Payments and banking: Can we move player money?

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.