Citizenship

7 Mistakes in EU Citizenship Restoration by Descent

Daniel Kovach, Senior International Law Attorney, BRIDGESDaniel KovachSenior International Law Attorney, BRIDGES

Updated: June 20269 min readExpert reviewed

Terms and costs verified: June 2026

7 mistakes when restoring EU citizenship by descent
Contents

A Bulgarian grandfather, Hungarian grandmother, Italian great-grandfather - thousands of people already have the right to an EU passport. But most of them lose years on simple mistakes. Incorrect surname transliteration, apostille from the wrong country, a delayed archive request - and the case falls apart. This article covers seven of the most common mistakes: what goes wrong, why it's critical, and how to fix it before submission rather than after rejection.

Bulgaria - Processing Time24-36 months (queue at the Ministry of Justice)
Hungary - Degree of KinshipAny direct Hungarian ancestor, without generation limit
Italy - 2025 ReformParent or grandparent only (2 generations maximum)
Romania - Waiting PeriodUp to 24 months via ANC, EU citizenship without residence requirement
Archive Requests6-18 months waiting period from Bulgarian and Romanian archives
Bulgaria - Court in Case of Archive LossDescent can be proven through court if vital records are destroyed

EU Passport by Descent: Right Exists, but Documents Don't

Citizenship by descent programs in Bulgaria, Hungary, Romania, and Italy are not a benefit or investment. This is restoration of a right that already exists. If your parent or grandparent was a citizen of one of these countries, you can obtain an EU passport without purchasing property or relocating.

Sounds simple. In practice - one of the most document-intensive processes in immigration. Each country requires its own logic of proof, its own apostilles, and its own transliteration. Errors at any stage set the case back months.

Below are seven mistakes we see most often. Read this before you start gathering documents.

Mistake 1. "Grandmother was Bulgarian" - This Is Not Proof

Family history is a starting point, not proof. The state does not accept memories, relatives' stories, or family photographs as grounds for passport issuance.

Original documents or archival copies are required: ancestor's birth certificate, marriage certificate (if surname changed), documents confirming ancestor's citizenship at the time of your parent's birth. Each link in the chain requires a separate document.

People arrive convinced: "We always knew grandfather was Bulgarian." But there is no record under that surname in the Plovdiv archive. Or the record exists under a different name - because Soviet census records Russified names. Genealogical reconstruction begins with archival search, not family traditions.

Tip: Before starting the process, order a preliminary archive search. This takes 2-4 weeks and will show whether a documentary basis exists for your case.

Mistake 2. Archive Requested One Month Before Submission

This is one of the most painful mistakes. A person spends six months preparing document translations, paying for apostilles, coordinating with a notary - and at the last moment realizes that the key archival certificate will take another year to arrive.

State archives of Bulgaria, Romania, and Hungary operate on a queue system. Actual archive certificate issuance times: Bulgaria - 3-9 months, Romania - 6-12 months, Hungary - up to 18 months for pre-war records. This is not an anomaly, it is the norm.

If documents are stored in a regional archive of a small town or in church records, timelines can be unpredictable. Sometimes archives clarify that the collection is under restoration or relocation.

Tip: Submit archive requests at the very beginning - in the first month of working on the case. Gather everything else in parallel. By the time you receive archival documents, you will have the entire package ready.

More details on Bulgarian timelines - in the article "How Long Does Bulgarian Citizenship Take".

Mistake 3. Apostille Is Placed by the Wrong Country

An apostille certifies a document's authenticity for use abroad. It is placed by the country that issued the document - not the country to which you are submitting.

Common confusion: a document from Bulgaria must be apostilled in Bulgaria, not in Russia or Ukraine. Russian notarial certification of a Bulgarian archival document does not work. A Bulgarian apostille on a Russian birth certificate makes no sense either.

Another mistake: apostille is placed on the translation instead of the original. The original (or archival copy) is apostilled. The translation is certified by a notary of the country of submission - separately.

For Italy, the scheme is more complex: Italian documents are apostilled in Italy, Russian documents - in Russia (Ministry of Justice or Ministry of Foreign Affairs), and then translated by a sworn translator in Italy. If the chain is broken, the entire package is returned.

Tip: Before apostille placement, clarify requirements with the specific consulate or ministry. Each country has its own regulations, which sometimes update without public notice.

Mistake 4. Surname Written "in Russian" - Documents Don't Match

Transliteration is a technical issue that destroys cases. In Soviet documents, Bulgarian, Hungarian, and Romanian surnames were recorded according to Cyrillic transcription rules. In original documents of EU countries - according to local Latin alphabet rules. These variants often do not match.

