Vassilev & Chisuse Law Firm authored the Bulgaria chapter in The Legal 500 Country Comparative Guides: Blockchain & Crypto Assets. The publication examines MiCA, crypto-asset services, DeFi, tokenisation and practical legal issues for blockchain businesses.
By Atty. George Chisuse, Managing Partner · 2026-10-30 · Legal review: 30 October 2026
Vassilev & Chisuse Law Firm (VC Law) has authored the Bulgaria chapter of The Legal 500 Country Comparative Guides: Blockchain & Crypto Assets. The chapter examines the legal framework governing blockchain technology and crypto-assets in Bulgaria, with a practical focus on the questions faced by technology businesses, financial institutions, investors and digital-asset service providers.
The full Bulgaria chapter is available in English on The Legal 500 website: Bulgaria, Blockchain & Crypto Assets.
The Legal 500 Country Comparative Guides bring together jurisdiction-specific legal analysis in an accessible question-and-answer format. The series helps in-house legal teams, founders and cross-border advisers understand how the same business activity may be treated under different national legal systems.
The Bulgaria chapter addresses 16 questions spanning regulated crypto-asset services and the broader legal issues arising from distributed ledger technology. A recurring theme is that the legal treatment of a blockchain project depends on the rights associated with the asset and the functions actually performed, rather than the technology or terminology used to describe it.
The analysis examines Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), Bulgaria's Markets in Crypto-Assets Act and the roles of the relevant supervisory authorities. It explains how authorisation requirements for crypto-asset service providers interact with other regimes, including the rules applicable when a token constitutes a financial instrument.
Other issues include decentralised finance (DeFi), decentralised autonomous organisations (DAOs), tokenisation, smart contracts, custody, ownership and security interests over crypto-assets. The chapter also discusses anti-money laundering obligations, sanctions, taxation, data protection, consumer rights and the treatment of blockchain-related disputes.
For businesses operating across borders, the chapter considers access to the Bulgarian and wider EU markets, cross-border provision of authorised services, and the restrictions affecting non-EU providers, including the narrow circumstances in which reverse solicitation may be relevant.
A blockchain application is not regulated simply because it relies on distributed ledger technology. The decisive questions concern the nature of the token, the rights it confers, the service provided to customers and who exercises control over the activity. These issues should be assessed when the operating model is being designed, rather than only after a product has been built.
Following the end of Bulgaria's transitional regime on 1 July 2026, providers carrying on services within MiCA's scope generally need the relevant authorisation or another valid legal basis for performing those services. Businesses planning EU-wide operations must also account for the applicable cross-border notification procedures.
For more detail, read our guide to MiCA authorisation and CASP licensing in Bulgaria.
Our contribution to The Legal 500 Country Comparative Guides provides an opportunity to explain Bulgaria's legal framework to an international audience. It reflects VC Law's work on crypto-asset regulation, CASP authorisation, corporate structuring, tokenisation and compliance matters.
We advise on the legal classification of tokens and services, preparation for MiCA authorisation, anti-money laundering requirements and digital operational resilience where relevant to the business model. Further information is available on our MiCA licensing and regulated crypto-asset services page.
VC Law has also contributed to a separate international publication, discussed in our article on Bulgaria in Chambers Global Practice Guides: Blockchain & Crypto-Assets. These are distinct contributions with complementary perspectives on the legal and regulatory environment.
The Bulgaria chapter was authored by Vassilev & Chisuse Law Firm (VC Law) for The Legal 500 Country Comparative Guides.
It addresses blockchain and crypto-asset regulation, MiCA, crypto-asset services, DeFi, tokenisation, smart contracts, taxation, anti-money laundering controls and cross-border operations.
The English-language chapter is publicly available at The Legal 500: Bulgaria, Blockchain & Crypto Assets.
If your business is considering crypto-asset activities in Bulgaria or elsewhere in the European Union, contact VC Law for a legal assessment of the operating model, relevant regulatory obligations and potential next steps.
This article provides general information and does not constitute individual legal, tax or investment advice. The applicable legal requirements depend on the facts, structure and activities of each project.