Bulgaria

Bulgaria's gambling regime is in an active reform phase as at October 2026. A draft Gambling Act amendment package, submitted for public consultation around 24 September 2026, proposes a near-total ban on gambling advertising and a requirement for real-time NRA equipment monitoring, layered on an already in-force affiliate-licensing regime effective 1 August 2026 and a gross gaming revenue tax rise to 25% effective 1 January 2026. The NRA Gambling Office has also seen internal leadership instability, with its Director of Gambling Policy departing on 18 June 2026. No core licensing, entry-pathway or product-class change has been evidenced: the structural route to market is stable even as the cost, advertising and technical-compliance perimeter tightens around it.

The affiliate-licensing regime for Bulgaria's gambling sector was introduced through the transitional provisions of the State Budget Act for 2026 (State Gazette issue 69), which amended the Gambling Act with effect from 1 August 2026, and this regime remains in force. A draft Act amending and supplementing the Gambling Act, notified to the European Commission on 2 October 2026 as TRIS notification 2026/0536/BG, would terminate all active gambling-affiliate licences created under that August 2026 regime, with termination effective from 1 January 2027. This would reverse the affiliate-licensing framework within five months of its creation. The draft remains at public consultation stage (item 12738-K, closing 23 October 2026) and has not been tabled before the National Assembly. An operator holding or seeking a Bulgarian affiliate licence today is operating under a regime created by budget-linked transitional provisions that a separate, later draft instrument proposes to unwind entirely.

The affiliate operator licence, created under the August 2026 State Budget Act and administered by the National Revenue Agency with an annual fee and commission withholding, is itself the subject of a draft proposal opened for public consultation on 23 September 2026. That draft Gambling Act amendment would terminate all active affiliate licences from 1 January 2027, reversing a regime that had been in force for only a matter of weeks. The draft is a proposal before the legislature, not an enacted instrument, and the current affiliate licensing framework remains operative pending any enactment. No change to core operator licensing conditions beyond the affiliate class was evidenced this cycle.

Affiliate marketers whose remuneration is linked to referrals, deposits, bets, or gross gaming revenue must now hold an NRA-issued approval, effective 1 August 2026 under transitional provisions of the 2026 State Budget Act amending the Gambling Act (State Gazette issue 69). This is a primary-legislation change brought in via a budget-act transitional provision rather than a standalone gambling-law amendment, and the National Revenue Agency has issued official guidance to affiliates and operators clarifying the scope of remuneration structures that trigger the approval requirement. The change directly extends Bulgaria's gambling-licensing perimeter beyond operators to the affiliate-marketing layer of the value chain, a segment that had not previously required its own regulatory approval. Operators relying on affiliate-driven acquisition should treat this as a new counterparty-compliance obligation: verifying that every affiliate in a performance-linked arrangement holds the requisite NRA approval before continuing to pay commission on referred activity.

A new gambling_affiliate_licence category was created under the Gambling Act as amended by Section 34 of the State Budget Act 2026, issued by the NRA Gambling Office with five-year validity. The category captures performance-linked affiliate remuneration, specifically commission, deposit, bet or winnings-based arrangements, while flat-fee or time-based advertising remains outside its scope. The licence is confirmed by NRA official decision R-CU-30-9/27.01.2026 and corroborated by multiple trade-press sources reporting the 1 August 2026 in-force date. The underlying instrument mix is MIXED: the enabling change arrives through budget-act transitional provisions rather than a freestanding gambling statute, so the licence sits on an enabling-Act foundation of only partially tested durability, notwithstanding the confirmed operational fact of its issuance and five-year term.

