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Crypto License in Bulgaria

Bulgaria stands out as a jurisdiction with a predominantly unregulated environment for crypto businesses, focusing primarily on anti-money laundering and counter-terrorist financing. Oversight from the Bulgarian National Bank (BNB) and the Financial Supervision Commission (FSC) aligns with European Central Bank standards. Rather than establishing a national regulatory framework, the government anticipates forthcoming EU-wide regulations. Crypto businesses in Bulgaria, however, must obtain a license from the National Revenue Agency (NRA), responsible for tax administration and other state receivables. In 2019, the Bulgarian Council of Ministers introduced the "Digital Bulgaria 2025" program, aiming to foster digital growth through innovations like distributed ledger technology (DLT) and artificial intelligence, along with stringent standards for cybersecurity and interoperability. Although the national government is in early talks about cryptocurrency adoption, entrepreneurs can currently benefit from straightforward licensing rules and a favorable tax regime, positioning themselves for potential increased demand across various sectors.
The License
The provision of specific services necessitates crypto authorization from the Bulgarian supervisory authority, including:
  • Exchange of cryptoassets into another type of cryptoasset
  • Exchange of cryptoassets into fiat money and vice versa
  • Safeguarding private cryptographic keys on behalf of customers
  • Holding, storing, and transferring cryptoassets

Currently, the government does not facilitate testing programs or regulatory sandboxes. However, in 2020, plans were announced to launch a Sofia Sandbox. This initiative aims to create a secure, small-scale testing environment for emerging business models not yet covered by regulations. The Sofia Sandbox serves as a platform for monitoring developments and experiments closely within the Bulgarian regulatory framework.

Why Bulgaria

Bulgaria currently lacks a crypto-specific license specifically regulating crypto-related economic activities. There are no specific restrictions or obligations, and companies can even accept cryptocurrency as collateral for loans without falling under a particular regulatory framework. However, for Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) compliance, most crypto-related businesses still require a license under the Measures Against Money Laundering Act (MAMLA).

Cryptoasset exchanges and custodial wallet providers must register in the public register maintained by the National Revenue Agency (NRA), which is also responsible for granting crypto authorization. Upon registration, companies receive a company certificate, equivalent to a crypto license. This certificate, issued by the national authority, is the official document permitting cryptoasset entrepreneurs to engage in crypto-related economic activities within the general regulatory framework.

Key characteristics of a Bulgarian crypto license include:

  • No Local Staff Requirement: There is no mandatory need for local staff, providing flexibility for businesses.

  • Speedy Application Process: The application process is efficient and conducted at a rapid pace, ensuring a swift licensing procedure.

  • Remote Application Completion: The entire licensing application process can be successfully completed remotely, offering convenience and accessibility.

  • No AML/CFT Compliance Officer Requirement: Unlike some jurisdictions, there is no obligatory need for an Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) compliance officer.

  • Low Initial Share Capital: The initial share capital requirements are notably low, starting from 2 BGN (approximately 1 EUR), making it financially accessible for businesses entering the crypto space.

Taxation

For tax purposes, the National Revenue Agency (NRA) in Bulgaria aligns treatment of cryptoassets with the definition outlined in the Measures Against Money Laundering Act (MAMLA) and adheres to the policies set forth by the European Bank Authority. Both natural and legal persons are identified as tax-liable entities. Regular allowances and exemptions, along with specific rules introduced by the European Union (EU), are applicable. Notably, cryptocurrencies are VAT-exempt, considered equivalent to providing financial services. However, other crypto-related economic activities may be subject to a standard 20% VAT rate.

Key tax rates in Bulgaria include:

  • Corporate Income Tax: 10%
  • Individual Income Tax: 10%
  • Social Security Contribution: 24.3% (13.72% paid by employers, 10.58% paid by employees)
  • National Health Insurance: 8% (4.8% paid by employers, 3.2% paid by employees)
  • Withholding Tax: 5% (levied on distributed dividends)

Various types of income from crypto-related activities are subject to taxation, including income from trading or exchanging cryptoassets, acquiring cryptoassets, mining cryptoassets, exchanging cryptoassets into another type, and income from staking.

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