Bulgaria’s newest fund‑based residency‑by‑investment scheme promises permanent residency from the moment the application is approved and eligibility for citizenship after five years. The program has attracted attention as a possible alternative to Portugal’s Golden Visa, which has recently faced significant changes.
Recent developments in Portugal’s Golden Visa
- Real‑estate route closed (Oct 2023). Most applicants previously used this pathway; it is no longer available.
- Remaining routes:
- Donation of €250 000
- Scientific‑research investment of €500 000
- Job‑creation schemes (limited use)
- Qualifying investment funds of €500 000 (the most common current route)
- Citizenship timeline: Parliament voted in April 2026 to extend the required residence period from 5 years to 10 years. The vote is awaiting presidential signature; the change is expected to become law.
- Processing backlog: The immigration authority (IM) is issuing first‑residency cards in more than two years for many applicants. The citizenship clock starts only after the card is received, adding the backlog time to the overall timeline.
Bulgaria’s Golden Visa (fund‑based)
- Launch: Late 2023, making it the newest active EU residency‑by‑investment route.
- Schengen access: Bulgaria joined Schengen in Jan 2025 and adopted the euro in 2026.
- Investment requirement: €512 000 in qualifying exchange‑traded funds (ETFs). The funds may include real‑estate exposure; the current selection consists of about three qualifying options, primarily government‑bond‑weighted.
- Additional costs: Expect 10–15 % of the headline investment for legal fees, government fees, due‑diligence, document legalization, and biometrics.
Cost comparison
| Item | Portugal | Bulgaria |
|---|---|---|
| Minimum investment | €500 000 in qualifying funds | €512 000 in qualifying ETFs |
| Ongoing fees | Renewal of temporary residency every 2 years (several thousand euros per renewal) | No renewal required; permanent residency granted immediately |
| Extra expenses | 10–15 % of investment for ancillary costs | 10–15 % of investment for ancillary costs |
When renewal fees are accounted for, the total cost over a decade narrows the gap between the two programs.
Processing speed
- Portugal: First residency cards can take > 2 years due to IM backlog.
- Bulgaria: Typical timeline is 7–8 months from start to receipt of the permanent‑residency (PR) card:
- Pre‑approval: 8–10 weeks
- D‑visa issuance: ~30 working days
- PR application processing: ~45 days
Residency and citizenship timelines
-
Portugal:
- Temporary residency granted after investment; must be renewed every 2 years.
- Permanent residency after 5 years of continuous status.
- Citizenship currently set at 5 years, but the pending law would extend it to 10 years.
- Effective time to citizenship, factoring in the backlog, is approaching 10–12 years for new applicants.
-
Bulgaria:
- Permanent residency granted immediately upon approval.
- Standard citizenship requirement is 10 years, but the Golden Visa allows an application after 5 years of permanent residency (i.e., 5 years from approval).
- No applicants have yet completed the citizenship process because the program started in late 2023; the first naturalizations are expected around 2028–2029.
- Applicants must renounce their previous citizenship within three years of naturalization, unless a specific legal exception applies.
Physical presence requirements
- Portugal: Minimum of 7 days per year in the country; applicants must keep travel records.
- Bulgaria: No minimum stay required for residency. Maintaining a local address (≈ €200 /month) is advisable for future citizenship applications, even if the holder does not reside there regularly.
Investment flexibility
- Portugal: Wide range of qualifying funds, allowing investors to tailor risk profile and sector exposure.
- Bulgaria: Only three qualifying funds, primarily bond‑weighted; less flexibility in risk management.
Family inclusion
- Bulgaria: Spouse and children under 18 are covered at no extra investment. Dependent parents are not included. Same‑sex spouses are not recognized for family reunification.
- Portugal: (Not detailed in the source, but generally broader family inclusion.)
Language requirements
- Permanent residency: No language test for either country.
- Citizenship:
- Portugal: A2 level Portuguese required; exam can be bypassed through certain government‑sponsored language courses.
- Bulgaria: A2 level Bulgarian required; exam consists of 20 multiple‑choice questions (pass mark 12) plus an oral interview, offered twice a year with no course‑based shortcut.
Tax and healthcare considerations
- Holding Bulgarian PR or citizenship does not automatically make the holder a Bulgarian tax resident. Tax residency generally requires ≥ 183 days per year in Bulgaria or establishing the centre of vital interests there.
- U.S. citizens remain subject to U.S. worldwide income tax regardless of residency status.
- Returns from Bulgarian qualifying funds are classified as Bulgarian‑source income, potentially creating a filing obligation in Bulgaria even for non‑residents.
- Public healthcare in Bulgaria is linked to physical residence and contributions to the social security system; non‑residents typically need private health insurance.
Program stability and political context
- Both Portugal and Bulgaria’s programs are currently operational. Portugal’s main issues are policy changes (citizenship timeline) and processing capacity; the program itself is not expected to be discontinued.
- Bulgaria’s fund‑based scheme was designed to avoid the EU pressure that shut down its earlier bond/real‑estate fast‑track program in 2022. No significant domestic opposition exists as of now, but the broader EU trend shows tightening of such schemes (e.g., Spain closed its Golden Visa in 2025, Ireland in 2023). Low application volume helps keep Bulgaria under the political radar, but future changes cannot be ruled out.
Key disqualifiers for the Bulgarian program
- Limited fund selection – only three qualifying ETFs.
- Renunciation requirement – must give up existing citizenship within three years, which is a barrier for many U.S., U.K., and other dual‑citizen investors.
- No same‑sex spouse recognition – excludes LGBTQ couples.
- Higher investment threshold – €512 000 versus €500 000 for Portugal.
Who might prefer Bulgaria’s Golden Visa?
- Investors for whom the speed to permanent residency and eventual citizenship is the primary objective.
- Applicants willing (or able) to renounce their current citizenship, or who fall into a legal gray area that permits retention.
- Opposite‑sex couples without dependent parents who do not need same‑sex spouse inclusion.
- Those comfortable with a limited set of investment funds and a bond‑weighted risk profile.
- Individuals from countries with limited global mobility who value immediate EU permanent residency and Schengen travel, even without immediate citizenship.
In summary, Bulgaria’s Golden Visa offers faster processing and immediate permanent residency compared with Portugal’s increasingly delayed and administratively heavier route. However, the Bulgarian scheme’s stricter citizenship conditions, limited investment options, and renunciation requirement make it suitable only for a specific subset of investors. Portugal remains more flexible in fund choice and family inclusion but suffers from longer processing times and an uncertain future citizenship timeline.
