Bulgaria’s Golden Visa Could Lose Its Biggest Advantage: No-Residency Permanent Residence

Bulgaria may be preparing one of the most important changes to its investor residence framework.

For years, Bulgaria has occupied a distinctive position in the European golden visa market. While many countries offer residence permits in exchange for investment, Bulgaria’s program has stood out because it could provide permanent residence from the beginning, without requiring the investor to live in the country.

That feature made Bulgaria especially attractive for global investors seeking a European residence anchor, Schengen access, EU optionality, and a potential long-term path to citizenship without immediate relocation.

Now, that advantage may be at risk. A proposed bill tabled in Bulgaria’s National Assembly would introduce a stricter residence requirement for permanent residence holders. If approved, any foreigner who spends less than six months and one day in Bulgaria during the previous calendar year could lose permanent residence status.

For Bulgaria’s golden visa investors, this would represent a major shift. A program once known for flexibility could become a program requiring real physical presence.

Why Bulgaria’s Golden Visa Has Been So Attractive

Bulgaria’s investor residence route has long been one of Europe’s more overlooked options.

It has not received the same attention as Portugal, Greece, Malta, or Hungary. Yet for a certain type of investor, Bulgaria has offered something very valuable: immediate permanent residence through qualifying investment.

Unlike ordinary residence permits, permanent residence provides a stronger and more stable immigration position. It can allow investors to establish a long-term legal connection to the country without going through multiple temporary renewals first.

The program has also appealed to investors because Bulgaria is a member of the European Union and part of the Schengen Area. This makes Bulgarian residence relevant not only for access to Bulgaria itself, but also for broader European mobility planning.

Another important element is Bulgaria’s tax environment. The country has traditionally been known for a relatively competitive tax system within the EU, including a flat income and corporate tax rate. For investors who may actually relocate and become tax resident, that can make Bulgaria more interesting than higher-tax European alternatives.

But the most distinctive advantage has been simple: investors could obtain permanent residence without needing to live in Bulgaria. That may now change.

What the Proposed Bill Would Do

The proposed reform would change how absence and presence are measured for permanent residence holders.

Under the current framework, the relevant rule has been more focused on extended absence from the European Union as a whole. This meant that a permanent resident could generally avoid losing status as long as they did not remain outside the EU for a prolonged period.

The proposed bill would narrow the test dramatically. Instead of looking at absence from the European Union, the new rule would focus on physical presence in Bulgaria itself. A permanent residence holder would need to spend more than half of the previous calendar year in Bulgaria.

In practical terms, this means the investor would need to be in Bulgaria for at least six months and one day. For global investors, entrepreneurs, and families who obtained Bulgarian residence precisely because they did not intend to relocate immediately, this would be a significant change.

The legal nature of the program would shift from “permanent residence with no real stay obligation” to “permanent residence requiring substantial presence.”

Why This Matters for Investors

Golden visa applicants often choose programs based on lifestyle flexibility.

Many do not want to move immediately. They want a Plan B. They may live in Dubai, London, Singapore, Miami, Istanbul, São Paulo, Buenos Aires, or another global city, while maintaining a European residence option for the future.

For these clients, physical presence requirements matter.

A requirement to spend more than six months per year in Bulgaria is not a minor administrative obligation. It changes the entire planning equation.

Spending more than half the year in a country may affect tax residency, family logistics, children’s education, business management, travel patterns, and the applicant’s relationship with other jurisdictions.

A golden visa that requires no relocation serves one purpose. A golden visa that effectively requires relocation serves another.

That does not mean Bulgaria would become unattractive. It means Bulgaria would become attractive to a different type of applicant.

From Backup Plan to Real Relocation Strategy

If the bill becomes law, Bulgaria’s investor residence route may move away from the classic “Plan B” model.

Instead of being mainly useful for investors who want optionality without relocation, it may become more relevant for those genuinely willing to spend significant time in Bulgaria.

This could include entrepreneurs looking for an EU operating base, families seeking a lower-cost European lifestyle, investors interested in tax residency, or individuals who want to build a stronger connection to the country.

For these applicants, Bulgaria may still offer important advantages.

It has EU membership, Schengen access, competitive taxes, relatively affordable living costs, a strategic location between Europe and the Balkans, and growing relevance as an investment destination. But the marketing message would change. The question would no longer be: “Can you obtain European permanent residence without living there?”

The question would become: “Are you prepared to make Bulgaria a real part of your life?”

The Citizenship Question

One of the reasons Bulgaria has attracted interest is its potential pathway to citizenship.

Bulgaria’s investor route has been viewed as a possible long-term strategy because permanent residence could begin immediately, and citizenship eligibility may arise after several years, subject to the applicable requirements, including language and legal conditions.

For many investors, the absence of a physical presence obligation made this especially powerful. They could maintain residence status and later evaluate whether naturalization made sense. If Bulgaria introduces a substantial residence requirement, the citizenship strategy becomes more serious — but also more demanding.

