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Bulgaria: fintech & payments regulation

Regulated

Bulgaria fintech & payments: dual supervision by BNB and FSC under EU-mandated frameworks

Lead regulator:
Bulgarian National Bank
Key law:
Law on Payment Services and Payment Systems (transposing PSD2)
Last updated:
2026-07-12

Bulgaria maintains a fully regulated fintech and payments environment governed primarily by the Law on Payment Services and Payment Systems, which transposes EU Payment Services Directive 2 (PSD2). The Bulgarian National Bank (BNB) serves as the primary supervisor for payment institutions, e-money institutions, and payment system operators, enforcing strict licensing and capital requirements through detailed ordinances such as Ordinance No. 16.

The Financial Supervision Commission (FSC) regulates securities markets, investment firms, and insurance intermediaries, while also acting as the competent authority for crypto-asset service providers (CASPs) under the new Law on Crypto-Asset Markets, which implements the EU’s MiCA regulation. Recent regulatory activity in 2025 and 2026 highlights a focus on operational resilience, including specific protocols for euro cash frontloading and detailed licensing procedures for crypto-asset service providers.

Notable restrictions include rigorous anti-money laundering (AML) and counter-terrorist financing (CTF) obligations, such as mandatory declarations for cross-border transfers exceeding BGN 30,000 and strict due diligence for payment accounts. The regulatory landscape is characterized by high compliance costs and detailed administrative requirements, reflecting Bulgaria’s alignment with EU financial standards ahead of its adoption of the euro.

Who regulates

  • Bulgarian National Bank

    Primary supervisor for payment institutions, e-money institutions, payment systems, and credit institutions.

    [1][2]

  • Financial Supervision Commission

    Supervisor for securities markets, investment firms, insurance intermediaries, and crypto-asset service providers.

    [3][4][5]

Core laws & rules

  • Law on Payment Services and Payment Systems (2018)

    Transposes PSD2, establishing the legal framework for payment institutions, e-money institutions, and payment systems under BNB supervision.

    [2]

  • Law on Crypto-Asset Markets (2026)

    Implements EU Regulation 2023/1114 (MiCA), regulating public offerings and trading of crypto-assets and licensing crypto-asset service providers under the FSC.

    [4]

  • Law on Markets in Financial Instruments (2026)

    Regulates financial markets and investment intermediaries, implementing MiFID II, MAR, and SFDR under FSC supervision.

    [3]

Licensing & registration

  • Payment Institutions / E-Money Institutions

    Requires comprehensive documentation, fit-and-proper assessments for management, and adherence to capital requirements set by the BNB. Capital: As per EU directives and BNB ordinances (specific floor not stated in provided text, but Ordinance No. 16 mandates detailed application submissions). Timeline: Ongoing; Ordinance No. 16 (2018) remains the procedural basis.

    [2]

  • Crypto-Asset Service Providers (CASPs)

    Licensing established under Regulation No. 77 (2026), requiring specific application forms, documentation on key personnel, and organizational requirements. Capital: Not specified in provided text. Timeline: Regulation No. 77 issued 12.03.2026.

    [5]

  • Investment Intermediaries

    Requires licensing under the Law on Markets in Financial Instruments, with strict capital and organizational requirements. Capital: Not specified in provided text. Timeline: Governed by 2026 Law on Markets in Financial Instruments.

    [3]

Restrictions & warnings

  • Cross-border transfers of BGN 30,000 or more to third countries require specific supporting documents and declarations from payment service providers.

    [6][7]

  • Payment institutions must adhere to strict due diligence, account identification via IBAN, and detailed record-keeping for payment transactions.

    [1]

  • Credit institutions must report weekly inventory data and fee structures to the BNB and handle suspected counterfeit currency according to strict protocols.

    [8][9]

Direction of travel

  • Regulatory focus is shifting towards the implementation of MiCA and the operational preparations for Bulgaria's adoption of the euro, including detailed cash management and frontloading protocols.

    [4][10]

  • The FSC is actively updating fee structures and licensing procedures for crypto-asset and investment services, indicating a maturing and increasingly detailed regulatory regime.

    [11][5]

Sources

  1. Ordinance No 3 of the BNB on the Terms and Procedure for Opening Payment Accounts, Executing Payment Transactions and Using Payment Instruments · 2018-04-18
  2. Ordinance No. 16 of the BNB of 29 March 2018 on Granting Licenses and Approvals, Entry into the Register under Article 19 of the Law on Payment Services and Payment Systems, and Requirements to the Activity of Operators of Payment Systems with Settlement Finality · 2018-03-29
  3. Law on Markets in Financial Instruments · 2026-07-08
  4. Law on Crypto-Asset Markets · 2026-05-29
  5. Regulation No. 77 of 12.03.2026 on the Conditions and Procedures for Licensing and Conduct of Activities by Asset-Backed Token Issuers and Crypto-Asset Service Providers · 2026-03-12
  6. Ordinance No. 28 on Information and Documents for Third-Party Cross-Border Transfers · 2012-12-18
  7. Appendix to Ordinance No. 28 of the MF and BNB · 2013-01-14
  8. Ordinance No 47 of the BNB on Conditions for Providing Information by Credit Institutions and Retaining Banknotes and Coins in Levs · 2025-07-31
  9. Appendix No. 2 under Article 5, paragraphs 3 and 4 and Article 6, paragraph 2: Protocol for the retention of banknotes/coins suspected of intentional damage, criminal involvement, or worthlessness · 2025-09-24
  10. Ordinance No 46 of the BNB on Frontloading and Sub-frontloading of Euro Banknotes, Euro Coins and Starter Euro Coin Kits · 2025-07-31
  11. Ordinance No. 76 of 12.06.2025 on the Fees Collected by the Financial Supervision Commission · 2025-06-12

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This guide is compiled automatically from 11 primary-source documents published by Bulgaria's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.