Example: the Bulgarian surname Georgiev in Soviet records appears exactly as such. In a Bulgarian document - Georgiev. In some old Bulgarian vital records - Georgieff or Gyorgiev (depending on dialect and region). Three variants - and the state sees three different persons.

Hungarian surnames are particularly complex: word order is reversed (surname before given name), diacritical marks (ö, ü, ő, ű) are lost in transliteration, female suffixes (-né) create confusion in children's documents.

For Romania, the problem often arises with Moldovan roots: the same family could have had a surname in three variants - Romanian, Russian, and Soviet Moldovan.

Advice: before submission, obtain a linguistic certificate or affidavit of identity. Many countries accept such a document as an explanation of discrepancies. However, it must be prepared in advance, not explained verbally at the appointment.

Error 5. Not aware of Italy's 2025 reform.

Until 2025, Italian citizenship by right of blood (jure sanguinis) could be restored through any number of generations. A great-great-grandfather who emigrated in 1900 gave the right to a great-great-grandson in the fourth generation.

In 2025, Italy introduced a reform. Now the right to citizenship by descent is recognized only for direct descendants within two generations: parent or grandparent. If the Italian ancestor is a great-grandparent or further, the case is closed under the new rules.

The reform affected thousands of applications already in processing. Some were withdrawn or suspended. Those who had only planned submission through court (the judicial route was popular for circumventing consulate restrictions) found themselves in limbo.

For people with Italian roots in the third generation and beyond, alternatives should now be considered: long-term residence, an investor program, or naturalization after three years as a spouse of an Italian citizen.

More about investment programs in Italy - on the page. "Investor residence permit in Italy.".

Error 6. When Bulgarian archives are lost, they are immediately surrendered.

In Bulgaria, a significant portion of civil vital records from the 19th to early 20th century has been destroyed. Fires, wars, floods, poor storage during the Soviet period - the causes vary, the result is the same: the archive is silent.

Many in this situation believe the case is closed. This is not so. Bulgarian legislation provides for a judicial procedure to establish descent when documents are lost or absent. The court considers circumstantial evidence: church vital records, census sheets, notarial inheritance documents, witness testimony from relatives, family photographs with dates and locations.

Church records in Bulgaria have often survived where state archives burned. The Bulgarian Orthodox Church maintained parallel records of baptisms and marriages. This is a separate, lesser-known source.

The judicial route takes longer than the standard procedure - adding 6-18 months. But it works. The key is to begin it with a lawyer who understands Bulgarian evidentiary standards, not simply one who translates documents.

Read more: "Bulgarian citizenship by descent." and program page..

Error 7. Choosing a country by "speed" without checking the queue.

"They say Bulgaria is faster than Romania" - such comparisons circulate on forums and often become outdated by 1-2 years. Real timeframes depend on the current workload of the authority, not on theoretical figures in articles.

Current benchmarks as of mid-2026: Bulgaria (Ministry of Justice) - 24-36 months from submission of a complete package. Hungary (procedure through the Interior Ministry or embassy) - 12 to 24 months depending on the country of submission. Romania (through ANC) - 18-24 months. Italy (consular route) - 2-4 years in some consulates, especially in Latin America.

Moreover, a "fast" country may prove unsuitable for your specific lineage. If you have a Bulgarian grandfather and a Romanian grandmother - do not choose a country by speed. Choose by documentary basis: where you have more surviving documents, the higher your chances of success.

Advice: before choosing a country, conduct a comparative assessment of documents for each line. This takes 1-2 consultations but saves years.

Compare programs: Bulgarian citizenship and Hungarian citizenship..

Cost: what is included in the real budget.

The cost of restoring citizenship by descent consists of many line items. Here is a complete breakdown for one applicant (using Bulgaria as an example).

Expense itemAmountRefundability
Government fee (Bulgaria)~200-400 BGN (~100-200 €)Non-refundable
Passport fee~300-500 € / personNon-refundable
Archive requests (2-4 documents)50-300 € eachNon-refundable
Apostilles (for each document)30-80 € eachNon-refundable
Notarial certifications50-200 €Non-refundable
Translations (sworn translator)20-60 € / pageNon-refundable
Bank commissions and transfers50-150 €Non-refundable
Agent assistance€2000-5000 (depending on complexity)Non-refundable

Total per 1 applicant: €3000 to €7000 (excluding travel and unforeseen archive expenses)

For a family of 4 people (applicant + spouse + 2 children): €8000 to €18,000 - provided that children are submitted jointly with a parent

Detailed cost breakdown for Bulgaria - in the article "Cost of Bulgarian citizenship".

