Refusal of Bulgarian citizenship by descent: 5 main reasons

Why Bulgarian citizenship attracts applicants

A Bulgarian passport is a European Union passport. With it, you can freely live, work, and study in any of the 27 EU countries without visas and work permits. Visa-free entry is available to more than 170 countries, including the Schengen area, the United Kingdom, and most Latin American countries.

The main advantage of the Bulgarian route is that you do not need to invest money. The citizenship-by-investment program was discontinued in 2022. Only one legal route remains: proving Bulgarian descent through genealogical lineage.

This makes Bulgarian citizenship accessible to descendants of Bulgarians who ended up outside the country in the 20th century - in Russia, Ukraine, Moldova, Kazakhstan, and other former Soviet countries. Many of them have the right to a Bulgarian passport but do not know how to properly obtain it.

This is where mistakes occur. Applicants submit documents without understanding the Ministry of Justice requirements and receive a refusal. Let us explain why this happens.

How the descent-based program works

Citizenship by descent (po proiskhod) is a constitutional right of anyone who has a Bulgarian ancestor. The Bulgarian Citizenship Law allows you to obtain a passport if your parent or grandparent was a Bulgarian citizen.

The process works as follows. You collect documents proving Bulgarian descent through genealogical lineage: birth certificates, marriage certificates, and documents of your ancestor with Bulgarian citizenship. The package is submitted through the Bulgarian consulate in your country.

The consulate forwards the documents to the Bulgarian Ministry of Justice. There, the case is reviewed by the Citizenship Council (Suvet po grazhdanstvo) - a special advisory body. The Council examines each document, the chain of kinship, and the family history. Based on its findings, it provides a recommendation to the Minister of Justice.

The Minister of Justice makes the final decision: to grant citizenship or refuse. The entire process takes from 24 to 36 months. After approval, you receive a Bulgarian passport - a document of an EU citizen.

Reason 1: No proof of Bulgarian descent

The most common reason for refusal is that the applicant cannot prove that their parent or grandparent was specifically a Bulgarian citizen. A general feeling of "we have Bulgarian roots" without documentary evidence is not an argument for the Ministry of Justice.

What exactly must be proven? First, your ancestor must have held Bulgarian citizenship - not simply lived in Bulgaria or be ethnically Bulgarian. Second, there must be an unbroken documentary chain: from you to that ancestor through birth and marriage certificates of each generation.

Weak points that most often lead to refusal:

• No documents confirming the ancestor's Bulgarian citizenship
• Documents exist, but they contain no indication of citizenship or place of birth in Bulgaria
• A gap in the documentary chain - for example, a birth certificate of one of the parents is missing

If you are unsure whether you have the necessary documents, start by searching for them rather than submitting an application.

Reason 2: Loss of archival documents

In the 20th century, many documents were destroyed: fires, wars, relocations, Soviet repression. Applicants come empty-handed and receive a refusal. However, this is not a dead end.

Bulgarian legislation provides for alternative sources of documents. The main one is church registry books (metrični knigi). Before the introduction of civil registration, all birth, marriage, and death records were registered by the Orthodox Church. Many of these books have been preserved and are stored in Bulgarian diocesan archives.

What else helps restore the documentary chain:

• State Archive of Bulgaria (Darzhavna agentsiya Arhivi) - contains documents on Bulgarian communities abroad
• Regional archives of Bulgarian provinces - particularly important for families from border regions
• Census archives - data on family composition by census years
• Court procedure for establishing a fact - a court can recognize the fact of birth or citizenship based on witness testimony and circumstantial evidence

Searching for alternative sources takes time, but makes the case solid. Without this stage, filing an application is premature.

Reason 3: documents without apostille and translation

Documents from other countries are not accepted in their original form. Every foreign document must undergo mandatory legalization and translation procedures. Violation of this rule is one of the most frustrating reasons for rejection, because the documents exist, but are improperly formatted.

What is required for each foreign document:

• Apostille – a special stamp confirming the authenticity of the document. Affixed by an authorized body of the country that issued the document. Russia has withdrawn from the Hague Convention – this creates additional difficulties for Russian documents.
• Notarized translation into Bulgarian – the translation must be performed by a certified translator, and the translation must be notarized.
• Legalization by consul – for countries not party to the Hague Convention, consular legalization is required instead of an apostille.

