Residence permit renewal procedures

Bulgarian Parliament is considering законопроект No 52-602-01-29, which proposes significant changes to the conditions for maintaining Permanent Residency (PMJ) and Long-Term Residence (DVZH) status. Currently, PMJ can be revoked after more than 12 consecutive months outside the EU. The proposed amendments differentiate between DVZH, which retains the 12-month rule, and PMJ, which would require a minimum physical presence of 183 days in Bulgaria each calendar year. Investor benefits are to be abolished; the investment threshold of 511,292 BGN will remain, but the privilege of residing outside the country will be removed. Violation of the 183-day rule will lead to PMJ annulment and reset the 5-year residency requirement for citizenship. This new rule will also affect categories such as spouses of Bulgarian citizens, individuals of Bulgarian origin, and long-term residents. As there is no transitional period, the law is expected to take effect three days after its publication and could potentially affect residents retroactively.

Proposed legislative changes in Bulgaria, specifically законопроект No 52-602-01-29, aim to alter the conditions for maintaining Permanent Residency (PMJ). A key change is the introduction of a requirement for PMJ holders to be physically present in Bulgaria for at least 183 days each calendar year. This contrasts with the current rule allowing up to 12 consecutive months of absence from the EU. Investor privileges associated with PMJ are reportedly being removed, although the investment threshold may remain. This new requirement could affect various categories of residents, including investors, spouses of Bulgarian citizens, individuals of Bulgarian origin, and long-term residents. The potential for retroactive application due to the lack of a transitional period is also a concern.

Holders of permanent residency (PMP) in Bulgaria cannot be absent from the country for more than 12 consecutive months without risking their status.

Discussions are ongoing in Bulgaria regarding proposed amendments to the Foreigners Act that may impact permanent residency (PMZh) status. The proposals suggest a strict residency requirement for PMZh (over 6 months and 1 day per calendar year, or status annulment). Long-term EU residency (DVZh), governed by EU Directive 2003/109/EC, is presented as having more flexible absence rules (max 12 consecutive months from EU, max 6 consecutive years from Bulgaria). However, there are conflicting views, with some sources claiming that these amendments are not yet adopted and that transitioning from PMZh to DVZh might introduce even stricter residency requirements.

A user reported submitting documents for a new residence permit (or similar "card") for non-EU citizens in Bulgaria in early August last year. The process took 30 minutes, with only a few people in line at each of the two open windows. This indicates a period of relatively quick service compared to potentially longer wait times currently observed.

When receiving a Bulgarian residence permit (VnZh), the required documents are: your foreign passport, any previous residence card (if renewing), and a bank card or cash to pay the fees for the new card issuance. A national passport (e.g., Russian passport) is not required for the collection process. The foreign passport is not submitted but is presented to receive the VnZh stamp or card.

There is uncertainty regarding the renewal of Bulgarian residency permits (VNZh) and permanent residency (PMZh). Individuals who have resided in Bulgaria for six months annually for the past five years and hold permanent residency are concerned about potential new regulations that may impact renewal processes and residency requirements. It is advisable to stay informed about legislative changes.

For permanent residence (PMR) in Bulgaria, the requirement is to be present in the country for at least 50% of the time over 5 consecutive years. Total absences must not exceed 30 months, with a single exit not exceeding 6 months. Health insurance (zdravna kasa) contributions are mandatory for PMR holders; failure to pay leads to penalties and may negatively impact citizenship applications.

For VNJ/PMJ (residence permit) renewal in Bulgaria, a 'certificate of marriage validity' (справка о действительности брака, Russian Form No. 5) is now required from Russia, a new requirement since February. This certificate can be obtained at Russian MFCs for approximately 350 rubles, typically within 20 minutes. It confirms the current validity of the marriage; a simple copy of the marriage certificate is no longer sufficient. The Russian certificate must be translated and notarized by a Bulgarian notary in Bulgaria. The process can be complicated if the marriage was registered outside Russia or if a divorce occurred for a marriage registered abroad. It is recommended to clarify the current requirements with the Bulgarian Migration Directorate for PMJ renewal, as the deadline for submission (14 vs. 30 days before expiry) is under discussion.

When applying for the renewal of a Bulgarian VNJ (residence permit), the applicant's current VNJ card is not taken away and remains valid. The applicant is permitted to leave Bulgaria and re-enter using this valid VNJ card until its specified expiration date.

There is conflicting information regarding the optimal application period for renewing a Bulgarian residence permit (card). Some applicants report being advised by Migration in Burgas to apply 'no earlier than one month and no later than 14 days before the card's expiration date.' However, others claim it is permissible to apply up to three months in advance, with the caveat that the new permit's validity period may commence from the date of application rather than the expiry of the previous card, effectively 'cutting off' part of the potential validity.

Holders of an expiring Bulgarian residence permit card can leave and re-enter the country while awaiting a new card issuance. The old card remains valid for this purpose until the new one is received.