Temporary Protection: New Rules for 2026

Bulgaria is changing the rules for extending temporary protection: what awaits Ukrainians liable for military service and what alternatives are there?

Bulgaria is introducing new conditions for reissuing temporary protection documents for citizens of Ukraine. In certain cases, obtaining a new registration card may now depend on proof that military obligations in Ukraine are being complied with.

Does this mean that Ukrainians liable for military service may lose the ability to live in Bulgaria legally? And can a long-term residence permit be obtained instead of temporary protection? 

Let us look at what has actually changed, who may be affected by the new requirements and why it is worth considering alternative ways of legalisation already now.

What changed on 4 November 2026?

The Council of Ministers of Bulgaria adopted Decision No. 834, which amended the procedure for issuing registration cards to foreigners with temporary protection. The document provides for two main changes.

• The validity of registration cards that previously expired on 4 March 2027 has been extended until 30 April 2027.

• Until 4 March 2028 — this is the period provided for new temporary protection registration cards.

However, the most significant change concerns not the deadlines, but the conditions for issuing the new documents.

Point 5 of the decision now contains a provision under which a new registration card may be issued upon submission of evidence that the applicant is complying with their military obligations in Ukraine — where such a requirement is applicable.

This means that when reissuing documents, certain categories of citizens may face additional questions and difficulties.

Who will be affected by the new requirements?

The changes are primarily a concern for Ukrainian men who, under Ukrainian law, are liable for military service.

But here important legal particularities must be taken into account.

The Bulgarian decision itself does not state that absolutely every man is obliged to submit a document on exemption from mobilisation. The wording used is “когато е приложимо” — “where applicable”.

In addition, a substantial exception is provided at European Union level.

Council of the EU Decision 2026/1912, taking into account the official corrigendum of 5 August 2026, excludes from the new restriction persons who held temporary protection in the relevant EU country no later than 4 August 2026 and have continuously maintained that status after that date. 

Two situations therefore need to be distinguished:

• Ukrainians who already had temporary protection and continuously maintain it in Bulgaria.

• Citizens who are applying for temporary protection for the first time or arranging it after an interruption.

For the second category, the new requirements may have considerably more serious consequences.

At the same time, an important practical question remains: exactly how the Bulgarian authorities will apply the condition on military obligations when reissuing cards to persons who already hold protection, taking into account the exception established by EU law.

It cannot be automatically assumed that the absence of a document on exemption from military service means loss of status. But the new requirement should not be ignored either.

A long-term residence permit in Bulgaria — a possible alternative to temporary protection

Against the background of the new rules, the question of switching from temporary protection to an ordinary long-term residence permit is becoming increasingly relevant.

An important difference: as of November 2026, the general rules for obtaining a long-term residence permit in Bulgaria do not provide for a universal requirement to confirm exemption from military service or mobilisation in Ukraine. 

The Law on Foreigners in the Republic of Bulgaria (ЗЧРБ) establishes independent grounds for obtaining a long-term residence permit. Depending on the procedure chosen, the lawfulness of the ground for residence, financial means, housing, medical insurance and other conditions provided for by law are checked.

At the same time, the requirements for individual categories of applicants may differ. For example, the grounds for obtaining a long-term residence permit, subject to the established conditions, may be:

• employment with a Bulgarian company;

• obtaining an EU Blue Card for highly qualified specialists;

• entrepreneurial or other activity permitted by law;

• family reunification;

• the status of a pensioner with sufficient means;

• other special grounds provided for by Bulgarian legislation.

However, having a company, income or real estate does not in itself always give the right to a long-term residence permit. Separate legal requirements exist for each ground.

It must also be taken into account that obtaining an initial long-term residence permit is in many cases linked to obtaining a type D visa. The possibility of changing status directly in Bulgaria or obtaining a type D visa in a country other than that of your citizenship should be checked individually.

The main advantage of a long-term residence permit is that it is an independent legal regime of stay, which does not depend on the annual extension of the EU-wide temporary protection mechanism. 

But to keep the long-term residence permit, you must continue to meet the requirements of the chosen ground.

And what if the solution is to be found in another EU country?

You should not limit your search for options to Bulgaria alone.

Other EU countries have their own national immigration programmes, which in some cases may be more suitable for a particular person or family.

For example, there are programmes for remote professionals, entrepreneurs, highly qualified workers, financially independent persons and family members of foreign residents.

Sometimes an unexpected solution may be to obtain a long-term residence permit in another EU country, even if the person has already been living in Bulgaria under temporary protection for several years. 

Such opportunities are particularly interesting for Ukrainians who work remotely, have their own business, receive a stable income from abroad or have family grounds for legalisation.

However, you need to understand that the rules differ from country to country. Some states allow applications to be filed directly from their territory, others require a consular procedure. The possibility of keeping temporary protection in Bulgaria alongside a new status must also be assessed separately.

And one more essential point: an ordinary long-term residence permit of one Schengen country does not automatically grant the right to live or work permanently in another country.

The choice of country and immigration programme must therefore take into account not only the possibility of obtaining the document, but also the person’s actual plans for residence, work and family.

Why you should not wait until April 2027

Although the validity of existing cards has been extended, the time available to prepare an alternative solution may turn out to be limited.

Switching to another ground of stay sometimes requires advance preparation, proof of income, arranging employment or corporate relations, as well as going through consular procedures.

In addition, changes in European migration legislation show that the rules of temporary protection continue to evolve.

The Council of the EU has already recommended that states create opportunities for a gradual transition of Ukrainians from temporary protection to other lawful grounds of residence — in particular, those related to work, study and family circumstances.

It is therefore wiser to check the possible options in advance than to face the need to change status urgently after problems with documents arise.

Bulgarian Expert: we will help you find a lawful way out even in a difficult situation

If you live in Bulgaria under temporary protection and are concerned about the new requirements, do not rush to conclude that you no longer have the possibility to stay in the European Union.

Every situation is individual. Even if one option for legalisation turns out to be unavailable, there may be other lawful solutions that you are not yet aware of.

The specialists of Bulgarian Expert will carry out an individual analysis of your situation, check the possible grounds for obtaining a long-term residence permit in Bulgaria and consider alternative immigration programmes in other EU countries.

We will help you assess the risks, identify a suitable legal path and prepare a strategy for further legalisation, taking into account your status, income, work, business and family circumstances.

Do not wait until the question of maintaining lawful stay becomes urgent. Get in touch for a consultation now — we will help you find a way out. 

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