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Contract reading

What BULBROKERS legally published, but does not want you to read

Every clause below is published by BULBROKERS itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: Bulbrokers EAD

withdrawalsdeemed acceptancesole discretionhidden feemargin callunilateral amendmentaccount closurecomplaint deadlineconflict of interestliability exclusion

Bulbrokers told its clients in November 2025 that it is closing and giving up its Bulgarian licence. Client cash now sits in a special account at Postbank, and there are five years from 31 March 2026 to collect it in person. The contract it still publishes dates from 2012. You get three days to object to a trade, you agree in advance to the prices your positions are force-closed at, and a negative balance is a debt you must pay. Its Spanish pages sell no dealing desk while its own policy says Bulbrokers is the market maker setting the prices.

Back to BULBROKERS

Contract risk

Money at risk
8.0/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
22
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
21
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
3

How the 22 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical6
Warning15
Notice1

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

2 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

Critical30 daysIn the contract. Jump to the clause this comes from.Bulbrokers is closing and has ended every client contractCritical3 daysTime to complain. Jump to the clause this comes from.Three days to object to a trade, then silence is agreement4 working daysWithdrawal limit. Jump to the clause this comes from.Withdrawals above 10,000 need four working days of notice$1000Fee you were not shown. Jump to the clause this comes from.Currency conversion happens at a rate Bulbrokers negotiates

What the documents say

22 clauses worth knowing about, worst first, each quoted from BULBROKERS's own files

01

In November 2025 Bulbrokers told its clients it was stopping work as a licensed investment intermediary and giving up its licence. It used clause 14(5)(3) of these same General Conditions to serve notice of termination on everyone.

Why this matters

Bulbrokers gave clients 30 days to say where to send their money. If you missed that, your cash went to a special account at Postbank, and it can be collected in person for five years from 31 March 2026.

Exhibit 1CriticalRarely seen30 days

С настоящото Ви уведомяваме, че с решение на едноличния собственик на капитала на “БУЛБРОКЪРС“ ЕАД от 03.11.2025 г., дружеството прекратява дейността си като лицензиран инвестиционен посредник и стартира процедура по доброволен отказ от лиценза, издаден от Комисия за финансов надзор.
Quoted in ВАЖНО СЪОБЩЕНИЕ ДО КЛИЕНТИТЕ НА БУЛБРОКЪРС: ПРЕУСТАНОВЯВАНЕ НА ДЕЙНОСТ
Read from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Oct 3, 2026Bulbrokers is closing and has ended every client contractVisit this page on the broker's siteDownload the full size image file

Our readingA broker that has already terminated every client contract is still publishing a full client agreement, and nothing in those documents tells a reader the business has stopped.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
3 November 2025The sole owner decides to end the business and surrender the licence.
13 November 2025Clients get 30 calendar days to say where their money and instruments should go.
15 January 2026The deadline for instructions is extended to 17:00 on this date.
31 March 2026Unclaimed cash moves to a special account at Postbank, collectable in person with ID for five years.
  • Worse together with Exhibit 21The documents left online describe a working broker, and none of them mentions that the business has stopped.
02

Bulbrokers' Spanish pages sell Sin mesa de operaciones (NDD), which means no dealing desk. Its own execution policy says Bulbrokers is the market maker on contracts for difference, sets the prices and acts as the place every order is executed on.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Why this matters

Bulbrokers takes the other side of your trade and chooses the price it fills you at. Its interest in that price is not the same as yours, and the Spanish page tells you the opposite.

Exhibit 2CriticalHarder than usual

BULBROKERS shall act as a market-maker for transactions with the contracts for difference with base asset securities, futures contract, index.
Clause 112 in Bulbrokers Best Execution Policy (Romanian and English), p.16
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must describe their own role to a retail client in terms that are fair, clear and not misleading, and must disclose when they are the counterparty. Bulbrokers discloses the market making in a policy document and advertises the opposite on its Spanish pages.

