The Suicide of the Bulgarian TRO Program

March 16, 2024
Last Updated: April 1, 2024
Bulgaria Schengen visa

The Suicide of the Bulgarian TRO Program: A Shift in Bulgaria’s Residency and Visa Policies

The prospect of opening a Trade Representative Office (TRO) in Bulgaria has long been a viable and straightforward path for non-EU citizens to acquire a D visa and Bulgarian residency. This program, known for its accessibility and simplicity, allowed foreign businesses a foothold in Bulgaria, also offering the possibility of eventual permanent residency.

Under the initial parameters, the program granted 12-month renewable temporary residency cards, leading to permanent residency for those residing in Bulgaria for 30 months within a 5-year span. Notably, the program had lenient financial requirements, with no specific turnover mandates provided the company’s turnover was positive in the past two years – even a modest profit of 1 EUR was acceptable. Additionally, a single TRO could sponsor up to three representatives for Bulgarian residency.

What to expect in 2024

However, recent developments indicate a significant shift in this policy. The latest draft of the Foreigners Act, in its most stringent form, suggests substantial changes. It proposes that foreign companies must demonstrate a minimum turnover of 500,000 BGN in one of the last two financial years to qualify. Moreover, the number of representatives allowed per TRO is reduced to two.

This proposed amendment, if ratified, could fundamentally alter the landscape for small businesses seeking EU residency through this route. The change seems to be in anticipation of Bulgaria’s integration into the Schengen zone and the commencement of Schengen visa issuance from April 1, 2024. Consequently, TRO would transition from a gateway to affordable EU residency to a more exclusive path, leading to Schengen D visas and residency. The tightening of requirements is poised to considerably diminish the pool of eligible TRO applicants.

Discussions and speculations about potential revisions to the Bulgarian TRO visa and residency program have been circulating since the summer of 2023. Despite the lack of concrete progress, there are indications that the government is gearing up for action. The proposed turnover requirement of 500,000 BGN, albeit seemingly steep, could be a reality soon, and even a reduced threshold would still affect a substantial number of applicants.

In light of these potential changes, we urge interested applicants to expedite their application processes. It’s a crucial time for those looking to leverage the current TRO program benefits before the window of opportunity potentially narrows. The evolving legislative landscape underscores the need for prompt action for those seeking residency in Bulgaria under the TRO program.

TRO compared to real-estate investment of 312,000 EUR

Investing 312,000 EUR in Bulgarian real estate qualifies you for a 12-month temporary residency card, similar to what you would receive by registering a Trade Representative Office (TRO) for a foreign company in Bulgaria. However, a significant difference exists between these two paths. The TRO route necessitates a 30-month stay in Bulgaria within any 5-year period to qualify for permanent residency.

Conversely, the real estate investment option offers greater flexibility, as it doesn’t mandate a specific duration of stay in Bulgaria. You are only required to visit Bulgaria annually to renew your temporary residency card over a 5-year period, making it a more accommodating choice for those seeking permanent residency.

TRO compared to Fund Investment of 512,000 EUR

While the Fund Investment of 512,000 EUR is a key component of the Bulgaria Golden Visa program, it shares only a basic similarity with the TRO in terms of initial application procedures. For both options, the first step involves applying for a D visa. Following this, a TRO applicant proceeds to apply for temporary residency, whereas a Fund Investor moves towards applying for indefinite permanent residency.


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