Bulgaria is the only EU member state on the FATF grey list. The Financial Action Task Force listed ten things Bulgaria had to fix. Item four was the accuracy of the beneficial ownership data in its company register. Your AML contact person is part of that data. So a filing most foreign owners treat as paperwork now sits inside a national commitment, graded from outside the country.
Quick answer: Your Bulgarian company needs an AML contact person when nobody entered on its file as a legal representative has permanent residence in Bulgaria. It has to be a named individual, not a firm. They sign a notarised consent first, and their details go into the Commercial Register with your beneficial owner declaration. They receive and pass on ownership information. They cannot manage or sign for the company.
Jump to: How we checked this · Who needs one · Three roles, one name · What they're on the hook for · What it costs to get wrong · Making the appointment · Signals your filing is stale · Why 2026 changed the stakes · Choosing by situation · FAQ
Last reviewed: September 2026. Checked against the FATF statement of 19 June 2026, the Measures Against Money Laundering Act, and current Registry Agency practice.
How we checked this, and what we couldn't confirm
Legal guides to this topic age badly, because the penalty regime moved in 2024 and the currency moved in 2026. So we went to the sources that carry dates rather than to summaries of them.
We read the FATF's 19 June 2026 statement directly rather than press coverage of it, and counted the listed jurisdictions ourselves. Every article number below was checked against the text of the Measures Against Money Laundering Act (ZMIP), not against somebody's summary of it. We also used the implementing regulation, last amended in July 2025. The State Agency for National Security (DANS) has published guidance on when contact person data is and isn't required, and we used that too. For what's coming, we used the EU AML package texts.
Three categories of source got thrown out. Anything describing the penalty for a missing beneficial owner filing at its pre-July-2024 level. Anything quoting lev amounts as current without saying they predate euro adoption. And any guide that treats "contact person" as a single role, because in Bulgarian AML law it names three different ones.
Three limits worth stating. The fine amounts here were legislated in lev, so the euro figures are conversions at the fixed rate of 1.95583 BGN to 1 EUR, not separately enacted numbers. The consolidated statute we worked from runs to early 2021, so any later penalty change here carries the date of the reporting that announced it. And we haven't quoted a state filing fee, because we couldn't confirm the 2026 euro tariff for this application. We'd rather leave a gap than publish a number you might budget against.
Who actually needs an AML contact person
The test is narrower than most people assume, and it points at the wrong person in almost every summary you'll read.
It's about your legal representative, not your owner. Does your company's file at the Commercial Register show a manager with permanent residence in Bulgaria? Then you don't need a contact person at all. DANS put this plainly in its guidance. Contact person data isn't requested where a permanently resident legal representative is already on the entity's file.
Run that backwards and the practical cases fall out fast:
- Foreign owner, Bulgarian manager: no contact person needed. A 100% German-owned EOOD with a Sofia-resident manager is clear.
- Foreign manager, no Bulgarian residence: you need one. This is the standard case for a remotely run company.
- Foreign manager with Bulgarian residence: no contact person needed, from the day that residence is on file.
- Dormant or holding company: still needed. Being exempt from declaring beneficial owners doesn't exempt you here.
That last one catches people. A company can sit outside the beneficial owner declaration duty and still owe a contact person filing. Different facts trigger the two obligations. Non-profit legal entities and formations registered in BULSTAT rather than the Commercial Register are inside the same rule.
Notice what's absent from the test. Nothing about turnover, nothing about sector, nothing about whether you trade. A dormant holding vehicle run from Dubai owes exactly what a busy trading company run from Dubai owes. If you're at the setup stage, this is worth deciding before incorporation rather than after, because it changes who you appoint as manager. Our notes on company formation in Bulgaria cover where the two decisions meet.
Three different roles get called "contact person"
Here's the thing that costs foreign owners the most money, and it isn't a fine. It's buying the wrong service for two years and staying non-compliant the whole time. Bulgarian AML law uses one label for three separate jobs.
The Article 63(4) contact person
This is the one this article is about. A local individual whose details sit in the company register so that ownership information about your entity can be obtained from someone inside the country. Every Bulgarian company without a resident representative needs one, whatever it does for a living.
