Bulgaria is considering an important change to the rules on residence permit renewal. The National Assembly is considering Bill № 52-602-01-29, which introduces a new principle: renewing certain residence permits would require actual presence in Bulgaria as well as retention of the original residence ground. Online, the proposal is already being called the “183-day rule” But that’s not quite the exact wording. We examined the bill itself and explain how long people would need to stay in Bulgaria, who would be affected, who is exempt and why the rule for permanent residence is a separate provision.
The main thing: The bill does not introduce one “183 days for everyone” rule. For some residence permit holders, it proposes presence for at least half of the previous authorised residence period, with specified exceptions.
What exactly does the bill say?
The proposal would add a new paragraph 14 to Article 26 of the Foreigners Act. Under the draft, renewal under Article 24(1) would be refused if the foreign national had spent less than half of the previous authorised residence period in Bulgaria. The draft expressly provides exceptions for people granted residence under Article 24(1), items 7, 10, 13 and 17–21 In other words, if the rule is adopted as currently drafted, insufficient actual stay will be a separate ground for refusing extension for those categories that are subject to the new requirement.
Why “183 days” is not an accurate description
For ordinary residence permits, the bill does not impose a fixed requirement of exactly 183 days in Bulgaria. It uses a different formula: at least half of the previous authorised residence period. For example, a permit issued for 12 months would require presence in Bulgaria for at least half that period; a six-month permit would require at least three months. For another permit length, half of that authorised period would be calculated. It is therefore more accurate to speak not of a “183-day law”, but of half of the previous authorised residence period.
How this can work in practice
Suppose a foreign national receives a one-year residence permit but lives in another country and only visits Bulgaria occasionally — for example, for a total of two or three months. If the proposal takes effect and that residence ground is not exempt, the actual time spent in Bulgaria would matter at renewal. The draft provides for refusal if presence was less than half of the previous authorised period. Therefore, the change is particularly important for foreigners who have a Bulgarian residence permit but who live outside the country for most of the year.
The rule does not apply to all holders of a residence permit
This is one of the most important details of the bill. The half-period rule would not apply to people granted residence under Article 24(1), items 7, 10, 13 and 17–21. It is therefore incorrect to say that “all Bulgarian residence permit holders must now live here for more than six months”. the exact ground under Article 24 on which residence was granted, before determining whether the proposed requirement applies to a particular person.
What will happen to trade representatives
For people whose residence is based on trade representation this is particularly important. If the particular residence ground is not among the bill’s exceptions, renewals after the provision takes effect would depend both on retention of that ground and actual presence in Bulgaria. Trade representatives who spend most of the year in another country should therefore monitor the final wording closely.
What about the pensioners?
Do not draw conclusions from the general half-period rule alone. The bill expressly exempts several grounds under Article 24. You must therefore check the specific item of Article 24 under which the permit was issued. First identify the legal residence ground, then determine whether the proposed requirement applies.
Where did “six months and one day” come from?
The same bill does indeed contain language “6 months and one day” But it falls into another category – permanent residence. The draft provides a separate ground for terminating permanent residence if the holder has not spent at least 6 months and 1 day Therefore, it is wrong to transfer this figure to a regular residence permit.
Temporary and permanent residence: different rules
For ordinary residence permit under article 24: check whether the person was in Bulgaria for at least half of the previous authorised period, and whether their residence ground is exempt. For permanent residence: the bill proposes a separate requirement of at least six months and one day in Bulgaria during the previous calendar year. These are two different rules and must not be confused.
What about long-term residence?
Long-term residence must not automatically be equated with either an ordinary residence permit or permanent residence. The bill separately provides for loss of long-term residence following absence from EU member states for 12 consecutive months, subject to the exceptions in its text. Saying that “all foreigners now need 183 days in Bulgaria” oversimplifies the proposals.
How would actual presence be counted?
This is a key practical question. The bill establishes the principle of presence in Bulgaria for at least half of the previous authorised period, but the cited provision does not set out a detailed mechanism for counting days and proving presence. After adoption, both the final wording and the Ministry of Interior’s implementation practice will matter.
Is the law in force?
So far, it’s a bill, not a rule that’s in force. Bill No. 52-602-01-29 was submitted to the National Assembly by the Council of Ministers on 28 July 2026. This is stated in the document itself. The proposed rule cannot yet be treated as an existing requirement applying automatically to current permits. The text may also change during the parliamentary procedure.
Do we have to go back to Bulgaria now?
There is currently no reason to change plans solely because of reports about a “new 183-day rule”. Monitor the final wording, commencement date and implementation practice. A particularly important issue is how new requirements would apply to people whose current permits were issued before the changes take effect.
What should residence permit holders do now?
First identify the exact residence ground under Article 24 of the Foreigners Act. Then check whether it falls within the draft’s exceptions. Those who spend most of the year outside Bulgaria and are not exempt should follow the bill’s progress particularly closely.
The key points
The draft does not establish a single rule for “183 days for all holders of a residence permit”. A rule is proposed for some holders of a regular residence permit not less than half of the previous authorized period of stay. Certain residence grounds would be exempt A separate requirement is proposed for permanent residence: 6 months and 1 day in Bulgaria for the previous calendar year Separate rules are proposed for long-term residence. Most importantly: This is a draft law, not a rule already in force.
Official source
The material was prepared on the basis of Bill No. 52-602-01-29 amending and supplementing the Aliens Act in the Republic of Bulgaria.
National Assembly of the Republic of Bulgaria — official record for Bill No. 52-602-01-29
“Window to Bulgaria” is following the changes
We are monitoring the bill and changes in Bulgarian immigration law. Once the final text is available, we will explain the new rules separately for each residence ground.
WINDOW TO BULGARIA
Immigration · Legal · Accounting assistance
