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Amendments to the Bulgarian Foreigners Act: Introducing a Legal Framework for Digital Nomads

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On 18 June 2025, the Bulgarian National Assembly adopted a Law Amending and Supplementing the Foreigners in the Republic of Bulgaria Act, promulgated in State Gazette No. 52 of 27 June 2025 (the "Law"). These amendments introduce significant changes to the regulatory framework governing the entry and residence of foreign nationals in the country, aiming to establish clearer rules and new residence opportunities for various categories of foreigners.

Among them is the formal introduction of the so-called “digital nomads” – a rapidly growing demographic in the global economy. Through these legislative changes, Bulgaria aims to address the evolving landscape of remote work and international business, positioning itself as a progressive and attractive destination. 

Who Qualifies as a Digital Nomad under the New Law? 

The Law defines a digital nomad as a foreign national who provides remote services using information technologies, without working for or rendering services to individuals or entities on the territory of Bulgaria. To qualify under this category, the foreigner must meet one of the following criteria: 

  1. Be employed under a labor contract by an employer registered/incorporated outside the European Union, the European Economic Area, or the Swiss Confederation, and provide remote services via information technologies; or
  2. Be a legal representative, member of the management body, owner, partner, or shareholder holding more than 25% of the capital of a company registered/incorporated outside the EU, EEA, or Switzerland, through which they provide remote services via information technologies, without conducting business or providing services to persons in Bulgaria; or
  3. Personally provide remote services using information technologies for at least one year prior to submitting the application, without working for or providing services to individuals or entities on the territory of Bulgaria, and without engaging in freelance activities within the country. 

In all instances, the applicant must provide evidence of an average annual income equal to or exceeding 50 times the statutory minimum monthly wage in Bulgaria for the preceding calendar year. The residence permit for digital nomads is granted for an initial term of one year, with the option of a single extension for an additional one-year period.

The Practical Impact of the New Provisions

The introduction of a dedicated legal regime for digital nomads marks a significant shift in Bulgaria’s immigration policy, which has traditionally focused on employment, investment, or family reunification. In light of the global shift towards remote work and increased worker mobility, the new rules provide a clear legal framework for foreigners who wish to reside in Bulgaria without engaging in local employment, while still contributing to the economy through local consumption of goods and services.

Why This Matters for Bulgaria

With its recent accession to the Schengen Area and the forthcoming potential adoption of the euro, Bulgaria distinguishes itself through its low cost of living, natural beauty, and rapidly advancing digital infrastructure. These factors make the country an increasingly attractive destination for digital nomads. By establishing a dedicated legal regime for this group, Bulgaria is well-positioned to attract a significant number of foreign nationals who choose to reside and spend within its territory, without competing with the local labor market.

Challenges and Open Questions

Despite the positive implications, the new provisions also raise several practical concerns. For instance, how will authorities verify that a digital nomad is not in fact providing services to local clients? What will be the administrative burden for applicants and for public institutions? Will Bulgaria be able to offer adequate conditions and support to attract and retain this mobile group of professionals?

Other Key Changes: Stricter Requirements for Foreign Trade Representatives

The 2025 legislative amendments also tighten the rules regarding the residence regime for representatives of foreign commercial entities operating in Bulgaria through registered trade representative offices. The changes include stricter financial criteria for the parent company, notably a requirement for a minimum annual turnover of BGN 100,000 for each of the two preceding financial years. Additionally, trade representative offices must now provide regular updates regarding their activities and current legal status, and any changes in their registration must be promptly reported. These measures aim to increase transparency and ensure the credibility of foreign commercial representation in Bulgaria.

Conclusion 

The 2025 amendments to the Foreigners in the Republic of Bulgaria Act reflect the country’s efforts to modernize its immigration policy in response to global trends. The introduction of a legal regime for digital nomads and the strengthened requirements for foreign trade representation are important steps towards aligning Bulgarian legislation with contemporary economic realities. These reforms have the potential to attract new categories of foreign nationals, stimulate economic growth, and promote international cooperation, while ensuring compliance, transparency, and legal certainty in the activities of foreigners and foreign organizations operating within Bulgaria.

By Kostadinka Deleva, Senior Partner, and Boris Iliev, Junior Associate, Gugushev & Partners, PONTES

Bulgaria Knowledge Partner

Schoenherr is a leading full-service law firm providing local and international companies stellar advice that is straight to the point. With 15 offices and 4 country desks Schoenherr has a firm footprint in Central and Eastern Europe. Our lawyers are recognised leaders in their specialised areas and have a track record of getting deals done with a can-do, solution-oriented approach. Quality, flexibility, innovation and practical problem-solving in complex commercial mandates are at the core of our philosophy.

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