Self-custodial wallet / non-custodial software in Bulgaria
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Bulgaria without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations attach to the publisher of self-custodial wallet software, as the publisher never holds, controls, or has access to user funds and therefore does not fall within the definition of a VASP under the Measures Against Money Laundering Act (MAMLA).
- The four VASP activities listed in bg.aml (exchange between virtual assets and fiat, exchange between virtual assets, transfer of virtual assets, safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets) all require custody or control — none apply to a non-custodial software publisher.
- No CDD, ongoing monitoring, STR, or record-keeping obligations arise because the operator is not an obliged entity under MAMLA.
Key Restrictions
- The software must be genuinely non-custodial — the publisher must never hold, control, or have access to users' private keys or funds.
- The publisher must not offer any ancillary services that would trigger VASP classification (e.g., integrated fiat on-ramp where the publisher acts as counterparty, swap API where the publisher executes trades, or any form of custody or transfer facilitation).
- Consumer protection and disclosure rules applicable to software publishers (e.g., Bulgarian Consumer Protection Act, EU Digital Services Act) apply generally but do not impose VASP-specific requirements.
Key Risks
- Regulatory re-interpretation risk: Bulgarian authorities (SANS/NRA) could take a broader view that publishing wallet software constitutes 'provision of services enabling control over virtual assets' under bg.aml.safekeeping-andor-administration-of-virtual, though the text refers to safekeeping/administration, not mere software publishing.
- No enforcement precedent exists in Bulgaria specifically addressing non-custodial wallet publishers, creating interpretive uncertainty.
- If the wallet integrates any value-added service (e.g., in-wallet swaps, staking, fiat conversion), the operator may cross into VASP territory and be subject to registration with the NRA and AML supervision by SANS.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Measures Against Money Laundering Act (MAMLA) (Закон за мерките срещу изпирането на пари - ЗМИП).
This act defines "virtual assets" and "virtual asset service providers" and brings them within the scope of obliged entities. It outlines the specific requirements for customer due diligence, reporting, and record-keeping.
Exchange between virtual assets and fiat currencies.
Exchange between one or more forms of virtual assets.
Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.
Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset are subject to AML/CFT regulation and are treated as financial activities for regulated virtual asset and stablecoin issuers.
In Bulgaria, AML/CFT supervision of VASPs is shared among multiple authorities, with the National Revenue Agency (NRA) as the leading registration and enforcement body, the Financial Supervision Commission (FSC) overseeing crypto-asset service providers within its regulatory perimeter, and DANS-FID retaining a role but no longer the sole or primary supervisor.
National Revenue Agency (NRA) (Национална агенция за приходите - НАП)
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a publisher of genuinely non-custodial wallet software does not meet the definition of a VASP under Bulgarian AML law (since it never holds or controls private keys or funds), so no VASP registration or AML obligations attach, but this conclusion depends on the software being strictly non-custodial with no ancillary services that would trigger VASP classification.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?