BULBROKERS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 6The firm that sets the price is the same firm whose closing prices you agreed in advance never to challenge.
  • Worse together with Exhibit 5Bulbrokers quotes the price and also decides when a price was wrong enough to void the trade.
03

If closing your positions leaves the account in the red, clause 72(10) makes you pay Bulbrokers the difference. You can end up owing the firm more than you ever put in.

In plain words

Negative balance protection is a limit that stops you owing more than you put in. Without it, one fast market move can leave you owing the broker money on top of your deposit.

Why this matters

There is no cap on what you can owe. A loss bigger than your balance turns into a debt to Bulbrokers, and that debt then carries daily interest.

Exhibit 3CriticalHarder than usual

Regardless of the acts of position closing undertaken by BULBROKERS, if as a result the balance under the client’s account is negative, the client must supply to BULBROKERS an amount equal to the shortage under the account.
Clause 72(10) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.27
Read from the broker's site on Open the reference

What it costsAt the 200:1 leverage in Bulbrokers' published Forex conditions, $1,000 of your money controls $200,000 of currency. Anything left owing after a forced close is yours to pay.

Set against a regulated standard: ESMA (EU), FCA (UK), CySEC (Cyprus)

National regulators across the EU adopted the ESMA retail measures for contracts for difference from 2018. Those require negative balance protection, so a retail client's loss can never exceed the money in the account, and they cap leverage on major currency pairs at 1:30. This contract makes the client pay any shortfall, and Bulbrokers' published Forex conditions offer up to 200:1.

BULBROKERS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 6Bulbrokers closes the positions, you agreed in advance to the prices, and then you pay whatever shortfall those prices leave.
  • Worse together with Exhibit 12The shortfall is a cash obligation, so the 0.1% daily default interest starts running on it.
04

You get three days to object to a trade confirmation, counted from when you receive it. Clause 43(2) treats your silence as acceptance, and clause 43(1) lets you object only that the order was executed inaccurately.

Why this matters

Miss three days and the trade stands, whatever went wrong with it. You also cannot raise any other ground, however good it is.

Exhibit 4CriticalHarder than usual3 days

The Client may submit a written objection to BULBROKERS in relation to the public confirmation within 3 days as from the receipt thereof. The Client may only object to any inaccurate execution of the placed order.
Clause 43(1) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.17
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA cannot normally turn a retail complaint away as too late until years after the event, and must point the client to an independent ombudsman. This contract gives three days and names no outside body.

BULBROKERS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 7Object inside three days and the reply still runs on rules Bulbrokers does not publish, with no fixed end date.
05

Any trade that came from a technical error or wrong price data is void under clause 65(4). Bulbrokers decides what counts as an error, and it is the firm that quoted you the price in the first place.

Why this matters

A winning trade can be cancelled because the firm says its own prices were wrong. The clause sets no deadline for that decision and gives you no way to contest it.

Exhibit 5CriticalHarder than usual

All transactions entered into as a result from technical errors or wrong data shall be subject to invalidation.
Clause 65(4) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.24
Read from the broker's site on Open the reference

You have three days to object, and silence counts as agreement

Clause 43 gives you three days to object to a trade confirmation, and clause 43(2) treats your silence as acceptance. Clause 72(9) has you agree in advance, unconditionally and irrevocably, to the prices Bulbrokers closes your positions at. A complaint runs on rules Bulbrokers does not publish, and the reply can wait for a board meeting with no date.

Complaint deadlines2 clauses flagged

Bulbrokers can close your open positions once your free cash reaches 20% of the margin those positions need. Clause 72(9) has you consent in advance, unconditionally and irrevocably, to the prices it closes them at.

Why this matters

You give up the right to argue about a price before you have even seen it. The firm setting that price is the same firm quoting the market to you.

