Overview of Bulgarian citizenship by investment
Last Updated on October 10, 2024 by Bulgarian Citizenship Team
Advocate Vasil Markov’s overview of Bulgarian citizenship by investment program
The Bulgarian Citizenship by Investment program is among the most transparent and affordable citizenship options in 2024. Every potential investor must now go through a pre-approval process with the Investment Agency before making any investment. This step helps streamline the application process and minimizes the risk of disappointment if the Bulgaria Golden Visa is not approved, regardless of previous efforts.
Investors are not required to open a private bank account in Bulgaria to invest in a Bulgarian Fund. The investment can be made by directly transferring the funds to the Fund’s bank account. The Fund Manager will handle all necessary documentation and submit it to the Investment Agency on the investor’s behalf. This eliminates the need for intermediaries such as investment brokerage firms, which often charge commissions and may delay document processing. Additionally, investors are not required to physically reside in Bulgaria to maintain their permanent residency status or to apply for Bulgarian citizenship.
For more information on the latest amendments to the Bulgaria Golden Visa program, please refer to our comprehensive guide on Bulgaria Golden Visa 2024.
Does the Bulgarian Citizenship by investment have a sound legal basis?
The Bulgarian citizenship by investment program does not have a dedicated government website as the Dominica citizenship by investment program. Despite this fact, the Bulgarian citizenship by investment program is supported by the Bulgarian legislation in the Foreigners of the Republic of Bulgaria Act and the Citizenship Act.
Investment in a Bulgarian Fund ETF (Exchange-Traded Fund)
Foreigners Act, Art. 25. (1) Foreign nationals may be granted a permanent residence permit if they:
Paragraph 6:
(v) hold shares or stocks with a value not less than 1,000,000 BGN in collective investment schemes ETFs originating from the Republic of Bulgaria, operating in accordance with the Law on the Activities of Collective Investment Schemes and Other Collective Investment Undertakings, provided that:
(aa) the net asset value of each collective investment scheme is not less than 5,000,000 BGN;
(bb) the collective investment scheme has been licensed or approved by the Financial Supervision Commission;
(cc) their investment strategy is primarily focused on investments in shares and/or bonds as described in point “a”;
Investment in a Bulgarian Fund AIF (Alternative Investment Fund)
Foreigners Act, Art. 25. (1) Foreign nationals may be granted a permanent residence permit if they:
Paragraph 6:
(g) hold shares or stocks with a value not less than 1,000,000 BGN in alternative investment funds AIFs established in the Republic of Bulgaria, managed by entities that manage alternative investment funds, originating from Bulgaria and operating in accordance with the Law on the Activities of Collective Investment Schemes and Other Collective Investment Undertakings, provided that:
(aa) the assets of each fund are not less than 3,000,000 BGN;
(bb) the alternative investment funds and their managing entities are licensed or registered by the Financial Supervision Commission;
(cc) their investment strategy is primarily focused on investments in Bulgarian assets and invests exclusively in shares, stocks, and bonds of Bulgarian companies, including special purpose investment companies.
For reference, please see the Foreigners in the Republic of Bulgaria Act.
Provisions for Bulgarian Citizenship
Article 12. (1) An individual who is not a Bulgarian citizen may acquire Bulgarian citizenship if, at the time of submitting the application for naturalization:
- is of legal age;
- has held a permanent or long-term residence permit in the Republic of Bulgaria for at least 5 years;
- has not been convicted of an intentional crime of a general nature by a Bulgarian court, and no criminal proceedings for such a crime are pending, unless rehabilitated;
- has a reliable source of income or employment ensuring financial self-sufficiency in Bulgaria;
- has demonstrated proficiency in the Bulgarian language, as determined by regulations issued by the Minister of Education and Science; and
- has been released from previous citizenship or will be released upon acquiring Bulgarian citizenship.
For reference, please see the Bulgarian Citizenship Act.
How long do I need to maintain the Bulgarian Fund investment?
The investment must be maintained for 5 years from the date your permanent residency is granted. After this 5-year period, you may choose to sell or keep your investment, and you can begin preparing your application for Bulgarian citizenship.
Financing the Investment in Bulgarian Funds
As of October 2024, there are no known financing options available for investments in Bulgarian Funds. Financing is explicitly prohibited under the Foreigners Act, Art. 25, Para 12, which states:
The acquired rights and assets resulting from the investments under Paragraph 1, items 6 and 8 may not be used as collateral for loans from credit and financial institutions during the period specified in Paragraph 11.
Although the same rules applied to bond investors in the past, they were still able to secure Bulgarian citizenship through financed options.
Where should I apply for Bulgarian citizenship?
You can lodge your citizenship application in person, with the Ministry of Justice in Sofia, Bulgaria or with the nearest Bulgarian embassy or general consulate. Citizenship applications are submitted only in person. You cannot authorize a lawyer or a consultancy firm to file your application on your behalf.
How long does it take to obtain Bulgarian citizenship through the Golden Visa program?
To be eligible to apply for Bulgarian citizenship through the Golden Visa program, you must hold permanent residency status for a full 5 years. After fulfilling this residency requirement, you can submit your citizenship application.
Assuming the following timeline:
- 8 months to obtain permanent residency,
- 5 full years of holding permanent residency,
- 12 months for the processing of your citizenship application, and
- 6 months for the Vice President to issue the citizenship decree,
The entire process should not take longer than 7 years from the time you begin until Bulgarian citizenship is granted,
Bulgarian Citizenship Act
Art. 35. (Amended, SG No. 41/2001, amended, SG No. 33/2010) (1) The Minister of Justice shall make a proposal for the issuing of a decree for granting Bulgarian citizenship within:
- (new, SG 16 of 2013) six months – on applications for acquisition of Bulgarian citizenship under naturalization under Art. 12a and 14a;
Article 35. (Amended – State Gazette, issue 41 of 2001, amended – State Gazette, issue 33 of 2010) (1) The Minister of Justice shall submit a proposal for issuing the decree under Article 34 within the following timeframe:
- (Amended – State Gazette, issue 21 of 2021) Twelve months for applications for acquiring Bulgarian citizenship through naturalization.
Time taken for issuance of Bulgarian passport
You can apply for a Bulgarian passport with the Ministry of Justice in Sofia, Bulgaria or with the nearest Bulgarian embassy or general consulate. Passport applications are submitted only in person by the applicant. You cannot authorize a lawyer or consultancy firm to file your citizenship application on your behalf.
Deadlines for issuing a Bulgarian passport – Ministries and Interior Ministry.
Ordinary issuance – up to 30 calendar days
Fast issuance – up to 3 working days
Express – up to 8 hours
NB: Citizenship application with embassies and general consulates are considered for a longer period.
Ordinary issuance – up to 90 days
Fast issuance – up to 60 days
Are EU citizens eligible to apply for Bulgarian citizenship by investment?
EU citizens cannot apply for Bulgarian citizenship by investment unless they hold a passport of a non-EU country.
Donations vs Investment
Some countries advertise citizenship by investment, but in fact, it is citizenship by donation. In other words, you do not get returns on your investments. This is the case with Dominica/ St. Kitts and Nevis (see http://nomadcapitalist.com/2016/06/20/best-citizenship-by-investment-programs/). On the other hand, the Bulgaria Golden Visa program requires the applicant to invest in a Bulgarian Fund. Your portfolio with the Fund generates returns, which can be capitalized when you complete the Golden Visa program. The Bulgarian program stands out as a genuine investment opportunity, offering both residency and the potential for financial growth.
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If you have any queries regarding investment and Bulgarian citizenship, please do not hesitate to contact us.
