Bulgaria BG

Bulgaria's crypto-asset regulatory architecture completed a structural transition this cycle. The Markets in Crypto-Assets Act, in force since 8 July 2025, designated the Financial Supervision Commission as the competent authority for licensing crypto-asset service providers and supervising asset-referenced tokens, while assigning supervision of electronic-money tokens to the Bulgarian National Bank. This designation repealed the National Revenue Agency's Article 9a AML-register as the operative authorisation basis for virtual-asset service providers, a genuine narrowing of what had previously been a lighter-touch registration pathway.

The eighteen-month transitional grandfathering period, under which entities registered on the legacy NRA register before 30 December 2024 could continue operating without a MiCA licence, closed on 1 July 2026. That deadline has now passed, meaning entities that had not obtained, or been refused, FSC authorisation by that date are, in principle, no longer entitled to rely on the transitional basis. This is an architecture-level finding: the closure of a grandfathering window is a structural narrowing of the regulatory perimeter, not an isolated enforcement incident, and it is consistent with the FIM analytical principle that architecture changes carry more diagnostic weight than any single enforcement action.

Evidencing that the new regime is operationally live rather than merely transposed on paper, the FSC issued Bulgaria's first MiCA crypto-asset service provider licence, to Alaric Securities, in April 2026. This finding is treated with caution: it rests on a single lower-tier vendor source with no corroborating primary or law-firm confirmation located this cycle, and confidence is assessed accordingly.

A remaining coverage gap should be stated plainly: no Tier-1 FSC or EUR-Lex primary source was directly retrieved this cycle for the MiCA/CASP designation or the grandfathering-window closure. The findings above rest on law-firm commentary (CMS Law, Wolf Theiss) and vendor-blog sourcing rather than direct regulator or EU-instrument text, and confidence tiers on the underlying claims are capped accordingly.

Outlook

The MiCA full-authorisation deadline for legacy NRA-registered VASPs sits on the regulatory horizon for the third quarter of 2026. General industry practice for legacy registrants had been to rely on the transitional grandfathering window; with that window now closed, entities that had not obtained FSC authorisation face, in principle, a compliance cliff. Watch for confirmation of any enforcement or licence-refusal action against a legacy registrant that failed to secure timely FSC authorisation, which would be the clearest incident-level test of how firmly the closure of the transitional pathway is being enforced in practice.

Bulgaria's AML/CTF architecture received a materially positive assessment this cycle. MONEYVAL's 17 June 2026 enhanced follow-up report formally closed Bulgaria's 5th-round mutual evaluation, rating all 40 FATF Recommendations as compliant or largely compliant. This closure followed demonstrated improvement in technical compliance across eight further Recommendations: confiscation, the terrorist-financing offence, proliferation-financing-related targeted financial sanctions, non-profit organisations, correspondent banking, sanctions, and mutual legal assistance. The evaluation cycle being closed had run since April 2022, so this represents the conclusion of a multi-year monitoring process rather than a single-cycle event, an architecture-level finding consistent with the FIM principle of weighting structural findings over isolated incidents.

The source underlying this finding is a direct primary publication from the Council of Europe / MONEYVAL, and confidence is rated Confirmed, the highest tier available. The overall jurisdictional risk direction on the AML/CTF dimension is assessed as decreasing as a direct consequence of the clean evaluation closure. This should be read as a positive structural signal for Bulgaria's obliged-entity ecosystem: a jurisdiction that has closed out its mutual evaluation with full compliance or largely-compliant ratings across all 40 Recommendations presents a materially lower architecture-level AML/CTF risk profile than one still under active monitoring for outstanding deficiencies.

Bulgaria's national AML implementing instrument, the Measures Against Money Laundering Act, was positively assessed within MONEYVAL's June 2026 follow-up, though no BG-specific development regarding the EU AML Package's supervisory-perimeter shift (AMLA direct or indirect supervision) surfaced independently this cycle beyond what is captured in the mutual-evaluation closure itself.

Outlook

With the 5th-round mutual evaluation now closed, the near-term AML/CTF outlook for Bulgaria is one of consolidation rather than active monitoring pressure. The improvement across eight further FATF Recommendations addressed specific technical-compliance gaps that had been outstanding since the original evaluation; the principal item to watch going forward is whether Bulgaria maintains this compliance trajectory as EU-level AML Package instruments, including AMLA's supervisory perimeter, phase in across the bloc, which would be the next structural test of the architecture just confirmed as sound by MONEYVAL.