Good news (mainly) for Bulgarian visa and Bulgarian citizenship applicants
The silent (implied) refusal, which we wrote about in our previous article, can now (effective from 03.09.2025) be appealed within two months. Prior to 03.09.2025, this period was only one month. Now the legal provision states:
Silent refusal or silent consent may be appealed within two months of the expiry of the period within which the administrative authority was required to issue a decision.
Art. 149, par. 2 of the Administrative Procedure Code
The above provision applies to appeals through the courts. The provision of Article 84 of the Administrative Procedure Code concerning the possibility of appeal through administrative proceedings is identical.
Applicants for Bulgarian citizenship often wait many years
This is definitely good news for all Bulgarian citizens. However, foreigners applying for a visa D, residence permit, and Bulgarian citizenship will benefit most from the legal changes. It is precisely these applications that most often sink into the “black hole” of the Bulgarian administrative swamp.
Silent rejection – why is it so insidious?
Generally speaking, a silent refusal occurs when the statutory deadline for administrative authorities to issue a decision has expired without the applicant being notified. The insidious nature of this provision is that the applicant almost never knows the statutory deadline by which a response should be given. Since no refusal is issued, the applicant simply waits, hoping that their application will be approved.
Instead, however, the deadline for a decision expires, followed by the deadline for appeal. After that, the legal options for appeal are exhausted without the applicant even realising that they have been refused. For more information, please read our previous article – Implied refusal to issue a visa, residence permit or Bulgarian citizenship.
As usual, should you have any additional questions, please don’t hesitate to contact us.
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