Exhibit 6CriticalHarder than usual20%

In case of closing of positions pursuant to the previous article, the client consents unconditionally and irrevocably to the prices, at which the positions are closed.
Clause 72(9) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.27
Read from the broker's site on Open the reference

Bulbrokers answers a complaint under its Internal Organization Rules, a document it does not publish. Clause 95(2) gives it 10 working days, unless it sends the complaint to a board meeting, and then the reply is due 3 working days after that meeting.

Why this matters

Nothing in the contract says when that board meeting has to happen. The 10 working days can become any length of time Bulbrokers chooses.

Exhibit 7WarningHarder than usual10 working days

An appeal filed by the client shall be considered by the investment firm in accordance with the Internal Organization Rules of BULBROKERS, as within 10 working days as from the filing of the appeal, and when it is heard on a session of the Board of Directors, of which circumstance the client shall be notified – within 3 working days counted from the session of the Board of Directors, the investment firm shall send to the client a written reply.
Clause 95(2) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.41
Read from the broker's site on Open the reference

The Spanish pages sell a broker the contract does not describe

Bulbrokers' Spanish pages promise no dealing desk, a regulated broker and protected funds. Its own execution policy says Bulbrokers is the market maker on contracts for difference and sets the prices itself. The same pages list it as registered with Spain's CNMV and in six other countries. The contract names one Bulgarian licence.

Language arbitrage1 clause flagged

Bulbrokers' Spanish pages list it as registered with Spain's CNMV and in six other countries, and every page of the client agreement is headed FCA UK Authorized. The agreement itself names one licence, from Bulgaria's Financial Supervision Commission.

Why this matters

A Spanish reader could believe a Spanish or UK regulator is watching their account. The firm's own English page puts it far more narrowly: subject to limited regulation by the FCA.

Exhibit 20WarningHarder than usual

The investment firm received a license N RG-03-009/14.07.2008 of the Financial Supervision Commission for performance of an activity as such on the territory of the European Union and European Economic Area and on the territory of third countries
Clause 2(5) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.2
Read from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Oct 3, 2026The claim, on Footer on every Spanish page, under the heading Inspección y entidadesVisit this page on the broker's siteDownload the full size image file
Our own capture of web.archive.org, taken on Oct 3, 2026What the contract saysVisit this page on the broker's siteDownload the full size image file

The price list is not published with the contract that makes it binding

Clause 84(1) puts every price in a Tariff, and that Tariff is not among the documents Bulbrokers publishes. Clause 84(3) lets the firm change it by posting a notice on its website and treats your silence as acceptance. Money you owe the firm carries 0.1% a day.

Cost disclosure3 clauses flagged

Every price Bulbrokers charges lives in a Tariff under clause 84(1), and that Tariff is not among the legal documents it publishes. Clause 84(3) lets the firm change it by posting a notice on its website, and treats your silence as acceptance.

In plain words

Remuneration means payments it receives.

Why this matters

You agree to a price list before you can read it. The next version binds you too, unless you write and object.

Exhibit 10WarningHarder than usual

BULBROKERS shall announce in a Tariff its standard commission remuneration under contracts with clients, as well as the type and amount of the expenses for the clients, if they are not included in the remuneration;
Clause 84(1) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.35
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must give a retail client the costs and charges of a service before they trade, in a form the client can keep. This contract makes a Tariff binding and leaves it off the documents page.

BULBROKERS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 14The same silence rule covers the General Conditions, so the terms and the prices can both move while you say nothing.

Pay in or take out in a currency other than your account currency and the conversion runs through Bulbrokers' own rates. Only amounts up to 1,000 units use the central bank rate, and above that clause 73(2) says the rate is by negotiation.

Why this matters

The bigger your transfer, the less you can check what rate you got. You also pay the bank charge at both ends, sending and receiving.

Exhibit 11WarningHarder than usual$1000

Upon depositing and withdrawal of funds in a currency other than the account currency, the account shall be certified by an amount in the base currency calculated: 1. for amounts of up to 1000 currency units – at the BNB exchange rate for the date; 2. for amounts exceeding 1000 currency units – by negotiation.
Clause 73(2) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.28
Read from the broker's site on Open the reference

What it costsMove 10,000 euro into a dollar account and all of it sits above the 1,000 unit line, so none of it uses the published central bank rate.