Bulgaria introduced a wholly new gambling_affiliate_licence class this cycle, administered by the National Revenue Agency and effective 1 August 2026, targeting affiliates who acquire players in exchange for performance-based (CPA/revenue-share) remuneration. The licence carries a five-year validity period and an annual fee of EUR 6,000. Foreign affiliate applicants must appoint a Bulgaria-domiciled authorised representative as a licensing condition. The framework derives from the transitional provisions of the 2026 State Budget Act (State Gazette issue 69) amending the Gambling Act, and is corroborated across three independent trade-press sources. Durability is MIXED: the licence rests on primary budget legislation, but its operative detail sits in transitional provisions rather than a freestanding statutory amendment, so the regime should be read as an enabling act with delegated administrative mechanics rather than fully settled doctrine.

Bulgaria's current online gambling operator levy is reported at 25 percent of gross gaming revenue as of 1 January 2026. The draft Act amending the Gambling Act, notified to the European Commission on 2 October 2026 (TRIS 2026/0536/BG), proposes raising this online levy to 21 percent in 2027 and 22 percent in 2028, introducing a EUR 100,000 monthly minimum per operator, and adding one-time state licence fees ranging from EUR 25,000 to EUR 100,000 for certain licence categories. These changes are draft-stage only, still within the public consultation that closes 23 October 2026, and have not yet been placed before the National Assembly. For cost-planning purposes, an operator should treat the 25 percent GGR figure as the operative rate and the proposed 21/22 percent schedule, monthly minimum, and new licence fees as a material but unconfirmed future cost trajectory.

The gross gaming revenue tax on online gambling operators in Bulgaria rose to 25%, from 20%, effective 1 January 2026, a change corroborated across multiple press sources and treated as confirmed. A subsequent proposal in July 2026 to raise the online-operator tax further was rejected by the Ministry of Finance. A newer draft, opened for consultation around 24 September 2026, proposes a different cost mechanism: a minimum monthly tax contribution of at least EUR 100,000 for online operators, alongside fixed minimum charges per machine or table for land-based venues. This minimum-contribution proposal remains unconfirmed and at consultation stage. Taken together, the confirmed 25% GGR rate is the operative cost baseline today, while the minimum-contribution mechanism represents a further cost escalation that has not yet been enacted and should be tracked as a distinct, separately-timed risk.

Bulgaria's gross gaming revenue tax stands at 25%, having been raised from 20% earlier in 2026. A further tax increase was proposed and rejected by the National Assembly in July 2026, but the same increase has been re-proposed in the Ministry of Finance's 23 September 2026 draft law, so operators should not treat the July rejection as settling the matter. Layered on top of the GGR tax, the new affiliate-licensing regime introduced a fixed EUR 6,000 annual fee for affiliate approval plus a 10% withholding on performance-based commission, which the licensed operator must remit before paying the affiliate. The combined effect for an operator running an affiliate-driven acquisition programme is a materially higher and more administratively complex cost base than earlier in 2026, with a credible near-term risk of further increases if the September draft law is enacted.

The new gambling_affiliate_licence carries an annual state fee of EUR 6,000, payable to remain in the regime, alongside a 10 percent withholding on performance-linked commission that the operator remits directly to the NRA on the affiliate's behalf. Where commission is found to have been concealed, this withholding rate doubles to 20 percent, materially raising the cost of any non-transparent commission arrangement. Together, the fee and withholding structure represent a new and non-trivial cost layer for affiliate businesses that previously operated without a licensing fee or a withholding mechanism at all. The fee figure derives from commercial-law commentary while the doubling penalty is independently corroborated by trade-press reporting, giving the overall cost picture Confirmed confidence at the claim level despite resting on T3-tier sourcing.

The cost-to-operate picture rose on two fronts this cycle. The gross gaming revenue tax applicable to lotteries, raffles, toto, bingo, keno and online gambling increased from 20 percent to 25 percent effective 1 January 2026, while slot and casino segments continue under fixed per-machine and per-table levies; this figure is rated Uncertain, resting on a single trade-press source with no direct State Gazette retrieval completed this cycle, though the underlying tax instrument itself is rated DURABLE. Separately, the new gambling_affiliate_licence introduces a recurring EUR 6,000 annual fee for any performance-based affiliate relationship. Together, the tax increase and the new licence fee raise the effective cost of operating in Bulgaria for both operators and their affiliate networks this cycle.