The internal control officer under Articles 106 and 107
Completely different duty, completely different population. This one applies only if your company is itself on the obliged entity list in Article 4 of ZMIP. Think banks and payment firms, accountants and tax advisers, notaries and lawyers. Real estate agents, dealers in high-value goods, gambling operators and company service providers are on it too. Those businesses run internal AML control, and the designated person's name goes to the Financial Intelligence Directorate at DANS within seven days. A trading EOOD selling software doesn't need one.
The central contact point
Narrower again. This one covers electronic money issuers and payment service providers headquartered in another EU member state, operating here in some form other than a branch. If you're not in that business, it isn't yours.
Why does the mix-up matter so much? Because the failures look identical from your desk. You've paid a provider, you have a contract naming a contact person, and nothing arrives in the post. Meanwhile the obligation you actually owed sits unfilled, and in the Article 4 case DANS is the body that notices.
What the contact person is actually on the hook for
Section 61 of ZMIP puts the duty in three verbs: receive, hold, and make available. What has to be received, held and made available is adequate, current and accurate information on the entity's beneficial owners. That includes detail on the rights those people hold. This last part does real work. It isn't a name and a passport number, it's the shape of the control.
Information travels two ways here. Obliged entities that are entitled to demand it can ask, which in practice means your bank, your notary and your accountant. Law enforcement and DANS can ask too. Your contact person is the address that answer comes from.
Now the limits, because providers are vague about these and buyers assume too much. A contact person has no management or representation powers. They can't sign a contract, open an account, bind the company, or act as its director. They are a point of contact for ownership information and nothing beyond it. Anyone selling you a contact person appointment as a substitute for a local director is selling you something the register won't treat as one.
One honest gap. The statute says "receive" without defining how hard the person has to work at it. Must a contact person actively chase a silent shareholder abroad, or only stay reachable and pass on what arrives? Bulgarian courts haven't settled it, and legal commentary has flagged the question as open. That's a reason to appoint someone who documents what they asked for and when, rather than someone who simply lends you a name.
What it costs to get this wrong
Exposure splits unevenly between the company and the individual, and the gap is wider than most people expect.
Your contact person carries a personal fine under section 118(5) of ZMIP for failing to perform the duties in sections 61 and 62. It runs from BGN 100 to BGN 1,000 (EUR 51 to EUR 511) the first time. A later occasion doubles the range to BGN 200 to BGN 2,000 (EUR 102 to EUR 1,023).
The company's exposure is the serious one, and here's the part that makes it bite. Your contact person's details are item 3 of the Article 63(4) declaration. They sit in the same filing as your beneficial owners. So a missing contact person is a missing part of that filing, not a separate, lesser offence.
Section 118(4) is what turns that into real money. Once a company has been penalised for not filing that data and still doesn't file, the penalty lands again every month. Bulgaria set the beneficial ownership filing sanction at BGN 5,000 for a company on 16 July 2024, up from a BGN 1,000 to 10,000 range. At the fixed conversion rate that's EUR 2,556 a month. Leave it unresolved for a year and the arithmetic reaches roughly EUR 30,700.
Put those side by side. The company's monthly sanction is about five times the worst single fine the contact person can receive. Owners often ask whether appointing someone shifts the risk onto them. That ratio is your answer. They take a small slice, and you keep the rest.
Directors don't sit outside this either. Section 118(1) catches whoever commits a breach of the Act or permits one to be committed, a concept Bulgarian law calls dopustitelstvo. Case law puts a filter on it: the company itself has to be found liable before its director is. That's a sequencing protection, not immunity.
One point cuts the other way, and it's the one owners never hear. Section 63(7) obliges your beneficial owners to hand the company, or its contact person directly, all the information needed to make these filings. That duty is real and it's theirs. So a contact person chasing a silent shareholder isn't asking a favour, and a shareholder who stonewalls isn't merely being unhelpful.
Making the appointment: what the register wants
Mechanically this is short work, but two steps derail timelines.
Your contact person must be a natural person permanently resident in Bulgaria. Bulgarian citizens qualify on citizenship. A foreign national qualifies on permanent residence, not on owning property or spending summers here.
