Bulgaria Brings Gambling Affiliates Under a New Licensing and Tax Regime

Bulgaria has introduced a new regulatory framework placing gambling affiliates under direct licensing and tax obligations, significantly changing the way businesses can promote licensed gambling operators in the country.

The new rules, which entered into force on 1 August 2026, bring affiliate marketing into the scope of Bulgaria’s gambling regulatory system. Affiliates that generate remuneration based on measurable results linked to gambling activity are now required to obtain authorisation and comply with a dedicated taxation regime.

The reform forms part of a broader government effort to bring previously unregulated activity into the taxable economy and increase oversight of Bulgaria’s gambling sector.

New licensing requirement for affiliates

Under the new framework, businesses involved in promoting gambling activities must obtain an affiliate licence from the National Revenue Agency (NRA).

The licensing process requires applicants to provide information about the channels through which gambling is promoted. This includes websites, mobile applications, social-media accounts and relevant video or streaming platforms.

The framework provides for different forms of authorisation, including approval for a specific affiliate activity, shorter-term arrangements and licences covering a period of up to five years.

Existing affiliate relationships were given a transitional window. Businesses that already had an agreement or arrangement with a licensed gambling operator as of 1 August were required to submit their applications by 15 August 2026. Existing agreements could remain in effect while the licensing process was being completed.

The legislation therefore moves affiliates from a largely commercial relationship with gambling operators into a formally regulated position within the gambling ecosystem.

A two-part tax on affiliate activity

One of the most significant elements of the reform is the introduction of a two-component state fee.

Licensed affiliates are subject to an annual fixed charge of €6,000, together with a 10% variable charge on performance-based commission.

The variable component applies where affiliate remuneration is linked to measurable results. These can include the number of players referred, deposits, bets or other agreed performance indicators.

This means that affiliate arrangements based on CPA, revenue share or other performance-related structures may have direct tax implications under the new system, depending on how the remuneration is calculated.

The annual component is payable each year, while the variable element is connected to the commission earned through qualifying performance.

Government targets previously untaxed affiliate income

The changes are closely connected to Bulgaria’s broader objective of increasing tax collection from gambling-related activities.

Government estimates have indicated that Bulgarian gambling affiliates generate approximately BGN 450–500 million in annual commissions. The introduction of licensing and taxation is intended to bring this activity into the formal taxable economy.

The authorities have set significant revenue expectations from the wider gambling reforms, with additional tax receipts projected at approximately €100 million during 2026 and rising to around €150 million in 2027.

The affiliate regime is therefore not simply an administrative licensing measure. It forms part of a wider attempt to reduce activity outside the formal tax system and increase the contribution of the gambling industry to public revenues.

Foreign affiliates face an additional requirement

The new framework also affects businesses established outside Bulgaria.

A foreign company wishing to conduct affiliate activity in the Bulgarian market must appoint an authorised representative with an active address in Bulgaria. The representative must have authority to enter into contractual arrangements on behalf of the affiliate and represent it before Bulgarian authorities.

For international affiliate networks and companies operating across several European markets, this requirement may create additional administrative and operational costs.

Businesses that previously operated from another jurisdiction without a Bulgarian presence may therefore need to reassess their corporate and compliance arrangements if they intend to continue targeting the Bulgarian gambling market.

Consequences of operating without a licence

The new framework gives the authorities significant enforcement powers.

Affiliates operating without the required authorisation may be subject to blocking measures. The NRA can also instruct banks and other payment service providers to restrict outgoing payments to unlicensed affiliates.

This creates a potentially serious commercial risk for businesses that continue operating without completing the required licensing process.

The consequences may extend beyond regulatory penalties. Payment restrictions could interfere directly with the collection of commissions and the ability of an affiliate to maintain its commercial relationships with gambling operators.

What the changes mean for the affiliate sector

The Bulgarian reform represents a substantial shift in the regulatory treatment of gambling affiliates.

Affiliate marketing has traditionally operated as an advertising and customer-acquisition activity positioned outside the licensing framework that applies directly to gambling operators. Bulgaria is now treating certain affiliate activities as sufficiently connected to gambling operations to justify direct regulatory supervision.

The practical consequences are likely to be particularly relevant for affiliates whose income depends on player registrations, deposits, betting activity or other measurable gambling outcomes.

Businesses operating in the sector will need to consider not only whether they require a licence, but also whether their existing contractual arrangements accurately reflect the new taxation rules.

Websites and other promotional channels may also need to be reviewed to ensure that the information submitted during the licensing process corresponds with the affiliate's actual activities.

A more closely monitored gambling marketing environment

The new regime is likely to increase transparency across Bulgaria's gambling advertising and affiliate market.

By requiring affiliates to disclose their websites, applications, social-media channels and other promotional platforms, regulators will have greater visibility over how licensed gambling operators are promoted and how customers are directed towards them.

At the same time, the financial burden of the regime could affect smaller affiliates disproportionately. A fixed annual charge of €6,000, combined with a 10% levy on qualifying commission, may make some lower-volume affiliate arrangements less commercially attractive.

Larger affiliates and established affiliate networks are likely to be better positioned to absorb the additional costs, but they will still need to adapt their compliance, reporting and contractual processes.

Increased compliance obligations for operators and affiliates

The changes also mean that gambling operators will need to pay closer attention to the affiliates with which they work.

Operators may need to verify that their affiliate partners hold the appropriate authorisation and that commission arrangements are structured in a manner consistent with the new rules.

For affiliates, compliance will extend beyond simply obtaining a licence. Companies should maintain accurate records of their promotional activities, commercial agreements, performance-based remuneration and the digital channels used to market gambling services.

International businesses should also assess their local representation arrangements and determine whether their existing corporate structure is compatible with the Bulgarian requirements.

Looking ahead

Bulgaria's new affiliate regime marks a significant development in the regulation of gambling marketing in Europe.

The introduction of mandatory licensing, a fixed annual fee and a performance-based levy creates a substantially more formal regulatory environment for affiliates operating in the Bulgarian market.

The immediate focus will be on implementation and enforcement as businesses adjust to the new requirements. For affiliates, the priority is to establish whether their activities fall within the regulated framework, secure the appropriate authorisation and ensure that their commercial and tax arrangements are capable of meeting the new obligations.

For gambling operators, the changes add another layer of responsibility when selecting and managing affiliate partners.

Ultimately, the reform reflects a broader regulatory trend: gambling authorities are increasingly looking beyond licensed operators themselves and towards the wider network of businesses responsible for acquiring customers, promoting gambling products and generating gambling-related revenue.

By fLEXI tEAM