Anything you owe Bulbrokers carries 0.1% a day in default interest under clause 94(2). It runs until you pay or the contract ends, and the clause sets no ceiling.

Why this matters

A shortfall left after a forced close starts charging you daily from that moment. Bulbrokers can also take what you owe straight out of the cash it holds for you.

Exhibit 12WarningHarder than usual0.1%

Unless otherwise agreed in the contract, upon delay or partial fulfillment of a cash obligation the guilty party shall owe default interest in the amount of 0,1% daily on the outstanding amount of the obligation until the fulfillment thereof, respectively until termination (rescission) of the contract.
Clause 94(2) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.41
Read from the broker's site on Open the reference

What it costs$1,000 left unpaid for 30 days adds $30. Left for a full year, the same debt adds $365.

Taking your money out needs notice, and closing the account needs another broker

Withdrawing more than 10,000 in your account currency needs four working days of notice under clause 73(6). The money is blocked in your account from the moment you ask. Ending the contract only works if you name another investment firm or depositary to receive your cash and instruments.

Exit conditions2 clauses flagged

Taking out more than 10,000 in your account currency needs four working days of notice under clause 73(6). Between 1,000 and 10,000 needs one working day, and below 1,000 needs none.

Why this matters

Your money is frozen while the notice runs. Clause 73(5) blocks the amount in your account from the moment you ask for it.

Exhibit 8WarningHarder than usual4 working days

The client may withdraw sums from the client’s guarantee account with a prior notice dependant on the amount of such sum: 1. for amounts of up to 1 000 USD, EUR or BGN – without a prior notice; 2. for amounts from 1 000 USD, EUR or BGN to 10 000 USD, EUR or BGN – by 1 (one) working day prior notice; 3. for amounts exceeding 10 000 USD, EUR or BGN – by a prior notice of 4 (four) working days.
Clause 73(6) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.28
Read from the broker's site on Open the reference

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Up to 1,000You can withdraw with no notice at all.73(6)1
1,000 to 10,000One working day of notice before the money moves.73(6)2
Over 10,000Four working days of notice before the money moves.73(6)3

Ending the contract yourself only works if you name another investment firm or depositary to receive your money and instruments. Clause 14(7) says that without it your notice does not take effect.

Why this matters

You cannot simply shut the account and have your cash sent to your own bank. Until you have signed up somewhere else, the contract stays alive.

Exhibit 9WarningHarder than usual

In case of termination of the contract on the grounds of par.5, т. 3 (by the client) the client shall be bound to specify another investment firm and/or depositary institution, where BULBROKERS shall transfer the client’s financial instruments and cash kept by it, submitting to it the orders and other documents required for that purpose. Otherwise the declaration of intention for termination shall not take effect.
Clause 14(7) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.7
Read from the broker's site on Open the reference
  • Limited by Exhibit 1When Bulbrokers wound the business down it offered to send cash straight to a client's own bank account, which clause 14(7) does not promise.

The Spanish bonus disappears the first time you withdraw anything

Bulbrokers' Spanish page offers a 50% bonus on a first Forex deposit of at least 150 euro. The bonus cannot be withdrawn, and taking out any amount at all removes it from the account. The page's own small print says the promotion ended on 31 March 2015.

Deposit bonus1 clause flagged

Bulbrokers' Spanish page offers a 50% bonus on a first Forex deposit of at least 150 euro. The bonus cannot be withdrawn, and taking out any amount at all removes it from the account.

Why this matters

The bonus is not your money and never becomes your money. The page's own small print says the promotion ended on 31 March 2015, yet the offer is still on the page.

