Proposed Changes to the Bulgaria Golden Visa Program

Bulgaria continues to offer permanent residency through an investment in a regulated investment fund of EUR 512,000, with a permanent residence card issued within 8 months from the start of the application.

However, the Bulgarian Parliament has proposed amendments to the Foreigners Act that would require permanent residents to spend at least six months and one day physically present in Bulgaria each calendar year to maintain their permanent residence status. The proposal was introduced in April 2026, while the draft bill was formally submitted to Parliament at the end of July 2026.

There has been very little publicity surrounding these proposed amendments. In fact, they largely remained under the radar, and only a single legal professional submitted comments during the public consultation specifically addressing the new physical presence requirement. This was our colleague Polina Berg. Although her comments were accepted into the consultation process, the draft legislation itself remained unchanged with respect to the six months and one day physical stay requirement.

Will the Bill Become Law?

In its current form, the bill does not appear to be in its final legislative shape. The proposed physical presence requirement applies to all categories of permanent residents, including individuals who obtained permanent residence based on Bulgarian origin or as family members of Bulgarian citizens. The bill also does not specify when these amendments would enter into force or whether they would apply to persons who have already acquired permanent residence.

Furthermore, the proposed legislation allows the Migration Directorate to assess each individual case based on the personal circumstances of the permanent resident and to determine whether the residence permit should be maintained or withdrawn.

For these reasons, we believe that the current draft is unlikely to be enacted without further amendments.

It is also important to understand that the Bulgarian Golden Visa currently offers considerably greater value than any comparable investment immigration program within the European Union. Bulgaria grants permanent residence immediately, whereas the same investment in Portugal currently leads only to temporary residence.

Rumours versus Facts

Nobody denies the possibility that the proposed bill could eventually become law. However, it is equally important to remain realistic.

The rumours have already achieved their primary objective: to reduce interest in the Bulgarian Golden Visa Program and to prevent it from attracting increased international attention following the reputational challenges faced by the Portugal Golden Visa Program.

There were also rumours in 2018 regarding the cancellation of the previous Bulgarian Citizenship by Investment Program. Nevertheless, that program continued to operate until 2022, when it was ultimately repealed.

There is no doubt that investment migration programs worldwide are becoming increasingly restrictive, and Bulgaria is not isolated from this global trend. Portugal currently experiences extremely long delays before applicants are even invited to provide biometrics. Turkey recently revoked approximately 6,000 passports within a single week. Caribbean citizenship-by-investment programs have lost visa-free access to the European Union, while Vanuatu has already been suspended and similar discussions continue regarding other jurisdictions.

What Is the Issue with Arton Capital?

Had Arton not published its article regarding the proposed legislative amendments, these changes would likely have remained under the radar even today. In that respect, we appreciate that Arton’s publication brought attention to the issue and prompted our team to take immediate action.

However, one legitimate question remains.

Why is Arton focusing so heavily on a program that they hardly sell?

The answer may be commercial rather than legal.

The Bulgarian program is not particularly attractive from a commission perspective because it is based on open-ended investment funds, where commissions are relatively modest and, in many cases, paid over several years.

Portugal, on the other hand, is largely based on closed-ended investment funds, where referral commissions can reportedly start from EUR 50,000 per investor.

This also helps explain why it became something of an open secret within the industry that applicants to the Portugal Golden Visa have been waiting 4-5 years merely for biometric appointments. When referral commissions are exceptionally high, there is naturally less commercial incentive to emphasize such delays, which are instead often described simply as “temporary” or “administrative.”

This raises another question.

Why did Arton not publish similar articles in 2023 or 2024, when Portugal Golden Visa applicants were already experiencing significant delays?

Advocate Markov was among the first law firms to publicly highlight the growing processing backlog. As early as July 2024, we warned that Portugal GV applicants were already waiting approximately three years merely to complete biometrics, while much of the investment migration industry continued to market the program aggressively and collect substantial referral commissions.

We leave our readers to draw their own conclusions.

What Advocate Markov Team Proposed

The global trend is clearly towards more regulated and more restrictive investment migration programs. Bulgaria cannot realistically remain completely outside this trend.

Instead of introducing a requirement that effectively eliminates the attractiveness of the Bulgarian Golden Visa for international investors, our team proposed several alternative measures. Any one of these or a combination of them would preserve the integrity of the program while significantly reducing its abuse potential:

• Increase the minimum investment amount.
• Increase government fees, following the approach adopted by Malta.
• Introduce a limited physical presence requirement of one to two weeks per year, similar to Portugal.
• Introduce stricter physical presence requirements only for applicants who subsequently decide to apply for Bulgarian citizenship, while maintaining the current permanent residence regime for long-term investors.

Such measures would achieve the objective of strengthening the Bulgarian program without undermining its international competitiveness or discouraging the very investors it is intended to attract.

When Will We Know Whether the Bulgarian Golden Visa Program Will Change?

The Bulgarian Parliament is in recess from 5 August until 23 August, and no legislative progress is expected before the end of the year.

The draft bill must still pass through several stages of the legislative process, including review by the relevant parliamentary committees, followed by two readings and votes in Parliament, before it can become law.

At this stage, it is too early to conclude whether the proposed amendments will be adopted in their current form, amended during the legislative process, or ultimately rejected.

The draft bill can be find at Законопроекти – Народно събрание на Република България .