Obtaining an EMI license in Bulgaria

Obtaining an EMI license in Bulgaria is mandatory for issuing E-cash. Virtual funds consent firms to supply instant and secure remunerations without being tied to physical currency. These monies are stored in user accounts, providing convenience for online deals, mobile remunerations and transnational deals. Issuers create a flexible pecuniary infrastructure, reducing the bills of processing traditional remunerations and attracting customers with a priority on the speed and availability of solutions.

Licensing opens up other opportunities as well. Firms are engaged in opening and servicing accounts, transfers, issuing and acquiring remuneration instruments. Initiation of remunerations, admittance to account information and other modern performances make such supports popular with transnational subscribers. And integration with transnational remuneration models (Visa, Mastercard, SEPA) consents to primely expand the client base and assert promptness of schemes.

Acquiring the permit in the polity gives the prerogative to supply loans linked to remuneration supports. For example, to temporarily cover the client's cash gaps. Such schemes are financed from their own budget. If the monies are raised by issuing E-cash, they are prohibited from being loaned.

An imperative area is operational and support services. Comprising customer support, transaction processing and data control. Such performances help assert the stability of the firm's schemes. The license consents participation in remuneration models, with the exception of systems with final settlement, which supplies access to transnational pecuniary channels.

Firms with a registered EMI license in Bulgaria can engage in supplemental schemes permitted by law and agreed with the supervisor. All areas of work necessitate strict abidance with norms, which contributes to the growth of trust from partners and clients.

Legal and organizational prerequisites for obtaining an EMI license in Bulgaria

Firms are necessitated to choose an appropriate legal form, assert clarity of the proprietorship framework, confirm the qualifications of control and the abidance of the operational infrastructure with statutory norms.

Available legal forms for getting an EMI license in Bulgaria

Obtaining an EMI license in Bulgaria is permitted for two types of business: joint stock companies (Aktsionerno druzhestvo, AD) or limited liability companies (Druzhestvo s ogranichenna otgovornost, EOOD/OOD).

A joint-stock company has a strictly regulated control model. Administration is entrusted to the supervisory team: it generates a strategy, oversees the execution of tasks and distributes powers. The executive body is responsible for the prompt execution of choices. Financiers participate in the dissemination of profits, control the firm's schemes through meetings and audits.

The prime advantage of AD is the prospect of issuing stakes. Investments are attracted without concluding complex agreements or altering the composition of founders. The number of proprietors is not constrained. The issue of stakes simplifies the capitalization of the firm and consents to a flexible directive of participation stakes. This is a prime tool for transnational projects and interaction with large monies, corresponding to transnational norms of clarity and accessibility. The best option for registering an EMI license in Bulgaria.

The open supervision framework and strict control by the Bulgarian National Bank (BNB) assert the credibility of the firm. This makes AD an ideal form for a trade linked to the issuance of E-cash, imperative if the firm is centered on scaling.

Setting up and handling an AD is expensive. The bills include mandatory annual financiers' meetings, detailed pecuniary reporting and regular audits. However, getting the permit in polity is an expensive sequence in principle.

EOOD and OOD supply entrepreneurs with a simple and flexible supervision model. Participants make key choices directly, without creating a supervisory team. They independently decide how to oversee the firm and save money due to the lack of formal sequences. However, the chances for raising capital are minimal. To sell stakes, you need to sign contracts and involve a notary, the number of proprietors is constrained.

As the volume of schemes boosts, trade proprietors are forced to oversee abidance with statutory prerequisites on their own. This boosts the operational burden and may necessitate the transformation of the LLC into an AD. The transformation sequence necessitates supplemental bills, comprising the arrangement of new statutory indentures, and re-audit. The form can be beneficial for obtaining an EMI license in Bulgaria, but in specific and specific situations.

AD is appropriate for large-scale projects with transnational ambitions. The issue of stakes supplies flexibility in financing, and the rigid supervision framework meets the prerequisites of the BNB.

An LLC is imperative for firms with regional schemes and constrained investment goals. However, the lack of a mechanism for raising capital and the intricate oversight when scaling make this form less advantageous for long-term growth.

Transparency of proprietorship framework for Getting EMI License in Bulgaria

To get the permit, firms must assert full clarity of the proprietorship arrangement. The BNB necessitates disclosure of all ultimate beneficiaries, comprising financiers and other persons who directly or indirectly influence oversight. Firms supply full details of each proprietor, including name, stakeholding, and sources of monies contributed to the capital.

If the financier is a licit entity, the firm is obliged to disclose its proprietorship framework to the level of individuals. The supervisor pays attention even to proprietors of minimal stakes if they receive expanded voting prerogatives or other influence on decision-making. Nominee proprietors cannot hide the real beneficiaries.

Expat financiers supply chain of proprietorship information, comprising territory of excise residence and proof of absence of excise claims or sanctions. This is imperative if participants are linked with high-threat jurisdictions.

Transparency includes not only providing up-to-date data upon enrollment, but also updating it in a timely manner. Firms are necessitated to inform the BNB of any alterations in the proprietorship framework, comprising the transfer of stakes or the inclusion of novel participants. Concealment of data, false information or fictitious representation of proprietors lead to the refusal to register an EMI license in Bulgaria or to the cancellation of the permit.

To obtain an EMI license in Bulgaria, it is mandatory to enroll a licit address in the polity. It is used for official correspondence with the National Bank (BNB) and other statutory supervisors. It is confirmed by a lease agreement, a certificate of proprietorship or a notarized declaration from the proprietor of the premises. The use of fictitious or virtual addresses is not consented.

The firm must conduct its prime schemes in the polity. Trade oversight, accounting, internal audit and transaction processing must be carried out from a physical office enrolled in the polity. It is prohibited to use residential or damaged buildings. The premises are equipped to perform all prime performances.

Personnel prerequisites for getting an EMI license in Bulgaria

Overseers and members of supervisory bodies must have proof of higher education at the master's level or equivalent qualification. At least five years of work experience is mandatory, of which three years must be in managerial positions in the pecuniary sector, or EMIs.

If a firm applies for the permit, its supervision must meet the prerequisites of the BNB. Candidates must not have a criminal record for intentional crimes, a ban on pecuniary positions or experience in managing bankrupt firms in the last two years. Their reputation must be impeccable. The supervisor's norms also apply to co-proprietors of a firm with a large stake in the capital. They must prove pecuniary stability and openness of the origin of monies.

Change of key personnel necessitates mandatory notification to the BNB. The firm must supply indentures asserting the conformance of new candidates with the established prerequisites in order to continue the sequence of obtaining an EMI license in Bulgaria or to handle the current permit.

The role of the Bulgarian National Bank (BNB)

This establishment handles the sequence of obtaining an EMI license in Bulgaria. The supervisor checks the licit framework of the firm, its form of proprietorship, sources of capital and the composition of financiers. Also, the qualifications of the overseers, their professional experience and reputation are analyzed. The operational infrastructure of the firm must abide with the declared trade scheme and the needs of the overseer.

To successfully interact with BNB, firms must strictly follow the instructions and abide by the supervisor's prerequisites. Getting an EMI license in Bulgaria is impossible without a complete and correct package of indentures. Errors or incomplete information may lead to delays or refusal. The openness of the proprietorship framework and the pecuniary position of the firm must be confirmed at all stages of the verification.

