New Requirements for Trade Representation Office (TRO) Residency Route in Bulgaria

1 July 2025

Private Clients, Citizenship and Immigration, Expat Assistance

As of June 2025, the Bulgarian legislation governing residence permits based on the registration of Trade Representation Offices (TROs) of foreign companies has been amended (State Gazette No. 52/2025). These changes affect both newly established TROs and those already operating in Bulgaria.

The revised rules introduce new eligibility and reporting requirements, as outlined below:

Key Changes:

1. Financial Criterion

Foreign companies seeking to register a TRO in Bulgaria in addition to their tax compliance within the country of registration must now demonstrate:

    • An annual turnover of at least BGN 100,000 (approx. EUR 51,000) or its equivalent in foreign currency, achieved in each of the two financial years prior to registration. This must be confirmed by official documents submitted to the Bulgarian Chamber of Commerce and Industry (BCCI).

2. Residency Limitations

A maximum of two representatives of the foreign company may be granted residence permits under this route. This reduces the number of trade representatives from three to two

3. Renewal Conditions Strengthened

Upon applying to extend their residence, TRO representatives must also:

    • Present evidence of office presence, actual representational activity, and/or relationships with Bulgarian partners.
    • Submit a new certificate of good standing (valid for 6 months from issuance).

4. Ongoing Obligations and Monitoring

    • The foreign parent company must submit a new certificate of good standing within 30 days of any changes in its registration status.
    • The TRO itself must report any changes in its registration circumstances within 7 days to the BCCI.
    • Bulgarian authorities may initiate the deregistration of a TRO if it is found non-compliant, and such deregistration will be communicated to the Migration Directorate.

5. Transitional Period

Existing TROs have up to two years from the entry into force of the law to bring their registration and documentation into compliance.

Key Differences from the Previous Regime:

Two major changes set the new regime apart from the previous framework. First, there was previously no requirement for the foreign company to demonstrate a minimum turnover—the introduction of the BGN 100,000 annual turnover threshold (for two consecutive years) raises the bar for eligibility. Second, the number of foreign trade representatives eligible for residence under this route has been reduced from three to two, limiting the number of individuals who can benefit from this basis for residency.

Implications for Clients

While the route remains available, companies must now be more established, maintain rigorous documentation, and demonstrate ongoing representative activity in Bulgaria.

We recommend that clients:

  • Review their eligibility in light of the new requirements.
  • Prepare any upcoming renewals well in advance.
  • Maintain active operations and clear records of representational activities.

Our team at New Balkans Law Office is ready to assist clients—both existing and prospective—in navigating these changes, evaluating their options, and ensuring compliance with the new rules.

Contact us today if you require support with your TRO registration or residence application.



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The Bulgarian and dual-qualified lawyers of New Balkans Law Office are regulated by the respective Bar of their registration. New Balkans Law Office is a brand name of Legal Services EOOD, a company registered under Bulgarian law. Reg’d No. 202331677. Further details are available here.

© New Balkans Law Office 2025