Applicants would need to think carefully about whether their physical presence supports not only residence maintenance, but also future citizenship planning. They would also need to consider whether spending more than half the year in Bulgaria creates tax residence, business substance, or family relocation issues.

This could make the program more credible from a naturalization perspective, but less flexible for investors who wanted a passive route.

No Transitional Rule: The Biggest Concern

One of the most important concerns is the lack of clarity around transitional protection.

According to the reported bill, there is no clear commencement date and no explicit grandfathering rule for existing permanent residence holders.

This matters enormously.

Investors who already obtained Bulgarian permanent residence may have structured their affairs based on the rules in force at the time of approval. If the new requirement applies quickly or retroactively to the current calendar year, some existing permit holders could face uncertainty.

Would the rule apply only going forward?Would existing investors be protected?Would the first tested year be the year after the law enters into force?Would applicants already approved under the old framework receive any special treatment?

These questions are critical.

A golden visa program depends heavily on trust. Investors commit capital because they expect the rules to remain predictable, or at least to change with reasonable notice.

If a country changes the conditions without transitional protection, the program may face reputational consequences.

A Broader European Trend

Bulgaria’s proposal fits into a wider European pattern.

Across Europe, golden visa programs are under pressure. Spain has closed its real estate-based golden visa route. Ireland ended its Immigrant Investor Programme. The United Kingdom closed its Tier 1 Investor Visa. Portugal has restricted its real estate option and continues to face political and administrative pressure. Malta’s citizenship-by-investment framework has faced major EU-level scrutiny.

European governments are increasingly trying to ensure that investor migration programs involve more substance, more compliance, and less purely passive residence.

In this environment, Bulgaria may be moving in the same direction: less passive optionality, more genuine connection.

From a policy perspective, governments may argue that permanent residence should reflect real residence. From an investor perspective, however, this changes the value proposition.

The tension is obvious. Countries want serious residents. Investors want flexibility. The future of golden visa programs will depend on how governments balance those two objectives.

What Makes Bulgaria Different

Bulgaria is not simply another European golden visa jurisdiction.

Its strongest feature has been the combination of immediate permanent residence, EU and Schengen relevance, relatively low tax rates, and no physical residence requirement.

That combination made it unusual.

Other jurisdictions may offer residence through investment, but not always permanent residence from the start. Some may offer no stay requirement, but only temporary residence. Others may offer a path to citizenship, but only after years of actual residence.

Bulgaria’s model brought several advantages together in one place.

If the new bill passes, that uniqueness may weaken.

Bulgaria would still remain relevant, but investors would compare it differently. It would compete more directly with relocation-based residence options rather than pure Plan B golden visas.

What Investors Should Watch

The most important point is that the proposal is not yet final.

Investors and advisors should monitor the legislative process carefully before making decisions. The text may change. Exemptions may be clarified. Transitional rules may be added. The final law may be narrower than the draft.

Key points to watch include: whether investor permanent residence holders are exempted; whether existing residents are grandfathered; when the rule would enter into force; which calendar year would be tested first; whether exceptional circumstances are recognized; how physical presence will be documented; and whether the requirement affects future citizenship eligibility.

These details will determine whether the change is manageable or transformative.

A More Serious Program, but a Less Flexible One

If Bulgaria adopts the proposed requirement, the program may become more serious in the eyes of regulators and policymakers.

A residence program that requires real presence may be easier to defend politically than one that allows investors to obtain permanent residence without living in the country.

It may also align better with the European Union’s increasing focus on substance and genuine links.

However, seriousness comes at a cost.

The program may lose many investors who are seeking flexibility rather than relocation. High-net-worth individuals often value residence options that do not disrupt their existing tax position, business operations, family life, or travel patterns.

For them, six months and one day is not a technicality. It is a lifestyle decision.

Final Analysis

Bulgaria’s proposed residency requirement could mark a turning point for one of Europe’s most distinctive investor residence programs.

The country has built its appeal around immediate permanent residence, EU access, Schengen relevance, and minimal physical presence. If the new rule passes, that model could change fundamentally.

For investors willing to live in Bulgaria, the program may still offer strong advantages: European Union residence, competitive taxation, strategic location, and long-term citizenship potential. For investors seeking a passive European backup plan, the proposal may significantly reduce the program’s appeal.

The outcome will depend on the final law, exemptions, transitional rules, and implementation practice. Until those details are clear, Bulgaria remains a program to watch closely. What is clear already is that the European golden visa market is moving toward a new standard.

The future belongs less to paper residence and more to genuine connection.

Bulgaria may be the next country to make that shift.

How Creimerman Law Can Assist

At Creimerman Law, we assist international families, investors, entrepreneurs, and globally mobile individuals with immigration planning, residency options, citizenship strategies, international structuring, tax residency analysis, and cross-border legal coordination.

Our team helps clients evaluate jurisdictions, understand residency and citizenship pathways, prepare documentation, assess compliance considerations, and design strategies aligned with personal, family, business, and financial goals.

Contact us at info@creimermanlaw.com for personalized guidance.

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