The supervisor supplies clear explanations and access to directives governing the licensing sequence. Firms can seek advice or clarification of individual prerequisites. Involving experienced consultants simplifies the arrangement of a trade plan and paperwork.

To successfully obtain an EMI license in Bulgaria, it is imperative to abide by BNB norms, promptly respond to requests and handle a professional dialogue with the supervisor. National legislation is fully compliant with the EU, making the polity a reliable jurisdiction for transnational firms.

Pecuniary necessities for obtaining an EMI license in Bulgaria

Enrollers are necessitated to have a base endorsed capital, meet prime prerequisites for funds, and handle liquidity. These aspects assert stability and guarantee smooth operation.

Prerequisites for authorized capital

The base budget for obtaining an EMI license in Bulgaria is 700,000 BGN (approximately 357,000 EUR). The amount must be fully formed at the time of application and open to cover potential losses and operational perils. The supervisor necessitates that the stake capital consists of reliable and proven funds. According to Article 26(1)(a–e) of EU Regulation No. 575/2013, these include money from the sale of stakes, supplemental contributions from founders, retained earnings of the firm and reserve funds.

The relationship between the endorsed capital and the firm's schemes is directly contingent on the volume of schemes and the level of perils. The BNB may necessitate a boost in the amount of capital in the event of a prominent expansion of trade, a boost in the issuance of E-cash or the emergence of new pecuniary commitments. Applicants for an EMI license in Bulgaria calculate the amount of capital based on forecast data from the trade plan. After the start of operations, it can and will be adjusted.

Firms that are part of groups with other pecuniary institutions, such as credit institutions, investment firms or insurance firms, cannot reuse their endorsed capital when calculating their own monies. This restriction is aimed at asserting the reliability and stability of capital and hindering artificial overstatement of the group's pecuniary indicators.

The BNB necessitates firms to be fully open about the origin of the monies used to form the capital. All pecuniary details and supporting documentation are supplied at the application stage and are checked for abidance with statutory norms. Failure to abide with the capital formation prerequisites or concealment of data may result in the suspension of the licensing sequence or refusal to issue an EMI license in Bulgaria.

The base endorsed capital is not only a mandatory licensing prerequisite, but also serves as a peril control tool. Its size and framework are controlled by the supervisor at all stages of the firm's performance schemes.

Own funds and their calculation

The equity capital of an EMI license candidate in Bulgaria must be at least 700 thousand euros at the time of enrollment. This amount is defined as the base endorsed capital for starting schemes. After the firm is launched and E-cash is given, supplemental prerequisites apply. The supervisor takes into account the volume of deals, where the basic calculation method supplies for handling at least 2% of the average monthly volume of issued E-cash.

To do this, the firm's liabilities data for the last six months are analyzed. Such prerequisites consent for the growth of the firm's turnover to be taken into account: the more deals, the higher the level of mandatory reserves.

The Bulgarian National Bank consents the use of alternative approaches to calculating equity. The choice of method depends on the nature of the activity of the firm with a enrolled crypto license in the polity :

• Method A is based on fixed overhead bills for the previous year, which is appropriate for start-up firms or those with constrained schemes.
• Method B is tied to the total volume of remuneration deals for the reporting period.
• Method C is centered on the firm's income from issuing E-cash and providing remuneration services, which takes into account its operational characteristics.

The choice of the appropriate method must be justified and agreed upon with the supervisor. If the calculations show a shortage of own funds, the firm is obliged to boost the capital to abide with the prerequisites. Otherwise, the Bulgarian National Bank may request a recalculation of the indicators and a boost in pecuniary reserves.

Obtaining an EMI license in Bulgaria necessitates strict capital prerequisites. The initial capital of 700 thousand euros serves as a starting point, and further adjustments to the amount of monies contingent on current schemes, expenditures and potential perils.

Liquidity and pecuniary stability prerequisites

Applicants for an EMI license in Bulgaria are necessitated to handle sufficient liquidity to meet their pecuniary commitments. Liquid funds must be open to cover performing expenditures and current perils arising in the course of business.

The BNB regularly analyses the pecuniary stability of a firm, comprising an assessment of liquidity and the quality of internal sequences. If the supervisor identifies increased perils or a discrepancy between the trade plan and the declared indicators, it has the prerogative to demand a boost in the amount of own funds by 20% above the established level. This measure is aimed at minimising potential pecuniary threats and asserting the stability of the firm as its liabilities grow.

In the event of a threat to solvency, the firm is necessitated to immediately notify the BNB. Failure to abide by this results in a serious violation of supervisory norms and may result in supplemental inspections or restrictive measures by the supervisor.

Handling pecuniary stability and an adequate level of liquidity is a need for getting the permit in the polity. The supervisor oversees abidance with these prerequisites at all stages of the company's schemes, imperatively during periods of growth and scaling.

Firms applying for an EMI license in Bulgaria are necessitated to supply a full package of indentures asserting the availability of equity and endorsed capital. If the company does not have prominent operational experience, calculations are made based on forecast data and a trade plan.

The trade plan must include the company's development strategy, pecuniary forecasts for the next three years, and peril analysis in stress and target scenarios. This indenture serves as the basis for assessing the company's pecuniary stability at the licensing stage and is used by the supervisor to verify the realism of the declared indicators.

The Bulgarian National Bank (BNB) has the prerogative to request supplemental clarifications or indentures regarding the framework of equity capital, sources of its formation and the state of the endorsed capital. Providing incomplete or inaccurate detail may result in suspension of the application or refusal to obtain an EMI permit in the polity.

Threat control and AML/KYC prerequisites for getting an EMI permit in Bulgaria

The prime conditions for licensing are: effective peril control, abidance with UML and KYC norms, handling liquidity and meeting BNB norms. Let's consider these aspects in more detail.

General threat control prerequisites for Obtaining an EMI License in Bulgaria

Applicants for an EMI license in Bulgaria are required to execute a threat control model covering the identification, assessment and control of all prime threats. Including operational, pecuniary, credit, liquidity and systemic factors. Particular attention is paid to threats linked with the vulnerability of internal sequences, human errors and failures in information models.

Threat control policies and sequences must be developed considering the specifics of the company's schemes. The supervisor necessitates a clear definition of the acceptable level of threats and the execution of mechanisms for their control in both normal and emergency situations. These strategies are subject to annual review or adjustment in the event of prominent alterations in the company's performing environment.

Internal control plays a prime role in asserting abidance with threat control policies. Control is liable for executing effective strategies and overseeing their execution. Audit departments are necessitated to regularly review the quality of the measures executed and supply recommendations for improvement, identifying potential weaknesses.

Firms must also consider systemic threats that may affect the pecuniary stability of the organization. Particular attention is paid to threats arising from failures of prime sequences or violations by system participants. The creation and maintenance of a threat control model is a prerequisite for obtaining an EMI license in Bulgaria. This model asserts openness in threat control and reduces the likelihood of pecuniary losses for the company.

Operational threats and their control measures

Applicants for an EMI warrant in the polity are necessitated to minimize operational threats linked with internal failures and external threats. Particular attention is paid to vulnerabilities in information models, human errors and unforeseen events that may disrupt the continuity of schemes.

