bulgarian firms licensed by the FSC under MiCA on 30 June 2026
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1 Jul 2026
End of the transition for firms in the national register
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Mentions of crypto ATMs in the law and licence decisions reviewed
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Bulgaria's Crypto-Asset Markets Act, published on 4 July 2025, names the Financial Supervision Commission (FSC) as the licensing authority.1 The transition for registered firms ended on 1 July 2026, and the Commission reported two licensed Bulgarian firms.1,5 The law and the licence decisions reviewed do not mention crypto ATMs.1,2,6
Last updated: October 2026
Regulatory Framework
The Crypto-Asset Markets Act supplements MiCA at national level. It was published in State Gazette No. 54 of 4 July 2025 and amended in No. 67 of 15 August 2025 and No. 25 of 10 March 2026.1,2 A law firm guide gives 8 July 2025 as the date it entered into force.8 The FSC is the competent authority, except where the Bulgarian National Bank has exclusive competence (Article 3), and it supervises the rules on crypto-asset transfers under Regulation (EU) 2023/1113 (Article 20).1,8
Under the transitional rule in § 3(1), persons registered before 30 December 2024 in the National Revenue Agency register could keep operating without a licence until 1 July 2026, or until a licence was granted or refused, whichever came first. Persons registered later but before the law took effect had to apply within three months (§ 3(2)).1 The FSC took over the register from the National Revenue Agency when the law took effect.8
The FSC can order unlicensed services to stop immediately (Article 32). The 2025 amendments added a power to publish websites offering unlicensed crypto services and, after three days, to ask the Sofia District Court to order internet providers to block them (Article 35a).1,2 Fines for breaches of listed MiCA articles run from BGN 1,400 to BGN 700,000 for the general case, and higher for repeat violations (Article 37).1 Whether those fines apply to a given unlicensed activity could not be confirmed from the text reviewed.
Licensing Timeline
| Date | What happened |
|---|---|
| 4 Jul 2025 | Crypto-Asset Markets Act published in State Gazette No. 541 |
| 15 Jan 2026 | FSC update: one licensed provider (Alaric Securities OOD), six applications pending, 214 entities listed in the national register4 |
| 4 Feb 2026 | FSC sets 16 February 2026 as the date for applications. It estimates four to five months for review, and asks firms stopping activity to file a wind-down plan by 1 March 20263 |
| 28 Apr 2026 | FSC decision licensing Belayer OOD for portfolio management, custody, administration and order execution (as reported)7 |
| 30 Jun 2026 | FSC notice: two Bulgarian companies are licensed, and the transition ends the next day5 |
| 1 Jul 2026 | Transition ends. Only licensed providers may offer crypto-asset services5 |
The FSC reported on 15 January 2026 that 64 providers licensed in 14 other EU member states could serve clients in Bulgaria. Its national register listed 214 entities, of which five had been removed at their own request and 19 struck off by the authority.4 A business daily reported that in early February 2026 eight companies had formally applied, one was licensed, three were under review and four were refused at the completeness check (as reported).6
Crypto ATMs
The law text, the FSC notices and the licence decisions reviewed do not mention ATMs.1,2,3,4,5 The FSC pages do not say whether a machine operator needs a licence for exchange services, which would follow from MiCA, or what its position is on machines. The one licensed provider whose services were found, Belayer, was licensed for portfolio management, custody, administration and order execution.7
What Is Not Known
The names of licence holders come from press reports and the FSC register could not be checked on 8 October 2026, so the current count may be higher than two. Whether the fines in Article 37 cover unlicensed activity, how long a new application takes, and how customer due diligence applies at a machine were not confirmed. These are questions for Bulgarian counsel and the FSC.
Sources and references
1. Crypto-Asset Markets Act, State Gazette No. 54 of 4 July 2025, text published by the FSC (PRIMARY, accessed 8 October 2026) | fsc.bg
2. Crypto-Asset Markets Act, text with amendments to State Gazette No. 25 of 2026 (PRIMARY, accessed 8 October 2026) | fsc.bg
3. Financial Supervision Commission, FSC expects applications for licensing of crypto companies by 16 February, 4 February 2026 (PRIMARY, accessed 8 October 2026) | fsc.bg
4. Financial Supervision Commission, crypto-assets update of 15 January 2026 (PRIMARY, accessed 8 October 2026) | fsc.bg
5. Financial Supervision Commission, From 1 July only licensed companies may offer crypto-assets in the EU, 30 June 2026 (PRIMARY, accessed 8 October 2026) | fsc.bg
6. Dnevnik Bulgarian Radio (dbr.bg), Only two Bulgarian companies with a crypto licence the day before the deadline, 30 June 2026 (SECONDARY, accessed 8 October 2026) | dbr.bg
7. Dnevnik Bulgarian Radio (dbr.bg), Belayer received a MiCA crypto-asset licence from the FSC, 29 April 2026 (SECONDARY, accessed 8 October 2026) | dbr.bg
8. CMS, Expert Guide to Crypto Regulation in Bulgaria, last updated 28 July 2025 (SECONDARY, accessed 8 October 2026) | cms.law
Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with the Financial Supervision Commission of Bulgaria before considering market entry.