Bulgaria Citizenship by Investment: The Abolished Programme

The Bulgaria Citizenship by Investment Programme: History and Abolition

Bulgaria offered what was, for many years, one of the most accessible routes to EU citizenship through investment available in the world. At a time when Malta's programme cost €880,000 or more and Cyprus required €2 million-plus, Bulgaria offered a pathway to full Bulgarian — and therefore EU — citizenship for approximately €1 million in government bonds, with an accelerated route available for a higher investment.

The programme ended in March 2022. Its abolition was not prompted by scandal in the same immediate way as Cyprus's closure in 2020, but rather by the steady ratcheting of EU political and legal pressure on investor citizenship programmes within member states — pressure that Bulgaria ultimately yielded to.

How the Programme Worked

The Bulgaria CBI programme was structured around investment in Bulgarian government bonds:

Standard route: Investment of approximately BGN 2 million (roughly €1 million at prevailing exchange rates) in Bulgarian government bonds. After five years of holding this investment and maintaining Bulgarian permanent residency, the applicant could apply for citizenship through a naturalised route. Physical presence in Bulgaria was technically required but not always rigorously enforced.

Expedited route: Investment of BGN 4 million (approximately €2 million) in government bonds allowed applicants to apply for citizenship after just one year of permanent residency, bypassing the standard five-year requirement. This was the route most frequently used by investors primarily seeking the passport rather than Bulgarian residency for lifestyle reasons.

Applicants were also typically required to make a real estate purchase (though this was not always a formal legal requirement, it was standard in practice) and to demonstrate no criminal convictions and a legitimate source of funds.

The resulting Bulgarian citizenship was full EU citizenship — with the right to live, work, travel, and vote across all 27 EU member states.

Why the EU Opposed It

The European Commission's objection to CBI programmes within EU member states operated on several levels:

Shared vulnerability principle: EU citizenship belongs to all member states collectively, not to individual countries alone. A Bulgarian citizen is also an EU citizen, able to move freely across the EU. If Bulgaria grants citizenship to an individual who passed inadequate due diligence, that individual can then settle in Germany, France, or any other member state. The Commission argued that this created a shared security and integrity risk that Bulgaria could not manage unilaterally.

Money laundering risk: The Commission pointed to the structure of Bulgarian government bond investment — large, liquid flows from foreign nationals — as inherently attractive to individuals seeking to legitimise funds or move capital across borders. The due diligence processes in place were judged insufficient to mitigate this risk adequately.

Commodification of citizenship: The Commission's formal position was that EU citizenship cannot lawfully be the subject of a commercial transaction. Selling citizenship for money — even investment — is, in the Commission's view, incompatible with the Treaty on European Union's conception of citizenship as a status reflecting genuine ties to a member state.

Following the Cyprus abolition in November 2020, the Commission intensified pressure on Bulgaria and Malta — the two remaining EU CBI programmes. Bulgaria abolished its programme in March 2022. Malta did not, resulting in infringement proceedings.

Bulgaria's Changed Position: Schengen Accession

An important development since the abolition of the CBI programme is Bulgaria's accession to the Schengen Area. Bulgaria joined Schengen for air and sea travel in March 2024, with internal land border controls removed on 1 January 2025, making it a full Schengen member. This is a significant change in the value of Bulgarian residency.

Prior to Schengen accession, a Bulgarian permanent residence card did not give the holder free movement across the Schengen Area — only within Bulgaria. Post-accession, Bulgarian residency (for non-EU nationals) gives access to Schengen travel on a valid residence permit, in addition to all rights within Bulgaria itself.

This makes standard Bulgarian residency more attractive for non-EU nationals than it was before. The five-year pathway to citizenship through ordinary naturalisation remains available and is now backed by a more valuable underlying residency status.