To protect critical sequences, firms generate security and reliability policies. These indentures cover physical and information security, equally data retention and cybersecurity measures. Organisations execute a framework that asserts protection against external attacks and information leaks, regular testing of systems and training of personnel to respond to incidents. After receiving an EMI license in Bulgaria, the policies are subject to mandatory annual review to consider new technological threats and alterations in the performing environment.

The polity’s national bank necessitates organisations to continuously oversee operational threats and regularly oversee the execution of policies. In case of prominent failures that affect the interests of clients or the stability of the trade, the firm is obliged to immediately notify the supervisor.

Effective control of operational perils, execution of continuity schemes and execution of cybersecurity measures are prime conditions for obtaining an EMI license in Bulgaria and asserting a sustainable scheme of the firm.

Pecuniary and liquidity threat control

When applying for an EMI warrant in the polity, it is mandatory to execute measures to control pecuniary and liquidity perils in order to handle stability and fulfill commitments to system participants.

Credit threats arise when participants fail to abide with their commitments. To control them, it is mandatory to oversee the commitments of the parties on a daily basis and execute guarantees to cover potential defaults. The supervisor necessitates system operators to use mechanisms to secure commitments, comprising collateral and other pecuniary instruments that minimize the threat of non-abidance with norms.

Liquidity threats are linked with the inability to repay current liabilities in a timely manner, despite the firm’s long-term solvency. Companies with an EMI permit in the polity are necessitated to execute mechanisms for overseeing liquidity and calculating the debit positions of system participants. The BNB requires that guaranteed monies cover the liabilities of at least two participants with the largest debit position. In systems with deferred net settlement, special attention is paid to rules to minimize the threat of delays, comprising the use of reserves and guarantee funds.

Loss coverage policies are a mandatory tool for the recovery of the system after defaults of participants. Organisations are necessitated to generate sequences for the dissemination of losses between the parties and to assert the restoration of funds in guarantee funds. If guarantee mechanisms are used to cover commitments during the trading day, their monies must be fully restored before the beginning of the next day. Otherwise, the suspension of the Bulgarian EMI license is possible until the need to re- obtain permits.

The BNB oversees the execution of pecuniary and liquidity threat control measures, regularly analyzing the effectiveness of the mechanisms executed. In the event of identifying weak points, organisations are necessitated to promptly make adjustments to assert an uninterrupted scheme and minimize the consequences of potential failures.

Thus, strict oversight of liabilities, execution of guarantee instruments and transparent loss allocation policies assert the pecuniary stability of EMI organisations.

AML and CTF

Applicants for an EMI warrant in the polity are necessitated to abide by the AML/CFT licit prerequisites set out in the MAMLA Act and EU directives.

AML policies and sequences must be tailored to the specifics of the firm and include measures to identify, oversee, and prevent suspicious deals. Organisations are necessitated to execute automated transaction overseeing systems that analyze customer deals to determine whether they match their pecuniary profile.

Organisations are necessitated to apply enhanced controls to customers or deals linked to countries that do not abide by transnational AML norms. The list of such jurisdictions is regularly updated based on recommendations from the Financial Action Task Force (FATF).

When working with these countries, it is mandatory to request supplemental detail about the sources of funds and the purposes of the deals, conduct careful oversight of all deals in real time, and report such deals to the competent supervisors for further analysis. Enrollers for the permit in the polity should take high-threat jurisdictions very seriously.

For deals exceeding thresholds, mandatory identification of the client and provision of supplemental indentures to confirm the origin of monies is necessitated. According to the statute, mandatory identification is carried out:

• for deals over 30,000 BGN (approximately 15,000 EUR) or equivalent in foreign currency;
• for cash deals exceeding 10,000 BGN (approximately 5000 EUR).

If deals are separate but have signs of interrelation, they are also subject to mandatory control. Organisations are obliged to record the circumstances of such deals and notify the Financial Intelligence Agency if suspicious signs are detected.

Applicants for an EMI license in Bulgaria are necessitated to generate internal criteria to identify unusual deals that fall outside the client’s normal activity. This includes unexpected large deals that are not consistent with the client’s normal pecuniary activity. Equally frequent transfers to accounts in offshore jurisdictions or deals with no apparent economic meaning or with abnormal payment frameworks.

Regular overseeing of client deals is mandatory. Organisations must record any suspicious activity and immediately notify the Financial Intelligence Agency

KYC sequences

Applicants for an EMI license in Bulgaria are necessitated to execute strict KYC sequences that cover all stages of interaction with clients. These sequences are aimed at identifying, verifying activities and minimizing the threats linked with money laundering and terrorist financing. It is mandatory to collect and verify personal data:

After securing an EMI warrant in the polity, it is mandatory to identify and document deals exceeding 30,000 BGN (approximately 15,000 EUR) or their equivalent in foreign currency. This prerequisite applies to both single deals and several deals if there is reason to believe that they are interrelated. If the threshold is exceeded, it is mandatory to record the origin of the monies. Verification of sources may include providing declarations on the origin of monies, contracts, invoices and other records, contingent on the nature of the deal.

Firms with an enrolled EMI license in Bulgaria are necessitated to identify the beneficial proprietors of licit entities, imperatively in cases of complex proprietorship frameworks. This includes multi-level holding frameworks, trusts or firms enrolled in offshore zones. Firms are necessitated to collect supporting documentation on all ultimate beneficiaries and update the data periodically.

Enhanced measures apply to politically exposed persons (PEPs), comprising officials, their close relatives and affiliates. For such clients, the firm is obliged to:

• Establish the source of origin of all monies and assets.
• Conduct regular overseeing of schemes.
• Obtain approval from senior management of the firm to enter into deals.

All documents collected within the framework of KYC and AML must be stored for at least five years from the end of the relationship with the client or the execution of a one-time deal. Continuous overseeing of client deals is mandatory at all stages of interaction, which consents identifying suspicious deals in real time. Each prerequisite is mandatory, their abidance is the only way to obtain an EMI license in Bulgaria.

The Role of the Bulgarian National Bank (BNB) in threat Supervision

The BNB regularly inspects the threat control systems of firms that have obtained an EMI permit in the polity. The supervisor analyzes internal policies and sequences, assesses their abidance with the established prerequisites and checks the quality of the execution of the mechanisms. Particular attention is paid to the policy of acceptable threat levels, response measures to threats and recovery schemes after operational failures. Firms are necessitated to confirm the effectiveness of their systems using real data and scenario tests.

If any shortcomings are detected, the BNB necessitates prompt correction of all weak links. Corrections must be presented in the form of a detailed plan, which defines the timeframes, methods for eliminating threats and the liable department. Firms with a given EMI permit in the polity are obliged to abide by the supervisor's needs within the established timeframes to handle pecuniary stability and trade continuity.

If prominent violations or threats to stability are detected, the supervisor has the prerogative to demand immediate correction of the situation. The BNB may suspend the issuance of E-cash or restrict certain schemes until the identified problems are completely eliminated. The purpose of such measures is to minimize potential threats and protect the interests of users of payment support. After receiving an EMI permit in Bulgaria, it is mandatory to promptly respond to orders and assert the smooth fulfillment of commitments to clients.

