Everyone thinks of changing the world, but no one thinks of changing himself.

Leo Tolstoy

On 01.04.2019, the influential Bulgarian Chamber of Commerce and Industry published an open letter from the Association of Employers’ Organizations in Bulgaria to the Bulgarian government, criticizing harshly the plans to amend the Bulgarian citizenship laws and to limit the options for those wiling to obtain Bulgarian Citizenship by Investment.

We are publishing bellow an unofficial English translation of the letter. The original text (in Bulgarian) can be found on the website of BCCI.

Letter of the “Association of Employers’ Organizations in Bulgaria” about the proposed amendments of the Law on Bulgarian Citizenship and proposal for consideration of the Concept for Development of the Bulgarian Program for Investment Immigration



Regarding: Draft for amendment of the Law on Bulgarian Citizenship and proposal for consideration of the Concept for development of the Bulgarian Program for Investment Immigration


On behalf of the Association of Employers ‘Organizations in Bulgaria (AEOB), which brings together the four representative employers‘ organizations at national level, we appeal to you, about our desire to bring forward the discussion and the agenda of the Law on Bulgarian Citizenship and the Investment Immigration Program, allowing third-country nationals to acquire residence and / or citizenship in Bulgaria through investments in accordance with the adopted legal framework.

Investment – migration programs are a global industry allowing countries to attract a significant volume of investment and to compensate for the contraction of market relations. In Bulgaria, this policy line was set 20 years ago and its full management could provide a broad field for development.

Taking into account the possibilities of such programs and the good results achieved by the other European countries, we are very worried that Bulgaria is in one of the last places in terms of effectiveness. The normal response should be to improve the regulatory framework in order to make it easier to attract investors through it, to simplify the procedures and to strengthen the control and enforcement rather than (to suggest) a complete denial of the system. It is also beneficial to study the foreign experience that has shown significant results for the respective countries. We believe that in order to make progress and achieve the objectives set in the program, the state needs to demonstrate and provide strong support in this area. Active administration, broad awareness and quick action on the process of obtaining residence and / or citizenship in Bulgaria are essential for the progress of the program and the flow of investment in our country.

Despite the need for the government to initiate additional measures to respond to the challenges and reduce the risks associated with security, money laundering and corruption, this is not a reason to refuse to implement the program through the adoption of legislation changes. The establishment of good communication between the countries, institutions and investors is feasible through the introduction of additional and simplified legislative mechanisms and the creation of a single coordinating body.

Last but not least, we would like to point out that the proposed 14-day public consultation deadline is far from sufficient to provide competent views from all stakeholders.

In this regard, we suggest NIS to discuss and eventually complement the proposed legislative changes and the Concept of Development of the Bulgarian Investment Immigration Program, for which we remain at your disposal with our expertise, both for formulating the appropriate changes in the direction of improving the regime, and for the motives.


Chairman of the Management Board of the “Bulgarian Chamber of Commerce and Industry”
AEOB rotating chairman for 2019
At the request of “Bulgarian Industrial Capital Association”, “Bulgarian Industrial Association”, “Bulgarian Chamber of Commerce and Industry” and “Confederation of Employers and Industrialists in Bulgaria”

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