NBLO advises EOS Matrix on successful BNB authorisation as credit servicer under CSCPA

NBLO’s team, led by Svetoslav Ivanov (Partner) and Petro Tyufekchiev (Managing Associate), has successfully advised and assisted EOS Matrix EAD (EOS Matrix) in obtaining one of the first credit servicer licences issued by the Bulgarian National Bank (BNB) under the new Credit Servicers and Credit Purchasers Act (CSCPA), positioning both EOS Matrix EAD and NBLO at the forefront of Bulgaria’s implementation of Directive (EU) 2021/2167 on credit servicers and credit purchasers (Directive).

Background of the CSCPA Licensing Regime

As we set out in this note, the CSCPA introduces a specialised authorisation regime for entities that service certain non‑performing credit exposures originated by EU banks. The CSCPA sets out detailed licensing, organisational and conduct‑of‑business requirements for credit servicers, including governance, fitness‑and‑propriety criteria, complaints handling, outsourcing, and reporting obligations. 

Under the new framework, credit servicers are subject to authorisation from the BNB and may then passport their services across the EU in line with the Directive. This has created a significant regulatory inflection point for existing Bulgarian collection and recovery businesses, which had to make a transition to fully regulated status in order to continue operating in respect of covered portfolios.

NBLO’s Role and EOS Matrix’s Credit Servicer Licence

EOS Matrix is the largest debt collection and receivables management company in Bulgaria, with a long‑standing presence on the local NPL and retail collections market. In anticipation of the authorisation requirements of the CSCPA, EOS Matrix engaged our law firm to design and implement its path to authorisation as a credit servicer with the BNB.

NBLO’s mandate encompassed:

• Mapping EOS Matrix’s business model, corporate structure and activities against the CSCPA’s scope, exclusions and transitional provisions, to confirm the exact perimeter of regulated “credit servicing” functions.
• Structuring and preparing the licensing application dossier, including governance, policies, internal controls and compliance framework documentation in line with the CSCPA’s requirements and emerging BNB practice.
• Advising on adaptations to EOS Matrix’s operational processes (including complaints, arrears handling, outsourcing and data protection alignment) to ensure readiness for post‑authorisation supervision.

Following this process, EOS Matrix successfully obtained its credit servicer licence from the BNB, allowing it to continue and expand its activities with full regulatory clearance under the CSCPA. This outcome confirms EOS Matrix’s position as a compliant and future‑proof market leader, and highlights NBLO’s capability to deliver complex regulatory authorisation projects in a novel and evolving framework.

Why the Credit Servicer Licence Matters for the Bulgarian Market

The EOS Matrix credit servicer licence is one of the first licences under the CSCPA regime, setting a practical benchmark for market participants and demonstrating that large collection platforms can successfully adapt to the Directive‑driven regulatory environment. For creditors and investors, working with a licensed credit servicer offers improved regulatory certainty, standardised consumer‑protection processes and clearer oversight by the BNB.

For NBLO, the project evidences the firm’s ability to:

• Navigate EU‑level regulatory innovation and its transposition into Bulgarian law.
• Lead complex licensing engagements involving intensive coordination with regulators and detailed alignment of business operations with new statutory standards.
• Support major market players in maintaining continuity of business while meeting heightened compliance expectations.

NBLO’s Experience in Financial Services Regulation

NBLO has a strong financial services regulatory practice on AML/CTF, sanctions, fintech, AIFM/AIF, crypto‑asset regulation, and key EU frameworks such as AIFM Directive, MiCA, DORA, AMLR and PSD2/EMD2. From its bases in Sofia and London, the firm helps banks, payment institutions, funds and crypto businesses turn complex Bulgarian and EU regulatory requirements into clear, workable compliance and governance solutions for cross‑border operations.