# MiCA in Bulgaria: Lessons from the First Licensed CASPs | Future Finance Forum 2026 - Channel: [ETHSofia](https://streameth.org/ethsofia) - Date: 2026-10-06 - Duration: 34:27 - Topics: Alaric Securities, Blockchain Week Bulgaria, Bulgaria, CASP, DLT Pilot Regime, Damyan Leshev, Dimitar Stoyanov, ESMA, European Ethereum Institute, Eversheds Sutherland, F3 2026, Financial Supervision Commission, Future Finance Forum, Ivan Takev, MiCA, Vyara Savova, crypto regulation, e-money tokens, Science & Technology - Watch: https://streameth.org/watch/yt-DpKOezq1AVw - YouTube: https://www.youtube.com/watch?v=DpKOezq1AVw ## Description With Damyan Leshev (Eversheds Sutherland, moderator), Ivan Takev (Alaric Securities), Vyara Savova (European Ethereum Institute) and Dimitar Stoyanov (Financial Supervision Commission). With Bulgaria's MiCA transitional period over and five crypto-asset service providers now licensed by the Financial Supervision Commission, this panel looks at what the first licences actually took. Ivan Takev explains how Alaric Securities fitted crypto into an existing investment firm, and Dimitar Stoyanov names the two most common weaknesses in applications: flawed policies and key staff who do not meet the requirements. Vyara Savova argues the MiCA review should fix the white paper notification period and make the DLT Pilot Regime permanent. The panel also covers tokenised stocks under MiCA or MiFID, the dual licensing of e-money tokens, ESMA supervision of significant CASPs, and whether Bulgaria is crypto-friendly. Panel at Future Finance Forum 2026, 25 September 2026, Sofia. Part of Blockchain Week Bulgaria 2026. Speakers ▸ Damyan Leshev, Partner and Co-Head of Financial Services (Bulgaria), Eversheds Sutherland (moderator) Damyan Leshev is a partner at Eversheds Sutherland Bulgaria, heading the crypto practice. With 20+ years in banking & capital markets law, he is one of Bulgaria's first crypto lawyers. He bridges traditional finance with digital assets regulation. Recognised by Chambers Europe, IFLR 1000 & Legal 500. LinkedIn: https://www.linkedin.com/in/damyan-leshev ▸ Ivan Takev, Head of Capital Markets and Investments, Alaric Securities Ivan Takev is Head of Capital Markets & Investments at Alaric Securities, where he also leads the crypto division. A former CEO of the Bulgarian Stock Exchange, he brings 25+ years of expertise in institutional finance, regulation, market infrastructure, and trading, bridging traditional and digital assets. LinkedIn: https://www.linkedin.com/in/ivantakev ▸ Vyara Savova, Senior Policy Lead, European Ethereum Institute Vyara is a web3 & human rights lawyer based in Sofia, Bulgaria. Senior Policy Expert at the European Ethereum Institute, shaping EU regulation for open, permissionless, decentralised blockchain applications. PhD candidate researching legal automation through smart contracts. LinkedIn: https://www.linkedin.com/in/vyarasavova ▸ Dimitar Stoyanov, Chief Expert, Regulatory Regimes of Investment Activity, Financial Supervision Commission Dimitar’s interest in financial markets dates back to his tenure as a Member of the European Parliament (2007–2014). Dimitar returned to the FSC’s authorisations team in December 2025, where the entry into application of MiCAR presented a unique opportunity to contribute directly to the authorisation of the first crypto- asset service providers (CASPs). Chapters 00:00 Bulgaria's first MiCA licences and the MiCA review 01:31 Adding crypto to an existing investment firm 04:16 Challenges on the way to the first licence 05:30 The regulator's view: why applications fall short 09:18 What the MiCA review must fix: white paper notification 12:56 Tokenised stocks: MiCA or MiFID? 16:21 The DLT Pilot Regime and the market integration package 20:11 E-money tokens: a MiCA gray area 22:37 Do EMT services also need a payment licence? 24:27 ESMA supervision of significant CASPs 29:17 Is Bulgaria a crypto-friendly jurisdiction? 33:21 Closing 34:14 Closing titles Blockchain Week Bulgaria: https://www.blockchainweek.bg ETHSofia: https://www.ethsofia.com Future Finance Forum: https://www.blockchainweek.bg/f3 Follow Blockchain Week Bulgaria X: https://x.com/BWBulgaria LinkedIn: https://www.linkedin.com/company/blockchain-week-bulgaria Follow ETHSofia X: https://x.com/EthSofiaBG LinkedIn: https://www.linkedin.com/company/ethsofia Telegram: https://t.me/+b-33LJUpAB5iODNk Nothing in this video is financial advice. About the organiser Blockchain Week Bulgaria, ETHSofia and the Future Finance Forum are organised by the Bithope Foundation, founded in 2014 by Vladislav Dramaliev. Inspired by Andreas Antonopoulos, it is Europe's first non-profit operating exclusively with bitcoin donations. Over more than ten years, it has supported 50+ charitable campaigns, and in January 2016 it co-founded the Sofia Crypto Meetup, now the region's longest-running monthly crypto event. https://bithope.org ## Transcript Um first of all what I would say is that a year ago Bulgaria doesn't have any didn't have any um YC regime only a vast registration regime for crypto firms but uh then uh it came bigger And following the end of the transitional period on 1st of July, now we we are proud to say that we have already five crypto accessories providers licensed by the financial supervision commission. But um the rule book