Firms are necessitated to submit peril control reports to the BNB on a regular basis. Quarterly reports cover current perils and incidents, describe control measures and the results of their application. Semi-annual reports include an analysis of the effectiveness of policies and sequences, equally the dynamics of alterations in prime perils. The execution of new measures and the results of overseeing must be disclosed in detail.

BNB checks the reports for completeness and accuracy of data. Logical control helps to identify hidden inconsistencies and potential threats. If errors or deficiencies are detected, firms are necessitated to submit a corrected document within 14 days. This consents BNB to promptly identify systemic perils and oversee the stability of firms with a registered EMI license in Bulgaria.

Regular supervision and the prerequisite to correct deficiencies assert abidance with norms and reduce the likelihood of threats to the territory's pecuniary system.

Technical and operational prerequisites for obtaining an EMI license in Bulgaria

The candidate must assert a robust technical configuration in accordance with the prerequisites of the BNB. This will necessitate the execution of control, data protection and cybersecurity systems, equally the development of detailed trade continuity schemes. All solutions must assert the stability of schemes, prompt recovery in the event of failures and the protection of confidential detail.

Infrastructure for making payments

Payment systems that operate with E-cash and supply linked supports are necessitated to guarantee fault tolerance and assert uninterrupted schemes. To obtain an EMI license in Bulgaria, it is mandatory to execute a technical architecture with high fault tolerance, comprising mechanisms for automatic recovery in case of failures and regular data backup. Operational performances can be outsourced to third parties, but only in strict abidance with the prerequisites of the supervisor:

1. The transfer of performances is possible only to organizations that abide with EU norms for data protection and transaction security.
2. Firms are necessitated to enter into a detailed agreement that supplies for the outsourcer's liability in the event of technical failures or security threats.
3. Full openness of all outsourced sequences, comprising BNB's access to details for supervisory audits.

BNB necessitates handling internal control over prime performances and regular overseeing of the quality of services supplied by third parties. Relevant for EMI license candidates in Bulgaria and existing firms.

System operators are necessitated to execute backup data processing centers to assert the continuity of remuneration services in the event of technical or external failures. Servers must be located in geographically remote locations to minimize the peril of data loss and failure of the entire system.

After receiving a payment license in Bulgaria, it is mandatory to regularly test the reserve capacities for abidance with the regulator's prerequisites:

• Full data synchronization between the primary and backup center in real time.
• The ability to transfer operations to backup capacities with minimal latency, not exceeding the acceptable time threshold set by BNB.
• Ready to restore critical services within two hours of a failure.

The regulator necessitates operators to document the reliability of backup capacity and submit test results as part of mandatory reporting.

To register an EMI license in Bulgaria, it is mandatory to execute systems for overseeing and managing deals in real time. These solutions must assert the smooth execution of remuneration deals and the timely detection of errors, failures or suspicious schemes.

• Automatic detection of anomalies in transaction data with notification of liable departments.
• Logging of all schemes and immediate notification of critical incidents to minimize perils.
• Technical control over the execution of calculations with simultaneous transmission of details to users and the regulator.

BNB mandates firms to regularly check the performance of overseeing systems and report the results. Ineffective performance of these systems may lead to supplemental supervisory measures from the regulator.

Data centers are necessitated to abide by transnational security norms and BNB prerequisites. The equipment is housed in premises with constrained physical access, 24-hour video surveillance and an intrusion control system. Registering an EMI license in Bulgaria will necessitate backup power supply and climate control systems to assert uninterrupted operation of the servers. Duplication of all critical components is mandatory to protect against failures and technical glitches.

Cybersecurity remains a central element of technical resilience. It is mandatory to execute data encryption technologies, asserting their protection at all stages of processing and transmission. Intrusion detection systems and firewalls are needed to prevent unendorsed admittance and oversee potential threats. Regular software updates and mandatory vulnerability testing consent perils to be identified and eliminated before failures occur.

Documentary evidence of abidance with the prerequisites and audit results are supplied to the Bulgarian National Bank on a regular basis. Failure to abide with the technical protection norms of the infrastructure of firms with an issued EMI permit in the polity may be grounds for the application of corrective measures by the regulator, comprising restrictions on the performance of operational schemes.

Data protection and privacy prerequisites

After getting an EMI permit in the polity, it is mandatory to abide by the General Data Protection Regulation (GDPR) and the national prerequisites of the polity. GDPR sets specific norms for the processing of personal details: lawfulness, minimization, limitation of the purpose and storage period. Processing of customer data is possible only on the basis of licit grounds: fulfillment of contractual commitments, abidance with the statute or getting explicit consent of the client.

Firms are necessitated to execute the principle of openness of processing, informing users about the purposes of collecting and using their data. Any transfer of details to third parties must be licitly justified and accompanied by guarantees of its security. Control over processing is assigned to an appointed employee - Data Protection Officer (DPO), who is liable for abidance with information protection norms and interaction with regulators.

Particular attention is paid to the prerogatives of customers to admittance, correct and delete their data. Firms with an EMI license in Bulgaria are necessitated to establish mechanisms to process such requests within the timeframes established by statute. In the event of a data leak, organizations must notify the competent supervisors no later than 72 hours after the incident is discovered.

According to statutory prerequisites, personal data of clients and transaction records must be stored in the territory of the EU. Firms working with cloud solutions are required to use providers certified according to GDPR norms and approved by the BNB. Each organization must document that the cloud storage configuration meets the prerequisites of confidentiality and security.

Data transfers outside the EU are only permitted in exceptional cases and if there are transnational agreements in place that supply an equivalent level of protection. BNB necessitates operators to be open about all information processing sequences and regularly confirm abidance with security norms.

Firms with a registered EMI license in Bulgaria are necessitated to abide with the established data retention periods. Personal details and transaction records must be stored for at least five years from the end of the trade relationship or a single transaction. This prerequisite is aimed at asserting auditability and supervisory review by BNB.

Organizations are necessitated to generate and handle data recovery sequences in the event of technical failures. Backup mechanisms must assert complete and prompt recovery of details in the event of any failure, while handling its integrity and availability. BNB necessitates documented evidence of the effectiveness of these mechanisms as part of regular audits.

Abidance with GDPR directives, data localization prerequisites and strict adherence to storage periods are mandatory conditions for obtaining an EMI license in Bulgaria. The regulator asserts strict control over the execution of these norms to protect the privacy and prerogatives of customers.

Software prerequisites for securing an EMI license in Bulgaria

It is mandatory to use software that complies with BNB prerequisites and EU norms. Certification covers technical and performance aspects, comprising data security, fault tolerance, and protection against unauthorized admittance. The software must abide with PSD2 and GDPR prerequisites, comprising access control performances, user identification and authentication, and protection of pecuniary details from leaks.

BNB necessitates documentary evidence of software certification, regular checks of its functionality and abidance with the regulator's prerequisites. The norms are valid from the first day after receiving the EMI license in Bulgaria . Any deviation from the approved norms may result in additional checks and corrective measures by BNB.

Enterprises with an issued EMI license in Bulgaria must use software that meets the prime functional prerequisites:

• Payment processing with the ability to synchronize data in real time between primary and backup systems.
• Handling transaction records, comprising transaction times, transaction identifiers and full customer data.
• Anomaly Detection Systems: automated overseeing of all deals to identify suspicious deals or potential violations. Key standard for obtaining and handling an EMI license in Bulgaria.
• Reporting: Ability to generate detailed reports for BNB in accordance with statutory prerequisites.

