Bulgaria vs Estonia
Crypto regulation comparison
Bulgaria
Estonia
Legal
Legal
Cryptocurrency is legal in Bulgaria and subject to a flat 10% tax on capital gains, one of the lowest in the EU. Bulgaria adopted the EU's MiCA framework and requires crypto service providers to register. The country has a notable history with crypto due to a large government Bitcoin seizure in 2017.
Estonia was an early mover in crypto regulation, offering licenses since 2017. However, a 2022 overhaul significantly tightened requirements, revoking hundreds of licenses and imposing stricter capital and compliance standards. Crypto gains are taxed at 20% (rising to 22% from 2025).
Tax Type
Capital gains
Tax Type
Capital gains
Tax Rate
10%
Tax Rate
20-22%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
NRA (National Revenue Agency), FSC (Financial Supervision Commission)
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
Regulated under EU MiCA framework
Key Points
- Flat 10% personal income tax rate applies to crypto capital gains
- VASPs must register with the NRA for AML compliance
- MiCA framework applicable from December 2024
- Bulgaria reportedly seized approximately 200,000 BTC in a 2017 crime bust (status debated)
- No specific crypto legislation beyond EU directives and general tax law
Key Points
- Estonia issued crypto licenses since 2017 but drastically tightened rules in 2022
- Hundreds of crypto licenses were revoked in 2020-2022 due to AML concerns
- New requirements include higher share capital (€100,000-€250,000) and local management
- Crypto gains taxed at 20% personal income tax (22% from 2025)
- MiCA framework applicable from December 2024