The National Revenue Agency holds an express power, in force since around 25 August 2026, to instruct banks and payment providers to block outgoing commission payments to gambling affiliates operating without the licence now required under the 1 August 2026 affiliate-licensing amendment. This gives the NRA an enforcement mechanism that operates directly at the payment layer, rather than through administrative penalty alone, meaning unlicensed affiliate traffic can be interrupted at the point of payment. This power sits alongside, and reinforces, the affiliate-licensing regime: an unlicensed affiliate faces both direct financial sanction and the practical risk of having its commission payments blocked before they are received. No further cross-border payment-flow restriction specific to gambling has been identified.

The draft Gambling Act reform under consultation since 23 September 2026 would impose additional financial-registration obligations on foreign operators earning revenue from the Bulgarian market, named in trade press alongside the proposal for real-time connection of gaming equipment to the National Revenue Agency for data reporting. No further detail on the scope, registration mechanism, or compliance timeline for the foreign-operator financial-registration proposal has been retrieved this cycle. Both proposals remain in public consultation rather than enacted, and operators serving the Bulgarian market from abroad should treat them as a signal of tightening financial oversight rather than as a specified requirement that can yet be implemented against.

The new affiliate-licensing regime introduces a payment-flow mechanism alongside its licensing requirement: a 10% withholding on performance-based affiliate commission, which the licensed operator must apply and remit before the balance reaches the affiliate. This creates a new intermediated payment step for any operator-affiliate relationship structured around referral, deposit, bet, or gross-gaming-revenue-linked commission. Separately, and on the enforcement side of the payment-flow picture, the NRA Director's blocking power under Article 17(1)(9a) of the Gambling Act extends to payment channels operated by banks and payment providers, meaning an unlicensed affiliate's or operator's access to payment rails can be cut off as part of the same blocking action that targets its online presence.

The NRA's new payment-blocking-order power is the most direct payments-flow development of this cycle, allowing the agency to block outgoing bank and payment-service-provider transactions destined for unlicensed gambling affiliates. This directly targets the commission payments that operators would otherwise remit to affiliates lacking the new gambling_affiliate_licence, converting the licensing requirement into an enforceable payments-level control rather than a purely administrative one. The power is corroborated by FocusGN trade-press reporting on the affiliate framework now in force and sits alongside the 10 percent (or 20 percent, where concealed) withholding that operators must already apply to performance-linked commission remitted to licensed affiliates, meaning payment flows to affiliates are now subject to both a withholding mechanism when licensed and a blocking mechanism when not.

The NRA's expanded blocking authority, enacted via the 2026 Budget Act amendments to the Gambling Act, extends to the payment-adjacent ecosystem surrounding unauthorised gambling platforms and their promotional channels. This reflects the regulator's stated shift toward supervising the full gambling ecosystem, affiliates, distribution channels and payment-adjacent actors, rather than licensed operators in isolation. No payments-specific licensing or transaction-blocking mechanism distinct from the general platform-blocking power was identified this cycle.

The draft Gambling Act reform under consultation since 23 September 2026 includes a proposal for real-time connection of gaming equipment to the National Revenue Agency. This would be a new data-reporting obligation on licensed equipment if enacted, but no further technical specification, such as the data fields to be transmitted, the connection protocol, or an implementation timeline, has been retrieved this cycle. The proposal is named alongside other draft reform elements in trade press reporting without independent elaboration. Pending enactment and the publication of implementing technical standards, operators cannot yet assess the system changes this requirement would demand.

