Why type D visas to Bulgaria are refused, and how to avoid a refusal

Reasons for refusal

Refusals are most often faced by those applying for a visa on the grounds of “trade representative”. It is no secret that for a long time this basis was a real loophole for everyone wishing to move to Bulgaria: the activity of trade representative offices was not monitored in any way, and the overwhelming majority of them were effectively fictitious, i.e. legally existing but not carrying out any activity and without real transactions for the company. Gradually the requirements for such representative offices began to tighten, but even now quite a few companies offer potential immigrants places in such representative offices. On the one hand, this may be unawareness of the mass refusals of type D visas on this basis; on the other hand, people often want to take the risk themselves, since the trade representative office still remains one of the few options for obtaining a long-term residence permit for those who have not reached retirement age.

Now, however, such organisations are treated far more attentively than before. The activity of representative offices is checked, and those who obtain visas on this basis are interviewed. And if during the interview it turns out that the trade representative has not the slightest idea of what the company does, what his duties are, and who else is registered in the representative office, and cannot answer all the questions, this means that he simply decided to buy a place in the representative office, which is by no means encouraged by the Bulgarian authorities nowadays. The result is a refusal of the type D visa.

At the interview at the consulate people often make a mistake and start getting confused in the terminology, they cannot clearly explain whether they will work for pay or for free. Some frankly start talking about their plans to move to Bulgaria with the whole family, to obtain a permanent residence permit and citizenship, and some are ready to reveal their intention, after Bulgaria, to set off to conquer other EU countries. Naturally, the consulate staff are left in no doubt about the visa applicant’s intentions, and in most cases the visa is refused.

Another frequent reason for refusal of a type D visa is connected not with the applicant’s mistakes but with the activity of the company he represents. Thus, the company must carry out economic activity, and it must have been operating for at least two years. Whereas previously no importance was attached to the fact that the potential representative had no relation to the company, now attention is paid to whether he is an employee of the company and how he is formally engaged with the company at all. In addition, information about him must be entered into the BULSTAT register in good time.

It is extremely undesirable for several representative offices to be registered at the same address, especially if it is the address of a company openly engaged in selling places in trade representative offices (as a rule, the Bulgarian authorities are perfectly well informed about the activities of such firms). Now all these details are carefully checked, and any inconsistencies count against the applicant and may serve as grounds for refusing the visa.

How to avoid refusals?

There is only one way — to comply with all the requirements of the law and not to hope that the consulate staff will turn a blind eye to any discrepancies. Everything must be flawless. The ideal option is to register your own trade representative office on behalf of your own company, which has been operating and paying taxes for at least two years. As an alternative, you can at least conclude a contract with a company so that there is evidence of a connection with it.

It is important to prepare for the interview so as to know all the information about the company and its activities, the general director and the employees well. Of course, there is no need to memorise everyone’s biography, but having a general idea will do no harm. At the interview you should not say too much about your plans to relocate to Bulgaria.

In general, it is worth thinking your words through carefully. It would not be superfluous to prepare for the interview with the help of experienced professionals who know how the interview is conducted and what tricky questions can be expected.

At present, the problems of trade representative offices existing only on paper do not greatly affect those who already hold a long-term residence permit in Bulgaria. But there have been cases of inspections of representative office premises and detailed interviews with representatives about their knowledge of the company, the director, the other representatives and their own duties under the work plan. Sometimes proof of advertising activity and of real transactions over the whole period is required, and the work plan and the company’s power of attorney under which the representative operates are requested. Often the firms selling places do not provide this at all. And proving one’s real work in the representative office is the responsibility of the representative himself and his own risk. If there is evidence that the representative’s work is fictitious, this means that he is staying in the country without grounds, the long-term residence permit is annulled and 72 hours are given to leave. So vigilance will do no one any harm, in order to calmly wait for the status of a permanent residence permit or EU long-term resident status.

The staff of Bulgarian Expert will help you prepare any set of documents and will advise you on matters of the type D visa, the long-term residence permit and citizenship.

The “D” visa is a long-stay visa.

Residence permit in Bulgaria (long-term residence permit)

Trade representative office in Bulgaria