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Amendments to the Bulgarian Gambling Act, which entered into force on 1 August 2026, introduced a specific licensing regime for affiliate operators promoting gambling games. The new rules define who qualifies as an affiliate operator, introduce a separate licence for this activity, and impose specific requirements regarding licensing, advertising by such operators and fees.
1. Who is an affiliate operator?
An affiliate operator is a person other than an organiser of gambling games who promotes them under an agreement in return for a performance-related commission, such as commission linked to the number of participants attracted, deposits, bets or winnings paid out. Ordinary advertising, media or technical service providers do not fall into this category where their remuneration does not depend on such results.
The new regime applies to both Bulgarian and foreign natural and legal persons, including sole entrepreneurs. A foreign affiliate operator must appoint an authorised representative with an address in Bulgaria and sufficient authority to represent the operator before Bulgarian authorities and courts and to enter into agreements on its behalf.
2. What licence is required?
From 1 August 2026, affiliate operators must hold a separate licence for promoting gambling games issued by the Executive Director of the National Revenue Agency (“NRA”). The licence identifies the affiliate operator and its representatives, as well as the websites, mobile applications, social media profiles and video or streaming platforms through which gambling games are promoted.
Importantly, affiliate operators may promote gambling games only on behalf of organisers holding a valid gambling licence and must comply with the statutory restrictions applicable to the advertising of gambling games.
3. What are the registration and ongoing compliance obligations?
Affiliate operators are required to submit an application for licence prior to commencement of activity. Persons already promoting gambling games under an agreement or arrangement with licensed organisers of gambling games as of 1 August 2026 must apply for a new licence by 15 August 2026. Their existing agreements remain effective until the licence is issued.
4. How much does the licence cost?
Maintaining an affiliate operator licence involves a two-part government fee – EUR 6,000 per year plus 10 per cent of the performance-related commission. The variable component is withheld and paid to the NRA by the organisers of gambling games that pay the relevant commission. Where a sham transaction conceals performance-related commission, the variable fee increases to 20 per cent of the concealed commission.
5. What are the penalties for non-compliance?
The regime is supported by substantial financial sanctions. Promotion of gambling games without the requisite licence, or on behalf of an organiser not holding a valid licence, may result in a financial penalty of EUR 5,000 to EUR 20,000, doubled in the event of repeated violations; natural persons are subject to a fine of EUR 3,000 to EUR 10,000.
Furthermore, the Executive Director of the NRA is empowered to suspend an affiliate operator’s licence for a period of three to six months. Repeated or serious breaches may result in permanent revocation of the licence.
The new framework marks a significant shift in the regulatory treatment of gambling affiliate marketing in Bulgaria: performance-based promotion is no longer merely a commercial or advertising arrangement, but a specifically regulated and licensed activity. Affiliate operators and organisers of gambling games should therefore review their existing arrangements, licensing status, advertising practices and contractual relationships to ensure compliance with the new requirements and minimise the risk of significant financial and regulatory consequences.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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