MiCA (Markets in Crypto-Assets Regulation)
By xChange.bg team
Published
MiCA replaced a patchwork of national crypto registration regimes with one EU regulation. It applies directly in every member state, so a Bulgarian user and a French user are protected by the same core rules. This page explains the regulation in general terms and is not legal advice.
What MiCA covers
MiCA applies to anyone who issues, offers to the public or seeks admission to trading of crypto-assets in the EU, and to anyone who provides crypto-asset services. It has three main building blocks:
- Crypto-assets in general (Title II). Offerors must publish a white paper with fixed content and are liable for it.
- Stablecoins (Titles III and IV). E-money tokens reference one official currency. Asset-referenced tokens reference other values or a mix. Both need an authorised issuer, reserves and a redemption right. Issuers may not pay interest on e-money tokens.
- Service providers (Title V). Exchanges, brokers, custodians and transfer services must be authorised as crypto-asset service providers. They have to segregate client assets, publish prices and execution policies, handle complaints, and are liable for losses of client crypto-assets caused by incidents attributable to them.
Title VI adds market abuse rules. The regulation does not cover crypto-assets that are financial instruments or deposits, or unique non-fungible tokens (Article 2).
Timeline
- 30 June 2024: rules for asset-referenced and e-money tokens apply.
- 30 December 2024: the rest of MiCA applies, including the licence requirement for service providers.
- 1 July 2026: the longest possible transition period for providers already operating under national law ends (Article 143(3)).
MiCA in Bulgaria
Bulgaria adopted its Markets in Crypto-Assets Act (ЗПКА) on 20 June 2025. It was published in State Gazette issue 54 of 4 July 2025 and took effect on 8 July 2025. The Financial Supervision Commission (КФН) became the competent authority for providers, and the Bulgarian National Bank for e-money token issuers based in Bulgaria. The register of virtual currency providers that the National Revenue Agency used to keep passed to the КФН.
Bulgaria used the full transition. Firms registered with the NRA before 30 December 2024 could keep operating until 1 July 2026 or until their licence was granted or refused. On 30 June 2026 the КФН announced that from 1 July only licensed companies may offer crypto-asset services, and that firms without a licence must follow their exit plans and help clients move their assets.
Example
Say you kept 2,000 USDC on a small Bulgarian platform that was in the old NRA register but did not obtain a licence. From 1 July 2026 that platform may no longer offer crypto-asset services. You can move the 2,000 USDC to a provider listed in ESMA's register or to a self-custody wallet, paying the network fee and any withdrawal fee the platform charges.
Common confusion
- MiCA does not ban specific tokens by name. It sets conditions that tokens and providers have to meet.
- A licence is not a guarantee against losses. Crypto-assets can still fall in value, and e-money tokens are not bank deposits.
- MiCA is not a tax law. Tax reporting by providers comes from DAC8.
Frequently asked questions
When did MiCA start to apply?
- Titles III and IV, covering asset-referenced tokens and e-money tokens, have applied since 30 June 2024. All other parts, including authorisation of crypto-asset service providers, have applied since 30 December 2024, under Article 149 of the regulation.
Who enforces MiCA in Bulgaria?
- The Financial Supervision Commission (КФН) is the competent authority under the Markets in Crypto-Assets Act, in force since 8 July 2025. The Bulgarian National Bank supervises e-money token issuers based in Bulgaria.
Can a provider licensed in another EU country serve Bulgarian clients?
- Yes. A crypto-asset service provider authorised in one member state can serve clients across the EU after its home supervisor notifies the host countries under Article 65. It does not need an office in Bulgaria.
Does MiCA cover self-custody wallets?
- MiCA regulates custody as a service, where a provider controls clients' crypto-assets or their private keys. A wallet where only you hold the keys is not a custody service provided to you, although the provider that sends funds to it or receives funds from it remains regulated.
Does MiCA regulate NFTs and tokenised shares?
- Mostly no. Article 2 excludes crypto-assets that are unique and not fungible, and crypto-assets that qualify as financial instruments or deposits, which remain under other EU financial laws.
What happened to Bulgarian firms in the old NRA register?
- Firms registered with the NRA before 30 December 2024 could keep operating until 1 July 2026 or until a licence decision. From that date only licensed or passported providers may offer crypto-asset services in Bulgaria.