A formal trade representative office no longer guarantees a long-term residence permit in Bulgaria

The new wave of checks was prompted by the final decision of the Supreme Administrative Court No. 13158 of 17.12.2025, which established that formal registration of a trade representative office is not sufficient grounds for residing in the country.

The decision has become a reference point for the migration authorities and the lower courts.

Analysis of case No. 7876/2025

The case concerned an appeal by a national of North Macedonia who had been granted the right to long-term residence under Art. 24, para. 1, item 6 of the Foreigners in the Republic of Bulgaria Act — as a trade representative of a foreign company.

Following a check carried out by DANS, it was established that:
— the applicant does not know the company’s products;
— he has no information about its clients and partners;
— he is not familiar with the company’s lines of business;
— he is in fact unable to explain the purpose of his presence in Bulgaria.

On the basis of these findings, the “Migration” department at SDVR revoked the residence permit under Art. 40, para. 1, item 3 of the ZChRB — as having been obtained on the basis of incorrect data.

The Supreme Administrative Court upheld the decision. The ruling is final and not subject to appeal.

Key findings of the court

1. Actual activity matters more than registration.
The court pointed out that the purpose of the law is the active promotion of foreign business development in Bulgaria. Registration with the Bulgarian Chamber of Commerce and Industry in itself guarantees nothing.

2. Lack of knowledge is treated as false information.
If a representative cannot explain what the company does and which services it promotes, this is regarded as the provision of inaccurate information when obtaining the long-term residence permit.

3. The burden of proof lies with the foreign national.
If the authority points to the fictitious nature of the activity, it is the applicant who must prove otherwise.

Practical significance

Following this decision, checks by DANS and the migration authorities are being stepped up, a long-term residence permit may be revoked even some time after it was issued, and representative offices that exist only formally are in a zone of increased risk.

How to avoid a refusal or the revocation of a long-term residence permit

1. Confirm genuine business activity:
— contracts or minutes of negotiations;
— business correspondence;
— marketing materials;
— evidence of participation in exhibitions and meetings;
— reports on the work carried out.

2. Know the company’s business:
— the structure of the business;
— products and services;
— sales markets;
— the strategy for entering the Bulgarian market.

3. Ensure an actual presence:
— a real office or coworking space;
— working contact details;
— a website, corporate e-mail;
— expenses for maintaining the representative office.

4. Prepare for inspections in advance and conduct internal audits of your activities.


Bulgaria is entering a stricter stage of oversight of long-term residence permits based on trade representative offices. Those who genuinely run a business and have real activity can defend their status. Those whose representative offices exist only on paper should assess the risks now.