Is it possible to have your Bulgarian citizenship revoked?
Many clients ask about the chances of having their Bulgarian citizenship revoked. The good news is that losing Bulgarian citizenship is very rare. In most cases, revocation is extremely difficult, close to impossible. Compared to other EU countries like Malta, Cyprus, and Portugal, Bulgarian Citizenship Law is far more protective. The legal options to remove someone’s citizenship are limited and strictly regulated.
There are still specific cases where Bulgarian citizenship can be revoked. It is important to understand these scenarios. The risk of revocation depends largely on the way a person was naturalised. As a general rule, people who obtained Bulgarian citizenship by origin face the highest risk. In contrast, those granted citizenship for special merits are almost fully protected. Below we will describe the situations in which the Bulgarian state may legally remove or withdraw citizenship. These cases are extremely rare, but they do exist.
Why the risk of revocation depends on the way the person was naturalised?
Let’s begin with the most basic rule. Bulgarians by birth cannot be deprived of their citizenship. This principle is firmly rooted in the core values of the Bulgarian Constitution. It protects every person who acquires Bulgarian citizenship at birth:
A person who is a Bulgarian citizen by birth cannot be deprived of Bulgarian citizenship.
Art. 25, par. 3 of the Bulgarian Constitution
In other words, a Bulgarian citizen can lose his citizenship only if he was naturalised. This means the person did not receive citizenship at birth, but obtained it later in life.
Loss of Bulgarian citizenship for naturalised persons
Bulgarian law does not formally distinguish between the different naturalisation routes. However, the method of naturalisation plays an important role when revocation is considered. This is because the procedure for each naturalisation route is different and involves certain specific actions. And if these actions were performed wrongly and with bad intent, this may be considered as a reason for revocation of the citizenship.
Below, we explain under which circumstances this is possible.
When can a naturalised person be deprived of Bulgarian citizenship?
The Bulgarian Citizenship Law foresees two distinct options for “revocation” of citizenship. These are namely the “Revocation of the naturalisation” (art. 22) and “Deprivation of Bulgarian citizenship” (art. 24). The key difference is that the first applies to serious irregularities or fraud committed during the naturalisation process. The second option concerns cases of serious misconduct after citizenship has already been acquired that is not related to the naturalisation process itself.
Revocation of the naturalisation
Let’s see what the Bulgarian Citizenship Law stipulates.
Naturalisation on the basis of which Bulgarian citizenship has been obtained may be revoked if the person:
art. 22, par. 1 of the Bulgarian Citizenship Law
- has made use of data or facts which have become the basis for acquiring Bulgarian citizenship and which have been established in a court of law to be false, and/or
- has concealed data or facts which, if they had been known, would have been grounds for refusal to acquire Bulgarian citizenship, and/or;
- has failed to notify a change under Article 32a.
It is important to note that the law does not mandate automatic revocation even when one of the above three grounds is present. The Bulgarian Citizenship Law uses the expression “may be revoked”, which is fundamentally different from “shall be revoked”. This distinction matters, because revocation is discretionary rather than obligatory. In practice, citizenship will be revoked in most cases, where any of these grounds exist, although not in every case.
Deadline for revocation
There is an additional limitation on the authorities’ power to revoke Bulgarian citizenship. The law provides that revocation may only take place within 10 years after naturalisation, unless the person is involved in terrorism. Furthermore, revocation is not permitted if the person has only Bulgarian citizenship and no other citizenships.
The revocation of the naturalisation shall be admissible only until the expiration of 10 years from the acquisition of the Bulgarian citizenship, except in the cases when the data and facts under par. 1, p. 1 and 2 or the change referred to in p. 3 relates to the person’s involvement in terrorism and provided that the person does not remain stateless.
art. 22, par. 2 of the Bulgarian Citizenship Law
Use of false data or facts, which have become the basis for acquiring Bulgarian citizenship
This is the first and by far the most common ground for revocation, accounting for roughly 85% of all cases. It applies when a person has already obtained citizenship by origin, but it is later discovered that the data or facts (documents or very rarely – statements) used during the application, most often birth certificates claiming Bulgarian origin, were false (forged).
In recent years, the authorities in Bulgaria have drastically tightened their checks. As a result, many individuals, particularly from ex USSR countries, are now facing criminal prosecution, and some have already been convicted. You can also read our article An increasing number of criminal cases against applicants with fraudulent proof of origin for Bulgarian citizenship by origin (in Bulgarian).
Only with a court order
It is important to emphasise that revocation is possible only when the falsification of the facts and documents has been formally confirmed by a Bulgarian court. An allegation or suspicion by the authorities is not sufficient. A valid court decision is required before citizenship can be revoked on this ground.
Only if the false data or facts (documents) are the basis for granting Bulgarian citizenship
Another important point is that citizenship can be revoked under this option only when the falsified facts or documents were the actual basis for granting Bulgarian citizenship. If a person submitted a forged diploma together with a resume during a naturalisation procedure for citizenship by origin, this falsification would not justify revocation. This is because a diploma or formal education is not a legal requirement for obtaining Bulgarian citizenship by origin, and therefore its falsification does not influence the decision to grant citizenship in Bulgaria.