Exhibit 18WarningStandard wording50%

El bono sirve sólo para operaciones comerciales y no se puede retirar. Si se realiza un retiro de cualquier cantidad, el bono será debitado de la cuenta.
Quoted in Bono de bienvenida (Spanish welcome bonus and promotion terms)
Read from the broker's site on Open the reference

Bulbrokers can move the margin rules and leave you owing money

A negative balance after a forced close is a debt you must pay under clause 72(10), with no cap on it. Clause 72(4) lets Bulbrokers raise the margin you hold whenever it judges the market risky. Your password counts as your signature, and the firm is not liable if someone else uses it.

Account control4 clauses flagged

Bulbrokers can raise the margin you have to hold and change the level at which it force-closes you. Clause 72(4) needs nothing more than its own opinion that the market has become risky.

Why this matters

A margin rise you did not plan for can turn a healthy position into a forced close the same day. Bulbrokers also reserves the right to add up the balances of accounts it treats as related when it applies these limits.

Exhibit 13WarningHarder than usual

BULBROKERS shall have the right in case of high market volatility caused by decisions of the central banks, key economic and political news and other circumstances resulting in its opinion to increase of the risk from trade with financial instruments to change its minimal guarantee amount requirements.
Clause 72(4) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.26
Read from the broker's site on Open the reference

Bulbrokers changes the General Conditions by pinning a notice in its offices and posting it on its website. Clause 14(3) then treats you as having accepted, unless you write and say you do not.

Why this matters

You have to watch the website to know what you have agreed to. Miss a change and the contract says you agreed to it anyway.

Exhibit 14WarningHarder than usual

If the client does not accept the changes in the General conditions, he has the right to terminate his contract immediately. BULBROKERS will assume that the client has accepted the changes in the General conditions, if he didn’t notified that he does not accept them.
Clause 14(3) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.6
Read from the broker's site on Open the reference

Your username and password count as a legally valid signature, and clause 91(2) treats every order sent with them as a signed written order from you. Bulbrokers is not liable if someone else uses them.

Why this matters

If your login is stolen, the trades are yours to pay for. If the platform fails while you are trying to close a position, that loss is yours too.

Exhibit 15WarningHarder than usual

The using of username and password has the effect of legally valid signature under Art. 13 of the Electronic Document and Electronic Signature Act and Art. 8 of the Accountancy Act.
Clause 85(5) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.37
Read from the broker's site on Open the reference
  • Worse together with Exhibit 3An outage you cannot trade through can end in a forced close, and the shortfall after it is still your debt.

Ask Bulbrokers to treat you as a professional client and you give up ten protections listed in its rules, including any payout from the Investor Compensation Fund. Two of three tests qualify you, one of which is a portfolio above 500,000 euro.

Why this matters

A non-professional client gets 90% of a claim back from the fund, capped at 40,000 leva. A professional client gets nothing from it.

Exhibit 22NoticeStandard wording90%

a professional customer shall not be subject to indemnification out of the Investor Compensation Fund.
Clause 6(1)10 in Rules for Customer Categorization of Investment Intermediary Bulbrokers PLC, p.5
Downloaded from the broker's site on Archived copyOpen the reference

One bank account in, one bank account out, and no deletion date

Open the account remotely and clause 7(6) ties every payment in and out to the one bank account you registered. Clause 86(4) also wants one order signed on paper in a Sofia office before you can order online. The privacy policy keeps your data for an indefinite period where you gave consent.

Onboarding and data2 clauses flagged

Open the account from a distance and every payment in and out must use the one bank account you registered. Clause 86(4) also says you must place at least one order on paper in a Bulbrokers office before you can order electronically.

Why this matters

Close that bank account and your route out closes with it. Card deposits come back only to the same card, so an expired card is a problem you have to fix before you see your money.

Exhibit 16WarningRarely seen

Remittances made by the client in connection with obtaining and providing investment and ancillary services under a contract concluded remotely shall be made only to and from the bank account referred to in the preceding sentence.
Clause 7(6) in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.4
Read from the broker's site on Open the reference

Our readingMost online brokers finish onboarding remotely. This contract keeps a physical step in the middle of it: one order signed on paper in a Bulbrokers office before any electronic order counts.