under uh which they were licensed is already being rewritten and now the European Commission is uh focusing on Mika review which uh the consultation uh will end uh next week. So the European Union is uh trying to discuss and negotiate how to uh regulate cryptoformms in the future. So in the next 30 minutes what I would like to see is and uh what would like to hear is both of the story meaning um what actually demanded the licensing process so far and uh what we can expect in the near future in terms of the European legislation. So in that in with that in mind my first question would be to Ivan which is u uh the head of crypto practice and uh crypto uh industry in war securities which is the first licensed um crypto assets investment forum both in Bulgaria. Um so Ivan uh you have been the first of the first taking this uh route and as a licensed investment firm. Um my question would be um what part of your existing setup um helped in your big application and uh what you needed to build from the scratch. Um yes uh well as you pointed out we are an investment firm with a history uh dating back to uh 2011. Uh so um yeah we already have an established trading business. What we had to do however in this particular case was to incorporate crypto into our traditional trading uh business. So it fits [snorts] uh well and serves its purpose. And uh I have to use that hateful word synergies, but we saw a lot of synergies for our traditional uh business uh uh w with crypto. So um it will allow us to uh reach customers that are far in countries uh geographically far from Bulgaria with capital restrictions. So crypto would eliminate the borders and um um facilitate our main trading uh business and um yeah what we had to build from uh scratch. Well um um we had to incorporate crypto into into our systems. This is a new asset class for us and we had to incorporate it in a way uh that it creates no friction with with the traditional asset classes that we offer to to our customers. Uh from technical standpoint this is a series of integrations with executing venues um uh clearing brokers, custodians uh whatever but this is more or less our bread and butter. uh we've done that uh before and we completed that that kind of uh setup. uh from licensing perspective uh yeah we we already had all all the rules in place but we had to adapt them so that uh crypto fits into uh them and u in terms of uh operational resilience uh IT security um business continuity everything should have been aligned uh so crypto fits into its place >> okay so you take this route first. So what was the major hurdles in your journey towards uh having this crypto license or uh a successful notification? >> I wouldn't call them hurdles. Um these were more like challenges uh you know for both us and the regulator because we were both paving the way ahead. >> Yeah. Um yeah um the challenge was from licensing standpoint was meeting all the requirements within very strict uh time frames because some of some of the deadlines that are part of Mika um cannot really be changed and the regulator had a lot of questions raised many issues with us. We had to respond on on a very timely manner from business perspective. Again, um incorporating crypto in a way that it creates no friction with our business and our IT systems support crypto natively rather than offering it as a as something like standalone product that has uh nothing in common with the existing uh business. And from IT perspective, these are the integrations. They were challenging but we completed them. >> Okay. My next question would be to de meter. The financial provision commission has publicly refused to examine a number of incomplete uh applications on on the grounds of the merits. So um what is the most uh common reason a file never reaches the in that review phase meaning the substantive uh assessment and from from the regulators perspective uh what are the major mistakes ma applicants uh usually make in their applications. >> Yeah. All right. Hello everyone and I hope that you feel welcome in the beautiful city of Sophia. those of you who come from abroad. So the main challenge that uh the financial supervision commission uh faced in the assessment of the applications that we have received is uh it can be generalized as a lack of the necessary mentality. uh the lack of the idea that uh from now on this uh the players in the in the crypto asset services they will have to operate in the reg regulated environment. So there are requirements that has to be met and uh some of the applicants not all but uh quite a number of the applicants actually had a very uh how to say not very serious approach to the to the whole process and so we observe uh problems in uh mainly two directions. One is uh the setup of the internal policies and procedures. Many of the legacy vasps that uh came to apply uh they try to create some policies and procedures but uh we find them very flow in many of the cases and uh the other direction that we find uh it is challenging for the sector is uh the creation of the necessary staff and the team. So the the occupation of the managerial position by by persons that meet the requirements the key function holders there have to be some several key functions like the compliance officer chief compliance officer the the chief IML officer which can