How can one obtain Bulgarian citizenship through investment in ETFs?
After Bulgaria revamped its “Golden Passport” program in March 2021, ETFs became one of the most desirable investment option for the majority of our clients. We remind you also that there are plenty of other investments that are suitable for the citizenship program. In this article however, we will explain the legal requirements that apply to the ETFs so they can be used for the Bulgarian CIP.
What ETFs are eligible to invest in and obtain Bulgarian citizenship by investment?
The Bulgarian law for the foreigners is specific as to the ETFs that can be used for investment residence and citizenship. The applicants have to invest in the following:
- Units or shares in collective investment schemes originating from Bulgaria, operating in accordance with the Law on the Activity of Collective Investment Schemes and Other Collective Investment Undertakings, and provided that :
- The net asset value of each collective investment scheme is not less than five million Bulgarian Lev (2 556 460 EUR);
- The collective investment scheme has been licensed or authorized by the Financial Supervision Commission;
- The investment strategy is focused mainly on investments in shares and/or bonds of Bulgarian companies traded on a regulated market or a multilateral trading system in Bulgaria.
Is there a pre-approved list of ETFs that are eligible for the investment citizenship program?
There is no pre-approved list of ETFs. According to the law, the candidates need to obtain preliminary approval by the InvestBulgaria Agency of the chosen ETF. Currently, the Agency does not provide any pre-approved list of selected ETFs. In other words, it is the applicant’s responsibility to identify and select the ETF and then to request pre-approval from the Investment Agency. When such is received, the investment can be effected.
Members of the VD&A Gold Club or clients with premium subscription with us will obtain free comprehensive legal and financial eligibility advice as to the choice of ETFs.
Can the ETFs be bought from outside of Bulgaria via the applicant’s bank or financial broker?
Yes, the ETF’s can be purchased from outside of Bulgaria. There is no legal requirement for the investment to be done through Bulgarian financial institution. We do however recommend using Bulgarian account for speed of processing and easier pre-approval with InvestBulgaria Agency. Please note that in certain cases it may be easier to make the investment from abroad though. Please contact us for assistance if you have any doubts.
How to proceed if you are at the stage of selecting the ETF for your Bulgarian CIP
There are basically two different scenarios:
If you are VD&A Gold Club Member or have premium subscription for your CBI application
If this is the case, your personal manager from our company will take care about everything. We will prepare a list of ETFs that we believe will be eligible for the program. Our financial consultant will discuss with you all pros and cons of each ETF and will provide written professional advice for your consideration. Although there are no pre-approved ETFs, as explained above, we believe that our recommendations will virtually guarantee you an approval by the Investment Agency.
If you have regular subscription for your Bulgarian CBI application
All our clients will be provided with general guidance as part of our standard package for citizenship services. It will be the client’s responsibility however to identify the ETF that complies with the legal prerequisites, as explained above. Before submission of the application to be pre-approved by the Investment Agency, we will advise the client whether we recommend the ETF for the purposes of the investment program or we don’t. If the client requires comprehensive investment guidance, such can be provided as additional service.