GH GambleHub

Bulgaria - NRA and Tax Model

Regulator and legal framework

Regulator: NRA - licenses, maintains registries, collects taxes/fees, conducts inspections, initiates blocking of illegal sites and payment channels.
Legislation: National Gambling Act + by-laws (technical standards, reporting, advertising, protective measures).
Registers and IT circuit: register of licenses and domains, register of self-exclusion, control gateways for the exchange of reporting data with operators.


Perimeter and permission types

Online (remote)

Online Casinos/Slots

Online poker/player-versus-player games

Online sports betting

Other remote formats (skill draws/games with separate permit mode)

Mandatory requirements: local representative, platform/game certification, integration into NRA, KYC/AML reporting buses, responsible play tools (limits, timeouts, self-exclusion).

Offline (land-based)

Casino (Tables/Slots), Gaming Rooms (AWP/VLT)

Bookmaker shops

Sweepstakes (where applicable)

Basic requirements: location and zoning, security and video control, equipment accounting (serial numbers, licensing of each device), online cash registers/fiscal devices, availability of RG materials.


Responsible play and self-exclusion

A single register of self-exclusion is maintained by the NRA; the operator is obliged to check the player's status during registration/login/deposit and before communication (email/SMS/push).
Limits and behavioral measures: deposit/loss/time, "reality checks," "cool-off" and panic button, visible transaction history, links to help lines.
Age and verification: 18 + (bets) and 21 + (casinos - according to the internal policy of the site/jurisdictional requirements); mandatory pre-game identification and verification of the source of funds for risk triggers.


Advertising and Marketing

Conservative model: limited channels, banning aggressive incentives and misleading statements.
Sports sponsorship and outdoor advertising - under restrictions; age marking, "responsible" disclaimers, prohibition of communications to self-excluded are required.
Affiliates: jointly and severally liable; the operator is obliged to control tone/targeting/geofilters of partners.


Tax model (high-level, 2025)

💡 Below is a practical "map" that should be updated when calculating P&L, since rates and methods are periodically updated by the regulator.

Online segment (remote)

Gross Gaming Income Tax (GGR): Applies to all online verticals (casino/slots, poker, betting).
Base: bet amounts minus winnings paid (bonus/jackpot adjustments - according to the NRA methodology).
Reporting and payment: frequency - calendar (usually monthly) with subsequent reconciliation and desk checks.

Offline segment (land-based)

Fixed fees:
  • for slot machines (AWP/VLT) - fixed grant/month. per unit;
  • for game tables - fixed grant/month at the table;
  • additional local fees (municipal) - depending on the place.
  • For some offline verticals, combined models are possible (fix + share of GGR) - according to the current NRA tables.

National taxes and other

Corporate income tax (CIT): 10% (common rate).
VAT: gaming activities are usually exempt, but third-party services (marketing, IT, outsourcing, consulting) are taxed in a general manner.
Target contributions/fees: for licensing/renewal, for expertise, for verification of equipment/software and to the funds of the responsible game.


Technical requirements and data

Certification of software/games/RNG in accredited laboratories; version control and immutability of builds.
Logging: sessions, deposits/conclusions, rates/calculations, bonus obligations, limit changes, RG events, marketing touches.
Integration: reporting gateway to NRA (machine-readable uploads), access to the inspector on request, storage of logs by time.
Information security and privacy: encryption in transit/in storage, secret management, vulnerability management, incident notification.


Licensing: What the NRA is watching

Ownership and "fit & proper": beneficiaries, key persons, reputation, group structuring.
Financial stability: capital, lack of tax debt, calculation of sources of financing.
Technologies: architecture, continuity of work, DR/BCP, anti-fraud, KYC/AML, player protection, correct reporting.
Contracts: only with providers/outsourcers with the required permits/certifications.


Practical checklist for market entry

Legal and corporate

1. Choose a perimeter: online casino/slots, poker, betting; offline casino/lounge/PPS.
2. Prepare dossiers on beneficiaries and key-persons, ownership structure, sources of funding.
3. Form a licensing package with the NRA (including fees and bank guarantees, if required).

Technology and Compliance

4) Certify platform/games/RNG; implement end-to-end logs, anti-fraud and anomaly monitoring.
5) Build KYC/AML with sanction/PEP screening and SoF/SoW trigger checks.
6) Integrate the RG self-exclusion and mechanics register (limits, timeouts, panic button, reality-checks).
7) Set up uploads in NRA formats, incident reporting regulations.

Marketing & Affiliates

8) Policy of "moderate advertising," uniform disclaimers, age-gating, prohibition of touching self-excluded; contracts with affiliates with strict compliance KPIs.

Finance and taxes

9) Simulate P&L: online - GGR tax, offline - fixed fees/combined schemes, plus 10% CIT and VAT on purchased services.
10) Set up separate accounting: player funds/jackpots/bonus commitments vs operating funds.


Frequent errors of applicants

Underestimation of the reporting loop (incomplete fields, untimely transmission, misalignment of logs).
Incomplete self-exclusion check points (especially in CRM mailings and retargeting).
Use of uncertified providers/games or inconsistent domains.
Incorrect tax assessment (mixing GGR tax with fixed offline fees; ignoring CIT/VAT on services).


Trends 2025 +

We will put the squeeze on the illegal offer: increased blocking of sites/payments, coordination with banks and payment providers.
Telemetry and "data-driven" surveillance: extending machine-readable reporting and in-depth RG behavioral metrics.
Advertising: point adjustment of restrictions, control of affiliate channels, requirements for the transparency of offers.
Fiscal contour: calibration of methods for bonuses/jackpots and periodic updates of bets/fees.


Conclusion

The Bulgarian post-devolution model of the NRA is "financial and technical" supervision with an emphasis on online segment GGR taxation, fixed offline fees, strict reporting and player protection. Operators prepared for data discipline, neat marketing and transparent tax practices are given predictable jurisdiction with clear admission rules and robust enforcement.

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