be combined in this case but anyway this is uh those staff requirements and there are also formal requirements that has to be met and uh that we observe that is creating difficulties for the applicants to meet these requirements. The important thing that I would like to send as a message is that uh we would like to see fine procedures and and welldeveloped procedures not just something that was spilled out of the AI with a bad prompt because we also we can say that there were such cases but uh procedures and policies we can fix during the authorization procedure. So we would we want to be helpful for the industry. We uh give the necessary instructions and uh the procedures and policies can be fixed but uh the staff uh this is more difficult because if the person is not uh meeting the requirements then the only fix is to replace that person and we have observed several replacements during the uh authorization procedures and that is delaying the procedure because any replacement will restart uh the assessment process. Thank you very much and um well I would agree with this uh big applicant should be serious enough in order to obtain a license. I'm talking uh from from consultant perspective of course but totally agree with with the meter. So a question to Van Commission is consulting on the ma review until 30th of September this year. um after the first uh licensing wave, what is the one thing the MC review really has to fix and what should set aside? >> Yes, thank you for this question and uh thank you also for having me here. I'm in a really interesting position including uh quite literally on the stage between a regulated CASP and a supervisor and also [snorts] someone who is working day-to-day on um on on the on the licensing frameworks like in the licensing paperworks um I come from the perspective of more the infrastructure so representing the Ethereum ecosystem. Um so for us it's also very important to have this uh point of view of how it would all work in total. So when we are right now for example um also responding to the Mika consultation uh which by the way I um really suggest you all do because how the European Commission collects this responses is literally by their amount. So when you fill up the form they will at the end of the day just check who is who has responded in what what way and that would be calculated then in the in the final um uh overview of all the responses. So it literally all your uh opinions matter in this case. So please do uh do take the time to take to check the consultation and respond. Um but for us what is important is to uh have this holistic uh point of view of how all the parts operate. So on the one hand it's the CASPs on the other it's how the regulatory and the supervisory perimeter operates and we are also paying attention to the broader ambitions of the European Commission the European Union in general which is something um which is there are some shifts in that as well and the current um approach is to consider Europe uh as the competitive power that it has the possibility to become in the in the broader term especially compared to other jurisdictions. So with that in mind um because we have I have a long list of um answers to choose from because we are making quite a few suggestions but I would say an important aspect would be uh the notification uh period that we currently have for white papers. >> Okay. um because it's currently 20 days and uh from a practical point of view it really um is not helpful when it comes to the compliance and to the to the overall uh competitiveness angle of Europe because in many cases we we don't have any such delays in the listing of of uh crypto assets. So in Europe we have this delay of 30 days more or less like a whole month in total where um we really lose a lot of liquidity including like from coming from um European um uh users. So that's something to think about especially as it's a notification. It's not really something that the uh competent authorities have any direct say from from day one. So this evaluation could also be happening while there is already a listing. So just an idea something to definitely uh think about because we have been hearing um that it's an issue coming from the industry as well. So yeah that would be my direct take. >> Okay thank you. Um probably the artist should be scratched out from the mika but this is my personal opinion. Um so um question to Ivan um Abarak expects large scaleization of traditional assets which actually brought your uh interests in uh in crypto and uh we all know that um a large portion of uh tokenized stocks is already sold to to European um retail investors. Um so from a financial perspective are those crypto assets to be regulated under Mika or financial instruments to be regulated under MIFIT? Um I I think that um the the the form should take precedence over the uh sorry the the essence should take precedence over the form meaning that if something is a tokenized security it should be treated exactly as a security. Uh but there is a great butt. It means that uh I mean that uh all of the all of the um entitlements that come with a specific uh financial instrument should be applicable to the tokenized instrument as well. This is currently not a fact unfortunately. You know that uh Robin Hood for example is offering trading