Common mistakes: apostille is expired, translation is not notarized, translation is made into a language other than Bulgarian. Check every document before submission.

Reason 4: discrepancies in surname spelling

Bulgarian surnames often changed when moving to other countries: they were transliterated, Russified, or shortened. As a result, documents of one person contain two or three spelling variations of the same surname. The Ministry of Justice will not independently establish that this is the same person.

Typical cases of discrepancies:

• Bulgarian "Ivanov" became "Ivanovym" in Soviet documents
• Female Bulgarian surnames ending in "-ova" were often recorded in the USSR without the ending
• A great-grandfather emigrated under one surname, his descendants registered documents under another

Solution – an explanatory note (obiasnitelna zapiska). This is a document in which you explain both spelling variants in writing and attach evidence that it is the same person. In complex cases, a court ruling on establishing personal identity may be required.

The more documents with both spelling variants of the surname attached to the explanatory note – the more convincing the case. It is better to prepare such a note in advance, without waiting for a request from the Ministry.

Reason 5: attempting to buy citizenship

Bulgaria's "golden passport" program – citizenship in exchange for investments – was officially abolished in 2022. This happened under pressure from the European Commission, which demanded closure of EU citizenship sales schemes.

Since 2022, it is impossible to buy Bulgarian citizenship. No amount of investment in real estate, government bonds, or business grants the right to a Bulgarian passport. Consultants who offer to "obtain Bulgarian citizenship for investments" are misleading you.

Why it is important to know this:

• Applicants who relied on the investment route waste time and money
• The only working route is to prove Bulgarian descent through documents
• Attempts to bypass document requirements through "connections" or "special schemes" result in rejection and loss of money

If you have no Bulgarian roots – Bulgaria is not your option. For investment citizenship in the EU, consider Malta (residence permit) or other programs.

What the Citizenship Council checks

The Citizenship Council (Savvet po grazhdanstvo) under Bulgaria's Ministry of Justice is the main body that decides the fate of your application. Understanding what it checks helps prepare your document package correctly.

The Council checks several key areas:

• Documentary chain of descent – every link from you to a Bulgarian ancestor must be confirmed by original documents or their notarized copies
• Document authenticity – the Council has the right to request verification of apostilles and translations, and send inquiries to foreign government bodies
• Security check – standard verification of the absence of criminal convictions, international sanctions, or inclusion on undesirable persons lists
• Compliance with legal requirements – all formal conditions of the Bulgarian Citizenship Law

In individual cases, the Council may summon the applicant for an interview – especially if questions arise regarding documents or additional clarifications are needed. Based on the results of the review, the Council makes a recommendation to the Minister of Justice.

What documents are needed for filing

The standard document package for obtaining Bulgarian citizenship by descent includes several groups:

Your personal documents:

• Birth certificate (with apostille and translation)
• Valid passport (copy)
• Marriage certificate, if you changed your surname

Documents along the family line (for each generation):

• Birth certificates of parents, grandparents, great-grandparents
• Marriage certificates (confirming surname change)
• Death certificates (if the ancestor is deceased)
• Documents confirming the ancestor's Bulgarian citizenship: Bulgarian passport, extract from Bulgarian archives, citizenship certificate

Additional documents:

• Explanatory notes in case of discrepancies in surname spelling
• Extracts from Bulgarian archives (if available)
• Court decisions (in case of lost archival documents)

All foreign documents must be accompanied by an apostille and a notarized translation into Bulgarian.

Procedure for submission through the embassy

Applications can be submitted through the Bulgarian consulate in your country of residence, whether in the UK, the US, Russia or elsewhere. A personal visit to Bulgaria for submission is not required.

Procedure:

• Step 1: Document collection. Collect the complete package, obtain apostilles, and arrange notarized translations into Bulgarian.
• Step 2: Schedule a consulate appointment. Schedule an appointment at the Bulgarian consulate. In Russia – the Bulgarian Embassy in Moscow. In Ukraine – the Embassy in Kyiv or consulates in Odesa and Lviv.
• Step 3: Document submission. During the appointment, a consular officer accepts the package and verifies completeness. You pay the consular fee.
• Step 4: Transfer to the Ministry of Justice. The consulate forwards the package to the Bulgarian Ministry of Justice in Sofia.
• Step 5: Review. The Citizenship Council examines the case. Processing time: 24-36 months. Additional document requests may be submitted during this period.
• Step 6: Decision. The Minister of Justice signs a decree granting citizenship or issues a reasoned refusal.

