Overview of Bulgarian EMI Licensing
Bulgaria offers an EU-compliant pathway to electronic money institution licensing, operating under the Payment Services and Payment Systems Act (PSPSA). As a European Union member state, Bulgarian EMI authorization provides access to the broader European market through passporting arrangements while offering competitive operating costs compared to Western European alternatives.
The Bulgarian National Bank (BNB) serves as the primary regulatory authority for electronic money institutions, applying European standards while accommodating the specific characteristics of the Bulgarian financial market.
Legal Framework
Bulgarian electronic money regulation derives from EU harmonization requirements:
Payment Services and Payment Systems Act (PSPSA): The primary domestic legislation governing payment services and electronic money issuance in Bulgaria, implementing relevant EU directives.
EU Directive 2009/110/EC: The Electronic Money Directive establishing common standards for EMI authorization and operation across EU member states.
EU Payment Services Directive (PSD2): Directive 2015/2366 governing payment services, implemented in Bulgarian law.
Anti-Money Laundering Legislation: Bulgarian AML requirements aligned with EU Anti-Money Laundering Directives.
Corporate Structure Options
Entrepreneurs seeking Bulgarian EMI authorization may establish operations through recognized corporate forms:
Joint-Stock Company (AD): The traditional structure for larger financial services operations, requiring higher minimum capital but offering flexibility for equity investment and corporate governance.
Limited Liability Company (OOD): A more accessible structure for smaller operations, with simpler governance requirements while meeting EMI licensing standards.
Both structures must satisfy the BNB's requirements regarding governance, capital adequacy, and operational capability.
Services Available Under Bulgarian EMI License
Licensed electronic money institutions in Bulgaria may provide:
Core E-Money Services
- •Issuance of electronic money against receipt of funds
- •Redemption of electronic money at par value
- •Distribution and redemption of electronic money through agents
Payment Services
- •Operation of payment accounts
- •Execution of payment transactions including fund transfers
- •Card issuance and merchant acquiring
- •Money remittance services
- •Payment initiation services (with appropriate authorization)
Capital and Prudential Requirements
Bulgarian EMI applicants must satisfy capital requirements aligned with EU standards:
Initial Capital: Minimum €350,000 for electronic money institution authorization, deposited in a Bulgarian bank account.
Ongoing Capital: Own funds must be maintained at the higher of the initial capital requirement or amounts calculated according to prescribed methods based on outstanding e-money.
Safeguarding: Customer funds must be protected through segregation in designated accounts or coverage by appropriate guarantees.
Authorization Process
The Bulgarian EMI licensing process follows established regulatory procedures:
Pre-Application Phase
- •Business model development and regulatory assessment
- •Corporate structure establishment
- •Capital arrangement and proof of funds
- •Premises and personnel recruitment
Application Submission
- •Complete documentation package submitted to BNB
- •Application fee payment
- •Formal acknowledgment of receipt
Regulatory Review
- •BNB assessment of application completeness
- •Evaluation of business plan viability
- •Fitness and propriety assessment of management and shareholders
- •Review of compliance frameworks and technical capabilities
Decision
- •License granted (with or without conditions)
- •Or refusal with stated reasons
Post-Authorization
- •Implementation of operational systems
- •Banking relationship establishment
- •Connection to payment infrastructure
- •Supervised commencement of activities
Documentation Requirements
Bulgarian EMI applications require comprehensive documentation demonstrating:
Corporate Information
- •Company registration documents
- •Articles of association
- •Shareholder structure and beneficial ownership
- •Registered office documentation
Business Planning
- •Detailed business plan covering at least three years
- •Financial projections and capital adequacy analysis
- •Description of proposed services and target markets
- •Pricing policies and fee structures
Governance and Management
- •Organizational structure
- •Management CVs and fit and proper documentation
- •Internal governance arrangements
- •Policies and procedures manuals
Compliance Framework
- •AML/CFT policies and procedures
- •Customer due diligence protocols
- •Risk management framework
- •Internal audit arrangements
Technical Documentation
- •IT systems architecture
- •Security measures and controls
- •Business continuity planning
- •Data protection arrangements
Advantages of Bulgarian EMI Licensing
EU Market Access
Bulgarian EMI licenses enable passporting to all EU/EEA member states, providing access to the broader European market from a single authorization.
Cost Competitiveness
Bulgaria offers significantly lower operating costs than Western European alternatives, including office rental, professional services, and personnel costs.
Regulatory Alignment
Full alignment with EU financial services directives ensures Bulgarian licenses carry credibility throughout the European market.
Banking Sector
Bulgaria's banking sector includes both domestic institutions and subsidiaries of major European banks, providing options for corporate banking relationships.
Compliance Obligations
Licensed Bulgarian EMIs must maintain ongoing compliance with:
Prudential Requirements: Continuous capital adequacy and safeguarding compliance.
AML/CFT Obligations: Customer due diligence, transaction monitoring, and suspicious activity reporting to Bulgarian Financial Intelligence.
Regulatory Reporting: Periodic submission of financial and operational returns to BNB.
Conduct Requirements: Fair treatment of customers, transparent pricing, and complaint handling procedures.
Practical Considerations
Timeline
BNB processing times vary based on application quality and complexity. Well-prepared applications with complete documentation typically progress more efficiently.
Professional Support
Given regulatory complexity, most applicants engage local legal counsel and compliance specialists familiar with Bulgarian requirements.
Banking Relationships
Establishing corporate banking facilities requires due diligence by prospective banking partners; early engagement is advisable.
Personnel
Appropriate qualified personnel must be in place, including compliance expertise and operational capability suited to proposed activities.
Conclusion
Bulgarian EMI licensing provides a viable pathway to European electronic money market participation, combining EU-standard authorization with competitive operating costs. Success requires thorough preparation, including robust business planning, comprehensive compliance frameworks, and appropriate professional support.
Companies considering Bulgarian EMI authorization should carefully evaluate whether the jurisdiction aligns with their business objectives and operational requirements before committing to the licensing process.