BNB necessitates the software to support integration with internal peril handling and reporting systems, consenting for overseeing of the quality of pecuniary deals and abidance with statutory norms.

Once an EMI license is obtained in Bulgaria, the software must be regularly updated to eliminate vulnerabilities and assert abidance with current security prerequisites. Before each update, mandatory testing is carried out to confirm the system’s functionality and resistance to potential failures. Testing covers:

• Checking for compatibility with other infrastructure components.
• Assessing the effectiveness of new features and their impact on operational stability.
• Vulnerability testing using scenarios of potential cyber attacks and failures.

Companies with a registered EMI license in Bulgaria are mandatory to record the results of testing and supply them to the BNB upon request. BNB also necessitates the execution of continuous overseeing systems to promptly identify failures and control the execution of software updates.

The software must assert a high level of availability and have mechanisms for automatic recovery in case of technical failures. Failure to abide with the prerequisites for updating and testing may lead to statutory intervention and restrictions on the firm's schemes.

Use of certified software, abidance with functional and technical prerequisites, equally regular updating and testing are mandatory conditions for receiving an EMI license in Bulgaria.

abidance with safety norms to obtain an EMI license in Bulgaria

Applicants must execute multi-layered cybersecurity measures to protect data and assert the continued operation of the infrastructure. Mandatory norms include:

• Data encryption: applies to all stages of data transmission and storage. It is mandatory to use algorithms not lower than AES-256 and TLS 1.2 protocols or higher.
• Two-factor authentication (2FA): mandatory for users and employees to access systems. Solutions include SMS codes, hardware tokens, or biometric verification.
• Protection against DDoS attacks: firms are necessitated to execute systems for automatic detection and filtering of malicious traffic with minimal response time to the threat.

The overseer necessitates firms to supply documentary evidence of abidance with technical norms, comprising results of stress tests and vulnerability audits. Physical protection of servers and data centers is an integral condition for earning an EMI license in Bulgaria . Server rooms must be equipped with biometric identification systems and multi-level authentication mechanisms to limit admittance to endorsed personnel only.

It is mandatory to execute 24/7 video surveillance with mandatory storage of records for at least 90 days and regular inspections of security measures guarantee additional protection of the infrastructure. To prevent equipment failures, server rooms must be equipped with uninterruptible power supply systems (UPS) and effective climate control that handles a stable temperature regime.

Enterprises are necessitated to supply BNB with detailed physical security reports, comprising infrastructure audits and vulnerability remediation schemes. If a firm has an EMI license in Bulgaria and processes payment card data, it is mandatory to abide by the PCI DSS (Payment Card Industry Data Security Standard). Prime prerequisites include:

• Protect cardholder data: Encrypt data at rest and in transit.
• Access control: restricting admittance prerogatives to details based on the need to perform work duties.
• overseeing and testing: regular audit of systems for vulnerabilities and log analysis to prevent leaks.

BNB requires firms to annually demonstrate PCI DSS abidance by submitting a Report of Audit (ROC) or Self-Assessment Questionnaire (SAQ).

To obtain an EMI license in Bulgaria, it is mandatory to generate and execute schemes for responding to security incidents, asserting prompt elimination of threats and minimizing their consequences. The schemes include mandatory overseeing systems with the performance of automatic detection of violations and cyber attacks. In the event of threats, firms are obliged to immediately block them and restore normal operation of the infrastructure within the period set by the BNB (up to two hours).

Companies with a registered EMI license in Bulgaria are necessitated to immediately notify the overseer of prominent incidents, including cyber attacks and operational failures, and to supply a report on the measures taken and the results of their execution. Effective response to security threats is monitored by BNB through regular checks and audits, failure to abide with norms may result in the suspension of the permit.

Business continuity and operational resilience

To obtain an EMI license in Bulgaria, it is mandatory to generate and execute a Business Continuity Plan (BCP) to minimize the perils of downtime and assert uninterrupted operation of the infrastructure. The document must cover all operational sequences, including the restoration of critical systems and testing the resilience of the infrastructure.

Critical services whose interruption threatens operational sustainability and pecuniary stability should be identified. These include transaction processing, operations overseeing and data protection systems. The disaster response plan should include step-by-step instructions for eliminating disruptions, temporary solutions and priority actions. BNB necessitates that the restoration of prime mechanisms last no more than 2 hours. Repeated failure to abide with the standard leads to the revocation of the obtained EMI license in Bulgaria.

Enterprises are necessitated to conduct quarterly testing of the continuity plan to verify its relevance and effectiveness. The testing includes modeling scenarios of technical failures, cyber attacks or equipment failure, equally assessing the duration of system recovery and the level of data loss (RTO and RPO). Also, stress tests are conducted to verify the resilience of the infrastructure under peak loads. All results and adjustments to the plan are recorded and provided to the overseer upon request.

Companies with an issued EMI license in Bulgaria are required to submit annual reports to the overseer on the effectiveness of the continuity plan, including test results and corrective measures to eliminate weaknesses. Failure to abide with the operational resilience prerequisites may result in corrective actions by BNB or temporary suspension of the permit.

To support operational stability, the firm needs to execute systems for overseeing the fault tolerance of equipment and software solutions. These systems provide automatic detection of failures, their isolation and redirection of work sequences to backup capacities. BNB necessitates that overseeing sequences include regular log audits and recording of all anomalies in the operation of systems.

Generating a detailed BCP, regular fail-safe testing and handling the technical infrastructure in accordance with statutory prerequisites are mandatory conditions for getting an EMI warrant in the polity.

Reporting prerequisites for firms with an issued EMI license in Bulgaria

Organisations with an issued EMI license in Bulgaria are necessitated to submit regular and timely reports to the BNB to oversee their operational and pecuniary schemes. Reporting is subject to strict prerequisites, violation of which may result in fines or suspension of the permit.

BNB necessitates mandatory reporting at clearly defined intervals:

• Quarterly reporting covers pecuniary performance, transaction volumes and e-money issuance dynamics. Firms must disclose all operational data in detail to assess the sustainability of their schemes.
• Annual reporting includes full disclosure of pecuniary results and audit reports for the reporting period. Confirmation of abidance with the base endorsed capital and equity norms is a mandatory element of the annual report.
• Reporting at the request of the overseer is submitted if there is a need to provide clarifications or supplemental data on current issues.

Also to regular reporting, firms with a registered EMI permit in Bulgaria are necessitated to immediately notify BNB of prominent alterations in the proprietorship framework or handling bodies. Threats to the firm's pecuniary stability must be reported, including lack of liquidity or failure to meet equity ratios. The overseer is also notified of technical incidents affecting the continuity of schemes (infrastructure failures, data leaks or cyber attacks). The incident report must be submitted within 24 hours of its discovery.

BNB sets reporting norms to assert openness and verifiability of data. They are provided in digital format through the overseer’s official platform. All data must be verified by endorsed persons of the firm and accompanied by documents proving compliance with statutory prerequisites, such as audit reports, results of infrastructure resilience tests or calculations of pecuniary indicators.s

Compliance with reporting deadlines is a critical prerequisite of the BNB. Delays in submitting data, equally incomplete or unreliable data, are considered a serious violation. Firms are required to keep copies of all reports submitted to the BNB for at least five years. The documents must be open for inspection by the overseer at any time.

