Market Link Guide - Bulgaria


Key features

CSD link as defined under CSDRa


Type of link

Indirect link to Central Depository AD (CDAD) via Eurobank Bulgaria AD

Direct Operated link to Bulgarian National Bank (BNB) via Eurobank Bulgaria AD

a. CSD Regulation (EU) No 909/2014, Article 2(29).


Custodian/Account operator


Central Depository AD (CDAD)

Bulgarian National Bank (BNB)

Eurobank Bulgaria AD


Not available



CDAD: 74780000G07H7WL0WI31

BNB: 5299001WEKCK7E65TI48


Country of incorporation



Account type

Omnibus account

Omnibus account

Mirror Omnibus account

Legal Account name / holder

CDAD: Clearstream Banking SA clients account

BNB: Clearstream Banking SA

Clearstream Banking SA clients account

Operational arrangements

Settlement in T2SNo 
Settlement free of paymentYes  
Settlement against paymentYes 
  •  Against payment settlement only for securities that settle in CDAD;
  •  Eligible settlement currency: Bulgarian Lev (BGN).
Settlement against payment in central bank money account of CBL/CBL customersNo

CDAD: CBL holds a cash account at the Custodian. Against payment settlement in BGN takes place on the cash account of Eurobank Bulgaria at the Bulgarian National Bank.

BNB: Not available.
Bridge settlementNo 
Shaping facilityNo 
Partial settlementNo 
Settlement penalty feesNo 
Pre-matchingYesImmediate release flag.
Back-to-back processingNo 
Automatic compensationNo 
Registered securitiesYesRegistration takes place automatically upon settlement.
Multi Market SecuritiesNo 
Lending and borrowingYes 
Proxy votingYes 
Investment FundsYesCSD-eligible funds and ETFs.
Liquidity Hub ConnectNo 
Sale and purchase of rightsYes 
Repo servicesYes 
Market restrictionsNo 
Daily reconciliationYes 
Link eligible for use in Eurosystem credit operationsNo 

Moment of entry of instructions

BNB: 'The moment of entry of a transfer order (request) is considered to have entered in the ESROT system as soon as it has successfully passed the entry check and admitted to further processing.

CDAD: The moment of receiving syntactically matched messages.

Irrevocability of instructions

BNB: In case of matching requests from the two parties to the transaction, the transaction shall become irrevocable.

CDAD: The moment of participants’ messages matching and the formation of a common settlement request. After that moment no one can deny or cancel the transfer.

Finality of instructions

BNB: The settlement of government securities transactions shall be deemed final after crediting the government securities settlement account of the acquirer.

CDAD: The moment of transferring the money and the securities.

Legal arrangements

The below section is based on the legal opinion obtained by CBL that was issued on 26 March 2020 for the direct operated link and 12 February 2020 for the indirect link. The information is provided for guidance only and should not be considered in isolation or as constituting a complete or definitive legal advice on any specific matter.

No insolvency proceedings against the Account operator/Custodian


Liability for negligence


Book-entry regime with in rem rights


No entitlement of the Account operator/Custodian/CSD


Recognition as direct CSD account-holder


Recognition of nominee concept

Confirmed. While the nominee concept is not generally recognised under local law, CBL will be recognised as account holder of the accounts held in its name but on behalf of its underlying customers.

No right of retention to the Account operator/Custodian


Segregation of assets at the Custodian/CSD


No right of use


No upper-tier attachments

Although upper-tier attachments are not prohibited under local law, a third party affected by an upper tier attachment has the right to file a claim to ensure that its assets are not attached by a creditor.

Insolvency of the Account operator/Custodian/CSD with no impact on CBL's rights 


Shortfall pro-rated among holders

Local law does not regulate specifically shortfall of securities, though a shortfall shall be borne by the account holders to whom the relevant securities have been allocated, while the Custodian/CSD shall be liable for any deficiencies.

Record keeping period of at least 10 yearsConfirmed

Settlement finality in case of insolvency