Huge demand from Asian high-net-worth entrepreneurs for EU citizenship

Premium citizenship is one of the most valuable assets in the world of wealth. EU citizenship tops the wish list for many. With full living rights in 30 European countries, the EU passport offers unmatched freedom for those who can afford it. And not surprisingly, the options to obtain Bulgarian citizenship were a key topic at this year’s investment migration event in Ho Chi Minh City. Somewhat unexpectedly, Bulgarian citizenship for special merits emerged as the hot ticket this year.

From investment to special merits

In recent years, fast-track EU citizenship options have been sharply restricted by European politics. Most citizenship by investment programs were cancelled, with the final blow delivered to Malta’s program by the European Court of Justice, ending the last EU investment citizenship route.

author: Alexander Dobrinov


restaurant in Vietnam

Many thanks to my friend and client J.J. for making my stay in Ho Chi Minh City – unforgettable. I also thank our clients H.F. and T.T. for finding the time to come and meet in Saigon.


EU citizenship by special merits becomes the new standard for the wealthy

This year in Vietnam, it has become clear that citizenship by merits will dominate the EU citizenship market in the coming years. To my own surprise, virtually all Asian HNWI were asking for one thing only – how can they qualify for citizenship by merits. And even more surprisingly, most of them already knew that money doesn’t buy EU citizenship anymore. The right approach does. Money only helps as an add-on.

When one door closes, another opens.Alexander Graham Bell

The Maltese boost

Interestingly, almost all HNWI interested in the Bulgarian citizenship for special merits program first heard about it because of Malta. In 2025, Malta introduced a new Citizenship by merit program after cancelling its previous Citizenship by investment scheme. Soon after, many agents began promoting aggressively the new Maltese program. This created fresh demand and made the term “citizenship by merit” hot on the market. You can read more about the new Maltese program and how it compares to the Bulgarian program in our article.


questions and answers

Some questions and answers about the Bulgarian citizenship for special merits

Today, we will answer a series of questions from a client who has been involved in the Bulgarian citizenship for special merits process for about six-seven months. Whether this client is real or hypothetical is irrelevant for the purpose of this article.

Here are the questions, which we will try to answer below:

  1. When will I get my permanent residency?
  2. How long after permanent residency will we finalise and apply for citizenship?
  3. How long after the application will we hear a yes or no from the government?
  4. How much is the potential cost to me for the project we will do for Bulgaria?
  5. With the new change for the government are you still getting new approvals for citizenship?
six-seven

So let’s start with the answers below:

When will I get my permanent residency?

The strategy for this particular customer is in line with the strategy for the majority of the clients, willing to obtain Bulgarian citizenship by merits. Namely, it is to first establish a presence in Bulgaria, in order to be recognised, so he can be of real benefit to the country. In his situation, we have decided that the best initial approach to the application is obtaining a permanent residence permit through an investment in Bulgarian ETFs.

Obtaining a permanent residence permit through investment requires preliminary approval from the Bulgarian Investment Agency. In some cases, this approval is subject to significant delays.

Recently, we have advised certain clients to proceed with the investment even before receiving the agency’s approval. This is possible because the act of making the investment itself is not legally tied to obtaining that prior approval.

This approach is logical, as the ultimate goal is not the residence status, but obtaining Bulgarian citizenship by merit. In most cases, the investment can be utilised even if done before the preliminary approval.

In rare situations where this is not possible, the applicant may need to make an additional investment solely for the residence application. Although such cases are expected to be uncommon, this strategy can save a significant amount of time.

It is also worth noting that both we and the Bulgarian authorities expect applicants seeking citizenship by merit to be ready to fully engage in the process, including financially.

Why establishing a presence in Bulgaria?