in tokenized securities in in the EU. >> Um but you you cannot vote with your token at the general meeting of the shareholders. Uh so more or less your rights are pretty limited. The the uh the full scale tokenization that I expect to come to the market uh will be brought in by the heavyweights in the industry. Uh for example, NASDAQ plans to uh launch tokenized trading in Q2 of 2027 and that will dramatically change the face of uh of the industry. Uh so the the tokens as described by by NASDAQ will bear the full shareholder rights. uh for example and they will benefit from the liquidity of the primary NASDAQ um markets. So the tokenized instruments will be traded um as regular shares only the clearing and the settlement performed by DTCC uh may take either traditional electronic form or or crypto form. Uh so this will be the the real revolution in in tokenization. M um so yes in a nutshell I think that if something resembles an instrument it should be financial instrument it should be treated like one even though uh there is a specific uh provision in Mika saying that uh financial instruments even though they might be issued in in a tokenized form should be regulated by method too but we are quite far from that uh moment I don't think there is a any country in the world that can uh allow uh issuing financial instruments directly natively into a tokenized uh form. Okay, >> you clearly cannot do that in Bulgaria. Uh but the tokenization yes again uh the substance should take uh prevalence um of the form. >> Thank you very much. Um yeah, I would agree with this this one. This is uh kind of the interplay between [snorts] between Miffit and and Mika and also in financial perspective as well. Um question to uh Viara. Um the European Commission's so-called MP initiative um also reworks the DOT pilot regime uh in parallel with the big uh review. Um so what is Europe currently building and uh how? >> Yes. So um it's again going back to my whole position as uh an observer of the system in a more holistic way. Um while we are focusing quite quite a bit on Mika which is definitely a point of like where we should be focusing on. Uh there are other moving elements currently on the European Commission level that would also affect the market broadly speaking. So this is the miss proposal. Uh within it we we have this proposal of um uh improving the DOT pilot regime which is as of as you can tell by its name it's currently a pirate regime. It has a deadline um after which basically it's there there is this discussion that needs to take place whether or not to extend it or to turn it into a permanent regime. So that's currently what's happening and from our point of view it's actually something that would be quite useful for the for for the industry broadly speaking in Europe um for for this to turn into a a permanent um system that would allow for the tokenization that is now a very hot topic uh to to occur in in in in much more certain terms. So uh in our response we were discussing also the uh the the maximum caps that are currently there that should be removed or at least um um increased um and also the in including many more assets in the scope of what is going to be possible as part of the DOP pilot regime. And very quickly I I just want to comment also on kind of add the plus one to the um uh to the discussion of keeping the financial instruments as part of the currently existing uh framework. So even going a bit forward as to perhaps adding a definition that would go into Miffier. though it's not uh so member state specific because currently us as lawyers we know very well that there there is this discussion going for decades about the lack of a common definition of what a financial instrument is in the European Union which will affect then all the discussions that we're having on putting them on DOT because we will then bring all the uncertainty but the extra complexity of of also having this DT um uh infrastructure so I would go also towards this uh substance over form uh and go a step further into kind of trying to also unify what we understand as like this digital DOT based instrument going into Miffier so we don't reproduce the issues that we currently have with the current financial instrument uh structure. So I will intercede here and I will share my view that uh actually there is uh no turning break from the DT pilot regulation because we already have uh uh throughout Europe uh several uh license authorized market infrastructure under the DOT pilot. So I don't think that there is turning back >> and uh actually tokenization of securities and financial instruments it's the the next big thing. It's it it's continue to be discussed widely. There is a lot of interest that we see >> both on the European and on national level. So I don't think that anybody would want to scrap this. It [snorts] will be developed for sure. The tricky question is to see how exactly it will be developed. >> Yeah. Um okay. Thank you very much uh for this insight and um the next question would be probably um about the again ma licensing procedure from from our perspective as a consultants uh what we usually see when we advise our clients uh taking this route uh having uh MA casp uh license is that major challenges under the the ma licensing processes it's actually are actually in the dual