Bulgaria Enforces Affiliate Licensing Across Digital Channels

The Bulgarian Parliament’s legislative file defines a gambling affiliate as a person other than a gambling organiser that promotes games under a contract or arrangement in return for commission linked to results. The listed performance measures include the number of players attracted, deposits, bets and winnings paid.

The remuneration model is therefore central to determining whether a supplier falls within the licensing perimeter. A business is not classified as an affiliate merely because it provides advertising, media placement, content production or technical services. Where payment depends on registrations, first-time depositors, wagering activity, revenue or another measurable acquisition result, the arrangement is likely to fall within scope.

Mixed contracts require particular attention. Operators and suppliers should separate fixed media or technology fees from cost-per-acquisition and revenue-share payments, ensuring that the written terms correspond with the commercial substance of the relationship.

This assessment is also necessary when expanding affiliate activity in the country. Commercial developments such as the opening of additional Bulgarian traffic opportunities across affiliate brands must now be evaluated against the licensing position of both the traffic source and the operator receiving the players.

Applicants must provide details of all websites, mobile applications, social-media profiles, video platforms and streaming channels used to promote gambling. The licence certificate records these channels alongside the affiliate’s identity and representatives, making the declared digital footprint part of the regulatory approval.

For affiliate groups operating multiple domains or content brands, this creates a continuing inventory requirement. Compliance teams should maintain an authoritative register covering domains, subdomains, comparison sites, apps, creator accounts and streaming profiles. Marketing teams should not activate a new channel until its effect on the licence record has been reviewed.

The requirement is particularly relevant to social-native acquisition. A tracked link placed in an influencer profile, video description, livestream or messaging channel may form part of the regulated promotional activity even when the affiliate does not control a conventional comparison website.

Regulators are increasingly extending enforcement beyond B2C operators to the intermediaries that generate exposure and traffic. Sweden’s recent scrutiny of affiliates and influencers promoting unauthorised gambling demonstrates the broader direction of travel. In Bulgaria, affiliates must verify that every promoted operator holds an active domestic licence and that all content complies with national advertising restrictions.

The National Revenue Agency administers gambling licensing, supervision and related public claims in Bulgaria. Applications may be submitted by Bulgarian or foreign legal and natural persons, including sole traders.

The statutory review and examination period for an affiliate application is seven days from receipt. If documents are incomplete or additional information is required, the NRA must notify the applicant within three days and provide seven days to correct the deficiencies. The review period stops while the authority waits for the requested material.

Foreign affiliates are not expressly required to incorporate a Bulgarian company, but they must declare an authorised representative with an address in the country. The representative must be empowered to conclude contracts for the foreign affiliate and represent it before Bulgarian public authorities and courts.

A correspondence address or nominal contact will not meet that standard. Applicants should ensure that powers of attorney, board approvals and internal delegations expressly cover the authority required by the Gambling Act.

Maintaining an affiliate licence carries a two-component state fee. The affiliate pays a fixed annual amount of €6,000 by 31 March. A business licensed after that date must pay before receiving its licence certificate.

The variable component is 10% of performance-linked commission. The licensed gambling operator that accrues the commission must withhold the amount, submit the required monthly declaration and transfer the fee to the NRA by the 15th day of the following month.

Operator finance teams should incorporate the obligation into the NRA’s electronic gambling declaration process. Commission statements, tracking data, invoices and declared amounts should be reconciled before each reporting deadline.

The law raises the variable rate to 20% where a sham transaction is used to conceal performance-based commission. Reclassifying acquisition or revenue-share payments as unrelated services without changing their underlying economic purpose therefore creates material financial and regulatory exposure.

These affiliate charges must not be conflated with Bulgaria’s separate 25% variable state fee for gambling operators. The affiliate framework establishes an additional payment and reporting chain; it does not replace or extend the operator fee.