Want to check your chances before applying?

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How to verify the document base before starting

Before spending money on apostilles and translations, you need to answer three questions

First: are there documents of your ancestor? A birth certificate or metric record of an EU country citizen is the foundation. Without it, there is no case. This is verified through a preliminary archive request or genealogical search

Second: is the chain from your ancestor to you traceable? Each generation must be confirmed by documents. If there is a gap in the middle (for example, no birth certificate of your parent), it must be recovered through the civil registry or court

Third: do you meet the country's requirements? Italy has limited depth to two generations. Hungary requires language knowledge (basic level for some categories). Bulgaria does not require residence. Conditions vary

Preliminary assessment takes 1-2 consultations. It will show whether there is a document base, which country to apply to, and how long it will realistically take

Expert commentary

"The most common situation in our practice: a person is confident that they have the right to a Bulgarian passport because that's what their mother said. We start an archive search - and it turns out that grandfather changed his surname when he moved, and the metric books burned in 1944. This doesn't mean the case is closed. Through court and church archives, we have restored genealogical lines even in such cases. But it takes six months longer than the standard path. That's why we always say: start by checking the document base, not by choosing a country. The country is chosen based on documents, not rumors about speed."

Anna Kovalevskaya, Head of Legal, BRIDGES

Romania: features that are rarely discussed

Romania is one of the most accessible ancestry-based programs. Citizenship is granted through the National Citizenship Agency (ANC) without a residence requirement. The ancestor had to be a Romanian citizen before 1940 - this includes much of Moldova, parts of Ukraine, and part of Bulgaria according to historical borders

Popular mistake: people with Moldovan roots think that Moldovan citizenship automatically means the right to a Romanian passport. This is not true. You must prove specifically Romanian citizenship of your ancestor at a specific historical moment - through documents from that period

Another feature: Romania accepts applications through diaspora abroad, but personal presence at the oath-taking stage is mandatory. This must be taken into account when planning

Waiting time - 18-24 months. The case is reviewed centrally, without regional division, which makes the process more predictable than in Bulgaria

Hungary: language and documents from Soviet archives

Hungarian citizenship by descent is not limited by the number of generations. If you can documentarily prove a Hungarian ancestor in any generation - the case is considered. This makes Hungary attractive for families whose Italian or Bulgarian path is closed

The main requirement that is often forgotten: knowledge of Hungarian. Not academic - conversational level is sufficient to speak with an official. But this requires preparation, especially for those who have never studied Hungarian

Documents from the Soviet period from Ukraine, Russia, or Kazakhstan are accepted - but with mandatory apostille and certified translation. If documents are from Hungarian archives of the pre-war period, archive waiting times can reach 18 months

More details on requirements: program page on Hungarian citizenship.

Where to start: practical order of actions

If you know about an ancestor who is an EU citizen but have not yet started the process, here is the working order of steps

Step 1. Collect all family documents you have on hand. Birth, marriage, and death certificates of all generations from your ancestor to you

Step 2. Determine which country and line you have more documents for. If there are several options - assess each one

Step 3. Order a preliminary archive search for your ancestor's country. This is a parallel process - it can be conducted while you are assessing other options

Step 4. Clarify the requirements of the chosen country as of the current moment. The Italian reform of 2025 is a live example of how rules change without broad notification

Step 5. After receiving archived documents – compile a complete package, obtain apostille certification, translate, and submit.

Seven errors: brief summary

  • Error 1. Relying on memory instead of documents.
  • Error 2. Delaying archive requests until the last moment.
  • Error 3. Obtaining apostille certification in the wrong country.
  • Error 4. Ignoring discrepancies in surname transliteration.
  • Error 5. Not being aware of Italy's 2025 reform and relying on distant ancestors.
  • Error 6. Giving up when Bulgarian archives are unavailable instead of pursuing legal action.
  • Error 7. Choosing a country based on rumors about processing speed without verifying actual queue times.

Each of these errors costs a minimum of several months. Some close the case entirely.

Bottom line: documents decide everything

EU citizenship by descent – a real pathway for hundreds of thousands of people from the CIS. Bulgaria, Hungary, Romania, and Italy issue passports to descendants of their citizens. This is not an investment or a benefit – it is restoration of rights.