nature of the e money tokens probably also in the outsourcing regime. So Ivan, my question to you is uh would you concur in your view about this and in your general um expertise so far in Mika? Um about the the e-money tokens um yes uh we we definitely um see a lot of potential in that as I said previously we have an electronic money institution as a part of the the corporate uh structure and the um the stable cons allow us to reach to customers who are geographically very far from us uh markets that are no that were no longer that were not present uh until that uh moment And of course we uh we we need to overcome that kind of limitation that stems from uh the no paper of the European Banking Authority. Um and um yeah, our long-term plans actually um include uh obtaining uh MA authorization uh for the uh electronic money institution so we get can operate um in uh uh with with stable cons as well. Um yeah, this is one of the gray areas um and the and the big dropouts of of Mika, but hopefully that will be uh fixed in one or two years. Uh I don't know when exactly. Uh so the that um regulatory gap is fixed now and all regulated entities have the comfort and uh the the freedom to perform their services in a fully regulated manner. >> Yeah. Well, um a question to the meter and um probably this is the million dollar question is um the meter from from the regulators p perspective does a make a license applicant contemplating uh providing services related to many tokens also need payment services provider license. >> Yeah, sure. Uh unfortunately the situation now stands like this. If uh there is an applicant that is applying for authorization for transfer and custody and would like to provide also services for EMTs uh in order to provide transfer and custody for EMTs that uh CASP will have to also have authorization from the Bulgarian National Bank as a PSP authorization. uh we could issue the authorization for custody and transfer but it will explicitly say that it is not allowed for the EMTs and we expect that uh we are kept in uh in the loop uh about uh the application and the assessment of the application as a PSP in front of the Bulgarian National Bank. So uh this is uh following the guidelines of the no action letters of the European banking authority. M >> in these letters the EBA itself said that the idea was not to have dual authorizations but at this point this is where we stand and unfortunately there is nothing that I don't think that uh there is something that Bulgaria can do before there is more broader European approach negotiated on the European level. M okay. Um so yeah question to to V. The commission proposed in December 2025 uh that ESMA directly supervised all CASPs but um [snorts] u member states now appear to converging on ESMA um regulating only a significant CASPs um under this MISP initiative. Um so does a two-tier model fix fragmentation or rather second one in your view? >> Yes. Um that's also something again overlaps between the different frameworks um that I have the I guess the uh chance to uh to see um because in MISP we have this proposal of the direct supervision of CASPs uh under ESMA. So the current discussion is going towards direct supervision of significant CASPs. So now I can already tell you kind of it's a it's not official public uh discussions but I know for a fact that there are already discussions that uh uh try to clarify what a significant CASP would mean. So this for us also means um that we will have indirectly at first a definition of what an insignificant or a small cast would mean. So uh this would also be a possibility for because also discussion coming from the industry. They're currently um the the level playing field isn't quite fair when it comes to smaller CASPs and big CASPs. So this would also be an opportunity for smaller CASPs to have a more streamlined regime in the future. If we have for example a structure in which we have the big CASPs under ES asma direct supervision smaller caps CASPs remaining on the member state level and then we actually have a more streamlined approach towards towards smaller cast because it's quite visible already that they do not pose the same level of risk uh and uh they don't they don't have the same resources it's kind of clear so from that point of view I consider this proposal of the of the direct supervision of all CASPs a a really good opportunity to have this broader discussion on okay actually now that we know how Mika is uh playing in in practice how do we make it easier for all market participants to have a fair chance at entering the market >> okay um so from the regulator's perspective uh what would that split means for uh CASPs already authorized in Bulgaria [snorts] and uh what should stay in your view in the buckle for regulators in their competence. >> I didn't get uh very well the question. >> Uh the question would be if we have this split between significant cases and like small caps casps let's call it that. So this is a tricky question for the FC because we have vested interest in the answer basically >> but uh I can show you I can share with you personal insight as a representative of the FC in the digital finance standing committee of ESMA. I had the opportunity to observe from her firsthand the procedure on the authorization of Binance and without getting