Is Bulgaria the New Portugal for Golden Visa Investors?

Bulgaria is attracting fresh attention from international investors, but it is not yet a direct replacement for Portugal. The strongest conclusion from Jonathan’s discussion is simple: Bulgaria may become a niche option for some families, especially those prioritising permanent residence and minimal physical presence, yet Portugal still offers the more established and more practical long-term route for most people seeking a European Plan B.

That distinction matters because many investors are not merely buying residence; they are trying to preserve family flexibility, protect capital, and keep open a credible route towards citizenship. Bulgaria can help with some of those goals, but not all of them with the same level of certainty.

Why Bulgaria is entering the conversation

The appeal of Bulgaria is partly psychological and partly structural. Portugal’s nationality reform has made the old model feel less secure and less straightforward for some investors, so people are naturally scanning the market for alternatives. Jonathan’s point is that this change in sentiment has created room for countries that were previously overlooked.

Bulgaria now looks more relevant because it is an EU member state, part of the Schengen area, and, as of 1 January 2026, a euro area member. Those are important markers for investors who want a foothold in Europe rather than an isolated residence permit in a smaller market. They do not, however, make Bulgaria equivalent to Portugal. The comparison only works if the route also delivers a stable legal status, a sensible investment framework, and a believable pathway to citizenship. (Source: European Commission)

Jonathan also emphasises that Bulgaria’s lower cost of living can make it attractive as a place to reside in practical terms. That said, the investment entry point itself is not low. The commonly discussed qualifying route starts at roughly €512,000, so the programme should not be mistaken for a bargain simply because the country is less expensive to live in.

How the Bulgarian Golden Visa works

The main attraction of Bulgaria’s investment residence route is that qualifying investors can obtain permanent residence from the outset, rather than beginning with a sequence of temporary permits. For investors who want long-term stability and do not want to manage repeated renewals, that is a meaningful feature.

Jonathan explains that the most talked-about route is the fund-based option, while other routes exist through higher-value securities or business activity. In his view, the business route is more hands-on and less appealing to many international applicants because it requires active ownership, job creation, or the purchase of company assets. The overall programme is therefore narrower than Portugal’s, both in the number of routes and in the surrounding ecosystem.

Family inclusion is possible, typically through spouse and dependent children. The programme is aimed at non-EU and non-EEA nationals who can show a clean criminal record and lawful source of funds. Jonathan treats those requirements as standard for the sector, but he is clear that the narrower investment market makes Bulgaria less flexible than Portugal.

Another practical advantage is that there is generally no minimum annual stay requirement for maintaining the permanent residence status. For investors who want to keep living elsewhere, that is an obvious benefit. But it should be understood as a residence feature, not proof that the route will work equally well as a citizenship strategy.

Residence is not citizenship

This is the central caution in Jonathan’s analysis. Bulgaria may offer permanent residence, but that does not mean it offers a reliable shortcut to a passport. Under Bulgarian law, a person who has held permanent residence for at least five years may become eligible to apply for citizenship, but eligibility is not the same as automatic approval. The naturalisation process still involves language, financial, and good-character requirements, and the legal position on dual nationality must be checked carefully. Bulgarian law currently requires, for ordinary naturalisation, at least five years of permanent or long-term residence before an application can be made, alongside the usual statutory conditions. (Source: Bulgarian Ministry of Justice)

Jonathan’s view is that the biggest practical issues are threefold. First, the language requirement is more demanding than many investors assume, especially because Bulgarian uses the Cyrillic alphabet and is not a mainstream second language for most applicants. Second, the track record for progressing from investment residence to citizenship is limited. Third, the issue of dual nationality may be decisive for many families, because retaining an existing passport is often the whole point of the exercise.

For those reasons, he is wary of describing Bulgaria as a true citizenship-by-investment solution. The route may exist in law, but in practice it is still too early to treat it as a proven remote passport strategy.

Why Portugal still sets the benchmark

Jonathan does not deny that Portugal has changed. On the contrary, he says the nationality reform has damaged trust and made the route more complicated. But he argues that damaged is not the same as dead. Portugal still has several advantages that are difficult to replicate.

One is the remote residence model. Portugal remains attractive to families who want to progress towards permanent residence or citizenship without having to uproot their lives immediately. Another is the mature professional ecosystem. Lawyers, fund managers, banks, advisers, and other service providers have worked around the Portuguese Golden Visa for years, which gives investors more support and more predictable execution than they are likely to find in a newer programme. A third is the breadth of the investment market. Portugal offers a more developed range of qualifying routes than Bulgaria, whose universe of options is much narrower.

Portugal also has a clearer historical track record. That matters because investors are not only buying a legal structure; they are buying confidence that the structure will function as expected over time. Jonathan’s point is that Bulgaria lacks that proof of concept. It may become more credible, but it has not yet earned the same level of trust.

Current Portuguese nationality rules now require at least five years of legal residence for naturalisation, but the recent 2026 reform also introduced tougher requirements and higher residence thresholds for some applicants. In particular, the Ministry of Justice states that the new law, which entered into force on 19 May 2026, raises the minimum residence period to seven years for EU and CPLP nationals and to ten years for other nationals, while also adding cultural, historical, and civic knowledge requirements. Those changes help explain why investors are looking elsewhere, but they do not make Bulgaria an obvious substitute. (Source: Portuguese Ministry of Justice)

Who Bulgaria may suit, and who it probably will not

Jonathan’s practical conclusion is not that Bulgaria should be dismissed. Rather, it should be understood as serving a different use case.

It may suit investors who are comfortable with a less familiar legal environment, who have strong local advice, and who are genuinely prepared to meet the language and naturalisation requirements later on. It may also suit families whose primary aim is residence in Bulgaria itself rather than a proven remote pathway to a European passport.

By contrast, Bulgaria is unlikely to suit investors who need dual citizenship, who want broad investment choice, who see language as a serious obstacle, or who are looking for a mature and well-tested route to citizenship without relocating. For those people, Portugal remains the stronger default, even after the recent reforms.

The most balanced way to view the market is therefore this: Bulgaria is worth watching, and it may become more important over time, but it is not the new Portugal. Investors should compare the facts carefully rather than reacting to headlines or online momentum. The right route is the one that fits the family’s objectives, risk appetite, and long-term plans, not simply the option that is receiving the most attention at the moment.

Important information: This article is provided for general information only and does not constitute legal, tax or investment advice. Programme rules, legislation and investment conditions may change, and readers should obtain appropriate professional advice before making any decision.