The draft 2026 State Budget of the Republic of Bulgaria Act proposes significant amendments to the Gambling Act which, if adopted, would affect both affiliate service providers and the regime for combating unlicensed B2C operators. The principal proposals may be summarised as follows:

1. Licensing of affiliate providers

Going forward, affiliate providers would be subject to licensing. The principal features of the regime are as follows:

• Affiliate providers would be permitted to provide services only to licensed B2C operators;

• Obtaining an affiliate provider license would require certain conditions to be met;

• Affiliate marketing would have to comply with the general marketing requirements and limitations;

• The NRA would be empowered to block webpages, mobile applications and social media pages of unlicensed affiliate providers;

• During the licensing procedure, the affiliate provider would be required to list exhaustively all websites, mobile applications, social media profiles and video streaming profiles that it will use for the provision of the affiliate marketing services;

• New taxation of affiliates:

- a license maintenance fee of EUR 6,000 per annum;

- plus 10% on the result-based commissions;

- the fixed fee is payable annually, while the result-based commission is payable monthly by the operators, who would be required to withhold the 10% and remit it to the NRA on behalf of the affiliate provider;

• A very short window would be available for the submission of licensing applications by all existing affiliate providers.

2. Measures against unlicensed B2C operators

The draft also proposes measures to strengthen action against unlicensed B2C operators:

• Carrying out or allowing the marketing of (unlicensed) B2C operators would constitute a breach of the Gambling Act;

• At least once a month, the Executive Director of the NRA would provide to all payment institutions the IBANs of all blacklisted operators and of operators whose license has been revoked. The procedure for providing the data would be set out in an Ordinance;

• Payment institutions would be required to block any gambling-related transfers to those IBANs.

At this stage, these amendments constitute proposals contained in the draft 2026 State Budget Act and remain subject to the legislative process; their wording and scope may therefore change before adoption. The firm will continue to monitor developments and keep its clients informed of any material changes.