in any details because I cannot do this uh it was a very very tedious and torturous process. So for such kind of global CASPs there is a sound underlying logic for the authorization to be moved on a paneerup level because these are global players and there is a very little argument that can be put forward from the perspective of local substance and uh vice versa for the truly local players maybe it for them it will be much more efficient that the authorization will be kept on the national level. >> So uh there is a logical explanation of this idea. The the big challenge will be where we we will draw the line. So the definition of significant or global or yeah so the the first tier and the second then >> the the line will that will divide the first and second tier casps. Uh so we'll see. It's uh it's still uh it's still something that is going to be debated in the coming months. >> So we'll see where where we'll move uh from now on. But uh uh maybe it's uh it will be a good thing for the local players to be kept because it's much easier to to work with the with the NCAs >> and for the global ones to go to ESMA. So >> yeah. >> Yeah. Okay. Um cautious of timing I'll skip uh one of the questions in my agenda and uh just to ask um what we see here in Bulgaria is that um a large number of international casps already passported their services in Bulgaria and uh we have only five licensed uh local players here in in Bulgaria which it's uh the standards of the Bulgarian markets it's quite good but probably not sufficient. So uh my question here is um is a Bulgarian licensing cup or a host market or in other words can we say that uh Bulgaria is a crisp uh sorry crypto friendly jurisdiction or crypto unfriendly jurisdiction from from your perspective and from the regulators perspective of course. >> Yeah. All right. So the terms friendly and unfriendly are a bit emotional. So I I don't would not like to to go there. Uh but uh already we have the numbers. We have uh five authorizations which is per capita comparable to Germany and ahead of other jurisdictions like France and Italy. So we are doing fairly well. uh in my opinion the number of uh passportization notification is not crucial because some uh cast are just notifying uh just in case they will have some reverse solicitation client and not as Mr. totive can explain as is the case with their with their CASP and um so um this is not crucially important but uh uh what I would uh think that is uh our aim here and uh the chair of the FC in his speech will provide more detail is that we want to have a good business. So we are friendly towards good business and uh if all the requirements are met, if the credential requirements are in place, if the the local substance is really present uh and we see this strong team with strong rules, we are one of the 10 jurisdictions in the EA that has a class 3 CASP authorized. So the the numbers are quite uh tailing, but uh we really strive to have a a sound business. So Bulgaria will be will become um uh renowned for the very high quality crypto asset services that are provided here. And I think that this is quite manageable and that we have uh great people here in Bulgaria that really can bring this standard forward. Yeah. Thanks. Thank you very much about this and uh we are probably the same question to you from your perspective. Are we a friendly or unfriendly crypto jurisdiction is you know seeing uh from the point of view of the uh discussions in the in in the European Union. >> Yeah. So I'm uh I might be biased because I'm based here. I'm based here by choice. So, um, I really love what's happening in Bulgaria, uh, particularly, uh, when it comes to crypto. And I need to point out something. I I keep telling that, but I I really want to scream it from the roofs, but I'm extremely impressed by what our National Competent Authority is doing with all these events, including speaking in public, answering questions. That is not the rule in Europe. I can tell you that. And then we also have the numbers that back up that that's actually what's happening here is quite um uh meaningful in terms of uh like the percentage that we see in the European Union. So I I'm I'm really I'm I'm happy with what's happening in Bulgaria and I I guess now that we already have the data, we will go towards improving also things on the European Union side which would then reflect also on the on the on the market here. >> So really nothing to add to what was already mentioned. >> Okay. Thank you. and um course of timing. Thank you uh to the public uh for your questions. I guess that we don't have enough time to uh to ask some of these very interesting questions. But uh I would say that uh at least from my perspective on my behalf and behalf of Ian uh Deita and Vas we are uh always uh on your disposal after the discussion to answer these questions. uh they are very interesting actually and uh thank you very much Deita Vara and Ian for your participation here. I I think that we we had a very valuable discussion uh on Mika and different perspectives from the regulators point of view from the applicant's point of view and uh from the point of view of what we can expect uh from the European legislation in the near future. So, thank you very much. >> And thank you. >> And yeah, >> thanks. Thanks. >> Fantastic.