Strict abidance with regular and irregular reporting prerequisites, handling openness and prompt interaction with the overseer are prime conditions for handling an EMI license in Bulgaria.

pecuniary reporting: framework and norms

Organisations with an issued EMI license in Bulgaria are necessitated to submit pecuniary statements in strict accordance with International Financial Reporting Standards (IFRS). The mandatory composition of pecuniary statements includes:

• Balance sheet: A complete statement of a firm's assets, liabilities and equity as of the reporting date.
• Income statement: The pecuniary results for a period, including revenues, expenditures, and resulting net profit or loss.
• Statement of cash flows: Cash flow data reflecting operating, investing, and financing schemes.

The reports are submitted annually and also, if mandatory, at the request of the overseer. All data in the reports must be confirmed by an audit opinion of an independent auditor who meets the prerequisites of the BNB. The audit is carried out annually, and the results are submitted to the BNB no later than 30 April of the following reporting year.

After getting an EMI license in Bulgaria, it is mandatory to abide with the minimum norms for endorsed capital and equity. BNB regularly checks abidance with the base capital threshold, which is set at 700,000 BGN (approximately 357,000 EUR). To this end, the pecuniary statements must contain detailed calculations of equity and details on all sources of capital formation.

Audit and control of pecuniary stability

The pecuniary statements of firms with a registered EMI license in Bulgaria are subject to external and internal audit annually.

The external audit is carried out by an independent audit firm, approved in the register of the Bulgarian National Bank. The results of the audit include confirmation of the reliability of the pecuniary statements, equal abidance with the prerequisites for own funds and liquidity.

The internal audit is conducted annually and is aimed at checking the internal control framework, the pecuniary stability of the firm and abidance with the BNB prerequisites. It covers the correctness of capital calculations, the execution of the provisions of the trade plan and the sustainability of the performing model. It is carried out by employees of the firm with a registered EMI license in Bulgaria.

Firms are prerequisite to confirm quarterly abidance with the level of their own monies, which is calculated as 2% of the average monthly volume of given E-cash. If deviations from the norms are detected, organisations must provide a corrective action plan within 14 days and restore the standard level of their own monies.

BNB regularly reviews the submitted pecuniary statements for incomplete data, hidden losses or violations of capital prerequisites. If deviations are detected, the overseer may necessitate immediate correction of the situation, supplemental audit or tightening of control over the firm's pecuniary schemes.

Obtaining an EMI license in Bulgaria: detailed instructions

The first step is to prepare the paperwork. The following documentation must be collected:

• The firm's charter with a detailed description of the oversight framework, areas of activity and performing rules.
• Certificate of registration of a licit entity from the Bulgarian Trade Register with up-to-date data.

Expat founders are subject to supplemental prerequisites when applying for an EMI license in Bulgaria. They must provide notarized translations of the constituent indentures into Bulgarian.

• Bank certificate of deposit of monies, given by an accredited Bulgarian bank no later than 30 days prior to the application.
• Indentures evidencing non-state capital contributions in accordance with Articles 72 and 73 of the Trade Law, including non-monetary contribution valuation reports, if applicable.
• Declarations and indentures asserting the origin of monies, such as excise returns, asset purchase agreements or statements from foreign bank accounts.

• Proprietorship scheme with full disclosure of ultimate beneficiaries and percentage distribution of stakes/interests.
• List of financiers and partners with their identification data (surname, first name, national identification number or its equivalent for foreign persons).
• Details on organisations or individuals holding a qualified stake (10% or more) in the firm's capital, indicating their role and prerogatives.

Any errors in this group of indentures will be perceived by the overseer as an attempt to deceive. Be extremely careful when applying for an EMI license in Bulgaria.

• A strategic plan detailing all planned schemes of the firm, including the issuance of E-cash and linked supports.
• Forecast of pecuniary performance and assessment of the firm's sustainability for the next 3 years, including prime metrics such as net profit and transaction volume.
• A diagram of cash flows and operational sequences, accompanied by liquidity calculations and stress scenarios.

• A detailed list of persons managing and representing the firm, including:
  • A resume with detailed information about qualifications, higher education (Master's degree or equivalent) and experience in the pecuniary sector (at least 5 years).
  • Certificates of no criminal record asserting the candidates' clean reputation.
  • Indentures asserting professional competence and pecuniary stability (e.g. transcripts of previous positions or recommendations).
• Details on members of the firm's handling and control bodies, including audit and supervisory bodies.

Proof of remuneration of the enrollment fee for submitting an application to the BNB for an EMI license in Bulgaria.

Abidance with the full list of prerequisites and correct arrangement of indentures consents us to guarantee abidance with the norms of the BNB and minimize the perils of delays in getting an EMI license in Bulgaria.

Where to get the application form for an EMI license in Bulgaria

The indenture is provided by the BNB. It can be downloaded from the overseer's website ( https://www.bnb.bg ) in the section dedicated to licensing payment institutions and issuers of E-cash. The form is open for filling in digital form and is provided in PDF format. Organisations are necessitated to use a qualified electronic signature to certify the final version of the indenture before sending it through the framework.

A physical copy of the application for an EMI license in Bulgaria can be obtained from the Central Office of the BNB at the following address: Blvd. Aleksandar Batenberg 1, 1000 Sofia, Bulgaria. Company representatives are necessitated to present indentures asserting their authority (e.g. power of attorney) to receive the official application package.

The application is completed in Bulgarian using the approved BNB template. For foreign organisations, indentures may necessitate a notarized translation. Incorrectly completed or incomplete applications are returned to the applicant for revision.

Submitting an application to the Bulgarian National Bank

To obtain an EMI license in Bulgaria, you must submit an application and a full package of documentation to the BNB. For online submission, you must register on the official website of the BNB ( https://www.bnb.bg ) and obtain a qualified electronic key (signature), which is used to certify each uploaded indenture.

The framework supports PDF and a number of other approved formats, while the files must be clear, structured and easy to read. After each indenture is uploaded, the platform automatically checks the completeness of the package and issues a notification about possible errors or missing materials. Completion of the sequence is confirmed by the enrollment of the application for an EMI permit in Bulgaria, and the applicant receives a unique incoming number to track the status of the review through the personal account on the BNB portal.

Paper indentures are submitted in person or through an endorsed representative. All materials must be printed on official company media with the mandatory indication of its name, identification number and contact details. Certification is carried out by the signature of endorsed persons, and for Expat founders, notarized confirmation of the authenticity of the originals and translated indentures is necessitated. The package is divided into volumes by category, accompanied by a description and a numbering framework to facilitate verification by the overseer.

Along with the submission of indentures, the applicant is necessitated to pay an enrollment fee for consideration of the application for an EMI permit in Bulgaria. In 2024, the amount is 3,000 BGN, which is equivalent to approximately 1,530 EUR. The remuneration is made by bank transfer to the BNB bank account with the obligatory indication of the firm's details and the purpose of the remuneration. Without confirmation of pecuniary commitments, the application will not be accepted for consideration.

When submitting online, the framework generates a remuneration order that contains all the mandatory details, including the bank account number and a unique application identifier. Remuneration is made in Bulgarian leva (BGN), and a copy of the transfer confirmation is added to the prime package of materials.