Bulbrokers' privacy policy says it keeps your personal data for an indefinite period where you gave consent. Everything else is kept for at least five years after the contract ends.

Why this matters

Your ID copy, your bank account and your income details have no end date on them. The policy was last updated in June 2018 and still describes the GDPR as something it expects to come into force.

Exhibit 17WarningHarder than usual

BULBROKERS EAD registers and stores your personal data, which it administers for the purpose of providing the relevant service, for an indefinite period of time, in case of prior consent.
Quoted in Privacy Policy of BULBROKERS EAD, p.4
Read from the broker's site on Open the reference

Bulbrokers is your counterparty, and its best execution promise has an exit

On contracts for difference Bulbrokers is the market maker, sets the prices and acts as the venue your order is executed on. Its best execution policy does not apply when a third party executes, and orders for foreign markets go to Interactive Brokers. Clause 62(2) makes Bulbrokers liable only for passing those orders on.

Who you trade against1 clause flagged

Bulbrokers' best execution policy does not apply when someone else executes your order. Orders for foreign markets go to Interactive Brokers, and clause 62(2) makes Bulbrokers liable only for passing them on.

Why this matters

On a US or German share, the promise to find you the best price is not Bulbrokers' promise. If the fill is poor, the contract points you at a firm you have no contract with.

Exhibit 19WarningHarder than usual

The Policy shall not apply to the cases of submission of client’s orders for execution by a third party.
Clause 16 in Bulbrokers Best Execution Policy (Romanian and English), p.3
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC that pass retail orders to another firm still owe a duty to act in the client's best interests when they choose and monitor that firm. This policy says it does not apply where a third party executes.

BULBROKERS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Bulbrokers has given up its licence and ended every client contract

Bulbrokers told clients on 11 November 2025 that it was stopping work as a licensed investment intermediary. It used clause 14(5)(3) of its own General Conditions to serve notice on every client. Cash nobody claimed went to a special account at Postbank on 31 March 2026. It can be collected there for five years.

Company status1 clause flagged

Bulbrokers adopted the client agreement on its site in July 2012 and the conflicts policy in February 2008. Both rest on Ordinance No 38 and the 2004 investment services directive, and nothing in the set was written after 2018.

Why this matters

The protections European regulators brought in for retail traders after 2018 appear nowhere in the contract you would sign. The risk document is in Bulgarian only, while the terms say English is the language for non-resident clients.

Exhibit 21WarningHarder than usual

The General Conditions were adopted at a session of the Board of Directors of BULBROKERS EAD on 25.07.2012.
Clause §3 in General Conditions Applicable to Contracts for Provision of Intermediation Services, p.41
Read from the broker's site on Open the reference
Set against a regulated standard: ESMA (EU)

National regulators across the EU adopted the ESMA retail measures for contracts for difference from 2018, including negative balance protection and leverage caps. These documents were written before that and mention neither.

BULBROKERS is not licensed by this regulator, so this is a comparison of practice, not a finding of any breach.

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

The Spanish page sells a broker with no dealing desk while the execution policy says Bulbrokers makes the market and sets the prices itself.

Said in public, in Spanish

Sin mesa de operaciones (NDD)

Word for word in English: No dealing desk (NDD)

Spanish welcome bonus landing page, selling points beside the deposit button

In the contract · clause 112

BULBROKERS shall act as a market-maker for transactions with the contracts for difference with base asset securities, futures contract, index.

02

Spanish readers are told the firm is registered in seven countries, while the contract names a single Bulgarian licence.

Said in public, in Spanish

Registrado en la CNMV España, así como en Reino Unido, Hungría, Eslovenia, Grecia, Polonia y Rumania..

Word for word in English: Registered with the CNMV Spain, as well as in the United Kingdom, Hungary, Slovenia, Greece, Poland and Romania.

