Renouncing Foreign Citizenship for Bulgarian Naturalisation: Section 12 in Practice

Private Clients Insights, Citizenship and Immigration, Citizenship by Investment

Key Points

• Standard route. Non-EU permanent residents now naturalise under Section 12 of the Bulgarian Citizenship Act (“BCA”). The preferential routes under Sections 12a and 14a were repealed on 5 April 2022.
• Residence requirement. Five years of permanent or prolonged-term residence at the date of filing (Sec. 12(1)(2) BCA).
• Renunciation timing. Renunciation of foreign citizenship is not required at filing. Evidence is required only after the Citizenship Council issues its approval in principle, and must be produced within three years (Sec. 4(1)(12) of Regulation No. 1).
• Exempt categories. Spouses of Bulgarian citizens, EU/EEA/Swiss nationals, persons of Bulgarian origin, and nationals of treaty-reciprocity states are exempt from the renunciation condition (Sec. 12(2) BCA).
• Decision-maker. The Vice President of the Republic issues the naturalisation decree under devolved presidential power (Presidential Decree No. 9 of 22 January 2022).

For non-EU nationals who have built a life in Bulgaria on the basis of a permanent residence permit, the logical next step is often naturalisation. Following the 2022 repeal of the investor citizenship route, the vast majority of permanent residents now convert their status to Bulgarian citizenship through a single substantive pathway: general naturalisation under Section 12 BCA. This section sets out the legal framework, the substantive criteria, the procedural pathway from the Ministry of Justice to the Vice President’s decree, and most importantly in practice the timing and mechanics of the renunciation requirement.

The Legal Framework for Bulgarian Citizenship and Naturalisation

Bulgarian nationality law is regulated by two instruments. The Bulgarian Citizenship Act (Закон за българското гражданство, “BCA”), promulgated in State Gazette No. 136/1998 and in force since 20 February 1999, is the primary statute; it implements Sections 25 and 26 of the Constitution and is the exclusive substantive source of Bulgarian nationality law (Sec. 2 BCA). Procedural and evidentiary detail is supplied by Regulation No. 1 of 19 February 1999 on the Application of Chapter Five of the Bulgarian Citizenship Act (Наредба № 1), issued by the Minister of Justice under the statutory delegation in § 7 of the Transitional and Final Provisions of the BCA. The Regulation prescribes the application form (Annex No. 1), the exhaustive documentary set, and the post-filing procedure before the Citizenship Council.

Section 12 BCA: The Substantive Criteria for Naturalisation

Section 12, paragraph 1 BCA imposes six cumulative conditions which must be satisfied at the date of filing. A non-Bulgarian citizen may acquire Bulgarian citizenship if he or she:

1. is of legal age (18 or over) — Sec. 12(1)(1);
2. has held a permanent or prolonged-term residence permit in the Republic of Bulgaria for not less than five years — Sec. 12(1)(2);
3. has not been convicted by a Bulgarian court of a premeditated indictable offence and is not subject to ongoing criminal proceedings for such an offence, unless rehabilitated — Sec. 12(1)(3);
4. has an income or occupation enabling him or her to support himself or herself in Bulgaria — Sec. 12(1)(4);
5. is proficient in the Bulgarian language, established under a procedure determined by ordinance of the Minister of Education and Science — Sec. 12(1)(5); and
6. has been released from his or her previous citizenship, or will be released from it at the time of acquiring Bulgarian citizenship — Sec. 12(1)(6).

The Language Requirement

The language requirement is assessed through a 20-question, one-hour written test administered by the Center for Assessment in Pre-school and School Education (Център за оценяване в предучилищното и училищното образование) under the Ministry of Education and Science; a minimum of 12 correct answers is required to pass. The examination is held monthly, and candidates who fail must wait at least three months before re-sitting. 

Income and Clean-Record Evidence

The income condition is typically evidenced by an employer’s certificate of labour or service relations, or by the previous year’s declared income certified by the National Revenue Agency. 

