Bulgaria Revamps CBI Program: New Investment Options, Faster Processing

1st March 2021

Citizenship by Investment, For private clients, Citizenship and Immigration

On 26 February 2021, the Bulgarian Parliament approved а Bill amending the Bulgarian Citizenship Act and the country’s Citizenship by Investment Scheme thus introducing new investment options. The Government and legislators had mooted changes since January 2019. The changes are not in force yet (as of March 1) but are expected to be in the next 15 days.

Main changes

  1. New investment options are added
  2. Government/sovereign bonds are however no longer eligible
  3. The investment size required stays at the reasonable level of €0.5m (doubled to €1m for the fast track)
  4. Investment thresholds for one of the options (directly held equities) are increased
  5. Standard Track and Fast Track remain available
  6. Additional assurances to applicants are introduced
  7. Improvements are made for spouses of the investor
  8. Processing timelines are expected to be expedited

Investment Options

The overhauled investment routes leading to permanent residence and citizenship now are:

Investment options New amount
1 Stocks traded in Bulgaria ~EUR 1,024,000
2 UCITs (EU regulated fund vehicles) including exchange-traded funds (ETFs) with a focus on Bulgaria ~EUR 512,000
3 Investing in any way in Alternative investment funds (AIFs) (including private equity, venture and hedge funds), a part of whose focus is on Bulgaria ~EUR 512,000
4 Participation in a Bulgarian company carrying on a Certified Priority Investment Project (CPIP) – these are analogues of  EB-5 Regional Centers ~EUR 1,024,000
5 Participation in a Bulgarian company employing 10 Bulgarian persons or more ~ EUR 257,000
6 Participation in a Bulgarian private company, invested in any sector or geography ~ EUR 3,075,000
7 Investment in a Certified Investment Project (CIP) (this is different to CPIP above)  Exact amount and conditions are project-dependent.

Fast Track

Applicants using 1-4 above can fast-track by:

  • Doubling their investment “on identical statutory terms”; or 
  • Investing at least ~EUR 512,000 / ~USD 620,000 in a CPIP (as above)

Applicants using option 5 can fast-track by:

  • Doubling their capital investment, leading to the hiring of 20 people

How attractive are these options?

Bulgaria now offers a very sophisticated mixture of investment categories and may be ideally positioned for sophisticated investors.

While this is a bet also on the economic growth and the expansion and sophistication of the financial markets in Bulgaria, in general investments in financial markets tend to bring higher returns and preserve value better than real estate over time.  Undeniably, real estate remains instinctively more accessible for some investors (though some of the eligible listed vehicles are Real Estate Investment Trusts (REITs)).

Importantly, Bulgaria remains in the investment camp among RBI/CBI nations – as opposed to the complete switch to the donation camp (effected by Malta) or partial such (by Cyprus or Ireland).

Historically, Bulgaria has been little-pushed on CBI applicants due to the availability of products (bonds) which provided limited incentives to agents to sell. The newly eligible classes may create more incentive – eg, for alternative fund managers or IPOing businesses. Given that the investments will have their price at least partly set by public markets, this will at the same time limit concerns about transparency. 

As thus is resounding endorsement of CBI this is, Bulgaria is stating its firm support of CBI as a policy instrument. Although CBI policies are almost invariably under heightened political pressure (compared to other government policies), the current one can be expected to be stable for at least a period of time, particularly given the 2-year gestation period.  

Holding period

The investment must be maintained for an extra 2 years past grant of citizenship as well as 5 years in total.

Pre-approval process

For investors in options 1-3 (but not for options 4-7), the new legislation envisions a governmental pre-approval process. The exact nature of this process is yet to be detailed in secondary legislation, however in line with stronger EU anti money laundering requirements more substantial source of funds checks may be expected.

At a minimum, applicants will be asked to provide:

  • Proof of ID;
  • Sufficient funds for making the minimum investment required;
  • Clear source of funds information;
  • Information if the applicant is a PEP (PEPs are of course not prohibited from applying);
  • Information on the vocational/business/professional background of the applicant;
  • A Criminal Record Check from the country of origin or country of permanent residence (this reduces the current requirement)

Family of the main applicant

Another substantial improvement is that that under the new rules, spouses of applicants on the Fast Track would be able to apply for citizenship in a shorter time frame, 1 year after the main applicant’s citizenship, versus 3 years historically.

There are no changes to the application process for children who obtain citizenship within 6-9 months of the main applicant, grandchildren (12-18 months after), great-grandchildren (1.5-2.5 years after), etc.

Provisions on expedited processing

The legislators have also mandated expedited timelines for processing. Whether these will be closely kept will be a matter of practice and as such to be seen.

Grandfathering provision

The Bill contains an express grandfathering clause and there may be other grandfathering routes. Applicants with current valid PR may naturalise 5 years after investment or PR. Essentially, this maintains the old Standard Track. 

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