The new affiliate-enforcement regime extends materially into distribution and platform rules. The NRA may order the blocking of websites, apps, social-media profiles and streaming channels operated by, or used to promote, unlicensed affiliates, with telecom providers required to give effect to such orders within a 24-hour compliance window. This mechanism is corroborated by G3 Newswire reporting on the new licensing framework and sits alongside the parallel requirement that affiliates declare all promotional digital channels at the point of licence application. Together, the declaration duty and the blocking power give the NRA both advance visibility into an affiliate's distribution footprint and a fast-acting remedy against non-compliant channels once identified, a materially stronger platform-enforcement posture than existed before this cycle.

The NRA's expanded blocking authority, enacted via the 2026 Budget Act amendments to the Gambling Act, explicitly reaches websites, apps, social-media accounts and streaming channels distributing unauthorised gambling promotion or activity. This is a material widening of the distribution-platform enforcement perimeter, rated Confirmed and DURABLE. The new affiliate-licensing regime compounds this: performance-based affiliates who fail to obtain the new NRA licence now risk having their distribution channel blocked outright, connecting the licensing gate and the platform-blocking gate into a single enforcement mechanism directed at the promotional ecosystem surrounding licensed gambling operators.

Two enforcement developments moved together this cycle. First, the NRA Director gained a statutory power under Article 17(1)(9a) of the Gambling Act as amended to order the blocking of internet pages, mobile applications, and social or video-streaming profiles belonging to unlicensed affiliates, with that blocking power extending to payment channels via banks and payment providers. Second, the NRA's unlicensed-operator blacklist, which feeds this blocking mechanism, moved from a monthly to a daily refresh cadence, a purely operational escalation that materially compresses the window during which an unlicensed affiliate or operator can continue to transact before being cut off from payment rails. Both changes are dated to the same period as the affiliate-licensing reform and read as a coordinated enforcement build-out rather than isolated actions. No named enforcement events against specific entities were evidenced this cycle; the developments described are the creation of statutory power and operational cadence, not yet a record of individual actions taken under them.

The NRA gained two materially new enforcement powers this cycle, both confirmed and both corroborated by independent trade-press reporting. First, payment-blocking-order power over outgoing bank and payment-service-provider transactions destined for unlicensed affiliates, directly targeting the commission flows that sustain non-compliant affiliate arrangements. Second, website, app, social-media and streaming-channel blocking power, enforced through telecom providers within a 24-hour compliance window. Consistent with the statutory-licensing-stack theory appropriate to a civil-law jurisdiction, both powers derive from the same enabling amendment, Section 34 of the State Budget Act 2026, that created the affiliate licence itself, giving the enforcement regime a MIXED durability rating: real and currently in force, but resting on budget-act transitional provisions rather than a long-standing freestanding enforcement statute. Licence-revocation risk for affiliates concentrates on three drivers: promoting an operator without a valid Bulgarian gambling licence, failing to declare a promotional channel at the point of application, and commission concealment that would trigger the doubled 20 percent withholding rate and associated regulatory scrutiny. No enforcement-event history beyond the creation of these powers was surfaced this cycle; the register does not yet show a case record under the new regime.

The National Revenue Agency's enforcement toolkit was expanded this cycle to include the power to block websites, apps, social-media accounts and streaming channels associated with unauthorised gambling activity or promotion, per the 2026 Budget Act amendments to the Gambling Act. This power is rated Confirmed and DURABLE. A Sofia Regional Court decision reportedly included the prediction-market platform Polymarket among sites ordered blocked, evidencing active use of the expanded authority against a novel offshore product; this specific enforcement-action claim is rated only Uncertain, resting on a single trade-press source, with the Advennt confidence framework capping it there despite an upstream Probable flag. Read together, the durable statutory expansion and the reported enforcement event indicate a shift toward supervising the wider gambling ecosystem, affiliates, distribution channels and offshore platforms alike, rather than licensed operators alone.

