Payment institutionCore route
Payment institution is the anchor permission SKY7 maps for Bulgaria. The work starts by matching the product, client flow and revenue model to the regulator's activity perimeter.
- Lead
- 6–9 mo
- Capital
- €125K+
- Fit
- Primary
SKY7 · BULGARIA PROFILEUpdated · May 2026 · SKY7.LEGAL
BG
ISO 3166-1Republic of BulgariaSofia · GMT +2
- Region
- Europe
- Regulator
- BNB
- Currency
- EUR
- Working week
- Mon – Fri
- Filing language
- Bulgarian / English
- FATF status
- Increased monitoring
European Union · PI · EMIAvailable · active scoping
Bulgaria. An EU payments route under BNB supervision.
EU payment and e-money path with competitive operating costs and a clear central-bank supervisory perimeter. The Bulgarian National Bank maintains payment and e-money supervision under the Law on Payment Services and Payment Systems and Ordinance No. 16. The route is relevant for PI/EMI models that need EU passporting with a leaner operating cost base. SKY7 treats the route as a working legal and operational file: permissions, capital, substance, banking and regulator questions are mapped before the filing strategy is fixed.
- Lead time
- 6–9 mo
- Indicative planning window; live regulator queue and client readiness can change it.
- Capital floor
- €125K+
- Indicative planning assumption; final treatment depends on category, volume, safeguards and local interpretation.
- Primary scope
- PI
- BNB authorisation for payment institutions and electronic money institutions under Bulgarian payment-services law.
Route overview
What this route is really for
Bulgaria should be assessed against the live regulator source, not only a headline licence name.
Bulgaria is a payments and money-services route in European Union. The working file starts with PI · EMI, BNB, and the practical evidence a bank, counterparty or supervisor will expect after approval.
The Bulgarian National Bank maintains payment and e-money supervision under the Law on Payment Services and Payment Systems and Ordinance No. 16. The route is relevant for PI/EMI models that need EU passporting with a leaner operating cost base.
The route is strongest when the team can explain ownership, source of funds, governance, AML/CFT controls, technology vendors and launch volumes in one consistent story. SKY7 uses the first pass to decide whether Bulgaria should be primary, backup or removed from the shortlist.
Best fit
- Operator profilePayment and e-money teams that want an EU authorisation path with central-bank supervision and controlled setup costs.
- Regulator sourceBNB authorisation for payment institutions and electronic money institutions under Bulgarian payment-services law.
- TimingUseful when the project can support a 6–9 mo planning window and staged document production.
Watch points
- Core risksOwn funds, safeguarding, management fitness, outsourcing and local operating evidence.
- Capital€125K+ is an indicative assumption; the live requirement can change with permissions, volumes and risk profile.
- Sources checkedBNB Law on Payment Services and Payment Systems · Bulgarian National Bank
Permission map
The file is built around specific permissions
SKY7 separates the headline route from the permissions that actually matter for product launch, banking and investor diligence.
Electronic money institutionAdjacent permission
Electronic money institution is checked against ownership, governance, AML/CFT, capital and banking expectations so the filing tells one consistent story.
- Lead
- 6–9 mo
- Capital
- €125K+
- Fit
- Optional
PSD2/EU passporting perimeterEvidence layer
SKY7 converts psd2/eu passporting perimeter into an evidence pack: application forms, policy set, role map, financial model, local substance and response plan.
- Lead
- 6–9 mo
- Capital
- €125K+
- Fit
- Support
Capital and evidence
Budget the route before the filing starts
The capital number is only one line in the file. Regulators and banks also look for runway, safeguards, governance and credible operating substance.
| Item | Planning range | Working note | Owner |
|---|---|---|---|
| Primary routeBNB | PI · EMI | BNB authorisation for payment institutions and electronic money institutions under Bulgarian payment-services law. | SKY7 |
| Paid-up capitalHeadline marker | €125K+ | May vary by category, volume, client-money model, risk profile and current local interpretation. | Client |
| Operating runwayBudget evidence | 6–12 mo | A realistic runway supports regulator confidence and bank onboarding. | Client CFO |
| Governance packFit and proper | Role-based | Directors, MLRO/compliance, risk owner, outsourcing owner and escalation lines need to match the model. | Joint |
| Source packResearch | Official sources | BNB Law on Payment Services and Payment Systems · Bulgarian National Bank | SKY7 |
Planning ranges onlySource check completed 27 May 2026Confirm rulebook and local counsel before filing
Execution timeline
A regulated launch is a sequence of evidence
The 6–9 mo marker is a planning window. The live calendar depends on client readiness, source checks, regulator queue and quality of responses.
- 01Month 0
Source check and route memo
Confirm the live regulator position for Bulgaria, the activity perimeter and whether the route should be primary, fallback or avoided.
- 02Month 1
Entity and role map
Confirm ownership, directors, compliance roles, local presence, bank narrative and fit-and-proper evidence.