Clean-criminal-record evidence must be produced both from Bulgaria (a court conviction certificate and a prosecutor’s no-proceedings certificate) and from the applicant’s country of citizenship, the foreign document carrying an explicit statement that it is issued for the purposes of Bulgarian naturalisation.

The End of The Preferential Routes

The preferential and investor-driven routes to Bulgarian citizenship have been abolished. By the Act amending and supplementing the BCA, promulgated in State Gazette No. 26 of 1 April 2022 and effective 5 April 2022, Parliament repealed Section 12a BCA (preferential naturalisation linked to investment by certain categories of permanent residents) and Section 14a BCA (citizenship by investment), and terminated all pending proceedings under those provisions (§ 7 of the Transitional and Final Provisions of the amending Act). The first-reading vote on 24 March 2022 was unanimous: 218 members voted in favour, none against, none abstained. The citizenship-by-investment regime — under which the prescribed investment could be doubled (to BGN 2,000,000 at that time) in return for application after one year of permanent residence — no longer exists.

The practical consequence is that, save for the narrow categories of citizenship by descent (Sec. 15 BCA), by marriage (Sec. 13 BCA), and by special merit (Sec. 16 BCA), every applicant moving from permanent residence to Bulgarian citizenship now travels through the standard Section 12 procedure.

Renouncing Foreign Citizenship under Section 12(1)(6) BCA: Timing and Mechanics

The renunciation requirement is the single most misunderstood condition in Bulgarian nationality practice. Two points of clarification are essential.

Is prior renunciation required at the date of filing?

No. Section 12(1)(6) BCA expressly contemplates that the applicant either has been released from foreign citizenship or will be released from it at the time of acquiring Bulgarian citizenship. The implementing rule — Section 4, paragraph 1, item 12 of Regulation No. 1 — operationalises this by providing that the applicant submits, with the application, a document from the relevant foreign authorities certifying renunciation; and, where no such document is available, “it must be submitted within three years of receiving notification that the Citizenship Council at the Ministry of Justice has approved the applicant for Bulgarian citizenship.”

When does the renunciation document have to be produced?

After the Citizenship Council issues its positive opinion. The file is examined by the Citizenship Council (Съвет по гражданството) at the Ministry of Justice, constituted under Section 33 BCA, which gives an opinion on the application after written input from the Ministry of the Interior and the State Agency for National Security. Once the Council issues its positive opinion, the applicant receives a written notice that the application has been approved in principle and is invited to produce, within the three-year window in Section 4(1)(12) of Regulation No. 1, the foreign document evidencing renunciation. Until that evidence is produced, the file is not forwarded by the Minister of Justice to the Vice President of the Republic, and no decree of acquisition will issue.

Which applicants are exempt?

Section 12, paragraph 2 BCA exempts three categories: (i) spouses of Bulgarian citizens; (ii) citizens of an EU Member State, an EEA State or the Swiss Confederation; and (iii) citizens of countries with which Bulgaria has concluded a treaty establishing reciprocity. Persons of Bulgarian origin applying under Section 15(1) BCA are separately exempted, as Section 15(1) dispenses with the conditions of Section 12(1), items 2, 4, 5 and 6 – including the renunciation condition.

For nationals of states which do not permit voluntary renunciation as a matter of law or practice, a non-trivial population, including Argentina (constitutional bar under Section 75(12)), Iran, Morocco and several other states across Latin America and the MENA region, the three-year window can in practice prove impossible to satisfy, and naturalisation can stall at the post-approval stage. This is a known structural defect of the Bulgarian regime and a matter on which specialist advice is essential before filing.

Procedural Pathway: Ministry of Justice, Citizenship Council and Vice Presidential Decree

The application is filed in person at the Ministry of Justice (Citizenship Directorate) in Sofia or at a Bulgarian diplomatic or consular mission abroad, following prior online appointment (Sec. 29(1) BCA). At filing, the applicant is interviewed in Bulgarian on the basis of an approved questionnaire (Sec. 29(3) BCA).

