Bulgaria · MiCA-authorised CASP
Buy a CASP in Bulgaria — MiCA-authorised crypto licence
Cadena Brokers represents acquirers looking at the Bulgarian crypto licence market in its first full MiCA cycle. Every entity we present has been pre-vetted for standing with the Financial Supervision Commission, banking continuity, and the change-of-control mechanics that an inbound buyer faces under Bulgaria’s Law on the Markets in Crypto-Assets.
This page is for the buyer. If you are looking to sell a CASP, this is not your channel.
Why Bulgaria
FSC supervision and a grandfather window with a hard sunset
The Financial Supervision Commission of the Republic of Bulgaria is the competent authority for CASPs and asset-referenced-token issuers under MiCA. The Bulgarian National Bank handles e-money tokens. Domestic transposition runs through the Law on the Markets in Crypto-Assets (the Bulgarian MICAL), which adapts EU Regulation 2023/1114 to local supervisory practice and routes authorisation through Articles 6(2) and 15(5).
The acquirer-relevant fact: Bulgaria did run a pre-MiCA registration regime, through the National Revenue Agency’s AML registry. That register closed to new entrants on 30 December 2024, and the firms that sat on it can keep operating without a full MiCA file until 1 July 2026. After that, the grandfather is gone. Every NRA-registered crypto operator either converts into a fully authorised CASP or stops trading. That sunset is what’s compressing target-side decision-making this year, and it’s why the shortlist of acquireable Bulgarian crypto entities is forming faster than the public SERP suggests.
Once authorised, a Bulgarian CASP passports across the EU 27 under MiCA, the same way an EMI or a MiFID firm does. That is the practical value of buying the Bulgarian file rather than starting one in another Member State.
Scope
What an FSC-authorised CASP permits
An authorisation under Title V of MiCA covers any combination of the ten enumerated crypto-asset services. The minimum capital requirement under Article 67 scales with the scope you elect: EUR 50,000 for custody, advice, portfolio management, placement, and order reception/transmission; EUR 125,000 for exchange and order execution; EUR 150,000 for the operation of a trading platform, or one quarter of the prior year’s fixed overheads, whichever is higher.
The services in scope:
- Custody and administration of crypto-assets on behalf of clients
- Operation of a trading platform for crypto-assets
- Exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets
- Execution of orders on behalf of clients
- Placement of crypto-assets
- Reception and transmission of orders
- Advice on crypto-assets, and portfolio management
- Transfer services for crypto-assets
Two segregation rules matter for diligence. Portfolio-management and advisory CASPs may not hold client funds, client crypto-assets, or the means of access. Custodial CASPs operate under MiCA’s broader segregation regime, with daily reconciliation and asset separation from the firm’s own balance sheet. Multi-service authorisations almost always sit on top of both rules; confirm in the target’s compliance manual how the two are reconciled inside one operating entity. (Most NRA-registered firms had no equivalent obligation pre-MiCA, so the conversion files are where this gets tested.)
Inventory profile
What we broker here
Bulgarian CASP targets in our book share a profile: a single Bulgarian operating entity either already FSC-authorised or carrying an NRA-AML registration plus a live MICAL conversion file, a Bulgarian banking relationship that has survived MiCA-onboarding scrutiny (this is the gate where most Bulgarian acquisitions stall, since domestic banks remain selective on crypto-asset firms post-2024), an AML programme tested against the FSC’s enforcement posture, and a small but retainable compliance team. The pre-MiCA Bulgarian crypto cohort is finite and known, which makes diligence faster than in newer-MiCA markets.
We do not name targets in public materials. The acquirer-profile language above describes the diligence gates we apply when shortlisting; the actual entity, ownership, and authorisation status are released under NDA.
Acquisition process
From shortlist to FSC approval
The path mirrors any qualifying-shareholding acquisition in EU financial services: NDA, anonymised shortlist, target reveal, structured access to the data room, term sheet, FSC notification under MiCA Articles 41 and 42 (the qualifying-holding regime), conditions-precedent, closing. The FSC assesses fit-and-proper for the proposed ultimate beneficial owners, source-of-funds documentation, and the post-acquisition business plan. Where the target is an NRA-registered firm mid-conversion, the FSC will commonly resolve the conversion file and the change-of-control file together.