Footer on every Spanish page, under the heading Inspección y entidades

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of web.archive.org

In the contract · clause 2(5)

The investment firm received a license N RG-03-009/14.07.2008 of the Financial Supervision Commission for performance of an activity as such on the territory of the European Union and European Economic Area and on the territory of third countries

03

The contract header says the firm is FCA UK authorised, while the firm's own regulation page calls it limited regulation only.

Said in public, in English

Licensed investment intermediary Regulated by FSC Member of BSE-Sofia FCA UK Authorized

Running header on all 42 pages of the client agreement

In the contract

BULBROKERS is subject to limited regulation by the Financial Conduct Authority (FCA) with reg.No. 544872.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of web.archive.org

What changed quietly

This is our first reading of Bulbrokers, so there is no earlier version of this page to compare it with. The documents themselves have barely moved. The client agreement, the conflicts policy and both categorisation rules are byte for byte what Bulbrokers published years ago.

  • ADDEDClause · 2018.06.07 to 2018.06.22

    The Bulgarian privacy policy now points to a separate document retention and destruction policy, which Bulbrokers does not publish alongside it.

    Подробна информация може да намерите в Политиката за съхранение и унищожаване на документи.

  • ADDEDClause · 2018.06.07 to 2018.06.22

    Processing of cookie statistics for marketing was added to the list of purposes the Bulgarian privacy policy covers.

    − Обработване във връзка със статистическа информация, генерирана от бисквитките, които използваме за маркетингови цели.

  • REWRITTENClause · 2018.06.07 to 2018.06.22

    The last update date moved from 7 to 22 June 2018, and nothing in the policy has moved since.

    Последна актуализация направихме на 22 юни 2018г.

The documents this reading is based on

21 files, all published by BULBROKERS. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording BULBROKERS publishes.

How this reading was done

Every clause above was read out of a document BULBROKERS publishes itself

This reading was published on .

Documents
13 of 21downloaded from the broker's site, and 13 read in full
Pages opened
41pages walked to find those documents, footer links included
Older copies
5earlier versions downloaded, 4 identical to the copy we hold by fingerprint
Languages
EN vs ESthe language it advertises in, against the language it contracts in

Who the contract is with

Bulbrokers EAD

You contract with Bulbrokers EAD, a single-member joint-stock company registered in Sofia under number 115152520. Its licence is Bulgarian, РГ-03-0009/14.07.2008, from the Financial Supervision Commission. The privacy policy puts it in the group of Alfa Finance Holding AD. Orders for foreign markets go to Interactive Brokers LLC, which holds the money and instruments behind them. You have no contract with that firm. Some of the documents call the company Bulbrokers PLC rather than EAD.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

Bulbrokers puts numbers on its execution promise: for a non-professional client it weights price at 80% and costs at 20%. Most firms never quantify that. Its risk document calls currency transactions and derivatives trading extremely risky, in its own words. Clause 39 gives the client the whole benefit when the firm gets better terms than the client asked for, and clause 74 keeps client assets apart from the firm's own money. When it wound the business down it offered to send cash to a client's own bank account. It also prepaid five years of bank charges on the account holding unclaimed money.

Bulbrokers' website was not serving pages while we read. The closure notices and the Spanish and Bulgarian marketing pages quoted here come from preserved copies of its own pages. Bulbrokers' documents page lists five files we had not seen. We read four of them and did not open the rules for placing orders by telephone. We read parts, not all, of the 2016 execution policy, the 2016 costs and fees information and the foreign markets tariff. The Tariff of fees and commissions that the client agreement makes binding is not published with the other documents. We could not find a copy. In the English-only categorisation rules the article numbers did not come out. We took them from the bilingual version of the same rules.

How to check any of this yourself

Every quote above links to the BULBROKERS file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document BULBROKERS publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge BULBROKERS on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Oct 3, 2026.

If you represent BULBROKERS and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on BULBROKERS. Whether its licence is real and current is a separate check on the broker profile.

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