Serving expat and cross-border buyers in Bulgaria

A growing share of the people who look at Bulgarian property do not live in Bulgaria and do not share a country with each other. They are expats: Russian-, Polish- and English-speaking professionals and families who live in Poland, elsewhere in the EU or further away, hold one passport, live under another status, earn in a third currency and want a home, a rental or a second base on the coast or in the mountains. This briefing is about what an agency has to collect and check for such a buyer, and how to make the file clean before the notary.

Start with the buyer's status

The first question decides what the buyer can own. Under the Bulgarian rules described by advisers, citizens of EU and EEA states can buy apartments, houses and land on the same footing as locals. Citizens of other countries can buy apartments and buildings freely, but the Constitution does not let them own land directly. The usual route for a non-EU buyer who wants land is a Bulgarian company that holds it; an international treaty is the other, rarer route. See a law-firm summary of the position and an overview from a practitioner.

Two cautions follow. First, citizenship and residence are different things: a Russian-speaking buyer may hold a non-EU passport while living in Poland or Germany on a residence permit, and for the land rule it is citizenship that counts. Second, a company is not a free pass: whether further limits apply to particular categories of land, such as farmland, forest or border areas, is a question for the buyer's lawyer, not something an agent should answer from memory.

What to collect before you reserve anything

Ask for the same core set from every cross-border buyer, in the same order, and keep copies:

• A valid passport or national ID card, with a Bulgarian translation where the notary requires it.
• A tax or personal number. Foreigners with long-term or permanent residence in Bulgaria receive a Personal Number of a Foreigner (LNCh) that also works as a tax number. A buyer who has neither a Bulgarian personal number nor an LNCh and then owns property is described by advisers as having to register in the BULSTAT register within a few working days of the deed, with a fine for being late. This comes from one adviser's guide, so ask a lawyer to confirm the deadline and the steps for your client.
• Marital status. Notaries tend to ask about it, and property acquired during a marriage is generally treated as joint, so decide early who will be on the deed and who needs to sign. Confirm the exact practice with the notary you will use.
• Proof of where the money comes from, collected before the preliminary contract and not at the notary's door.
• The buyer's contact details in the country where the buyer lives, and the name of the person who will act under a power of attorney, if any.

Source of funds and AML: what applies to you

Real-estate intermediaries are obliged persons under Bulgaria's Measures Against Money Laundering Act, and notaries have duties of their own. In practice that means identifying the client and checking the identity documents, establishing who the beneficial owner is when the buyer is a company, understanding the purpose of the transaction and keeping records. Advisers describe thresholds, expressed in euro since the euro came in, of roughly EUR 15,000 for identifying a beneficial owner and EUR 5,000 for cash. Treat those figures as indicative and read the current text of the Act or ask your compliance adviser. A KPMG note on the 2023 amendments is a good place to start.

Looking ahead, the EU's AML Regulation is described as applying from 10 July 2027 and naming real-estate professionals as obliged entities across the Union. Agencies that build a proper onboarding file now will not have to rebuild it later.

Practical red flags to write into your checklist, for any nationality:

• Funds that come from a third party with no clear link to the buyer, or from a jurisdiction the buyer cannot explain.
• A buyer who will not say where the money was earned, or whose explanation keeps changing.
• A structure with several companies and no clear beneficial owner.
• Pressure to close very fast, to split payments, or to pay in cash.
• A price far from the market with no reason given.

Sanctions screening, done by the book

EU restrictive measures include asset freezes. As the European Commission's guidance explains, a freeze covers economic resources such as real estate, and selling an asset to a listed person is not allowed. That makes screening part of the file: check the buyer, the beneficial owner and any person paying on the buyer's behalf against the current EU lists, record the result, and stop and take advice if there is a match or doubt. See the Commission's guidance note.

Two points keep this fair and workable. A nationality is not a listing: assess each person on their own documents and the facts, never refuse or approve by passport alone. And banks that handle the payment may ask for more documents than you do, so tell Russian-speaking and other cross-border buyers early that proof of funds may be requested twice and that time should be allowed for it. Nothing here is a way around a check; if a check cannot be passed, the deal does not proceed.

Language and paperwork

The notarial deed is in Bulgarian. A buyer who does not read it needs a translator the notary accepts, and documents issued abroad usually need a certified Bulgarian translation. Agree who arranges and pays for the translation in the reservation agreement, so that the deed date does not slip.

A short checklist for your team

• Confirm citizenship and what the buyer wants to own, apartment or land.
• Collect ID, tax number, marital status and proof of funds before reserving.
• Screen the buyer and any payer against sanctions lists and record the date.
• Agree the translator, the notary and the order of signing in writing.
• Tell the buyer which documents the bank may ask for.

Working with D.H. Realting

D.H. Realting is a trilingual (Russian, English, Polish) overseas-property platform. We introduce buyers, including expats who live in one country and look at property in another, and we support the process around the deal. Agencies that handle the transaction locally and would like to be introduced to such buyers can contact us through our partners page.

This briefing is informational only and is not legal, tax or investment advice. Figures and rules are indicative, come from the sources named, and change over time; confirm them with a local lawyer or notary before you rely on them.