- 03Month 2
Control architecture
Draft the AML/CFT, risk, safeguarding/client-asset, outsourcing, complaints and technology controls around the actual product.
- 04Mid-file
Application file
Prepare regulator forms, business plan, financial model and supporting evidence for BNB.
- 05Regulator queue
Questions and evidence
Run a query tracker, refresh documents, collect additional evidence and keep management answers consistent.
- 066–9 mo
Approval and operating handover
Convert the authorisation into reporting calendars, control owners, registers, renewal triggers and banking follow-through.
Substance
The supervisor needs to see an operator, not a shell
Bulgaria should be approached with a substance plan that can survive regulator questions and later bank diligence.
Governance
Board and senior management
Define decision rights, reporting lines, committee cadence and escalation routes before the application is filed.
- /Fit-and-proper evidence
- /Board minutes and registers
- /Conflict management
Financial crime controls
AML/CFT and sanctions
Translate customer journeys into onboarding, monitoring, screening, suspicious-activity and recordkeeping procedures.
- /Risk assessment
- /KYC/KYB workflow
- /Monitoring and reporting
Operating presence
People, premises, vendors
Show where the regulated work happens, which vendors are outsourced and how the local team controls critical functions.
- /Local role map
- /Outsourcing register
- /Business continuity
Financial model
Capital and runway
Tie capital, revenue, cost base and transaction assumptions to the actual regulated permissions and first-year operating plan.
- /€125K+
- /12-month forecast
- /Banking narrative
Route comparison
Compare it against nearby routes
The right answer is often a primary route plus a fallback. These comparison cards use the same route-planning fields so the trade-off stays visible.
Bulgaria
- Regulator
- BNB
- Lead
- 6–9 mo
- Capital
- €125K+
Cyprus
- Regulator
- CySEC
- Lead
- 6–10 mo
- Capital
- €125K — €730K
Czech Republic
- Regulator
- ČNB
- Lead
- 5–8 mo
- Capital
- €20K — €125K
Estonia
- Regulator
- FIU Estonia
- Lead
- 3–4 mo
- Capital
- €250K
Comparison uses current route metadata and source-checked profile notes; it is not a legal ranking and should be refreshed before client-facing use.
SKY7 workplan
What SKY7 prepares for Bulgaria
The engagement turns route choice into a document set, decision log and handover pack that the client can keep operating after approval.
Source-backed route memo
A decision memo covering PI · EMI, source links, regulator expectations, capital marker, timing and go/no-go issues.
Gap list
A practical checklist of missing documents, owners, approvals and evidence required before drafting starts.
Application architecture
Document map, ownership chart, regulated activity perimeter, compliance role map and filing sequence.
Policy and control pack
Policies and procedures adapted to the product, customers, transaction flow, vendors and technology stack.
Regulator response desk
Query tracker, revised documents, evidence bundles and weekly status notes during review.
Operating calendar
Post-approval obligations, reporting dates, control owners, renewal triggers and banking follow-through.
FAQ
Questions clients ask before choosing Bulgaria
These answers keep the pre-filing conversation grounded while SKY7 confirms the live rulebook and the client-specific risk profile.
01Is Bulgaria available for new applications?
Available · active scoping. Availability should still be checked at the time of instruction because regulator appetite, category restrictions, queue length and transitional rules can change.
02What official sources did SKY7 check?
BNB Law on Payment Services and Payment Systems: https://www.bnb.bg/bnbweb/groups/public/documents/bnb_law/laws_payment_services_en~30.pdf | Bulgarian National Bank: https://www.bnb.bg/?lang=en
03How long does Bulgaria usually take?
The indicative planning window is 6–9 mo. A ready file can move faster; weak ownership evidence, unclear source of funds, missing policies or regulator questions can extend the calendar.
04What is the minimum capital?
The current indicative assumption is €125K+. Final capital treatment depends on the exact permissions, activity volume, safeguarding/client-asset model and local interpretation.
05Which activities fit Bulgaria?
The current route scope is PI · EMI. SKY7 confirms whether each product feature is regulated, exempt, prohibited or better placed in another jurisdiction.
06Can SKY7 provide a ready-made entity?
Where clean shelf or licensed inventory exists, SKY7 checks history, ownership, filings, bankability and transfer mechanics before recommending a handover.
07Do we need local staff or office space?
Usually some level of real substance is expected. The exact requirement depends on the permission, risk profile and regulator; it is scoped before filing.
08What does SKY7 need to start?
Product description, ownership chart, source-of-funds evidence, management CVs, transaction flows, target countries, vendor stack and any existing policy drafts.
Bulgaria desk
Need a source-backed route memo for Bulgaria?
Send SKY7 the product model, target customers and launch timing. We will confirm whether Bulgaria should be primary, backup or removed from the shortlist.
Desk
Bulgaria licensingBNB · European Union
ResponseOne working day after receiving the product summary.
Bring
Product mapActivities, customers, flows, counterparties and countries.
Current statusNew filing, ready-made acquisition, migration or regulator query.