In case of paper submission, the account details are provided at the Central Administration of the Bulgarian National Bank. The firm representative must confirm his/her authority to receive the details.

After the bank transfer is completed, the firm is mandatory to attach a copy of the remuneration order with a note on the monies being credited. This prerequisite is mandatory to complete the application sequence for an EMI license in Bulgaria. The absence of a supporting indenture will result in the refusal to register the materials and a delay in the consideration of the application.

Details for remuneration of the state fee can be obtained through the official portal of the Bulgarian National Bank in the section dedicated to fees and duties, or directly at the central office of the overseer.

supplemental fees may arise during the review sequence, for example when the overseer requests clarifications or supplemental information. Timely remuneration of all fees minimizes the peril of delays and speeds up the sequence of getting an EMI license in Bulgaria.

At the initial stage, BNB employees check the submitted package for completeness and abidance with prerequisites. If any deficiencies are found, the firm receives an official notification describing the violations and the deadlines for their correction. After successfully passing the initial check, the application is assigned a curator from among the overseer's employees. He or she coordinates further interaction, sends requests for supplemental clarifications and oversees the deadlines for their execution. Responses to requests must be provided no later than 10 working days.

The prime communication channels are emails and indenture exchange to the firm's licit address. If mandatory, the overseer may request a personal meeting with the applicant's representatives to discuss complex issues or supplemental prerequisites.

Stages and order of consideration of an application for obtaining an EMI license in Bulgaria

The sequence is strictly regulated. At the beginning, a primary analysis is carried out. BNB employees check the completeness and correctness of all submitted indentures. The absence of mandatory materials or errors in the design lead to the suspension of the application review and sending a notification to the applicant to correct the deficiencies within the specified period. The completeness of the package of indentures is critical for further progression of the sequence.

If there are no errors, a qualification check of the firm's key persons, including overseers, financiers and ultimate beneficiaries, begins. Professional experience, lack of criminal record, reputational perils and abidance with the BNB prerequisites for qualification and clarity of the proprietorship structure are taken into account. The overseer requests supplemental information if discrepancies or questionable data are found in the firm's proprietorship chain. To obtain an EMI permit in Bulgaria, you need utmost honesty, accuracy and speed of response.

If the employees and oversight have passed the check, the trade plan is analyzed for the realism of pecuniary forecasts, the sustainability of the performing strategy and abidance with the declared types of schemes. Particular attention is paid to:

• Pecuniary indicators, including base capital and performing expense forecast;
• Sequences of issuing E-cash and managing deals;
• Threat oversight policies and abidance with AML/KYC sequences.

The firm must confirm its ability to meet all the prerequisites of the overseer and assert pecuniary stability over the next three years. In parallel, a technical audit of the IT frameworks is carried out to assess the fault tolerance of the infrastructure, its ability to recover from failures and the level of cybersecurity. The overseer checks the availability of reserve capacity and the effectiveness of transaction overseeing frameworks, including real-time anomaly detection. The results of stress tests and audits must strictly abide by the prerequisites of the BNB for earning the permit in the polity.

The final stage is a physical inspection of the office and performing environment. This includes a visit by the overseer to confirm the physical location of the firm and its readiness for operational schemes. The office equipment, the presence of competent personnel in prime positions and the performing of internal controls mandatory for regular inspections and audits are assessed.

The overseer has the prerogative to request supplemental indentures, eliminate identified deficiencies and adjust operational sequences. Only full abidance with the established prerequisites guarantees successful receipt of an EMI license in Bulgaria.

Decision on the application and issuance of a permit

If the overseer identifies any deficiencies or inconsistencies during the application review sequence, the firm receives an official notification with a detailed list of comments. Common issues include:

• Incompleteness or incorrectness of the indentures provided;
• Technical unpreparedness of the IT infrastructure;
• Incorrect calculations of pecuniary forecasts and threat oversight models.

Up to 30 working days are allocated for eliminating the identified deficiencies, with the prospect of extending the period by decision of the BNB. Companies are necessitated not only to make adjustments, but also to submit supplemental supporting indentures, audit reports or results of repeated technical tests. The corrected data package is considered on a priority basis to minimize delays in issuing a permit.

Failure to respond to comments within the specified time limit or repeated non-abidances result in the rejection of the application for an EMI license in Bulgaria. The overseer's decision includes a clear justification for the refusal, indicating specific violations and non-abidances with the BNB prerequisites.

An EMI license in Bulgaria may be refused if the firm or its beneficiaries are provided with false information, incomplete information on the proprietorship structure, failure to confirm the base capital of BGN 700,000 and failure to meet the equity prerequisites. The reason may also be insufficient qualifications of the oversight or unsatisfactory results of the IT frameworks and BCP testing.

Companies have the prerogative to appeal the overseer's decision to the Bulgarian Administrative Court. The appeal must be filed within 14 calendar days from the date of receipt of the refusal. The applicant must submit new indentures or evidence asserting the elimination of deficiencies or refuting the overseer's findings. If the appeal is upheld, the court obliges the BNB to re-examine the application.

However, the appeal sequence necessitates prominent pecuniary bills and can take up to several months, so companies are advised to follow all BNB prerequisites as carefully as possible when submitting an application.

The issuance of an EMI license in Bulgaria is confirmed by an official order from the overseer indicating the effective date of the permit. Getting permission consents the firm to begin performing within the approved conditions and restrictions.

Once the application has been approved and the EMI license in Bulgaria has been received, the firm must complete the final formalities. The first step is to register in the register of licensed E-cash issuers of the BNB. The register contains the firm’s name, licit address, permit enrollment number and types of schemes. This information becomes publicly open.

The firm is also necessitated to prepare initial reporting asserting its readiness for operational schemes. The report contains information on the formed endorsed capital, the results of final testing of IT frameworks and the implementation of threat oversight measures. Special attention is paid to the readiness of the internal infrastructure and abidance with AML/KYC policies.

Once a Bulgarian EMI receives a license, statutory commitments for supervision and reporting come into force. The BNB begins overseeing the firm's schemes. Controls cover pecuniary stability, abidance with equity prerequisites, and regular updates of performing indicators. Companies must submit quarterly and annual reports, and promptly inform the bank about alterations in oversight, alterations in the trade plan, or technical failures.

Enrollment in the register, submission of initial reporting and abidance with all statutory prerequisites complete the licensing sequence. The firm receives the prerogative to issue E-cash and provide linked support on an official basis.

Penalties for violating the regulator's rules

Penalties for breach of EMI licensing conditions are regulated by Bulgarian statutes and EU directives, including Law No. 16 on Payment Services and Systems and Law No. 85 on Prevention of Money Laundering. The BNB supervises abidance with these prerequisites and applies sanctions contingent on the severity of the violation. The variability of sanctions takes into account the individual circumstances of each firm in order to minimize threats to the pecuniary framework and the interests of clients.

Penalties vary in severity (the more serious the violation, the harsher the penalty). Warnings are given for minor violations that do not pose a prominent threat to the pecuniary framework or clients. For example, this could be a delay in filing reports, errors in filling out indentures, providing incomplete information in reports, or failure to notify about minor alterations in the firm's structure.

