Residence permit for digital nomads: changes in the Foreigners in the Republic of Bulgaria Act

A Law on Amending and Supplementing the Foreigners in the Republic of Bulgaria Act (FRBA) was promulgated on June 27, 2025, introducing a number of changes in the residence regime of third-country nationals in Bulgaria. An explicit provision was included for digital nomads – persons who are financially secure and work in Bulgaria for foreign entities. Besides, the law formally reflects the complete accession of Bulgaria to the Schengen area by including the rules for issuance of uniform visas, free travel on a residence permit issued by another member state, etc.
With regard to digital nomads, at present the relevant texts are brief: §1, item 36 of the Additional Provisions of FRBA states that digital nomads are those that satisfy one of the following requirements:
– They work for an employer outside the EU and the EEA by providing remote services using information technology;
– are legal representatives, members of a governing body, company owners, partners or shareholders owning more than 25 percent of the capital of a company registered/incorporated outside the EU and the EEA, through which company they provide remote services but subject to the condition that they do not work for, nor provide services to entities in Bulgaria;
– have provided, in their personal capacity, remote services for a period of at least 1 year prior to the date of submission of the application for residence permit but subject to the condition that they do not work for, nor provide services to entities in Bulgaria.
Additionally, a new article 24c (numbering as per the Bulgarian version) has been added to the FRBA, which imposes the requirement that digital nomads must provide proof of an average annual income of no less than 50 minimum monthly wages in the Republic of Bulgaria. The permit is issued for a period of one year, which may be extended for another year – but only once. From the wording of the clause, it becomes clear that the residence permit does not duplicate the work permits; rather, it provides an opportunity for residence in very specific conditions related to the applicant’s work for countries outside the EU and the EEA. For the time being the legal text is extremely brief, and it is yet to be determined what specific requirements will be introduced for the documents attesting to that right of residence; this will be done by making amendments to the Rules and Regulations on the Implementation of FRBA.
The amendments also concern the rules for issuance of a residence permit for trade representatives of foreign companies. It is already explicitly provided that a permit is only issued if the foreign merchant is able to prove that it has an annual turnover for the preceding two years of no less than BGN 100,000, converted into the relevant currency. Additionally, the text specifies that the number of persons eligible for such a permit is reduced from three, as was allowed by the law thus far, to two. Also, the possibility is limited for foreign merchants to ascertain the circumstances of their activity and their proper tax status on the basis of declarations alone; going forward, this will be done only through official documents issued by the country of registration of the foreign merchant.
The legal texts regarding work permits are more focused, specifying a number of requirements for the documents attesting to secured place to live for the applicants, their employment contracts, etc. In addition, a requirement is introduced for the diplomas, where such are enclosed with the submission papers, to be recognized by NACID (the National Center for Information and Documentation); then the certificate of recognition needs to be enclosed after the foreign national has received a long-term residence visa for Bulgaria together with the residence and work permits. Additionally, in the procedure for issuance of a residence and work permit for highly skilled non-EU applicants of the type Blue Card of the EU, an opportunity to apply is also provided for persons who enjoy international protection in Bulgaria – i.e. with humanitarian or refugee status, without a vise being required.
In addition, persons carrying a Single Residence and Work Permit or a seasonal work permit are now subject to mandatory health insurance – their employer is obligated to pay their health insurance contributions just like those for persons with an EU Blue Card as from 2023. A new requirement for the work permit is that the employer must show up in person or send a representative when a foreign national submits in person an application and supporting documents for a residence permit to the offices of the Ministry of Interior.
Additionally, a simplified procedure is provided for change of employer for highly-skilled employees – after 12 months have expired since the issuance of the original permit, it is enough for the new employer to present the employment contract and a declaration that the working conditions for the foreign national are not less favorable that those for a Bulgarian national.
Supplemented in a similar way are the provisions regarding transfer of employees within the same corporation: legal definitions are introduced in the Additional Provisions of FRBA for the terms trainee and specialist; these bring clarity as to what categories of employees are eligible for a residence permit on such grounds.
Other amendments refine the provisions for granting permanent resident status in exchange for investments. According to the new texts, it is now admissible for the investment to be terminated after 5 years, without affecting the once granted right of permanent residence; this helped resolve a long-standing issue in the practice of the Ministry of Interior.
The amendments to the FRBA resolve long-standing practical issues while solidifying by legislative means a number of administrative practices, which means greater predictability of proceedings before the bodies and services of the Ministry of Interior.