Cost of processing

Citizenship by descent does not require investments but entails actual expenses for lawyers, archive searches, and document processing. Here is a complete cost breakdown:

The variation in archive search and legal service costs is explained by case complexity: if the documentary chain is preserved and incomplete – that is one task; if court proceedings are needed for restoration – that is another.

What to do after refusal

Received a refusal from the Bulgarian Ministry of Justice – do not panic. You have two options.

Option 1: Administrative court appeal. You have the right to appeal the refusal in the Bulgarian administrative court. The deadline for filing an appeal is 14 days from the date of receiving the refusal decision. The court checks the legality of the Ministry of Justice's decision: whether the law was applied correctly and procedures were followed. If the court finds the refusal unlawful – the case is returned for reconsideration.

Option 2: Resubmission with an improved package. If the refusal is based on insufficient documents – collect the missing materials and submit a new application. This is often more effective than court appeal: you eliminate the reason for the refusal rather than dispute the procedure.

What must be done immediately after receiving the refusal:

• Carefully read the reasons – what exactly did not satisfy the Ministry
• Show the refusal to a Bulgarian law specialist
• Determine strategy: court proceedings or resubmission
• Do not miss the 14-day deadline for filing an appeal if you choose to go to court

How to avoid rejection: checklist

Most rejections can be prevented if you prepare properly before submitting your application. Here is a practical checklist:

• Verify the documentary chain. Ensure you have birth and marriage certificates for each generation from you to your Bulgarian ancestor - with no gaps.
• Confirm your ancestor's Bulgarian citizenship. Birth in Bulgaria alone is insufficient - you need a document that specifically confirms citizenship.
• Check the spelling of surnames. Compare the spelling of surnames across all documents in the chain. If there are discrepancies - prepare an explanatory note in advance.
• Obtain apostilles. For all foreign documents - before submission, not after.
• Order notarized certified translations. All documents must be translated into Bulgarian by a certified translator.
• Search for church records if civil archives have been lost. Do not give up in the absence of civil vital records - church vital records are often preserved.
• Hire a lawyer. A specialist with experience in the Bulgarian Ministry of Justice will reduce the risk of technical errors.
• Do not submit an incomplete package. It is better to spend an additional 3-6 months gathering documents than to receive a rejection and start over.

Bulgarian citizenship: differences from residence permit

Bulgarian citizenship by descent is often confused with other statuses. Let us examine the key differences.

Citizenship by descent (by origin) - the main topic of this article. Grants a Bulgarian passport and full EU citizen rights. Requires proof of a Bulgarian ancestor. Timeline - 24-36 months. No investments required.

Bulgaria residence permit through real estate purchase - temporary residence visa. Does not automatically grant the right to work in other EU countries. The path to citizenship through a residence permit requires 5 years of legal residence in Bulgaria, knowledge of the Bulgarian language, renunciation of previous citizenship (in some cases). This is a completely different route.

Citizenship through investment - abolished in 2022. This path is closed.

Naturalization - after 5 years of continuous residence in Bulgaria. Requires a language exam and confirmation of financial self-sufficiency. Long and complicated for those who do not plan to live in Bulgaria.

If you have Bulgarian roots - citizenship by descent is the most direct and accessible path to a European passport.

Summary: is it worth applying

Bulgarian citizenship by descent is a real and working path to an EU passport. It takes time and requires serious preparation, but does not require investments. This makes it attractive for descendants of Bulgarians from CIS countries.

You should apply if:

• You have documentary evidence of a Bulgarian ancestor
• You are ready for 2-3 years of waiting
• You are prepared to invest €6,000-15,000 in document preparation and legal support
• An EU passport is important to you, not just residing abroad

You should apply later if:

• The documentary chain has not been fully collected
• You have not obtained apostilles and translations
• You have not resolved discrepancies in surname spelling

Learn more about the program and examples of successful cases:

• Bulgarian citizenship - program and conditions
• Bulgarian citizenship by descent: complete guide
• Cost of Bulgarian citizenship
• Timeline for obtaining Bulgarian citizenship