Such measures are used in cases where the violation occurred for the first time, did not lead to negative consequences and was promptly eliminated after a remark from the supervisor. Almost all enterprises with a given EMI license in Bulgaria face them. BNB considers a warning as a way to give the firm an opportunity to correct shortcomings without imposing pecuniary sanctions, handling its pecuniary stability.

pecuniary penalties for EMI licensing violations in Bulgaria contingent on the nature, severity and frequency of the incident. Base amounts start from 10,000 BGN (around 5,100 EUR) and apply for technical deficiencies such as late reporting or incomplete customer data. Although such cases do not pose prominent threats to the pecuniary framework, they necessitate prompt remediation to handle statutory abidance.

Fines of up to BGN 500,000 (approx. EUR 255,000) are imposed for violations that could affect the pecuniary stability of the firm. These include failure to abide with base stake capital or equity prerequisites. Systemic deficiencies, such as regular errors in customer verification, primely boost the threat of such fines being imposed, as they indicate deep problems in the firm's schemes.

Maximum fines of up to BGN 1,000,000 (approximately EUR 510,000) are applied for serious violations that threaten the interests of clients or the pecuniary framework. Including the lack of enhanced control over deals with high-threat clients and jurisdictions, failure to abide with mandatory AML/KYC sequences. Organizations with a turnover of over BGN 50 million can be fined an amount equal to several times their annual income. Such measures are aimed at hindering serious pecuniary threats and asserting abidance with transnational norms, imperatively in cases of systematic non-abidance with prime prerequisites. We recommend overseeing the rules and norms, as they may have changed since the EMI license was obtained in Bulgaria.

Temporary restrictions on schemes are imposed when identified violations pose a threat to the stability of the firm's schemes, the protection of the interests of clients or the fulfillment of commitments to the supervisor. These measures are applied in the event of prominent deviations in such critical areas as the threat oversight framework, the sustainability of the IT infrastructure or abidance with established supervisory standards.

Temporary restrictions are often imposed due to non-abidance of the IT infrastructure with established prerequisites. Including insufficient protection against cyber attacks, failures in transaction monitoring models, or lack of readiness to restore data in the event of technical problems. Such shortcomings weaken customer confidence and boost the threat of fraudulent deals. In such cases, the BNB suspends the issuance of E-cash or restricts certain remuneration deals until the violations identified are fully eliminated.

Restrictions are used when threat oversight models are violated. If a firm has not executed or does not support AML/KYC standards, if transaction control mechanisms do not abide with the prerequisites established by statute, etc. This is imperatively critical for organizations working with high-threat jurisdictions or prominent transaction volumes. In such circumstances, the supervisor may temporarily prohibit the opening of new client accounts or limit the provision of certain remuneration supports.

The duration of temporary restrictions depends on the intricate and nature of the identified deficiencies. Usually, such measures last for several weeks, but in exceptional situations they can be extended. In order to restore its schemes, a firm with a given EMI license in Bulgaria must provide evidence that all non-abidances have been eliminated. This includes updated documentation, external audit results and reports on the improvements made. The BNB conducts an supplemental check to confirm abidance with the prerequisites and only then lifts the restrictions.

Such sanctions create prominent pressure on endeavors. Suspension of prime sequences (issuing E-cash, conducting deals) may lead to loss of customers, reduced income and deterioration of reputation. We recommend consistently following the rules from the first day after receiving an EMI license in Bulgaria.

Revocation of a permit is an extreme measure of the BNB. The sequence is strictly regulated by statute and is applied only in the case of serious or systematic violations by the licensed firm. Common reasons:

• Submission of incorrect or knowingly false information at the stage of earning an EMI license in Bulgaria , comprising concealment of the actual ultimate beneficiaries, insufficient endorsed capital established by statute, necessitated for the scheme of the EMI.
• Systematic violation of AML and CTF sequences or insufficient KYC verification of clients.
• Regular unpreparedness for audits by the BNB, equally numerous technical or oversight failures that affect the stability of the model and the security of client monies.

The sequence for revoking a permit consists of several stages. First, the supervisor sends an official notice, indicating the violations identified and setting deadlines for their elimination. The firm is given the opportunity to eliminate the identified deficiencies and provide written explanations for each point. If the explanations are unsatisfactory or the violations critically undermine the security of the model, the BNB begins the sequence for revoking the permit. After analyzing all the circumstances, a final decision is made, which is officially published and communicated to the interested parties.

Without a valid EMI license, the issuance of E-cash and the provision of remuneration supports are prohibited in the polity. After the permit is revoked, the firm is obliged to transfer the assets of clients to other licensed organizations approved by the supervisor, settle its obligations to the BNB and creditors. This leads to serious reputational and pecuniary losses, and in the event of criminal violations, it may entail supplemental legal consequences.

Firms have the prerogative to challenge the BNB decision in the administrative court. The appeal must be filed within 14 calendar days from the date of receipt of the official notification of sanctions. The complaint specifies the grounds for cancellation of the decision and presents evidence asserting the illegality of the supervisor's actions or the elimination of the problems. For example, if the violation was due to a temporary technical failure or force majeure that could not be prevented, the given EMI license in Bulgaria can be returned. The firm can also try to prove that the violations were eliminated within a reasonable time and did not affect customers or the stability of the model.

The trial sequence involves consideration of all evidence and arguments of the parties. During the sequence, the court may request supplemental indentures, reports or explanations from the firm, equally hold hearings with the participation of representatives of the BNB. The trial lasts from several months to a year, contingent on the intricate details of the case and the volume of materials presented.

• Restore the decree on issuing an EMI license in Bulgaria;
• Reconsider your decision, limiting yourself to less severe sanctions (for example, imposing a fine instead of revocation of the permit);
• Provide the firm with supplemental time to correct the violations.

The BNB is obliged to execute the court decision within the established timeframe and notify the firm of the change in the status of its license. For the firm, this means the restoration of prerogatives to provide support and, in the event of loss of reputation, the prospect of rehabilitation in the market.

The sequence of appealing the decision necessitates prominent time and pecuniary resources. Comprising the bill of licit support and expenditures linked with long-term downtime. It is often easier to re-obtain an EMI license in Bulgaria. And the best option is to abide with the rules (or at least promptly respond to the supervisor's comments).

In case of a negative court decision, the firm loses the prospect of further appeal and is obliged to permanently cease its schemes as a licensed EMI in Bulgaria.

Conclusion

Acquiring an EMI license in Bulgaria necessitates strict abidance with the statute and careful arrangement of a trade plan that takes into account capital prerequisites, threat control and IT infrastructure. Once licensed, firms gain admittance to the European remuneration supports market and transnational models such as Visa, Mastercard, SEPA.

Violation of the established rules may result in pecuniary penalties, temporary suspension of schemes or revocation of the permit, which seriously undermines the trade reputation and stability of the trade. Challenging the supervisor's choices in court is possible, but it is linked with supplemental bills and can take a long time. To reduce the likelihood of such situations, organizations should assert clarity of the proprietorship framework, automate control over abidance with AML/KYC sequences and handle the necessitated level of capital provided for by the directives.

Competent execution of statutory prerequisites, constant monitoring of internal sequences and prompt elimination of identified deficiencies consent not only to avoid fines, but also to handle the received EMI license in Bulgaria.