Bulgarian CBI – common mistakes during the application

Renting in Bulgaria for the purposes of the CBI application

Recently we got the following question:

Can I rent a room in Bulgaria for 100 EUR per month and use it for the purposes of the Bulgarian citizenship by investment application?

The legally correct answer is of course – yes! The only legal requirement for the address that is to be used for the CBI application is that it has to be habitable. The local municipality will make sure that there is enough living space, based on the people registered. If all that is OK, the person can be officially registered there and with that, the legal requirements are met. However…

The expectations of the Bulgarian authorities from the investment citizenship candidates

The Bulgarian CBI program doesn’t currently require from the applicants to make any irrevocable donations. In other words, the Bulgarian state doesn’t directly benefit financially from the citizenship applications. The requirement to buy Eurobonds is also not benefiting the state budget, as all these Bonds are being sold in an instant on the international markets, without the added benefit of providing citizenship rights.

The core purpose of the Bulgarian investment citizenship program has always been to:

1. Attract new eligible citizens in order to combat the decline of the population growth in Bulgaria;
2. These eligible citizens are expected to benefit the Bulgarian economy, mainly through their business-oriented lifestyle and their (high) spending habits.

So in general, the Bulgarian authorities are looking to attract high-net-worth individuals (HNWI), who will in future, be of benefit for the economy of the country.

After all, all “investment citizenship” programs are intended for HNWI and UHNWI. The CBI programs in the EU are of course not an exception. And the Bulgarian authorities are not blind. They know very well that in Cyprus for instance, one has to start with an irrevocable donation of 150 000 EUR. On top of that, this person is expected to buy (and hold for lifetime) personal residential property with a value of at least 500 000 EUR. Another 2 million EUR investment is also required in Cyprus, but that’s not the subject of this article. In Malta, the only other EU CBI program, the donation requirements are much higher.

Mansion in Cyprus, dorm room in Bulgaria, really?

So on the tiny island of Cyprus one has to live in a 500 000 EUR house in order to be considered for investment citizenship. At the same time, we are asked, is renting a room for 100 EUR per month acceptable in Bulgaria?

Well yes, as we already stated above. Legally it is ok. Informally however, this is ridiculous. And rest assured, renting a student room for 100 EUR will render your “investor status” as questionable in Bulgaria, the very least.

The risks for your Bulgarian CBI application

Is there a country in the world that will welcome an investor, living in a student room for 100 EUR per month?

Please remember, the Bulgarian state is not obliged to grant you citizenship by investment! It may do so, if you fulfill all conditions. And if all relevant authorities (Citizenship Council, President, national security services, tax authorities, etc.) are feeling comfortable with your application.

Do you think your 100 EUR per month room will portrait you as investor who will benefit the economy of Bulgaria? Do you think that the authorities in Bulgaria will be happy to grant you EU passport? No matter how subjective their assessment may be, please think twice before jeopardizing your entire application.

Rent something decent, something that will show your status to the authorities. Even if you don’t intend on living in Bulgaria during the application, use an address that is up to your standards. Don’t be cheap in Bulgaria. The Bulgarian CBI program is a gift anyway – don’t try to squeeze the lemon any further. It may get really bitter if you get rejected.