On June 27, 2025, Bulgaria enacted significant amendments to the Foreigners in the Republic of Bulgaria Act (“FRBA”). While initial attention focused primarily on provisions for digital nomads—a notable innovation—the amendments introduce substantial changes to the standard Unified Work and Residence Permit (“UWRP”) regime, EU Blue Card provisions, seasonal worker regulations, and other immigration categories. This analysis examines the key changes affecting UWRP and EU Blue Card holders.
1. Previously, many foreign applicants were compelled to provide fictitious addresses for initial applications due to the practical impossibility of securing accommodation without first entering the country. The amendments now require proof of secured accommodation only at the time of visa “D” application submission and residence permit issuance. While this modification does not resolve the underlying "catch-22” situation—whereby applicants need accommodation to enter Bulgaria but must enter Bulgaria to secure accommodation—it eliminates the burden on prospective employees to execute lease agreements before receiving application approval.
2. Previously, UWRP holders were excluded from statutory public health insurance coverage. The amendments, through corresponding changes to relevant legislation, now subject UWRP holders to mandatory statutory public health insurance, thereby imposing additional financial obligations on both employers and employees.
3. The amendments establish automatic termination of residence permits upon employment contract termination. This provision must be interpreted in conjunction with Article 33k of the FRBA, which no longer provides that allprilongedresidence permits may transition to Blue Card status.Consequently, it remains unclear whether UWRP holders may transition directly to EU Blue Card status without undergoing the visa “D” application process. This uncertainty is compounded by the fact that UWRP holders are not specifically excluded from the categories listed in new paragraph 30, which enumerates persons ineligible for EU Blue Card applications. Absent judicial precedent or official administrative guidance, this matter requires clarification.
1.Article 33k contains identical amendments regarding secured accommodation requirements for EU Blue Card holders as those applicable to UWRP holders.
2.Prior to these amendments, the procedure for EU Blue Card holders to change employers lacked clarity. Parliament has now adopted two new paragraphs that clarify the required steps: only a new employment contract and declaration ofwork conditions are necessary.