MiCA in Bulgaria: From VASP Registration to CASP Licensing

Blockchain & Cryptocurrency, News

MiCA Authorisation for Bulgarian Virtual Asset Service Providers

The Markets in Crypto-Assets Regulation (MiCA) establishes a harmonised EU authorisation framework for crypto-asset service providers. For virtual asset service providers (VASPs) operating in Bulgaria, this represents a material regulatory transition: from a registration-based regime to full CASP licensing and ongoing supervisory oversight.

New Balkans Law Office advises VASPs on MiCA readiness assessments, licensing strategy, and the legal work required to maintain business continuity throughout the transition period.

What MiCA Means for Bulgarian VASPs

MiCA should not be approached as a straightforward re-labelling of existing activities. Competent authorities will expect firms to demonstrate a compliant operating model that satisfies authorisation standards across a range of areas, including corporate governance, internal controls, outsourcing oversight, and consumer protection documentation.

Firms are strongly advised to use the transition period constructively, building the evidence base and preparing the documentation required for licensing, rather than deferring this work until the final stage.

Recommended Next Steps

1. Confirm whether your current activities fall within the scope of MiCA and identify which CASP service categories are applicable to your business model.
2. Conduct a MiCA gap analysis and prioritise the workstreams necessary to meet authorisation requirements.
3. Develop a transition roadmap that maintains operational continuity whilst progressing towards full CASP licensing.

How NBLO Can Assist

Classification and Regulatory Strategy: We map your existing business model to the relevant MiCA service categories and provide advice on the appropriate licensing route, together with the practical sequencing of the authorisation project.

CASP Licensing in Bulgaria: We support the preparation of the CASP application and the legal framework required for authorisation, including governance structures and key internal policies.

Transition from VASP to CASP: We conduct a focused gap analysis for registered VASPs and develop a phased transition roadmap. Where necessary, we revise client-facing terms, disclosure documentation, and risk language to bring these into alignment with MiCA requirements.

Ongoing Regulatory Support: Following authorisation, we advise on regulatory queries, supervisory inspections, and change management projects, including the alignment of AML and sanctions controls with crypto-asset operational workflows.

Book a Free Consultation

If you are a Bulgarian VASP planning for MiCA compliance, we offer a free initial consultation covering the following:

• confirmation of the MiCA service categories applicable to your model;
• identification of principal readiness gaps and priorities; and
• an outline of a practical route to CASP licensing.

To arrange a consultation, please contact us at: crypto@newbalkanslawoffice.com or book a slot in Calendly.