But this right works only if documents are available. Family history without papers is not grounds for approval. Correct apostille, accurate transliteration, timely archive requests – each detail matters.

Italy's 2025 reform closed the pathway through distant ancestors. The Bulgarian queue is growing. The sooner you start, the sooner you get results.

If you know of an EU citizen ancestor – begin with a preliminary assessment. It will show whether there is a documentary basis and which pathway is realistic for you.

Frequently asked

Questions people ask before deciding

01Is it possible to obtain Bulgarian citizenship if archival documents are lost?

Yes. If state archives are lost or destroyed, Bulgarian legislation permits a court procedure to establish descent. The court reviews church records, census lists, notarial acts, and witness testimony. The procedure takes longer than the standard process, but it works.

02Did Italy change the rules for obtaining citizenship by descent in 2025?

Yes. The 2025 reform limited jure sanguinis citizenship rights to two generations: a parent or grandparent. Great-grandparents and more distant ancestors no longer provide grounds for the standard application path. For distant ancestors, investment programs or long-term residence are considered.

03How long does Bulgarian citizenship by descent take?

As of 2026 - from 24 to 36 months from the date of submitting the complete package to the Ministry of Justice. Archival requests add 3-9 months at the preparation stage. The court route in case of lost archives increases the timeline by an additional 6-18 months.

04Is it necessary to know Hungarian language to obtain Hungarian citizenship by descent?

Yes. Hungary requires basic knowledge of Hungarian language - sufficient for a simple conversation with an official during an interview. An academic certificate is not required, but preparation must be done in advance. Without this, the application will not be accepted.

05Can I apply for Romanian citizenship if an ancestor was from Moldova?

It depends on the period. The right to Romanian citizenship arises if the ancestor was a Romanian citizen before 1940. Part of modern Moldova was part of Romania during that period. You need to prove the ancestor's Romanian citizenship at a specific historical moment through documents from that time.

06How do I properly apostille documents from different countries?

The apostille is issued by the country that issued the document. A Bulgarian archival document is apostilled in Bulgaria. A Russian birth certificate is apostilled in Russia (Ministry of Justice or Ministry of Foreign Affairs). A notarized translation does not require apostille - it is certified by a notary in the country of submission separately.

07What should I do if the surname in Soviet documents differs from the surname in EU country documents?

You need to prepare a linguistic certificate or an affidavit of identity. This document explains the discrepancy: why two variants of the name refer to the same person. Most EU countries accept such a certificate as proof when accompanied by other supporting documents.

08How much does obtaining EU citizenship by descent cost?

For one applicant under the Bulgarian program - from 3,000 to 7,000 euros including archival requests, apostilles, translations, and agency support. For a family of four - from 8,000 to 18,000 euros. The exact amount depends on the complexity of the family tree and the number of generations in the chain.

09Can I simultaneously apply for citizenship of two EU countries if I have ancestors from both?

Technically - you can prepare two cases in parallel. However, EU countries require renunciation of previous citizenship upon naturalization (this does not apply to restoration). If both paths are restoration, consult with a lawyer: each country has its own position on dual citizenship.

10Do I need to live in Bulgaria or Romania to obtain citizenship by descent?

No. Neither Bulgaria nor Romania requires residence to obtain citizenship by descent. Personal presence is required only at the stage of obtaining a passport or taking an oath. The rest of the process is conducted remotely through the embassy or an authorized representative.

11What happens if a gap in documents is discovered during the case review process?

The case is suspended and the applicant is sent a request to provide additional documents. The response deadline is limited - usually 30-90 days depending on the country. If documents are not provided within the deadline, the case is closed and you must reapply. Therefore, it is important to identify gaps in advance and restore documents before submission.

12Which country is the fastest for obtaining citizenship by descent in 2026?

There is no universal answer. Actual timelines: Bulgaria - 24-36 months, Hungary - 12-24 months, Romania - 18-24 months, Italy - 2-4 years depending on the consulate. The choice of country should be based not on theoretical speed, but on the availability of documentary evidence along your specific lineage.

About the author

Daniel Kovach, Senior International Law Attorney, BRIDGES

Author: Daniel Kovach

Senior International Law Attorney, BRIDGES

Checks the legal grounds, manages document collection and oversees translations.

Specialisation
Repatriation and archive documents
Materials in the blog
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Personal programme selection is conducted by Anna Kovalevskaya, Head of Legal, BRIDGES.

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Anna KovalevskayaHead of Legal, BRIDGES
Anna Kovalevskaya, Head of Legal, BRIDGES