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MiCA CASP authorisation in Bulgaria

Bulgaria authorises crypto-asset service providers under MiCA through the Financial Supervision Commission. Since the EU transitional periods ended on 1 July 2026, only a full MiCA authorisation allows a firm to serve clients. The FSC has published FAQs that cover business plans, governance, staffing and how it assesses actual operational presence in Bulgaria.

OpenTransitional period ended on 1 July 2026; only full authorisation counts

Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them

Regulator · Financial Supervision Commission (FSC) ↗

Key facts

Minimum own funds (permanent capital)
€50,000, €125,000 or €150,000 depending on the class of crypto-asset servicesMiCA-Art-67as of 2026-10-08Source ↗
End of transitional period (EU)
1 July 2026: only authorised CASPs may provide servicesMiCA-Art-143(3)as of 2026-10-08Source ↗
Passporting
Authorisation allows services across the EU/EEA after notificationMiCA-Art-65as of 2026-10-08Source ↗
FSC guidance for applicants
FAQ published January 2026 covering business plan, governance, staffing and assessment of actual operational presence in Bulgariaas of 2026-10-08Source ↗

Realistic timeline

Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.

  1. HartsizScoping and gap analysis2–4 weeks
  2. YouCompany set-up, hires and application pack6–12 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
  3. RegulatorFSC completeness check and assessment16–36 weeksOutside our control; depends on queue and the quality of answers

Estimated end to end: 6–12 months. Not a guarantee.

What the regulator expects to see

  • Management body with sufficient good repute, knowledge and time commitment (MiCA Art. 68)
  • Registered office in Bulgaria, place of effective management in the EU and at least one EU-resident director (MiCA Art. 59(2))
  • AML/CFT compliance function under Bulgarian AML law
  • ICT risk-management framework under DORA

Questions we get

Can we keep operating while our application in Bulgaria is pending?

No. Since 1 July 2026 the MiCA transitional periods have ended across the EU, so only an actual authorisation allows a firm to provide crypto-asset services.

Does the FSC check whether we really operate in Bulgaria?

Yes. The FSC's January 2026 FAQ specifically covers how it assesses actual operational presence in Bulgaria, alongside governance and staffing.

Changes affecting this route

  1. European Union · Crypto · high impact

    MiCA transitional periods end across the EU

    ESMA confirmed that the last MiCA grandfathering periods expire on 1 July 2026. From that date, any entity providing crypto-asset services to EU clients without MiCA authorisation is in breach of EU law and must have implemented its wind-down plan. Firms without a licence now need a new application or the acquisition of an authorised CASP.

    Source ↗

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