They also have to agree, in a specific form. The consent is a separate notarised document, submitted with the declaration. That's the one structural difference between a contact person and the other individuals named in AML filings. A beneficial owner never consents to being disclosed. Neither does a senior management official named in place of one. Your contact person does, which means they can also decline, and can stop.
The filing itself is the Article 63(4) declaration, with the signature notarised. It goes to the Commercial Register, the Register of Non-Profit Legal Entities, or BULSTAT, depending on where your entity lives. Changes to the details are due within seven days.
Two things add weeks rather than days, and they're both about documents crossing a border. Corporate paperwork issued abroad needs an apostille and a sworn Bulgarian translation before the register will look at it. That's why translation and legalisation usually runs in parallel with the filing rather than after it. And if your manager is signing from abroad, their notarised signature needs the same treatment. Sequence it the wrong way and a filing that takes an afternoon in Sofia takes a month from Sydney.
Signals your filing is already stale
A contact person entry isn't a thing you do once. Since 16 July 2024 there's a mechanism that actively surfaces out-of-date entries, and it runs through the businesses you already pay.
Obliged entities under Article 4 have to notify the Registry Agency when they find a mismatch. The comparison is between the ownership data they hold on you and what your register file says. They get 14 days from spotting it. Your bank, notary and accountant are all in that population. They collect ownership data on you during routine onboarding and review. If it disagrees with the register, reporting the difference is their duty, not a courtesy.
So the practical question isn't whether anyone reads your file. It's who is comparing it to something. Four situations mean yours needs a look:
- Your contact person has moved abroad, changed their address, or stopped answering for you.
- Your manager gained Bulgarian residence, which may mean you no longer need the appointment at all.
- Ownership changed anywhere in the chain above the Bulgarian entity, including a step you consider foreign and unrelated.
- You're about to open a bank account, refinance, or sell, all of which trigger fresh ownership checks by someone with a reporting duty. If that's on your horizon, due diligence work normally finds this before your counterparty does.
Why 2026 changed the stakes
Three things moved, and they push in the same direction.
The FATF one is the headline. At its plenary on 19 June 2026, the Financial Action Task Force made an initial determination that Bulgaria has substantially completed its AML action plan. The FATF also decided Bulgaria warrants an on-site assessment, to verify that reform has begun and is being sustained. Bulgaria remains one of 22 jurisdictions under increased monitoring, and the only EU member state among them. Read the ten reforms the FATF lists and item four is the accuracy of beneficial ownership data in the register. An on-site assessment team checks claims like that by sampling the register, which is a blunt way of saying your file is the evidence. The full statement is on the FATF site.
Second, the currency. Bulgaria replaced the lev with the euro on 1 January 2026 at the fixed rate of 1.95583, so any guide quoting a lev-only AML fine was written before the changeover. The underlying statutory amounts were set in lev, which is why you'll see both figures in careful sources and only one in careless ones.
Third, the EU rulebook is arriving. Regulation (EU) 2024/1624, the AML Regulation, applies directly in all member states from 10 July 2027, with no transposition step. The accompanying directive phases in earlier, and its provisions on developing beneficial ownership registers fell due on 10 July 2026. The new EU Anti-Money Laundering Authority has been operating in Frankfurt since 1 July 2025. Bulgarian register practice is heading toward a harmonised standard. The direction of travel is from "something is on file" to "what's on file is right".
Choosing a contact person by situation
Match yourself to one of these rather than buying a generic package.
Sole manager abroad, trading. You need an appointment, and you should treat it as a service rather than a favour. The obliged entities that will query your file are the ones you bank with. A contact person who doesn't respond creates a discrepancy report, not a phone call. Use a provider who is contractually reachable during Bulgarian business hours. Skip the friend-of-a-friend arrangement here, because the person who stops answering is the one you can't invoice for the consequences.
Timing: residence application already in progress. The requirement ends the day a permanently resident legal representative is entered on your file. If your own residence certificate is four months out, don't sign a three-year contact person engagement. Ask for a term that matches the gap. Confirm what it costs to end the appointment early, because that takes a register filing rather than an email.
