Key Points
- Affiliates earning lower Bulgarian commissions face an effective state take of nearly 20%, not the headline 10%, because the fixed annual fee applies equally regardless of revenue size.
- Deputy Finance Minister Lyudmila Petkova confirmed Bulgarian gambling affiliates generate BGN 450–500m (£219m) in commissions annually, none of it previously taxed.
- The Ministry of Finance has projected €100m in new affiliate tax revenue for 2026, rising to €150m in 2027, meaning enforcement is a budget line, not a policy aspiration.
Something Shifted on 1 August, and Most Affiliates Missed It
On 1 August 2026, Bulgaria quietly reclassified every performance-based gambling affiliate operating in its market. No press conference, no industry consultation period. The change came buried inside the transitional provisions of the 2026 State Budget Act, published in State Gazette issue 69, which amended the Gambling Act rather than creating a new standalone instrument. One day, affiliates were marketing suppliers. Next, they were licensed participants in a regulated gambling market with fee obligations, reporting duties, and blocking powers attached.
Most coverage since has focused on two numbers: €6,000 and 10%. What those numbers actually cost, and who they cost the most, is a different story entirely.
What the Law Says, and Who It Catches?
The amended Gambling Act now lists the promotion of gambling by affiliate operators as a regulated activity in its own right under Article 1, Item 3. The trigger is not a company’s registered address or annual turnover. It is how payment is calculated. Any remuneration tied to a measurable result, whether that is players referred, accounts registered, deposits made, bets placed, or a share of gambling revenue, brings an entity inside the regime.
A company selling fixed-rate advertising space to a licensed operator sits outside the regime. A revenue-share arrangement renamed as a “monthly retainer” that still moves in line with player deposits does not. As Bulgarian.LLC noted in its analysis of the amended Act, the contract governs, not the label on the invoice, and the operator’s own compliance team now carries the withholding duty, which means they will check.
Both Bulgarian and foreign businesses may apply for a licence, including sole traders. Incorporation in Bulgaria is not required. Foreign applicants must, however, declare an authorised representative with an active Bulgarian address, empowered to sign contracts and represent the affiliate before state bodies and courts. Promoting an operator that does not hold a valid Bulgarian licence is prohibited outright, regardless of whether the affiliate itself is licensed.
The Two-Component Fee and Its Hidden Weight
Article 30a of the amended Gambling Act introduces what the legislature describes as a “two-component state fee”. The first component is a fixed annual payment of €6,000, ordinarily due by 31 March each year. Businesses that receive their licence after that date must settle the fee before the certificate is issued.
The second component is where the real commercial pressure sits. A variable charge of 10% applies to every performance-linked commission earned. The licensed gambling operator withholds this amount at source and remits it monthly to the National Revenue Agency, alongside a monthly declaration detailing the calculation basis. Where a sham transaction is used to disguise performance-linked commission as something else, that variable rate doubles to 20%.
Combine both aspects, and the real impact on a smaller affiliate will be much higher than 10%. An affiliate earning 60,000 euros in commissions from Bulgaria loses 6,000 euros due to the withholding tax and another 6,000 due to the annual fixed fee, losing around 20% of its total Bulgarian earnings even before paying for the content, employees, and media. If the affiliate earns 240,000 euros, the impact is about 12.5%. In case it earns 960,000 euros, the loss is about 10.6%.
The 10% variable charge applies to gross commission, not net margin. An affiliate running paid traffic against thin arbitrage margins in the Bulgarian market can go negative on that traffic while the same model looks healthy in every other jurisdiction. Cash flow is also affected immediately, because the operator withholds monthly rather than settling at year-end. Bulgarian corporate tax at 10% and a 5% dividend tax on distribution apply separately to what remains.
The Scale of Untaxed Revenue That Triggered This
This regime did not arrive through a gambling policy review. It arrived inside a budget, and the numbers written into that budget explain why enforcement will not be relaxed.
Deputy Finance Minister Lyudmila Petkova confirmed that affiliates generate between BGN 450–500m (approximately £219m) in commissions annually in the Bulgarian market, none of which had previously been taxed. The Ministry of Finance expects the new regime to bring in approximately €100m in additional tax revenues for 2026, rising to €150m in 2027. A revenue line that size, written into an approved budget, is pursued differently from a regulatory aspiration. The National Revenue Agency’s blacklist of unlicensed gambling sites moved to daily updates around the same time the law came into force, and banks and payment providers read that list to stop transactions, meaning an unlicensed affiliate feels this first as a payments problem rather than a legal one.
Three Licence Types, One Declaration Form
The NRA’s Gambling Office issued a declaration form that affiliates must complete to enter the licensing process. Applications require a detailed description of every web page, mobile application, social media profile, and video or streaming platform through which the affiliate operates. Three licence durations are available: a one-off affiliation activity, operations lasting under five years, and a full five-year licence.
Applications are processed on a seven-day decision window rather than the standard 60 days used for operator licences, on the assumption the file is complete on arrival. That assumption matters practically; an incomplete file restarts the clock.
The channel declaration is the element most affiliates underestimate. Declaring the full map of affiliated properties, across websites, apps, social accounts, and streaming platforms, is an inventory most portfolios have never formally written down. Adding a new property later is an amendment to a licence, not an administrative update.
What Already Happened, and What Comes Next?
The transition window for existing affiliates closed on 15 August 2026. Those already under active commercial contracts on 1 August had until that date to file an application and remain in the market while the file was reviewed. New entrants applying after 15 August have no transitional protection, and licensed Bulgarian operators are expected to verify the register before making any payment.
Blocking orders can be issued against affiliates operating without a licence. Once the NRA decides a blocking order is warranted, telecom providers must cut access to the affiliate’s pages, applications, and social profiles within 24 hours of publication. The NRA can also instruct banks and payment providers to block outgoing transactions to unlicensed affiliates. Before any blocking order is issued, the commercial reality arrives first: a licensed Bulgarian operator cannot lawfully pay an unlicensed affiliate, so the invoice simply stops.
The Finance Minister must also approve the reporting forms required for certain ongoing NRA obligations by 30 September 2026.
Expert Analysis: This Is Not a Compliance Upgrade, It Is a Market Filter
We should say plainly what most industry commentary has avoided: Bulgaria’s affiliate licensing regime is not designed to bring affiliates into a regulatory framework so they can operate more cleanly. It is designed to collect revenue from a money flow that was invisible to the Bulgarian tax system and to price out the operators who cannot justify the cost.
The regressive fee structure achieves this without explicitly saying so. A €6,000 fixed fee applied equally to an affiliate earning €60,000 and one earning €960,000 in Bulgarian commissions is not neutral regulation. It is a market filter. Smaller affiliates with modest Bulgarian traffic will leave the market or consolidate into larger entities that can absorb the fixed component. Larger affiliates will stay, pay the 10%, file the monthly declarations, and pass some of that cost back through renegotiated commission rates, which Bulgarian operators already anticipate.
The overall message to European regulators, however, is difficult to overlook. For the most part, all EU jurisdictions license the operator and make the operator responsible for its chain of marketing. The country of Bulgaria has simply taken away that escape path for affiliates by licensing the intermediary itself and making the affiliate responsible for payment and reporting as opposed to the operator paying it. In doing so, the traffic and the audience become the issue, as opposed to the registered address. There are several European regulators paying close attention, and at least one large jurisdiction is said to be considering a similar setup. Once again, Bulgaria may have caught everyone off guard with their gambling policy initiative.
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