Understanding the current (as per 2026) requirements for establishing a Trade Representative Office
Registering a Trade Representative Office (TRO) in Bulgaria was easier in the past. Foreign companies could quickly establish a presence. Representatives of the TRO could obtain residence status more easily. Now, the legislation is much stricter. Meeting the requirements for a TRO is challenging. Careful planning and full compliance are essential.
Foreign companies can still establish a TRO in Bulgaria and the Foreigners Law allows for two representatives of the TRO to obtain Bulgarian visa D and consequentially a residence permit. As stated above, the conditions for registering and operating a TRO are continually being tightened by the authorities. This raises the question of whether this option remains a viable pathway for obtaining residence status in Bulgaria. We believe the answer is yes, though with several important caveats.
Article 24 of the Bulgarian Foreigners Law
Article 24, par 1, p. 6 of the Foreigners Law stipulates that a long-term residence permit (and visa D) can be granted to foreigners, who are representatives of a registered in Bulgaria TRO. The different legal conditions are outlined below.
Proof of tax compliance and minimum annual turnover of the foreign company
Who can obtain visa D and residence permit?
Representatives of a foreign commercial company that has submitted documents proving tax compliance and an annual turnover of at least 51130 EUR, acquired for each of the two consecutive years prior to the registration of its TRO.
In other words, in order to open a TRO in Bulgaria (with the aim to secure residence status for its representatives), the foreign company must show:
- It is fully tax-compliant in its home country;
- It has generated at least 51130 EUR turnover per year, during each of the last two years.
This prevents inactive companies or shell companies from opening TROs for residence purposes only. The income requirement is easy to document if the turnover threshold is met. Tax compliance, however, is more subjective, as Bulgarian authorities cannot fully assess foreign tax laws.
Certificate of current legal status
What must be presented by the foreign company to the Bulgarian authorities?
A certificate of current legal status of the foreign entity, issued no earlier than 6 months and valid for 6 months from its issuance by the competent registration authority in accordance with national legislation.
This means, that the foreign company must present an official document (certificate of good standing) proving it legally exists and operates. This certificate must:
- be issued within the last 6 months, and;
- be valid for 6 months.
The purpose is to verify that the company is real and currently active. This condition is easy to fulfil, however translation and legalisation of the certificate is always required.
Verification by the Bulgarian Chamber of Commerce and Industry
How the documents of the foreign company must be verified:
These circumstances are certified by a certificate issued by the Bulgarian Chamber of Commerce and Industry (BCCI), based on the official documents provided by the foreign entity from its country of registration.
The BCCI reviews all documents and issues a certificate confirming that the company meets the requirements. This certificate is the foundation for establishing the TRO in Bulgaria.
Maximum number of representatives
How many foreigners can obtain visa D and residence permit through one TRO?
A residence permit on this basis may be obtained by up to two representatives of the foreign commercial company.
Each TRO can support up to two foreign citizens for residence permits (and visa D) in Bulgaria. This limit is fixed and cannot be exceeded. Previously it was possible for a much larger number of representatives to obtain residence status. This is no longer the case.
Extension of residence permits
What are the conditions to extend the residence permit, based on a TRO?
When an application for extending the period of residence is submitted, the Bulgarian Chamber of Commerce and Industry issues a new certificate after the commercial representative declares the activities carried out during the previous period of residence and in accordance with the activity program of the TRO.
To renew their residence permits, the representatives must prove that the TRO actually performed real activities in Bulgaria. They must show:
- evidence of a real, functioning office of the TRO in Bulgaria;
- conducted representative activities and/or relationships with Bulgarian partners, and;
- a certificate of current legal status of the foreign company valid for 6 months from the date of issuance;
This ensures the TRO is not a “virtual” or “fictional” office. Without real activity of the TRO in Bulgaria, renewal may not be granted. The requirement to demonstrate “real activities” can be challenging and often deters many foreigners. However, with careful and professional planning, this requirement can be fulfilled effortlessly.
Obligation of the foreign company to report changes
What are the obligations of the foreign company that has registered the TRO
The foreign company is obliged, within 30 days from the occurrence of changes in its registration, to present a certificate of current legal status issued no earlier than 6 months by the competent authority.
If the foreign company changes anything significant – name, address, ownership, director – it must provide updated documentation within 30 days. This keeps the Bulgarian authorities informed and prevents discrepancies.
Obligation of the TRO to report changes
The Trade Representative Office is obliged, within 7 days from the occurrence of changes in the circumstances of its registration, to declare them in writing to the Bulgarian Chamber of Commerce and Industry, which promptly notifies the Migration Directorate.
If anything changes in the TRO itself – office address, representatives, activities – the TRO must report this within 7 days. BCCI then informs Bulgarian immigration authorities about the changes.
Failure to report changes can lead to sanctions or deregistration.
Removal from the register
If there is data that the Trade Representative Office does not comply with legal requirements, competent state authorities inform the Bulgarian Chamber of Commerce and Industry with the aim of initiating actions for its deletion.
If the TRO is inactive or violates the rules, BCCI can remove it from the official register. This results in:
- loss of TRO status;
- invalidation of residence permits for its representatives.
Conclusion
The rules for establishing and maintaining a Trade Representative Office in Bulgaria are designed to:
- ensure foreign companies are legitimate;
- prevent misuse of residence permits;
- guarantee real economic presence;
- maintain transparency and compliance.
A TRO is not only a shortcut to residency. The TRO must operate as a real business representation, not merely as a virtual door to a visa D and Bulgarian residency. Although the conditions for residence via a Trade Representative Office are strict, it remains a viable option for many when no other alternatives exist.
Please don’t hesitate to contact us if you need any additional information or you want to register a Trade Representative Office in Bulgaria.