Following the recent changes to the Foreigners in the Republic of Bulgaria Act revamping Bulgarian citizenship by investment (CBI) and residence by investment (RBI), applicants now have a myriad new investment opportunities to qualify for CBI or RBI, including alternative investment funds (AIFs).

What are Alternative Investment Funds in this context?

An alternative investment fund is a legal creation of EU law, and it is largely what the name implies – a vehicle for a pooled investment in alternative assets:

any collective investment undertaking which raises capital from a number of investors with a view to investing it in accordance with a defined investment policy for the benefit of those investors and which does not require authorisation pursuant to the UCITS Directive.

AIFs can be open-ended or closed-ended; listed or unlisted. 

AIFs carry a higher risk than conventional investment funds, but are attractive to some investors due to their potential for greater reward. Such investors are typically professional investors (we use the phrase in its common meaning) or high net worth individuals (HNWIs).

Alternative Investment Funds Assets 

AIFs can focus on tangible alternative assets (for example, gold, wine, watches, etc) or intangible assets (equities, corporate bonds etc). Hedge funds, private equity funds and venture capital funds are commonly structured as AIFs.

Alternative Investment Funds in Bulgaria

Alternative Investment Funds are a relatively new vehicle in the Bulgarian financial market. They are the preferred vehicle for private equity investments in the technology sector. Many of the first batch of AIFs in Bulgaria were seeded with funding from public sources, but are run (within certain constraints) on a commercial basis.

AIFs as CBI investments

In order to qualify for EU citizenship, an investor may choose to invest in an AIF. The chosen investment must:

  1. Have assets of no less than BGN 3,000,000;
  2. the fund and its manager(s) must be licensed or registered by the Financial Supervision Commission;
  3. the fund’s investment strategy must focus mainly on investments in Bulgarian assets and they invest only in shares, stocks and bonds of Bulgarian companies, including REITs;

A number of funds currently on the market meet thеse requirements. Those AIFs generally are focused on the Bulgarian tech and digital start-up ecosystem and their investees include high-tech companies such as Allterco and Sirma Technologies.

We at Citizenship Insight by NBLO will be happy to introduce you to the AIF Managers in Bulgaria. 

AIF investment size

The Standard Track requires a single investment of BGN 1 mln (~EUR 500k). 

If an applicant wishes to go on the Fast Track, they can invest BGN 1 mln (~EUR 500k) and double this to a total of BGN 2 mln (~EUR 1 mln) at any point after holding a valid Bulgarian permanent residence permit for at least 1 year. 

Pre-Approval Process

Before investment, the applicant for citizenship by investment must go through a pre-approval process with the Bulgarian Investment Agency and meet the requirements for an identified source of funds (rather than source of wealth). Book a free consultation and we will be happy to advise you on this.

NBLO – Your Bulgarian Citizenship Lawyers

New Balkans Law Office is a boutique law firm with a strong practice in Bulgarian and EU immigration and nationality law. We deal extensively with applications for citizenship including Bulgarian citizenship by investment, Bulgarian citizenship by origin and Bulgarian citizenship by residence, settlement of family members of EU/Bulgarian citizens, and other citizenship and immigration related matters.

We have helped a number of high-net-worth individuals in obtaining Bulgarian citizenship by investment and today our clients are 100% successful.

For more information, please contact us at: or via our contact form.

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