Selling or arranging insurance in Bulgaria is regulated. A business must decide whether it will act as an insurance broker for the customer or an insurance agent for an insurer. The choice changes who files, whose products may be offered, and who carries liability.

Both models appear in the public register of the Bulgarian Financial Supervision Commission (FSC/KFN). Activity should not begin until the relevant entry is visible and the intermediary's operational safeguards are in place.

Insurance-distribution rules, FSC forms, fees, and EU monetary thresholds change. Confirm the current position before filing or signing an agency agreement. This guide is general information, not legal, regulatory, tax, or insurance advice.

Registration at a Glance

Broker and Agent Are Different Legal Models

The consolidated Bulgarian Insurance Code defines a broker as a company or sole trader performing intermediation for remuneration under a customer's mandate. It analyses risks and coverage, places contracts, monitors renewals, and assists with claims. “Fair and personal” advice requires analysis of a sufficiently broad market range.

An agent is a natural person or trader appointed to act in the insurer's name and for its account. It must identify its insurers and authorised products; offering several products does not make it a whole-market adviser.

For a new Bulgarian entity, our company-registration guide explains the preceding Commercial Register process. Incorporation alone never authorises insurance intermediation.

Requirements for an Insurance Broker

Legal Form, Management, and Good Repute

Only a commercial company or sole trader may be a broker. Managers, representatives, and the sole trader must satisfy the statutory reputation and insolvency tests. These include no disqualifying intentional-crime conviction, no deprivation of the right to hold a materially responsible position, and no specified history involving insolvency with unsatisfied creditors.

The person or persons responsible for managing insurance distribution must have higher education and either:

• at least two years' qualifying insurance experience plus the required training; or
• a pass in the FSC professional knowledge and skills examination.

The experience must be managerial or directly connected with concluding and performing insurance contracts at an insurer, reinsurer, broker, or agent. Distribution employees need at least secondary education, good repute, and the knowledge in Annex 3 to the Code. New distribution staff complete training and an examination; relevant managers and staff then complete at least 15 hours of continuing development annually.

Professional Indemnity and Client-Money Protection

A broker must continuously hold professional indemnity insurance covering the EU and EEA. Delegated Regulation (EU) 2024/896, applicable since 9 October 2024, sets the current minimum at EUR 1,564,610 per claim and EUR 2,315,610 in aggregate per year. These are policy limits, not a capital deposit or the premium paid for the policy.

The broker must separately protect premiums and claim payments passing through it. It chooses between:

1. maintaining own funds equal to 4% of premiums intermediated in the previous financial year, subject to a minimum of EUR 23,480; or
2. using one or more special client accounts solely for premiums and insurance payments.

Client-account money is outside the broker's estate, cannot be attached, and does not enter insolvency assets. Notify the FSC before changing safeguard method. Its current intermediary-limit page confirms the EUR 23,480 floor.

Broker Documents and Registration Procedure

The application follows Article 307 of the Insurance Code and FSC Ordinance No. 67. A typical file includes:

• the articles, memorandum, or company agreement;
• details and declarations for managers and representatives;
• the corporate decision appointing the person responsible for distribution;
• higher-education, experience, training, or FSC-examination evidence;
• office and branch addresses;
• professional indemnity policy;
• evidence of own funds or a Bulgarian bank certificate for each client account;
• information on shareholders holding at least 10%, close links, and beneficial owners;
• incompatibility and good-repute declarations; and
• information about the secure electronic-delivery profile required by Article 300b.

The broker may submit electronically using the Ordinance 67 form. The FSC decides within one month of receipt. If documents are irregular or more information is needed, the correction period must be at least 15 days. Registration is effective only after the decision, applicable payment, and entry in the public register—not when the company files its request.

The FSC's current fee schedule lists EUR 5,281.65 for broker entry. If an intended distribution manager needs the FSC examination, the published fees are EUR 317 for admission, EUR 209.63 for recognition of a qualification, and EUR 15.34 for a certificate or duplicate. Confirm the service, payment reference, and timing before transfer.

Requirements and Registration for an Insurance Agent

An agent may be a natural person, sole trader, or company. A natural-person agent practises a free profession and cannot simultaneously be an employee of an insurer. The agent signs a written agreement defining the products, classes, authority, territory, premium-handling rights, and maximum sums it may conclude.

By default, an agent may represent one life and one non-life insurer. The limit does not apply within an insurance group; with consent, extra appointments may cover non-overlapping classes. Coordinating nominally separate agents to evade this rule can constitute unregistered brokerage.

Managers and natural-person agents need at least secondary education, good repute, and appropriate knowledge. The insurer normally provides product-distribution training, conducts the examination, and issues the training certificate. It also organises continuing professional development.

An agent needs professional indemnity insurance at the EU limits unless its insurer assumes full responsibility in writing. Companies and sole traders also apply Article 306 money safeguards. A natural person normally uses a client account unless insurer responsibility applies. No separate account is needed when funds pass directly through an insurer-owned account.

Who Submits the Agent Entry?

For an agent of a Bulgarian insurer, the insurer checks the qualifications, reputation, ownership data, safeguards, and documents, then submits the request through the FSC online portal. Submission certifies that the insurer has completed that verification. A successful portal filing updates the register; the agent should wait for public confirmation and its identification certificate before selling.

A Bulgarian-based agent acting for an insurer from another EU Member State that provides services in Bulgaria without establishment must file its own request, with the Article 307 documents, within 14 days after signing the agency agreement. This is an important exception to the normal insurer-filed route.

The 2026 FSC tariff does not list a separate initial entry charge for a domestic agent. It does list annual supervision fees due by 31 March: EUR 35.79 for a natural person and, for a company or sole trader, EUR 383.47, EUR 766.94, or EUR 1,533.88 depending on prior-year premium income.