Concealing data or facts which, if they had been known, would have been grounds for refusal to acquire Bulgarian citizenship
This is the second legal ground for revocation of Bulgarian citizenship. It is closely related to the first ground described above, but there is an important distinction. While the first option concerns the submission of false data or forged documents, this ground applies to the concealment of relevant facts or information during the naturalisation process.
In practice, this provision is used extremely rarely and, to our knowledge, has not been applied in any recent cases. The reason is that the naturalisation procedure in Bulgaria is highly formalised and strictly regulated, leaving little room for undisclosed information. Every relevant fact must be supported by official documents, which means that misconduct typically involves document falsification (the first option) rather than concealment of information (the second option).
No formal court decision is required
Another important difference between this ground and the first option is that the law does not explicitly require the concealment of facts to be confirmed by a Bulgarian court. However, this requirement should be understood as essential in practice. In our view, if this ground is to ever be applied, revocation of citizenship should not be possible without a final court decision confirming the concealment. We believe this gap in the Bulgarian Citizenship Law, namely the lack of an explicit requirement for court confirmation of concealment, should be urgently addressed by the Bulgarian Parliament. This would help prevent potential misuse of the provision.
Failure to notify a change under Article 32a
This is the last option for revocation of Bulgarian citizenship and by far the most vague one. Let’s see what art. 32a stipulates:
The person referred to in Art. 29, par. 1 shall be obliged, within one month from the occurrence of the change in the facts and circumstances related to the acquisition of Bulgarian citizenship by naturalisation, exemption from Bulgarian citizenship or restoration of Bulgarian citizenship, to notify the Ministry of Justice and to submit the documents proving the change.
art. 32a of the Bulgarian Citizenship Law
The persons referred to in art. 29, par. 1 are all applicants for Bulgarian citizenship. This third ground provides the possibility to revoke citizenship if the applicant fails to inform the authorities of any changes in facts or circumstances related to the application within one month.
In practice, this provision is considered overly broad. As with the second option, a court decision is not explicitly required for citizenship revocation. Even more concerning, citizenship may be revoked for failure to report even minor changes, including those unrelated to the core requirements for obtaining Bulgarian citizenship, as is the requirement under the first ground.
No court decision required nor the changes need to be relevant to the citizenship approval
Similarly to the second option, we do not believe this ground can be applied without a court decision. We also consider that it cannot be lawfully used for failure to report changes that are not essential for the approval of a citizenship application.
However, as with the second option, there is a significant legal gap that should be urgently addressed by the Bulgarian Parliament. We intend to raise this issue with members of Parliament and hope for a swift legislative resolution.
Deprivation of Bulgarian citizenship
Deprivation is the other legal mechanism that can lead to the stripping of a person’s Bulgarian citizenship. According to the law:
A person who has acquired Bulgarian citizenship by naturalisation may be deprived of it if he has been convicted by a sentence which has entered into force of a serious crime against the Republic, provided that he is abroad and does not remain stateless.
art. 24 of the Bulgarian Citizenship Law
Under this option, there is no 10-year limitation period after which citizenship can no longer be revoked, unlike the rules applicable to revocation of citizenship.
Crimes against the Republic are defined in Chapter One of the Bulgarian Penal Code. These include offences such as treason, espionage, and related crimes, which are rarely encountered in practice. In addition, the offence must be classified as “serious” and confirmed by a final court judgement.
In practice, this ground is largely theoretical and is not applied frequently, so it is not examined in further detail here. Furthermore, revocation on this basis is only possible if the person holds another citizenship. Finally, a person can be deprived of Bulgarian citizenship only if he is abroad. This is an outdated legal condition that no longer reflects modern realities and should be removed from the legislation.
So what can we conclude about the legal options for stripping someone of Bulgarian citizenship
Ina nutshell, losing Bulgarian citizenship is extremely rare and very difficult for the government to effect it. There are certain serious legal gaps in terms of option 2 and 3 for citizenship revocation, which do not require a formal court decision, nor the false information to be legal ground for granting citizenship. These flaws should be addressed immediately by the Bulgarian Parliament and our team will do the necessary in due course.
As for naturalised Bulgarian citizens, the vast majority of citizenship revocation cases concern individuals who obtained Bulgarian citizenship by origin. This is mainly because, in many cases, they submitted forged birth certificates and other supporting documents.
Citizens granted Bulgarian citizenship for special merits are, in practice, largely immune from revocation. This is because there are very limited opportunities to submit falsified documentation in this procedure. The same generally applies to individuals who obtained citizenship through the Golden Visa route. Under this option all documentation is subject to thorough verification by the Bulgarian authorities during naturalisation.
If you have any questions about the possibility of revocation of your Bulgarian citizenship, please do not hesitate to contact us.