Transition from temporary protection to indefinite humanitarian status in Bulgaria

Obtaining humanitarian status also opens up the possibility of applying for Bulgarian citizenship in the future. This can be done five years after the date the status was granted. At the same time, the identity document must be renewed after three years, since this document will be required when applying for citizenship.

The Bulgarian legislation previously in force did not allow the State Agency for Refugees to consider applications for international protection if the applicant already held temporary protection status. Although such provisions were considered outdated and did not correspond to the current situation, they were applied in practice by administrative bodies and courts.

The legal situation changed following the ruling of the Court of Justice of the European Union of 20 November 2025. The court obliged European Union member states to accept and consider applications for subsidiary protection submitted by displaced persons from Ukraine, regardless of whether they hold temporary protection.

In Bulgaria, subsidiary protection is called “humanitarian status” and is governed by the Law on Asylum and Refugees. Under Article 32, paragraph 3 of the law, this status is equivalent to a permanent residence permit and is granted for an indefinite period.

For Ukrainian citizens with temporary protection, the Bulgarian Helsinki Committee has prepared an official template application for the transition to humanitarian status. The document is available for download at: https://asylum.bg/sites/default/files/ukrainian/doc/obrazec_molba.pdf

The application must be printed, completed and signed in two copies, and then submitted in person at a territorial unit of the State Agency for Refugees.

If the temporary protection registration card lists children under the age of 14, parents submit a single application on their own behalf and on behalf of the children. Minors aged 14 to 18 submit a separate application in person, which must also be signed by at least one of the parents.

Even when an application for humanitarian status has been submitted, persons with temporary protection are required to undergo re-registration after 4 March 2026 and to extend the validity of their temporary protection registration card. Holding a valid card is a mandatory condition for further consideration of the application.

Human rights organisations emphasise that humanitarian status establishes a stable legal connection with Bulgaria and cannot be arbitrarily transferred to another European Union country.

Short trips to other countries are permitted, however extended stays outside Bulgaria, as well as trips to the country of citizenship, may be regarded as grounds for reviewing or revoking humanitarian status.

The application is submitted in person at the territorial units of the State Agency for Refugees in Sofia, the village of Banya in the municipality of Nova Zagora, and the town of Harmanli. If the application is refused consideration or a negative decision is issued, the applicant has the right to appeal it in court.

Applications are expected to begin being accepted around March 2026. The information should appear on the website of the State Agency for Refugees.

Template application:

https://asylum.bg/sites/default/files/ukrainian/doc/obrazec_molba.pdf

Territorial units of the State Agency for Refugees:

Sofia:

• Sofia, Voenna Rampa district, 29 Prof. Ivan Georgov St (formerly 11 Lokomotiv St)

• Sofia, Ovcha Kupel district, 21A Montevideo St

• Sofia, Vrazhdebna district, 270 Botevgradsko Shose Blvd

Banya:

village of Banya, municipality of Nova Zagora, Mineralni Bani area No. 17

Harmanli:

Harmanli, Druzhba residential district No. 23