One of the main concerns for applicants who start any CBI application process is the chance for citizenship application refusal. 

While this is a perfectly reasonable concern, there are almost no bureaucratic processes that are 100% certain and if a service provider gave you a guarantee of certain success, you one should treat that with caution. Of course, it is reasonable to expect that if you have complied with a set of legal requirements, you will be granted approval of your application and further, that you will not experience any unexpected surprises.

In our extensive practice in Bulgarian citizenship by investment, we have been asked to advise a number of clients who have been refused because of non-compliance with the legal or procedural requirements through no direct fault of their own. Since in the nature of these administrative procedures, these applications take a comparatively long time from inception to conclusion, this is especially unpleasant, as it cannot be easily remedied immediately by a new application and the error may become apparent only after a time. Here we outline some of the reasons for citizenship application refusal where the failure is avoidable and can be prevented by careful selection of service provider; investment requirements and compliance with the programme requirements.

Reasons for Bulgarian citizenship application refusal

  1. The applicant buys an investment (eg, government bonds, previously). They give another party the right to act as an agent. The investment is sold or changed under a power of attorney without their knowledge by the agent,  and perhaps the applicant is not informed in advance. As the applicants are required to maintain the investment, and they have not maintained it intact, they are surprised when faced by a refusal.
  2. The applicant buys an investment which either doesn’t qualify or which is uncertain to qualify (eg, an insurance policy; certain derivatives etc). The product is  not transparent  and may appear on the face of it not to meet the requirements of CBI legislation. For example, an option to invest in some kind of “life insurance policy” with an element of an investment in equity was offered, but service providers marketing this option were unable to explain how this met the legal requirements of the programme. 
  3. Failure to evidence that the investment is kept. It is not uncommon for the Bulgarian authorities to request evidence that the investment has been maintained and there is an obligation to do so. It is standard practice for the relevant authority reviewing the application such as the Ministry of Justice to send a request to the Bulgaria Investment Agency  requesting up-to-date information about the holding of the investment. The Agency would in turn contact the applicant or his/her representative requesting such documentary evidence. A tight timeframe is given for such requests and failure to comply may result in the refusal of the citizenship application as authorities cannot confirm the continued holding of the investment.

While there is no published statistical information about the percentage of refusal, the main cause of rejections in our team’s experience is “failure to maintain investment” for the required total period of 5 years. This is usually because investors knowingly sell before the expiry of the period not being aware of the need to keep holding, or more commonly, because of use of lending, where the lender had control over the position and has sold it in advance. 

We have been involved in advising some such applicants on what their recourse may be against the provider/agent who they believe misled them.

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 to date our clients are 100% successful.

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

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