Bulgaria’s Gambling Affiliate Licensing Regime: Applications, Fees and Penalties

Gambling and iGaming, Corporate Clients Insights, Licences

Bulgaria has introduced a specific licensing regime for affiliate operators promoting gambling games, bringing performance-based affiliate marketing expressly within the scope of the Gambling Act. The new rules, which entered into force on 1 August 2026, create a distinct regulatory framework governing who may carry out affiliate activities, the licensing procedure, the channels through which gambling may be promoted and the fees payable by licensed affiliates.

The change is particularly relevant to the rapidly developing online gambling affiliate market. Affiliate arrangements have traditionally occupied a space between advertising and gambling regulation, with businesses commonly remunerated through CPA (Cost Per Action) arrangements, RevShare (Revenue Share) models or hybrid structures combining fixed and performance-based remuneration. Under the new Bulgarian framework, the nature of that remuneration can determine whether a marketing business falls within the licensing regime.

The Regulation of Gambling Affiliates in Bulgaria

The Gambling Act now expressly regulates the activity of promoting gambling games by affiliate operators.

An affiliate operator is a person other than the organiser of gambling games who, under a contract or other arrangement, promotes gambling games in return for remuneration linked to the results achieved. The relevant results may include the number of players attracted, deposits, bets or other measurable outcomes.

A CPA model, for example, may provide for remuneration when a referred player completes a specified action, such as registration or making a qualifying deposit. A RevShare arrangement may instead link remuneration to the revenue generated by referred players. Hybrid models may combine a fixed CPA payment with a percentage of revenue. Where remuneration is linked to the relevant gambling-related results, the arrangement may fall within the statutory definition of affiliate activity.

The position is different where a business provides advertising, media or technical services for a fixed or otherwise non-performance-based fee. The Gambling Act distinguishes those services from affiliate activity where the remuneration is not linked to the results specified by the legislation.

The distinction is therefore not merely one of terminology. The contractual remuneration model and the substance of the services provided may determine whether a business requires a gambling affiliate licence in Bulgaria.

When Affiliate Marketing Requires a Licence

The new regime is intended to capture performance-based promotion rather than ordinary advertising activity. Affiliate marketing carried out without the required licence is prohibited, as is the promotion of gambling games on behalf of gambling organisers who do not themselves hold the necessary Bulgarian licence.

A foreign affiliate cannot assume that its relationship with an established international gambling operator is sufficient to permit promotion to Bulgarian consumers. The relevant gambling organiser must hold the required Bulgarian authorisation, and the affiliate must comply with the separate requirements applicable to affiliate operators.

For businesses operating across multiple jurisdictions, the Bulgarian regime should therefore be considered as a distinct local licensing requirement rather than as an extension of an existing foreign affiliate arrangement.

Who Can Apply and What Does the NRA Require?

The Bulgarian regime allows both domestic and foreign businesses to apply for an affiliate operator licence.

Eligible applicants include:

• Bulgarian individuals;
• Bulgarian legal entities;
• sole traders;
• foreign individuals; and
• foreign legal entities.

The legislation does not impose a specific minimum share capital or investment requirement for affiliate operators comparable to the capital and investment requirements applicable to gambling organisers. This makes the regime structurally different from the licensing framework applicable to businesses actually organising gambling games.

Foreign applicants can retain their existing legal structure rather than establishing a Bulgarian company solely for licensing purposes. They must, however, identify an authorised representative with an address in Bulgaria. That representative must have sufficient authority to enter into contracts on behalf of the foreign affiliate and to represent it before Bulgarian public authorities and courts.

For international affiliate businesses, the appointment of the Bulgarian representative should therefore form part of the licensing strategy from the outset.

Eligibility Requirements and Grounds for Refusal

The licensing regime contains specific suitability requirements for applicants and their representatives.

A licence will not be issued where, among other circumstances:

• the individual applicant, or the person representing a corporate applicant, has been convicted of an intentional criminal offence of a general nature, unless rehabilitated;
• the applicant has previously had an affiliate licence revoked and less than 12 months have elapsed since the revocation;
• the applicant has been subject to a final fine or pecuniary sanction under the relevant provisions of the Gambling Act and less than 12 months have elapsed since the sanction became final; or
• the applicant has had an affiliate licence revoked or an affiliate registration terminated in another jurisdiction.

The regime therefore introduces a regulatory suitability assessment extending beyond the applicant’s current corporate status.

For Bulgarian nationals, certain information is obtained by the authorities ex officio. Foreign applicants are required to provide declarations concerning relevant criminal and regulatory circumstances, including whether they have had an affiliate licence revoked or registration terminated in another jurisdiction.

For international applicants, this makes regulatory history an important part of the initial due diligence process. The application should be prepared on the assumption that the applicant’s previous regulatory status will be relevant to the NRA‘s assessment.

The Application

The licensing procedure begins with a written application submitted to the NRA together with the required supporting information and documents. One of the most distinctive features of the new regime is the requirement to identify the channels through which gambling games will be promoted.

