The First Bulgarian White Paper in ESMA’s Register: A Web3 Breakthrough or Just a Regulatory Formality?

Disclosure: I collaborate with NativeArc — the issuer of the NX0 token discussed in this article. More on the Partners page.

🔑 Key concepts: MiCA (Markets in Crypto-Assets), ESMA, FSC, Utility Token, Base Layer 2, CASP.

The Bulgarian crypto scene has reached a new milestone in its institutional development. For the first time, a fully Bulgarian White Paper (an offering document / technical documentation for a crypto-asset offer) has been officially notified and entered in the public register of ESMA (the European Securities and Markets Authority).

The project belongs to the Sofia-based company NativeArc EOOD, and the token is called NX0.

But what does this actually mean from a legal, economic and technological point of view? Is the European Union approving the Bulgarian token, and what is the difference between a notification and a licence? In this article we take a detailed look, aimed at students, researchers and fintech enthusiasts.

1. Who is behind the project and what is NX0?

According to the documentation filed under the EU’s MiCA regulation (Markets in Crypto-Assets), NativeArc EOOD’s project aims to build a so-called “city wallet” – a loyalty platform that connects end users and local merchants in a shared rewards ecosystem.

Core technological and economic profile

• Infrastructure: NX0 is an ERC-20 token built on the Base Layer 2 network (a fast and low-cost L2 network on top of Ethereum).
• Classification: a PURE Utility Token.
• Token functionality: claiming and receiving cashback/rewards at merchants; unlocking user tiers based on the amount of NX0 staked (locked); reward multipliers; covering network fees and buying in-app services, where the token may be partially burned (token burning).

📌 LEGAL DEFINITION
NX0 expressly does not confer an equity stake in NativeArc EOOD, a right to dividends, a claim, governance rights or any right to the company’s assets. The document does not guarantee a buy-back or a stable price. The price is formed freely on the market.

Parameters of the planned offer

• Maximum volume: up to 8 million locked NX0.
• Fundraising target: a maximum of 3 million EURC (a euro-pegged stablecoin).
• Reference price: EUR 0.65 per 1 NX0 (with the caveat that this is only a reference value, not a market-guaranteed one).
• Minimum participation: 100 EURC via a self-custody wallet on the Base network.

2. The big regulatory question: an ESMA register entry ≠ a licence!

The media often confuse the terms “licence” and “notification”. For law and economics students, this difference is critical to understanding the MiCA framework.

The NX0 white paper is the first white paper from Bulgaria to be notified to the Financial Supervision Commission (FSC) and entered in the ESMA register. The document was filed under Title II of MiCA (for crypto-assets other than asset-referenced tokens, e-money tokens or financial instruments).

⚠️ MANDATORY WARNING FROM THE WHITE PAPER ITSELF
“This White paper has not been approved by any competent authority. The offeror is solely responsible for its content.” The document also warns that the token may lose its value, may not be liquid, and is not covered by deposit guarantee schemes.

How do we tell NX0’s regime apart from that of CASP companies?

As of September 2026, exactly five companies in Bulgaria have received a decision granting a CASP (Crypto-Asset Service Provider) licence from the FSC:

1. Alaric Securities OOD (the first licence issued in Bulgaria)
2. Bileyr OOD
3. Altcoins BG EOOD
4. Digital Assist OOD
5. FF Digital EOOD

💡 Takeaway: NativeArc EOOD should not be described as “the sixth licensed company”, but as a MiCA-notified offeror of a utility token.

3. A critical review: signs of legitimacy vs. open questions

From an academic-analysis standpoint, the project shows both strong positive signals and areas that call for careful scrutiny.

✅ Verifiable positive signals

1. A transparent legal entity: the company is real (UIC 205859199, LEI code 8755007WQLHUW5M9SP74), registered in Sofia in 2019, with Georgi Aleksandrov as managing director.
2. Standardised MiCA format: the document strictly follows the EU requirements for disclosing risks, tokenomics, technology and climate footprint.
3. Cross-border passport: the document states a planned offer in Bulgaria and 29 other EEA countries.
4. A real utility model: the token has a functional purpose (loyalty and discounts) rather than being described solely as a speculative asset.

⚠️ What the register entry does NOT automatically prove (risk areas)

• No automatic audit of the smart contracts: the regulator has not reviewed the code itself on Base Layer 2.
• No confirmation of the merchant network: registration does not guarantee that the announced partner merchants have signed contracts.
• No liquidity guarantee: the token may turn out to be hard to transfer or may lose value.
• No investor protection: NX0 is not covered by state investor-compensation or deposit guarantee schemes.

4. What does this mean for the Bulgarian fintech ecosystem?

If NativeArc manages to bring its platform to life in practice, the project could serve as a valuable case study for three main trends:

1. Crypto in everyday life (Beyond Speculation): an attempt to use blockchain technology for micro-transactions and loyalty in everyday purchases, rather than for speculative trading on exchanges.
2. A proving ground for the MiCA framework: a practical test of whether a Bulgarian company can structure a utility token under EU rules and use the EU passport to scale across the whole Union.
3. A bridge between Web2 merchants and Web3: taking fragmented loyalty programmes and bringing them together on a shared blockchain infrastructure.

Conclusion

NativeArc EOOD’s NX0 project is a pioneering example of how a Bulgarian company is using the new EU MiCA regulation to enter the European market transparently.

The claim that “ESMA approved a Bulgarian token” is factually inaccurate. The more defensible conclusion is:

🎯 THE BOTTOM LINE
NX0 is a publicly identifiable, regulatorily notified utility project under MiCA, but it has not been approved or guaranteed by ESMA or the FSC. Its real weight for the Bulgarian crypto sector will depend on execution, the partner network, technical audits and transparency after launch.

💬 Discussion questions for Fintech and Law classes

1. Should the regulator carry out a mandatory technical audit of the smart contracts upon notification under Title II?
2. How does MiCA change the competitiveness of European Web3 start-ups compared with those in the US and Asia?
3. Would you use a tokenised loyalty programme in your city?