MiCA Licence Lawyers: CASP Authorisation in Bulgaria and the EU

Legal assistance with MiCA licensing and CASP authorisation in Bulgaria and the EU: FSC applications, governance, AML, DORA and regulatory compliance.

MiCA licensing support starts with classifying the crypto-assets and services in the business model, then preparing the CASP application, governance arrangements and compliance documents. In Bulgaria, the FSC is the CASP licensing authority. ART and EMT issuer rules are assessed separately; the transitional period ended on 1 July 2026 and is not an ongoing route to market.

Key points

  • Classification of the activity or token determines the applicable regime.
  • CASP authorisation and issuer rules are separate legal questions.
  • Governance, own-funds and disclosure duties depend on the activity.
  • The competent authority controls the decision and timing.

Jurisdiction and applicable framework

MiCA applies directly across the EU to in-scope crypto-assets, issuers and service providers. Applicable technical standards and national rules governing the competent authority and procedure must also be checked.

Official sources

Last reviewed: 22 September 2026

MiCA creates an EU authorisation regime for crypto-asset service providers and rules for in-scope token issuers. Businesses providing regulated exchange, custody, execution or portfolio-management services require authorisation unless a specific legal exclusion applies. We guide CASPs and issuers through classification, applications, white-paper obligations and ongoing supervisory requirements.

We prepare CASP authorisation dossiers covering the programme of operations, governance arrangements, own-funds calculations, outsourcing policies, complaints handling, and conflicts-of-interest management required by MiCA Title V.

For token issuers, we draft or review crypto-asset white papers that meet MiCA's content, format, and liability rules - including the specific regimes for asset-referenced tokens (Title III) and e-money tokens (Title IV) - and coordinate notification with the relevant NCA.

What this includes

  • CASP authorisation application
  • Crypto-asset white-paper drafting
  • Own-funds & prudential calculations
  • Governance & outsourcing policies
  • AML/CTF & Travel Rule integration
  • Ongoing supervisory reporting

MiCA licensing: practical questions

Which activities require a MiCA / CASP licence?

Professional services such as crypto-asset custody, operating a trading platform, exchange, order execution, advice, portfolio management and transfers can fall within MiCA. The business model, token classification and applicable exclusions determine the scope. Article 60 provides a separate notification route for certain already regulated entities, within its limits. CASP authorisation is distinct from the rules for issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs).

How do lawyers prepare a CASP application?

MiCA licence lawyers and CASP authorisation lawyers assess the proposed services and prepare the programme of operations, applicant governance, management suitability evidence, applicable AML/CTF controls, DORA arrangements, outsourcing contracts and internal policies. Documents submitted to the regulator must reflect the actual business and applicable requirements; legal assistance does not guarantee authorisation.

Who licenses CASPs in Bulgaria, and how does EU passporting work?

The FSC handles Bulgarian CASP authorisation under MiCA and the national framework, including Ordinance No. 77. The Bulgarian National Bank has separate competence for EMT issuers and Article 60 notifications from entities under its supervision. An authorised CASP may provide covered services in other EU Member States through the Article 65 notification procedure; passporting is not a separate licence or permission for activities outside its authorisation.

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