Standard Naturalisation in Bulgaria

For those genuinely interested in Bulgarian citizenship today, the standard route is:

• Permanent residency application: Requires five years of continuous legal residency in Bulgaria (from initial temporary residency). Various grounds: employment, business, property ownership, family.
• Citizenship application: After five years of continuous permanent residency (total approximately ten years from first entry), applicants may apply for Bulgarian citizenship. Certain categories have shorter timescales — three years of permanent residency for spouses of Bulgarian nationals, for example.
• Language and civic requirements: A Bulgarian language test is required. There is no formal civic knowledge test at present, but this may change.
• Dual nationality: Bulgaria permits dual citizenship, so British and other applicants need not renounce their original nationality.

There is no investment shortcut remaining. The bond investment route and the one-year accelerated naturalisation pathway are both gone.

Who Had Been Using the Programme

The Bulgaria CBI programme attracted a different profile from Cyprus or Malta, primarily because of its lower cost relative to other EU options:

• Chinese nationals, for whom EU citizenship was a primary goal and the price differential from Cyprus or Malta was significant
• Russian and CIS nationals seeking EU mobility, for whom €1 million was more accessible than the Malta or Cyprus price points
• Middle Eastern investors seeking EU citizenship as part of a diversification strategy
• Individuals from developing economies for whom EU citizenship represented access to a dramatically better passport

Many applicants had little or no genuine intention of living in Bulgaria. The country served purely as a mechanism for EU citizenship acquisition. This profile of usage — purely transactional, no genuine connection to the country — was precisely what the European Commission objected to.

Current Alternatives to the Bulgaria Programme

Malta Citizenship by Naturalisation for Exceptional Services (no longer available): Malta operated what was, until 2025, the EU's last direct citizenship by investment route. On 29 April 2025 the Court of Justice of the EU (Case C-181/23, Commission v Malta) ruled the scheme unlawful, holding that it amounted to the commercialisation of EU citizenship. As a result, there is no longer any direct citizenship by investment programme in the EU. The remaining EU options all run through residency and ordinary naturalisation.

Portugal Golden Visa: Investment in a qualifying fund (from €500,000) or other qualifying assets provides EU residency. The property and capital-transfer routes were removed in October 2023; remaining routes include funds, scientific research, arts/heritage, job creation, and business. Citizenship eligibility after five years of maintaining the investment and minimal physical presence requirements. Portuguese is a major world language, and Portugal offers a high quality of life.

Greece Golden Visa: Property or fund investment from €250,000 (lowest tier) to €800,000 (Athens, Thessaloniki, and the most in-demand islands). EU residency, with citizenship by naturalisation possible after seven years of residence. No language requirement for residency.

Spain Golden Visa (closed): Spain closed its Golden Visa programme to new applicants on 3 April 2025. It previously offered EU residency for a €500,000 property investment, with a path to citizenship after ten years (or two years for nationals of Latin American countries, the Philippines, and certain others with historical ties to Spain). Existing holders are unaffected, but the route is no longer open to new investors.

Compliance Note

The information above reflects conditions as of mid-2026. Programmes and requirements change. EU pressure on citizenship and residency by investment schemes within member states continues to evolve, and further restrictions or abolitions are possible. We strongly recommend obtaining qualified legal and tax advice before making any investment decision related to citizenship or residency. Investment values can fall as well as rise.

How Global Investments Can Help

Our team has assisted clients who were considering the Bulgaria programme and who needed to map their options after its abolition. With Malta's citizenship route struck down by the Court of Justice of the EU in April 2025, there is no longer a direct citizenship by investment programme in the EU. The realistic paths to EU citizenship now run through medium-term residency and naturalisation — principally Portugal and Greece (Spain's Golden Visa closed to new applicants in April 2025). Each has its own cost structure, timeline, lifestyle implications, and tax considerations.

We can help you understand which programme is genuinely right for your objectives, prepare your application, coordinate with approved local legal counsel, and identify qualifying investment properties or funds. Contact our citizenship team for a confidential initial consultation.