Bulgaria Permanent Residency Could Be Revoked

Clarifying the Rules: Bulgaria Golden Visa & Former Bond Investors

In the interest of providing the most accurate information, we do not rely solely on court practice—even though we frequently challenge administrative decisions successfully. Instead, we always seek direct confirmation from the authorities involved.

For this reason, we submitted an official inquiry to the Migration Directorate to clarify the status of previous bond investors—those who obtained permanent residency through investments of €512,000 or €1,000,000 in Bulgarian government bonds between 2013 and 2022.

No Physical Stay Requirement — Then and Now

Under the former fast-track Citizenship by Investment program, there was no requirement for physical presence in Bulgaria. Once the investment was completed and permanent residency (PR) was granted, investors were not required to visit the country.

However, this changed with the amendments to the Citizenship Act in 2022. The program was discontinued, and all investors became subject to the standard requirements for maintaining PR in Bulgaria.

Visit Requirement: Not Bulgaria, but the EU

There is a common misunderstanding regarding the physical presence requirement.

Neither the current Bulgaria Golden Visa program nor the former Citizenship by Investment program required physical presence in Bulgaria. However, following the legislative changes in 2022, bond investors (2013–2022) became subject to a requirement to enter the European Union.

Yes—that is correct.

The requirement is not to visit Bulgaria specifically, but to enter the EU. This means your visit can be to any EU country, conveniently aligning with travel plans to destinations such as Greece, Spain, or Italy.

Once Every 12 Months — Not “Once a Year”

Another frequent misconception is that the requirement is to visit “once per calendar year.”

This is incorrect.

The rule is once every 12 months, which is stricter.

For example:

Visit in December 2022
Visit in January 2023

This does not cover you until March 2024. You would be in violation if more than 12 months pass between entries into the EU.

Latest Position from the Migration Directorate

According to the latest guidance, if your PR has not yet been revoked, you may still have the option to change your residency category.

Key Risks to Be Aware Of

If you are unsure whether you have met the physical presence requirement, it is essential to verify this before taking any action.

If you apply and are found non-compliant, your PR status may be revoked immediately, leaving no opportunity to correct the situation.
If your PR card has expired but your status has not been revoked, this is generally not an issue. The status remains valid even if the card itself has expired.

In such cases, you may initiate a new procedure under the current Bulgaria Golden Visa program by investing in an Alternative Investment Fund.

Why Pre-Check Matters

If your status is not verified in advance, your only remaining option may be a court appeal.

While court appeals can be effective—particularly in cases of D visa or C visa refusals—they are far less predictable and significantly more complex when it comes to PR revocation.

Advocate Markov has been recognized by the District Court of Plovdiv for his work and can handle such cases effectively and without unnecessary complications. However, many investors prefer to avoid building a court history altogether and instead opt for a smoother solution—transitioning from government bonds to a Bulgarian Investment Fund under the current program.

Why Consider the New Bulgaria Golden Visa Program

One of the key advantages of the current program is that no investment is required before pre-approval.

The pre-approval process involves:

The Investment Agency
The Migration Directorate
The National Security Agency

If there are no objections during pre-approval (for example, regarding missed EU visits), this is a strong indication that your PR can be renewed under the new category.

Only after approval is granted are you required to proceed with the investment.