Annual Fees and Broker Reporting

Broker annual supervision fees are also due by 31 March. The current brackets range from EUR 3,323.40 to EUR 5,368.56 according to prior-year premium income.

In addition, a broker files:

• annual supervisory returns by 31 January;
• half-year returns by 31 July; and
• an annual financial statement by 31 March when it uses own funds rather than client accounts as its money-transfer safeguard.

The returns are electronic, follow the current FSC schema, and require a qualified electronic signature. Registration should therefore be budgeted as an ongoing regulated operation, not a one-off certificate.

EU Passporting and Third-Country Intermediaries

A Bulgarian broker or agent may use the Insurance Distribution Directive passport for another EU/EEA state, but it must first notify the FSC with the destination, classes, and whether it will operate through a branch or under freedom to provide services. For first-time cross-border services, the FSC transmits a complete notification to the host regulator within one month and informs the intermediary. Host-state public-interest rules still apply.

Conversely, an EU/EEA intermediary registered in its home state enters Bulgaria through regulator-to-regulator notification rather than a duplicate full Bulgarian licence. Verify both home registration and the Bulgarian notification before launch.

A third-country intermediary generally needs a Bulgarian branch and local registration under the newer branch regime. Such a branch cannot use its Bulgarian entry to passport onward through the EU. Our Bulgarian branch guide explains the Commercial Register component, which remains separate from FSC approval.

Ongoing Conduct and Compliance Duties

Both intermediaries need compliance processes that work before the first sale:

• maintain a secure electronic-delivery profile and notify the FSC of it within seven days;
• report registered changes within seven days through the responsible filing route;
• preserve professional indemnity and client-money safeguards without a coverage gap;
• document annual training of at least 15 hours and supervise distribution staff;
• disclose identity, register entry, insurer relationships, qualifying ownership, complaints route, and the nature of remuneration before contract;
• identify and document the customer's demands and needs, provide understandable product information, and recommend only a matching product;
• disclose a direct customer fee or its calculation method;
• retain evidence of advice, disclosures, consent, and the insurance product information document; and
• maintain complaint handling, conflicts, data protection, and—where the distributed products bring the firm within scope—anti-money-laundering controls.

The public should be able to verify a broker in the FSC broker register and an agent in the relevant FSC agent register.

Common Registration and Operating Mistakes

• calling a multi-insurer agent an “independent broker” without broker registration
• treating professional indemnity limits as the price of the insurance
• omitting the separate own-funds or client-account safeguard
• assuming every agent is automatically covered by its insurer without a written responsibility declaration
• employing a natural-person agent as an insurer employee
• promising whole-market advice without performing the required fair and personal analysis
• starting activity after application but before public entry
• missing the new secure-delivery profile or seven-day change deadline
• budgeting the entry fee but not the annual supervision fee, reporting, training, and compliance systems

Pre-Launch Checklist

• Customer-side broker or insurer-side agent model documented
• Entity form and business objects aligned with the chosen route
• Managers, responsible person, and staff pass qualification and reputation checks
• Professional indemnity policy or valid insurer-responsibility declaration in place
• Own-funds or client-account safeguard documented where required
• Agency or customer mandate and remuneration terms signed
• FSC forms, ownership data, translations, and electronic signatures ready
• Public register entry verified before sales begin
• Training, complaints, disclosures, records, and reporting calendar operational
• EU notification completed before any passported activity

How Lion Consult Can Help

Lion Consult can select the structure, incorporate the entity, coordinate qualification and ownership evidence, review indemnity and client-money arrangements, and prepare the FSC submission and cross-border documents.

Contact Lion Consult before signing insurer appointments or committing to a launch date. The correct legal model should be settled before contracts, systems, and marketing are built around it.

Final disclaimer: This article reflects primary sources checked on 1 August 2026. It cannot determine whether an activity is insurance distribution, a person is fit and proper, or a product triggers additional conduct, investment-insurance, AML, consumer, or host-state rules. Confirm the live FSC forms and tariff.

Frequently Asked Questions

What is the difference between an insurance broker and an insurance agent in Bulgaria?

A broker acts under the customer's mandate, analyses risks and coverage, and may place suitable products. An agent acts in the name and for the account of one or more appointing insurers and may offer only the products and classes covered by those appointments.

What professional-indemnity limits apply in 2026?

The current EU minima are EUR 1,564,610 per claim and EUR 2,315,610 in aggregate per year. A broker must hold this cover; an agent may instead be covered by an insurer's written assumption of full responsibility.

Does a Bulgarian insurance broker need minimum capital?

A broker must protect transferred money either with own funds equal to 4% of the previous year's intermediated premiums, subject to a EUR 23,480 minimum, or through special client accounts. This is separate from professional-indemnity cover.

How long does broker registration take and what is the FSC fee?

The FSC decides on a complete broker application within one month and must allow at least 15 days to correct deficiencies. The current initial-entry fee is EUR 5,281.65; preparation and correction time are additional.

Can an individual register as an insurance intermediary?

An individual may be an insurance agent as a free profession, but a broker must be a commercial company or sole trader. A natural-person agent cannot be employed by the appointing insurer.

Can a Bulgarian broker or agent operate elsewhere in the EU?

Yes, after the required notification and FSC communication under the Insurance Distribution Directive passporting process. A third-country intermediary's Bulgarian branch cannot use its registration for onward EU passporting.

What ongoing duties apply after registration?

Intermediaries must maintain qualifications and safeguards, complete at least 15 hours of annual training, comply with disclosure and demands-and-needs duties, report relevant changes generally within seven days, and meet applicable periodic-reporting deadlines.