The Citizenship Council then deliberates and gives its opinion. On the basis of that opinion, the Minister of Justice makes a reasoned proposal to issue (or to refuse) a decree, within twelve months of filing in standard general-naturalisation cases (Sec. 35(1)(1) BCA). The decree itself is issued under Section 36 BCA. Although the Constitution vests the power to grant Bulgarian citizenship in the President (Section 98(9) of the Constitution), the President may devolve that power to the Vice President under Section 104 of the Constitution. In the current presidential term, by Presidential Decree No. 9 of 22 January 2022, citizenship decisions are exercised by the Vice President, assisted by the Commission on Bulgarian Citizenship established under Presidential Decree No. 36 of 22 January 2022. The decree enters into force on the day of issuance (Sec. 36, second sentence, BCA).

Realistic Timeline for Bulgarian Naturalisation

There is no statutory deadline for the Vice President’s decree under Section 36 BCA. In current practice, applicants under Section 12 BCA should plan for a total elapsed time of approximately twenty-four months from filing to decree — eighteen months for the Minister’s proposal under Section 35(1)(1) BCA plus, on practitioner estimates, roughly a further six months for the Vice President’s decree — and longer where renunciation cannot be promptly evidenced. Persistent administrative delay can be challenged by way of an action against “tacit refusal” before the Administrative Court – Sofia Region; following amendments to the Administrative Procedure Code effective from 3 September 2025, the appeal window stands at two months from expiry of the statutory period within which the administrative authority was required to act.

FAQs on Renouncing Foreign Citizenship for Bulgarian Naturalisation

Do I need to renounce my foreign citizenship before applying for Bulgarian citizenship?

No. Under Section 12(1)(6) BCA and Section 4(1)(12) of Regulation No. 1, the application is filed without prior renunciation. Evidence of renunciation is required only after the Citizenship Council issues its positive opinion, and must be produced within three years of that notification.

Can EU, EEA or Swiss citizens retain dual citizenship?

Yes. Section 12(2)(2) BCA exempts nationals of EU Member States, EEA States and the Swiss Confederation from the renunciation requirement. They may naturalise while retaining their existing citizenship.

Is the Bulgarian citizenship by investment route still available?

No. Section 14a BCA was repealed by the amendments published in State Gazette No. 26/2022, effective 5 April 2022, and all pending applications were terminated by operation of law. Investors moving from permanent residence to citizenship now follow the standard Section 12 procedure.

What happens if my country does not permit renunciation?

The file will stall after Citizenship Council approval unless the applicant falls within an Section 12(2) BCA exemption. Nationals of states that prohibit renunciation as a matter of constitutional or practical law — including Argentina, Iran and Morocco — should obtain specialist advice before filing, as the three-year window in Section 4(1)(12) of Regulation No. 1 cannot in practice be satisfied.

Who issues the decree granting Bulgarian citizenship?

The Vice President of the Republic, under powers devolved by the President pursuant to Section 104 of the Constitution and Presidential Decree No. 9 of 22 January 2022. The decree is issued under Section 36 BCA and enters into force on the day of issuance.

How long does the process take from filing to decree?

Approximately 24 months. Section 35(1)(1) BCA provides a 12-month period for the Minister of Justice’s reasoned proposal, but there are significant delays and in current practice a further period of roughly 6 months should be expected for the Vice President’s decree under Section 36 BCA. There is no statutory deadline for the decree itself.

How NBLO Can Assist

NBLO has acted on Bulgarian citizenship matters for over fifteen years and has guided clients from a wide range of jurisdictions, including those whose home states present the most acute renunciation difficulties, through every stage of the Article 12 procedure. Our team handles the substantive file preparation under Article 12(1) BCA and Article 4 of Regulation No. 1, advance assessment of renunciation feasibility, representation before the Citizenship Council at the Ministry of Justice, liaison with the Commission on Bulgarian Citizenship at the Vice Presidency, and, where necessary, administrative-court proceedings against tacit refusal before the Administrative Court — Sofia Region. We also advise on the upstream permanent residence position and the related private-client, tax and structuring questions that almost always accompany a move from residence to citizenship.

To discuss your circumstances on a confidential basis, please complete our Contact Form or write directly to citizenship@newbalkanslawoffice.com.