The draft Law Amending and Supplementing the Gambling Act, filed on the Council of Ministers' public-consultations portal as item 12738-K, is the single live reform vehicle for Bulgaria's gambling framework. It was approved by the Council of Ministers on 23 September 2026 and notified to the European Commission as 2026/0536/BG on 2 October 2026, and its public consultation period closed on 23 October 2026. As drafted, it would raise the online gambling fee to a range of 21 to 22 percent with a EUR 100,000 monthly minimum contribution, extend real-time National Revenue Agency monitoring from online operators to land-based casino and gaming-machine equipment on a four-month post-adoption compliance window, tighten the existing advertising restriction toward a near-total ban leaving only limited sponsorship and venue signage untouched, and abolish the existing affiliate-marketing licensing regime from 1 January 2027. None of these changes has yet been enacted, and the draft's next legislative step — committee reading, parliamentary vote, or further revision — is not confirmed in evidence reaching. The official State Gazette promulgation text has not yet been retrieved, leaving the precise pinpoint provisions of the draft unconfirmed beyond the consultation listing and secondary trade-press paraphrase.

A draft Act amending and supplementing the Gambling Act was notified to the European Commission under Directive (EU) 2015/1535 as notification 2026/0536/BG on 2 October 2026. The draft proposes four material changes: a near-total ban on advertising of gambling games, operators and their trademarks across all channels (with narrow exceptions for venue signage, the operator's own website, state lottery draws, and sponsorship of licensed sports clubs and federations); termination of all active gambling-affiliate licences, created under the August 2026 regime, effective 1 January 2027; an increase in the online operator levy to 21 percent in 2027 and 22 percent in 2028 with a EUR 100,000 monthly minimum and new one-time licence fees of EUR 25,000 to EUR 100,000; and extension of real-time deposit, wager and winnings reporting from online betting to land-based slot machines and casino equipment. Public consultation (item 12738-K) closes 23 October 2026. No government bill has yet reached the National Assembly, so none of these changes has legal effect as of this period.

A draft Gambling Act amendment package, submitted for public consultation around 24 September 2026, proposes three linked reforms: a near-total ban on gambling advertising retaining only limited sponsorship of sport, a requirement for real-time NRA equipment monitoring at land-based venues with a proposed 31 March 2027 compliance deadline, and a new tax and fee framework including a minimum monthly tax contribution for online operators. None of these provisions has been enacted. Notably, a predecessor proposal in July 2026, covering a blanket advertising ban and a further tax rise, was rejected by the Ministry of Finance, reportedly on channelisation-risk grounds, indicating that enactment of the current package is not assured. Primary National Assembly bill text or NRA gazette text, which has not yet been located, would be the development most likely to move these provisions from probable to confirmed.

The Council of Ministers opened a public consultation on 23 September 2026, closing on approximately 23 October 2026, on a Gambling Act overhaul proposing a near-total advertising ban, termination of the affiliate licence regime created in August 2026, real-time connection of gaming equipment to the National Revenue Agency, and a higher online levy. Opposition parties are reported to be pushing to broaden the draft further, raising the possibility that any enacted version could be more restrictive than the version currently under consultation. Separately, a February 2026 bill to raise the minimum gambling age from eighteen to twenty-one and a June 2025 proposal for mandatory loss and wagering limits remain pending with no reported movement.

A Ministry of Finance draft law (registration 12738-K) was published 23 September 2026, with public consultation running to 23 October 2026. As published, it would impose a complete ban on gambling advertising, raise licence fees and taxes, and terminate existing affiliate-operator licences effective 1 January 2027. It would also introduce a new Article 42a requiring real-time data transmission from casino and gaming-hall equipment, with an implementing ordinance due by 31 March 2027 and operator compliance required by 30 June 2027. Casino and slot variable-fee provisions, along with repeal of the alternative tax, are deferred separately to 1 January 2028, indicating the reform programme is staged across at least two effective dates rather than delivered in a single tranche. The 23 October 2026 consultation close is the near-term date that will determine whether these measures proceed, are moderated, or stall.