There are two main types of candidates for Bulgarian citizenship by merit. The first group includes foreigners who are already well known to the authorities in Bulgaria. These may be renowned athletes, musicians, entrepreneurs, and other public figures. In rare cases, a foreigner may have provided an accidental service to the country. One example is the case of the Serbian citizens who saved Bulgarian children after a road incident in the Lim River, in Serbia. Usually, such individuals require little assistance in obtaining citizenship by merit, as the Bulgarian authorities tend to act proactively in these situations.

The other group, and there are many more foreigners in this situation, is when the citizenship candidates are not known to the authorities. In this case these candidates need to establish presence in Bulgaria first. Without that, it’s hard to believe that coming out of the blue, they will be able to impress the Bulgarian establishment. To impress for so much, that they will be granted citizenship for special merits. And in most cases, the path to establishment of local presence is through investment in business or direct investment in ETFs.

With all that being said, the realistic expectation is the visa D to be obtained in about two months. This is after the investment in ETF is effected (this is NOT when the client has wired money to his Bulgarian account in preparation for the investment), backed by the preliminary approval by the Investment Agency. The legally foreseen term for issuance of visa D is 35 working days. After the visa D is obtained, the applicant can apply immediately for the permanent residence card.


How long after permanent residency will we finalise and apply for citizenship?

This is a very, very wrong question. Nobody can formally apply for citizenship by merits. Citizenship by merits is granted (not upon an application) by the President of the Republic of Bulgaria. What can be done however is to alert the relevant Minister, who can promote the candidate through the official channels so it can reach the President’s office.

It is important to note that before receiving the “official alert,” a candidate must have already established a reputation in Bulgaria. This is where we provide significant support. Understanding what Bulgaria values, and what will be recognised by the Minister, is essential for a successful outcome.

For every serious citizenship by merit client, we work closely with the authorities. We carefully promote the client’s skills and achievements to highlight their potential benefit to the country. The same approach applies to the client whose questions are addressed in this article.

Working in the background with the authorities

For this particular client, we have carried out extensive work with the political establishment. Our key task has been to highlight the client’s strengths and demonstrate how he could contribute to the country. All of this is done with strict adherence to privacy and confidentiality requirements.

So how long after all?

We have to stress again – the very question is flawed. Theoretically, we can send the “official alerts” immediately. Even if the client hasn’t yet obtained his permanent residence card. But the chances of approval in this case are extremely low. Realistically, if the client is serious and acts (more) swiftly and without too much hesitation, a realistic short term would be six months.


How long after the application will we hear a yes or no from the government?

Usually in one to four weeks. In some cases, the “application” can be passed to another Minister. In rare cases, we may resubmit the “application” to another Minister ourselves, dependent on the political and economic circumstances.


How much is the potential cost to me for the project we will do for Bulgaria?

This is again a mistaken way of looking at the matter. If a client treats citizenship by merit as a simple “project” with a fixed “cost” (beyond our legal consultancy fee), it indicates a misunderstanding of the process.

Citizenship by merits is not the same thing as citizenship by investment. Bulgaria is no Malta and it is not “all about the money“. And this is exactly the beauty of the Bulgarian program, as it, unlike Malta, has no issues with the European Commission.

That said, if we must provide an estimate, the client’s financial involvement can be roughly twice the amount required to obtain permanent residence through ETFs. In other words, about 50% would go toward purchasing ETFs, and the remaining 50% could support other relevant activities.

We are not suggesting that this money must be spent or paid to anyone else. Rather, it represents the estimated amount the client should be prepared to allocate toward meaningful contributions -not irreversible expenditures. This distinction is important.


With the new change for the government are you still getting new approvals for citizenship?

The current provisional government is in office since 19.03.2026. This is just over a month. To our knowledge they haven’t processed any citizenship by merits “applications”. This is logical, as the provisional government’s main task is to prepare the country for the next elections that will take place on 19.04.2026.


Well, I guess that’s all, folks. Bulgarian citizenship for special merits is not for everyone. Many, especially those who hesitate, may not succeed. Some will go for Malta, which, I agree, is promoted and marketed perfectly.Alexander Dobrinov

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