Bulgaria continues to attract foreign entrepreneurs and companies looking for a strategic step within the European Union and Schengen area. One of the most preferred pathways for non-EU citizens to establish a presence and potentially relocate to Bulgaria is through the registration of a Trade Representative Office (TRO) of a foreign company. While this procedure remains as one of the most attractive, recent legal changes have introduced new legal requirements, which businesses must consider before proceeding.
In this article, we will outline the updated framework, explain the opportunities it still presents, and offer guidance for those who are planning to move forward with registering a Trade Representative Office in Bulgaria.
What is a Trade Representative Office (TRO)?
A Trade Representative Office (TRO) is a non-commercial representation of a foreign company in Bulgaria. It does not have a legal personality and is not allowed to conduct business activities that generate revenue in Bulgaria. Its main purpose is to represent the parent company, conduct market research, promote products or services, and explore local partnerships while finding new clients and opportunities.
While it cannot issue invoices or perform direct sales, a TRO serves as a legitimate basis for obtaining a Type D long-term residence permit for third country citizens, enabling company representatives to legally reside and operate in Bulgaria.
New Legal Requirements for Opening a TRO – 2025 Updates
In June 2025 the Bulgarian parliament approved new requirements which should be fulfilled from the foreign companies in order to be eligible to register a TRO in Bulgaria. Until now, there were only two: the company to be active more than 2 years from the application date and to has no tax obligations. As these requirements still stand, there are some changes, which we will review below:
1. Reduction in the Number of Eligible Representatives
Previously, up to three individuals could be appointed as trade representatives under a single Trade Representative Office in Bulgaria. As of the latest legal amendments, this number has been reduced to two. Which means that only 2 non-EU citizens could apply for a long-term residence permit in Bulgaria on that legal ground.
- Up to 2 persons may now be registered as official trade representatives.
- As you know, Bulgarian is part of the Schengen area and this change reflects the government’s effort to tighten oversight and improve the integrity of the TRO system and also to be compliant with all the Schengen requirements.
2. New Financial Eligibility Criteria
Another significant change relates to the financial requirements of the foreign company. To be eligible to open a TRO in Bulgaria, the foreign company must now demonstrate not only that it was active for the last 2 year, but also stable business operations, proven by specific financial metrics:
- Minimum annual turnover of BGN 100,000 (approx. €51,000) for each of the last two calendar years prior to the application.
- The turnover must be proven by audited financial statements or other verifiable official documents and there could be checks from our authorities using their international connections.
These requirements aim to ensure that only serious, financially stable companies can benefit from the TRO mechanism and its related immigration privileges. It is more than logical, if a company wants to open a Trade Representative Office in another country, to be financially stable and has а certain volume of activity in order to seek growth internationally.
Why Do These Changes Matter?
While some may view these updates as stricter, they also enhance the credibility and security of the TRO procedure. For genuine companies seeking to expand their footprint in Europe, these criteria are entirely reasonable and still offer significant benefits:
- EU Market Access: Establishing a Trade Representative Office in Bulgaria is a first step toward entering the EU market and see what opportunities there are. Because as we know, there are many.
- Relocation Opportunity: The TRO route remains one of the most accessible legal grounds for non-EU citizens to obtain long-term residence in Bulgaria, but with these changes, there would be certainty for the Bulgarian authorities the representatives want to search for business niches in the foreign company’s scope.
- Tax and Business Environment: Bulgaria continues to offer one of the lowest corporate tax rates (10%) and an affordable cost of living, making it attractive for foreign professionals and businesses alike.
Are These Changes Valid for Already Registered TRO?
The brief answer is “yes”, but there would be a 2 years delay for already registered Trade Representative Offices. They will have enough time to fit into the new requirements and from 2027 they should be compliant with the current changes.
Brief Explanation of The Process of Setting Up a TRO
Here is an overview of the typical process:
- Document Preparation: Legalized and translated corporate documents of the foreign parent company.
- Registration with the Bulgarian Chamber of Commerce and Industry (BCCI).
- Application for Type D visa and residence permit.
- Appointment of up to 2 trade representatives, compliant with the new rules.
At Legalla.io, we assist clients throughout each step – from documents preparation and collection, legal translations to TRO registration and immigration formalities. We will be there for you step by step with an on spot representation when needed.
Is a TRO Right for You?
If you are a business owner or manager looking to:
- Expand you company’s activity into the EU;
- Explore the Bulgarian or regional Balkan market;
- Relocate legally to an EU country;
- Benefit from a more business-friendly environment, which the Schengen area offers,
then setting up a Trade Representative Office in Bulgaria may be the ideal option for you and your business. This is where we step in. Our legal team offers end-to-end solutions for TRO registration, visa assistance, and compliance with the new requirements. We ensure your application is complete, timely, and compliant with Bulgarian laws.