Dormant holding company. You still need one, and this is where owners overpay in the opposite direction. There's no monthly correspondence to handle and no bank relationship to service. What you're buying is a name that stays valid and a filing that stays current. Price it against annual maintenance, not against a full corporate secretarial package. Pairing it with the registered address you already need is usually the cheaper route.
Your business is on Article 4. Accountancy firms, real estate agencies, dealers in high-value goods, company service providers. You owe both obligations at once. There's the contact person filing in the register, and an internal control officer notified to DANS within seven days. Buying one and assuming it covered the other is the mix-up described above, and it's the most common one in this category. If bookkeeping and AML control sit with the same provider, our accountancy services page sets out where the two overlap.
Questions buyers ask before appointing one
Do I need an AML contact person if my Bulgarian company has a foreign owner?
Not because of the ownership. The test looks at your legal representative. A company owned entirely from abroad, but managed by someone with permanent residence in Bulgaria, doesn't need one. Flip it around and a Bulgarian-owned company managed from abroad does. Ownership location is the wrong thing to check, and it's the most common error in guides on this topic.
Can a law firm or accounting company be my AML contact person?
No. The role has to be a natural person with permanent residence in Bulgaria, so a company can't hold it. What a firm can do is nominate one of its own people. That individual is named in the register and consents personally before a notary. When you buy this as a service, check which named individual you're actually getting and what happens if they leave.
How much is the fine if my company has no contact person on file?
More than most people expect, because the contact person's details are item 3 of the same Article 63(4) declaration as your beneficial owners. Missing them is a missing filing. The sanction has been BGN 5,000 for a company since 16 July 2024, or about EUR 2,556. Section 118(4) re-imposes it every month until you file. The contact person's own fine is much smaller, at BGN 100 to BGN 1,000 the first time under section 118(5).
Does the requirement disappear if I get Bulgarian residence?
Yes, once you're the legal representative and your permanent residence is reflected on the company's file. This is the cleanest way out of the appointment, and it's why anyone mid-application should avoid locking into a long contact person term. The change needs a register filing to take effect, so it isn't automatic on the day your certificate is issued.
Is the AML contact person the same as an AML compliance officer?
No, and the confusion is expensive. The contact person under Article 63(4) is about ownership information and applies to almost any company without a resident representative. The internal control officer under Articles 106 and 107 applies only to obliged entities on the Article 4 list. Accountants, notaries, real estate agents and payment firms are examples, and that person gets notified to DANS within seven days. Some businesses owe both.
What happens if my contact person resigns?
They consented to the role, so they can withdraw from it. Nothing updates by itself when they do. Your file keeps showing someone who has stopped acting, and replacing them takes a register filing, due within seven days of the change. That's the argument for using a firm that can name a successor, rather than an individual whose departure leaves you starting the notary step again.
How long does it take to appoint one?
The Bulgarian side is quick, because it's a notarised consent plus a register filing. What sets the real timeline is paperwork crossing a border. Documents issued abroad need an apostille and a sworn Bulgarian translation, and a manager signing from overseas needs the same. Budget days if everyone is in Sofia, and two to four weeks if the signatures and corporate documents are coming from outside the country.
Where this leaves you
For most foreign-run Bulgarian companies this is a small, cheap obligation attached to a disproportionate penalty, which is a bad combination to leave on autopilot. The filing itself is an afternoon's work. The monthly sanction for an entity that never made it runs at about EUR 2,556. The mechanism that surfaces a stale entry now sits with the bank and accountant you already use.
Our advice is unfashionably boring. Check whose name is on your file. Check that they still live here and still answer. Then check whether you need the appointment at all any more. Most of the trouble we see comes from an appointment made correctly at incorporation and never looked at again.
We act as AML contact person for foreign-owned Bulgarian entities and handle the notarised consent and the register filing that go with it. It pairs with the share capital conversion into euro, if your company file still needs that step. Ownership checks come up again when opening a Bulgarian bank account. Tell us who's currently named on your company file and where your manager lives. We'll tell you whether you need an appointment, a replacement, or nothing at all. Start from the contact page.