Bulgarian Citizenship by Investment is based on provisions in the Bulgarian Citizenship Act. In early 2021, the Bulgarian Parliament partially amended the legislation governing Bulgarian citizenship by investment, moving the focus of the investment onto capital markets and investments such as in exchange-traded funds (ETF). 

One of these new options allows investment in Undertakings for the Collective Investment in Transferable Securities (UCITS) also known as Collective Investment Schemes in Bulgaria. To non-European investors, this type of funds may be familiar as mutual funds. Those funds or Collective Investment Schemes are managed by licensed Fund Managers and have an investment strategy which they set out in their prospectus.

What is an ETF? 

ETFs which many investors are familiar with can also be organised as a Collective Investment Scheme and thus be compatible with the requirements of CBI law in Bulgaria. ETFs were introduced in North America for the first time in the early 1990s and are perceived to allow casual investors access to markets which they may otherwise not find accessible. The current (as of Q1 2021) value of these in the US, for example, is believed to be about a quarter of the size of the US GDP on a PPP basis.

Thus making the ETF one of the investment vehicles that investors might wish to explore.

In correspondence which followed a piece covering ETFs in the Economist, a correspondent to the paper wrote: “With ETFs, the end result is lower fees, more transparency and fewer Wall Street pitchmen. Few tears will be shed.” (Patrick Cleary, Letters).

While in the US and Western Europe, this mode of investment has received a lot of investor attention, it has had less of a history and take-up in Bulgaria and what you may expect from international experience may not apply in quite the same way.  

ETFs invest in shares of companies in a particular index or sector, or in commodities, for example. In order to qualify for the Bulgarian citizenship, an ETF must meet certain requirements as per the Foreigners in the Republic of Bulgaria Act:

  1. The ETF should have a Net-Asset Value (NAV) of at least BGN 5 mln (or ~EUR 2,5 mln); AND
  2. The ETF should invest [exclusively?] in shares or corporate bonds of companies listed on the Bulgarian Stock Exchange – Sofia (BSE-Sofia).

If investors are considering investing in an ETF, but are not sure if that ETF meets the requirements, please contact us to see how we can assist you.

Where to purchase the ETF?

ETFs can be purchased on different stock exchanges or multilateral trading facilities. Thus raising the question?

Can I make the investment into an eligible ETF outside of Bulgaria using my existing bank/broker?

A purchase of an ETF outside of Bulgaria using the investor’s existing bank/brokerage is possible. 

However, the amended Foreigners in the Republic of Bulgaria introduced certain additional requirements about the holding of the investment. The Bulgarian Central Depository (a company supervised by the Financial Supervision Commission and appointed to perform a public function) is required to provide information about the holdings to the Bulgarian Investment Agency. 

When purchasing the investment in Bulgaria, this information is presented to the Central Depository by the relevant bank/brokerage/fund manager and the Central Depository has specific information about the holder of the investment. 

If investors are considering starting the process, they may wish to contact us first to make sure that requirements of the Foreigners Act are met. Please contact us to further discuss this with our experts. 

ETF Investment Amount

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

Under the Fast Track, preferred by the majority of applicants, investors need to initially invest BGN 1 mln (~EUR 500k) and can double this for a total investment of BGN 2 mln or ~EUR 1 mln at any point after holding a valid permanent residence permit for at least 1 year. This has the effect of accelerating their eligibility for naturalisation to the date of the 2nd purchase.

Pre-Approval Process

Before investment, the applicant for citizenship by investment must go through a pre-approval process with the Bulgarian Government including meet the requirements for an identified source of funds (rather than source of wealth). We will be happy to advise you on this,  please contact us.

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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