Bulgaria drafts 1.5% net fee cap on gambling transactions

Bulgaria’s Proposed 1.5% Fee Cap on Gambling Payments: A Comprehensive Guide

Overview: A Novel Fiscal Approach in the EU

Bulgaria has introduced a draft reform that would cap the net fees payment facilitators—such as banks, payment institutions, and e-money companies—can charge for processing gambling transactions at 1.5% of the transaction value. This represents a first-of-its-kind regulatory instrument within the European Union, shifting the focus from gambling operators themselves to the financial infrastructure that supports their payments.

The proposed rule targets two specific types of gambling-related payment operations: deposits (funds placed for participation) and payouts of winnings. Any fee or commission above the 1.5% threshold must be remitted directly to the state budget. The measure is currently in a public consultation phase, open until 23 October.

Key Provisions of the Draft Rule

How the Cap Works in Practice

Consider a user who deposits €1,000 into an online gambling account. The payment platform charges a €30 fee (3%) for processing that deposit. Under the proposed rule:

The same principle applies to payouts: if a gambling operator uses a bank to send winnings to a customer and that bank charges a fee above 1.5%, the excess is redirected to the government.

Rationale and Objectives Behind the Reform

Policymakers have stated two main motivations:

  1. Greater responsibility from payment facilitators – Entities that earn substantial revenues from high-risk gambling transactions should bear a share of the societal costs associated with problem gambling.
  2. Utilisation of the premium fee structure – Gambling payments are considered high‑risk in Bulgaria, often attracting processing fees significantly higher than standard transactions (sometimes 3–5%). The reform aims to capture this “premium” and channel it into the state budget.

The impact assessment further notes that due to the large volume of gambling transactions and the key role of payment processors in enabling them, a mechanism is needed to formally recognise that role. While the funds could theoretically be used for problem‑gambling initiatives, the draft does not specify an intended allocation at this stage.

Impact on Payment Providers and End Users

Compliance and Reporting Requirements

To enforce the cap, the draft imposes stringent obligations:

Failure to comply could result in fines or other penalties, though specific enforcement mechanisms are yet to be detailed.

Potential Outcomes and Broader Context

If enacted, the rule would represent a paradigm shift in how EU member states regulate gambling finance. Instead of taxing operators or imposing licence fees, Bulgaria is targeting the payment layer. This could:

However, the reform is still a draft. The public consultation period (ending 23 October) allows stakeholders—including banks, e‑money firms, gambling operators, and consumer groups—to submit feedback before the rule is finalised or potentially modified.

Timeline and Next Steps