A new edition of the Fintech Visits DG FISMA series brought Bulgaria’s fintech ecosystem into direct exchange with the European Commission’s DG FISMA. Led by the European Digital Finance Association (EDFA), the series is designed to surface practical market evidence on how EU rules are working in implementation, where implementation questions remain, and what would support cross-border scaling while preserving consumer protection, resilience, and market integrity.

This EDFA hosted Fintech Bulgaria and combined an ecosystem overview with company interventions focused on key policy files, including PSD3/PSR, CCD2, MiCA, DORA, eIDAS 2.0, and AML implementation.

Bulgaria’s fintech ecosystem in brief

Fintech Bulgaria, established in 2017, represents 75+ companies and 9,300+ employees. BFA _EDFA_DG FISMA The delegation highlighted the scale and maturity of the ecosystem, including around 180 fintech companies, approximately 12,000 employees, and EUR 1.3B in revenue (around 2% of GDP), with key hubs in Sofia, Varna, and Burgas.

The overview also underlined structural factors shaping competitiveness, including a flat 10% corporate and personal income tax, and Bulgaria’s stated Eurozone accession date of 1 January 2026.

Company interventions: market practice meeting regulatory change

To ensure comparability, each company contribution linked a business model overview to concrete regulatory touchpoints.

Cash Credit (digital micro-lending) described how the implementation of CCD2 is driving redesign of onboarding and affordability checks, including a stronger reliance on verified data and governance changes linked to automated decision-making. The briefing also highlighted cross-cutting compliance interactions with GDPR (Article 22), the AI Act (creditworthiness as high-risk use), and eIDAS 2.0 implications for digital identity and onboarding processes.

IRIS Solutions (open banking and A2A payments) presented its infrastructure for bank connectivity and payment initiation, with 80+ integrated banks and financial institutions and 90% coverage of financial institutions in Southeast Europe. The intervention focused on what is needed to scale Pay-by-Bank across the Single Market, including progress on PSD3 and the Payment Services Regulation (PSR), as well as the role of investment and EU-level support in strengthening Europe’s payments capacity.

Afranga (crowdfunding, licensed ECSP) highlighted barriers to scaling cross-border private credit via platforms, pointing to the “scale-up gap” between the EUR 5M ECSPR ceiling and the EUR 12M Prospectus Regulation threshold (subject to national implementation), which can create discontinuities in funding pathways. Afranga also raised operational constraints linked to cross-border tax frictions and the need for stronger proportionality in DORA application for smaller firms.

Truvity (AML compliance solutions) presented a regional compliance data and screening proposition designed for the SEE region, emphasising coverage depth and the impact of differing access to regulatory clarification. The intervention stressed the importance of predictable supervisory guidance and structured dialogue channels beyond the banking sector, to support consistent implementation for non-bank obliged entities.

Key policy themes raised

Across the ecosystem and company perspectives, several consistent themes emerged:

• Proportionality and implementation clarity: repeated calls for more predictable application of horizontal frameworks, particularly where smaller firms may face requirements similar in scope to larger institutions
• Cross-border scalability: practical barriers in payments, crowdfunding, and compliance services that limit Single Market expansion despite EU-level frameworks.
• Cost of compliance and market entry: concerns about the operational implications of licensing and ongoing compliance, including under MiCA and DORA, and the downstream impact on innovation capacity and competition.
• Identity and onboarding infrastructure: recognition that eIDAS 2.0 and the EU Digital Identity Wallet could materially improve KYC and authentication, while implementation details and timing remain open questions.

Conclusion

This Fintech Visits session reinforced the value of structured engagement between national fintech ecosystems and EU policymakers. Bulgaria’s interventions provided a practical view of how fast-growing fintech markets experience EU regulation in day-to-day implementation, and where targeted clarity, proportionality, and cross-border enablement could strengthen competitiveness while maintaining resilience and consumer protection.