MiCA and CASP Licensing in Bulgaria in 2026: VC Law in Chambers Global Practice Guides

Vassilev and Chisuse Law Firm (VC Law) has authored the Bulgaria jurisdiction chapter of the Chambers Global Practice Guides – Blockchain & Crypto-Assets 2026, providing a practical overview of crypto regulation, blockchain, digital assets and CASP licensing in Bulgaria. 

The publication examines the application of the EU Markets in Crypto-Assets Regulation (MiCA), Bulgaria's Markets in Crypto-Assets Act, the authorisation regime for Crypto-Asset Service Providers (CASPs) and the regulatory issues relevant to crypto exchanges, fintech companies, token issuers, investors and other participants in the digital-assets market. 

MiCA establishes a harmonised EU regulatory framework for certain categories of crypto-assets, their issuers and crypto-asset service providers. 

In Bulgaria, the European framework is complemented by the national Markets in Crypto-Assets Act. The Bulgarian Financial Supervision Commission (FSC) is the principal competent authority for the authorisation and supervision of crypto-asset service providers, while the Bulgarian National Bank has competence in certain areas, including e-money tokens and entities falling under its supervision. 

For crypto businesses, regulatory analysis therefore needs to form part of product and business-model design from the outset rather than being treated as a legal review shortly before launch. 

CASP stands for Crypto-Asset Service Provider. 

Under MiCA, providing regulated crypto-asset services professionally generally requires the appropriate authorisation unless a specific regulatory exemption applies. 

Regulated services include custody and administration of crypto-assets on behalf of clients, operation of a crypto-asset trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of orders, placing of crypto-assets, reception and transmission of orders, providing advice, portfolio management and crypto-asset transfer services. 

Whether a business requires a MiCA or CASP licence in Bulgaria therefore depends on the actual services and functionality offered to customers rather than the commercial label used to describe the product. 

Obtaining a CASP licence involves substantially more than filing a standard corporate application. 

An applicant must demonstrate a coherent operating model showing how the business will comply with its regulatory obligations in practice. 

Key areas include corporate governance, the suitability and experience of management, own funds and financial resources, AML/CFT and KYC arrangements, risk management, conflicts of interest, client protection, complaints handling, outsourcing, ICT systems and operational resilience under the Digital Operational Resilience Act (DORA). 

Where the business model involves custody or control over client crypto-assets, particular attention is required in relation to custody arrangements, private-key management, segregation and safeguarding of client assets and incident-response procedures. 

Regulatory architecture has therefore become part of the architecture of the crypto product itself. 

One of the first legal questions is determining exactly which regulated services the platform will perform. 

MiCA does not authorise an abstract commercial concept called a “crypto exchange”. The legal analysis is based on the functionality of the platform. 

For example, a product that initially provides only exchange of crypto-assets for funds may later introduce custody, crypto-to-crypto exchange, execution of orders, transfers or trading-platform functionality. Each additional feature may affect the regulatory characterisation of the business. 

A CASP licensing strategy should therefore consider not only the product on the date of application but also the company's realistic product and business roadmap. 

Businesses providing services within the scope of MiCA must therefore operate under the appropriate authorisation or another applicable regulatory basis expressly permitted under the legislation. 

The change marks Bulgaria's definitive transition from its previous registration-based approach to a framework based on authorisation, ongoing supervision and harmonised EU regulatory requirements. 

One of MiCA's central features is the ability of an authorised CASP to provide its authorised services across EU Member States through the Regulation's cross-border notification framework. 

Bulgaria may therefore serve as the home Member State for a CASP that intends, after obtaining the appropriate authorisation and completing the relevant notification procedures, to provide services in other EU markets. 

A licensing project should consequently consider not only Bulgarian operations but also the intended geographic reach of the business, target client groups, marketing strategy, outsourcing structure and cross-border infrastructure. 

MiCA does not operate in isolation. 

A CASP operating model must also be assessed against other applicable EU and Bulgarian legal regimes, including anti-money laundering and counter-terrorist financing requirements, rules governing transfers of funds and crypto-assets, data protection requirements and the Digital Operational Resilience Act (DORA). 

Legal, compliance and technology workstreams should therefore be developed as an integrated part of the licensing project. 

The Bulgaria chapter also considers the wider development of the digital-assets market. 

Topics addressed include tokenisation of real-world and financial assets, stablecoins, DeFi, issuance and public offerings of crypto-assets, crypto-asset white papers, market abuse, taxation, intellectual property and data protection. 

Together, these developments illustrate how European crypto regulation is evolving from isolated rules applicable to particular providers into a broader legal infrastructure for digital assets and tokenised finance. 

The contribution of Vassilev and Chisuse Law Firm (VC Law) to Chambers Global Practice Guides reflects the firm's work in MiCA, CASP licensing, crypto regulation, fintech and digital assets. 

Who Issues a CASP Licence in Bulgaria? 

The Bulgarian Financial Supervision Commission is the principal competent authority for the authorisation and supervision of crypto-asset service providers. The Bulgarian National Bank has competence in certain cases provided for under MiCA and Bulgarian law. 

Does a Crypto Exchange Need a CASP Licence in Bulgaria? 

Most conventional crypto-exchange models involve one or more services regulated under MiCA. The exact authorisation scope must, however, be determined by reference to the platform's actual functionality and operating model. 

Can a Former Bulgarian VASP Continue Operating After 1 July 2026 based on Its Previous Registration? 

The Bulgarian transitional regime ended on 1 July 2026. Registration under the previous framework does not, by itself, replace the authorisation required under MiCA. 

Can a Bulgarian-Licensed CASP Provide Services in Other EU Countries? 

MiCA provides a mechanism enabling authorised CASPs to provide their authorised services across EU Member States after completing the applicable notification procedures. The scope depends on the services included in the CASP's authorisation. 

What Are the Main Areas of a CASP Licence Application? 

A licensing project typically requires analysis of the business model and regulated services, corporate governance, prudential requirements, AML/KYC, ICT and DORA, outsourcing, custody and safeguarding, conflicts of interest, client protection and other applicable organisational requirements. 

How Can VC Law Assist a CASP or Crypto Business? 

VC Law advises businesses on MiCA and digital-asset regulation, including business-model structuring, CASP authorisation, regulatory readiness, AML/CFT frameworks, crypto-asset white papers, token classification, outsourcing, DORA and cross-border provision of services. 

Source: Chambers and Partners – Global Practice Guides, Blockchain & Crypto-Assets 2026, Bulgaria. 

This article is provided for general information only and does not constitute legal advice. Applicable regulatory requirements should be assessed by reference to the specific business model, services and circumstances.