The application must disclose, as applicable:

• websites;
• mobile applications;
• social media profiles;
• video platforms; and
• streaming platforms.

This requirement is commercially significant because these channels are not simply background information submitted to the NRA. They form part of the information recorded in the licence certificate itself. The certificate identifies the affiliate operator and the relevant websites, applications, social media profiles and video or streaming platforms through which gambling games are promoted.

For a large affiliate network, this can involve substantially more preparation than simply identifying the corporate applicant. Domains, applications, social media accounts and other promotional channels should be mapped and checked against the information included in the application.

The applicant should also ensure that its contractual arrangements with gambling operators accurately reflect the nature of its remuneration. In particular, businesses operating CPA, RevShare or hybrid models should assess whether the structure brings them within the statutory definition of affiliate activity.

The Bulgarian Licensing Procedure

The Executive Director of the National Revenue Agency is responsible for issuing, refusing, terminating and revoking affiliate operator licences. The procedure is significantly more streamlined than the general licensing process applicable to gambling organisers.

The NRA must complete the examination and assessment of an affiliate licence application within seven days of receiving it. Where the application is incomplete or additional information is required, the NRA must notify the applicant within three days and provide a seven-day period for the deficiencies to be remedied or the requested information to be supplied. The examination period is suspended while the applicant is given time to remedy the deficiencies. Once the examination has been completed, the application is submitted with a reasoned proposal to the Executive Director of the NRA. The Executive Director then has 14 days to issue a decision after the relevant circumstances have been established.

The decision is entered in the relevant public register and communicated to the interested parties. This procedural framework is considerably shorter than the standard timetable applicable to gambling operator licensing and reflects the narrower regulatory scope of affiliate activity.

Timing, Fees and the Cost of Compliance

The Gambling Act provides for an annual State fee for maintaining an affiliate operator licence consisting of:

• a fixed component of EUR 6,000 per year; and
• a variable component of 10% of the performance-linked commission remuneration received by the affiliate operator.

The variable component is particularly relevant to businesses operating CPA, RevShare or hybrid models because the regulatory cost is directly connected to the affiliate’s performance-based remuneration.

The fee structure therefore has a direct impact on the economics of the Bulgarian affiliate market. An affiliate with significant volumes of referred players and corresponding performance-based income will face a materially different regulatory cost from a smaller business generating limited commission revenue.

The Gambling Act also provides for State fees relating to the consideration of applications, licences and other administrative services. These should be distinguished from the annual fee for maintaining the affiliate licence.

What the Licence Covers

The licence is closely connected to the channels disclosed by the affiliate operator. The licence certificate contains, among other information:

• the affiliate operator’s identification details;
• information concerning its representatives;
• websites used for gambling promotion;
• mobile applications;
• social media profiles;
• video platforms;
• streaming platforms;
• the date of issue; and
• the duration of the licence.

Affiliate marketing channels should not be treated as an informal part of the business that can be expanded without regulatory consideration. Where an affiliate launches a new website, application, social media account or other promotional channel, it should first assess whether the change requires an amendment or other regulatory action.

The Bulgarian licence is therefore not simply an authorisation attached to a corporate entity. It also defines, to an important extent, the channels through which the licensed promotional activity is carried out.

Renewal, Amendments and Termination

Affiliate operator licences are generally issued for five years, unless a shorter period is requested by the applicant. An application for continuation must be submitted no later than two months before the expiry of the existing licence.

Where the circumstances previously established by the NRA have changed, the relevant supporting documents must be provided. Where there has been no change, the applicant may confirm the position by declaration. The operator should therefore treat renewal as an ongoing compliance process rather than an issue to be addressed immediately before expiry.

The same principle applies to changes in the business model or marketing infrastructure. Changes to the applicant, its representatives, remuneration arrangements or promotional channels should be reviewed from a licensing perspective before they are implemented.

Where an affiliate licence is terminated, the operator must return the licence certificate within seven days, cease the relevant activity where required and notify the gambling organiser on whose behalf the promotional activity was being conducted.

Next steps

For affiliate businesses, compliance begins with correctly classifying the activity. The fact that a business describes itself as a marketing agency, publisher or media company does not determine whether the Gambling Act applies. The remuneration model, the services provided and the manner in which gambling products are promoted must be considered together.

For gambling operators, the changes require greater attention to the regulatory status of their affiliate networks and to the contractual and operational arrangements through which customer acquisition is conducted.

The practical priority for businesses entering or continuing to operate in the Bulgarian market is therefore to assess their existing affiliate arrangements, confirm whether a licence is required, prepare the necessary information on their promotional channels and incorporate the new State fee structure into their commercial planning.

New Balkans Law Office advises gambling operators, affiliate businesses and international clients on Bulgarian gambling regulation, licensing, regulatory compliance and cross-border market entry. Our team can assist with assessing whether an affiliate activity falls within the Bulgarian licensing regime, preparing and submitting licence applications, reviewing affiliate agreements and advising on ongoing regulatory compliance.