Cadena handles the brokerage side. Bulgarian counsel sits alongside the buyer for the FSC filing; we can introduce one if the buyer has not already chosen.
Why Cadena
Buy-side mandate, fintech-only focus
- Buy-side only. We do not represent sellers anywhere. Every introduction we make is to a target whose owners have agreed to entertain a sale; we never trawl your interest back into the market.
- Pre-vetted Bulgarian inventory. Targets reach our shortlist after an FSC-standing check, NRA-AML conversion-status review, banking-continuity confirmation, and a sanctions and litigation pass. The Bulgarian crypto cohort is small enough that we know it line-by-line.
- Speed without shortcuts. Expedited closings on Bulgarian CASP files are realistic where the seller’s records are clean and the FSC file is current. We do not promise calendar weeks; we do execute without delay.
FAQ
Bulgaria CASP — buy-side questions
Is there a CASP licence for sale in Bulgaria?
You do not buy a Bulgarian crypto licence as a standalone instrument. You acquire the Bulgarian legal entity that holds (or has applied for) FSC authorisation under MiCA, through a share purchase that triggers the qualifying-holding approval under MiCA Articles 41 and 42. Cadena identifies a target whose owners are open to a sale, structures the SPA, and runs the change-of-control filing alongside Bulgarian counsel. The licence travels with the entity once the FSC approves the incoming shareholder.
What is a CASP licence in Bulgaria under MiCA?
A CASP licence is the FSC’s authorisation to provide one or more of the ten crypto-asset services listed in Title V of MiCA. The Bulgarian Law on the Markets in Crypto-Assets sets the procedural framework; the FSC issues a reasoned grant or refusal within 40 working days of a complete application, per MiCA Article 63(9). Once granted, the authorisation passports across the EU under standard MiCA notification procedures.
How does the FSC handle change-of-control on an acquired Bulgarian CASP?
MiCA Articles 41 and 42 set the qualifying-holding regime that applies to every Member-State CASP, Bulgaria included. Any acquisition reaching the 10%, 20%, 30%, or 50% threshold of capital or voting rights requires prior FSC notification and a non-objection decision. The regulator assesses fit-and-proper standing for the proposed ultimate beneficial owners, source of funds, and the post-acquisition business plan. The statutory assessment window runs in working days from receipt of a complete file, with one extension permitted if the FSC requests further information.
What happens to the 1 July 2026 grandfather sunset if a deal closes after that date?
The grandfather is a transitional permission for firms registered on the National Revenue Agency’s AML register as of 30 December 2024. It expires on 1 July 2026. After that date a target operating only on the grandfather can no longer lawfully provide crypto-asset services in Bulgaria. If your closing falls after the sunset, the target needs full FSC authorisation in hand at completion — otherwise you are buying an inactive shell with a pending MICAL file. Time the SPA so the conversion is either completed pre-closing or carried by you across the line with explicit FSC engagement.
What is the minimum capital for a Bulgarian CASP?
EUR 50,000, EUR 125,000, or EUR 150,000 of paid-in capital under MiCA Article 67, depending on which services the entity is authorised for, or one quarter of the previous year’s fixed overheads, whichever is higher. The lowest tier covers custody, advice, portfolio management, placement, and order reception/transmission. The middle tier adds exchange and order execution. The top tier is required where the entity operates a trading platform. A multi-service Bulgarian CASP typically capitalises at the highest applicable tier across its scope.
Next step
Request the Bulgaria CASP shortlist
Brief us on your strategic profile and target services. We respond with the current Bulgaria CASP shortlist and a structured route to first contact. See also EU-wide CASP coverage, the MiCA licence framework, the Bulgarian EMI route, and the Bulgarian PI route for comparable acquisition strategies.
