While everyone was focused on the proposed physical stay requirement for the Bulgaria Golden Visa by fund investment, almost nobody noticed that the requirement was quietly introduced for almost every other residence permit category in Bulgaria.

Yes, that’s right.

If you hold a residence permit through trade representation, real estate investment, or most other investment-based residence categories, you will now be required to physically reside in Bulgaria for six months and one day every calendar year in order to maintain your residence status.

Ironically, while the investment migration industry was discussing whether fund investors would lose their exemption, the exemption was ultimately preserved only for them.

Fund Investors Kept Their Privilege

Following last-minute efforts by our team, the Bulgarian Government accepted that introducing a mandatory six-month physical stay for fund investors would effectively destroy the purpose of an investment residency programme.

The exemption was therefore maintained.

Today, investors qualifying through Bulgarian investment funds continue to enjoy one of the strongest advantages within the European Union—permanent residence without the obligation to physically live in Bulgaria.

Unfortunately, the same cannot be said for real estate investors.

What Happened to Real Estate Investors?

For more than a decade, investors purchasing Bulgarian real estate worth at least EUR 312,000 expected a straightforward route towards permanent residence after maintaining their temporary residence status for five years.

Many invested substantially more than the statutory minimum.

Some invested EUR 500,000, EUR 1 million, or even more, believing that owning tangible real estate represented a safer investment than participating in an investment fund.

Today, those investors face a very different reality.

Unless they physically spend six months and one day every year in Bulgaria, they risk losing the very residence status they originally invested to obtain.

Why Did Nobody Object?

The answer is surprisingly simple. Almost nobody was paying attention. The Bulgaria Golden Visa by real estate had been under the radar for almost 13 years. Unlike Portugal or Spain, Bulgaria never experienced massive demand from foreign property investors.

Why?

Because it never needed to.

The Bulgarian property market has been exceptionally strong since recovering from the 2008 financial crisis. Local buyers have been purchasing apartments worth EUR 300,000–400,000 using 30-year mortgages. Demand has consistently exceeded supply. If hundreds of thousands of Bulgarians are already buying property, why would developers and estate agencies invest significant resources in attracting a few hundred foreign residency investors?

The market simply did not depend on them. As a result, nobody represented their interests when the proposed legislative amendments were discussed.

Ironically, Funds May Now Become the Better Real Estate Investment

The legislative changes have created an unexpected consequence.

Real estate investors who no longer wish to satisfy the physical stay requirement may consider contributing their property to a qualifying Bulgarian investment fund. Instead of personally holding the asset, the property could become part of a professionally managed investment portfolio.

Naturally, this only works if the property represents a commercially attractive investment.

For example, if a property is contributed to Bulgaria AIF – Fund, it cannot simply be transferred at the owner’s desired valuation. Bulgaria AIF is an investment fund and must protect the interests of all investors. Every asset must therefore be acquired at a valuation that offers genuine investment potential. If the property is worth less than the statutory minimum investment threshold, the investor may supplement the remaining amount with cash.

The result is significant. Instead of waiting five years while maintaining temporary residence and complying with the new physical stay requirement, investors may become eligible for permanent residence immediately through the fund route.

Are Investment Funds Really More Risky?

Many investors instinctively believe that bricks and mortar are safer than financial assets. The reality is often more complicated. A single apartment can easily be purchased at a 200% or even 300% premium over its intrinsic value, particularly during periods of strong market optimism.

A professionally managed investment fund operates differently. Rather than concentrating all capital in one asset, the fund spreads its investments across numerous listed companies, corporate bonds and other qualifying securities.

Bulgaria AIF, for example, invests in companies listed on the Bulgarian Stock Exchange and the BEAM Market, together with carefully selected corporate bonds. The portfolio is diversified across multiple issuers and sectors instead of relying on the performance of a single property.

Liquidity is another important consideration

Selling a high-value property often requires months of negotiations and, in a weaker market, substantial discounts. On the other hand, listed shares and bonds can generally be sold much faster. Funds are therefore not necessarily riskier than real estate. In many cases, they are simply better diversified, more transparent and considerably more liquid.

The Biggest Surprise

The biggest surprise is not that fund investors preserved their exemption. The biggest surprise is that real estate investors quietly lost theirs, and almost nobody noticed. Sometimes the most important legislative changes are not the ones making the headlines. They are the ones nobody talks about.