EMI license in Bulgaria: e-money institution (EMI) requirements (2026)

Bulgaria enacted domestic implementing legislation for EU Regulation 2022/2554 (Digital Operational Resilience Act) on 8 July 2025, amending the Law on Credit Institutions, the Payment Services and Payment Systems Act, and the Markets in Financial Instruments Act, extending binding ICT-risk and incident-reporting obligations across the payment and fintech sector.

Parliament adopted the Markets in Crypto-Assets Act on 20 June 2025 (in force 8 July 2025), implementing EU MiCAR as domestic law. The FSC supervises CASP licensing while the BNB oversees e-money token issuers; entities registered in Bulgaria's AML register before 30 December 2024 benefit from a grandfathering period to obtain a full MiCAR authorisation by 1 July 2026.

EU Regulation 2022/2554 (DORA) became directly applicable in all EU member states, including Bulgaria, from 17 January 2025. The Bulgarian National Bank formally notified all supervised entities, including payment institutions and e-money institutions, of their compliance obligations regarding ICT risk management, resilience testing, and incident reporting.

The remaining provisions of Regulation (EU) 2023/1114 (MiCA), covering the licensing and ongoing obligations of crypto-asset service providers, became applicable on 30 December 2024. Bulgaria's pre-existing VASPs registered under AML law were granted a transitional window to transition to full MiCAR authorisation ahead of the BG-specific Crypto-Asset Markets Act being enacted in 2025.

From early December 2024, BORICA's BISERA system introduced instant euro payment services connected to the Eurosystem's TARGET Instant Payment Settlement (TIPS) infrastructure, giving Bulgarian PSPs full SEPA reachability for euro instant transfers, a key milestone ahead of Bulgaria's planned euro adoption.

Amendments to the Payment Services and Payment Systems Act came into force on 1 September 2023, updating Articles 118-121 governing access to payment accounts for third-party providers (PISPs and AISPs). The changes refined the open-banking framework supervised by the BNB, clarifying liability and data-sharing rules for fintech firms.

From July 2023, all credit transfers in Bulgaria, including public-sector payments, were required to comply with SEPA Credit Transfer (SCT) and SEPA Instant Credit Transfer (SCT Inst) schemes of the European Payments Council, replacing legacy domestic BGN formats and aligning Bulgaria's payment infrastructure with the Single Euro Payments Area ahead of eurozone entry.

MONEYVAL's fifth-round Mutual Evaluation Report (adopted May 2022) rated Bulgaria 'Partially Compliant' on FATF Recommendation 15 (virtual assets), citing inadequate VASP risk assessment, insufficient coverage of VA activities, and weak application of AML/CFT preventive measures by VASPs, compelling heightened regulatory scrutiny and driving subsequent reforms toward MiCA alignment.

BORICA launched Bulgaria's first real-time domestic payment service, Blink, through the BISERA6 system in spring 2021, enabling BGN account-to-account transfers settled within 10 seconds around the clock. By 2024 the system processed 22.6 million transactions worth BGN 36.9 billion, a 102% year-on-year volume increase, and formed the technical backbone for later euro instant payment integration.

Bulgaria amended its Measures Against Money Laundering Act on 4 August 2020 to transpose AMLD5, bringing virtual asset service providers, exchanges, custodians, and transfer-service providers, into the AML/CFT regime. VASPs were required to register with the National Revenue Agency (NRA) and comply with KYC, transaction monitoring, and suspicious-activity reporting obligations.

Bulgaria enacted a wholly new Payment Services and Payment Systems Act (State Gazette No. 20, 6 March 2018; in force 9 March 2018), transposing PSD2 and introducing open banking, strong customer authentication, and access rights for third-party payment initiation and account information service providers. The BNB was designated the sole supervisory authority and issued Ordinance No. 16 governing payment and e-money institution licensing.