Dual citizenship of Ukraine and Romania or Bulgaria in 2026: what the multiple citizenship law changed

Since 16 January 2026, Ukraine has recognised multiple citizenship, and since 12 May 2026, Romania and Bulgaria have been on the list of states with which dual citizenship of Ukraine is lawful. A Romanian or Bulgarian passport is the passport of an EU citizen: the right to live, work and study in 27 EU countries — and your Ukrainian passport stays with you.

The window is open now: dossiers based on ancestry are filed without renouncing Ukrainian citizenship, and the B1 certificate for Romania can be submitted later, until 14 March 2027. Write to us — we will check your eligibility against documents and archives free of charge, and we handle the dossier and the case through to the passport.

In brief. Dual citizenship of Ukraine and Romania or Bulgaria has been lawful since 12.05.2026: Art. 5-1 of the Law of Ukraine “On Citizenship of Ukraine” (Law No. 4502-IX, in force since 16.01.2026) recognises the citizenship of states on the Cabinet of Ministers’ list, and Romania and Bulgaria were added to it by Resolution No. 589. You do not need to renounce Ukrainian citizenship (Art. 18); for Ukraine, you remain its citizen (Art. 2). Romania and Bulgaria do not require you to give up Ukrainian citizenship.

Is dual citizenship allowed in Ukraine in 2026?

Yes, since 16 January 2026: Law No. 4502-IX added Article 5-1 to the Law “On Citizenship of Ukraine”; its para. 6 recognises the citizenship of states whose citizens acquire Ukrainian citizenship under a simplified procedure. The list is approved by the Cabinet of Ministers — Romania and Bulgaria have been on it since 12 May 2026.

Multiple citizenship means that a person holds the citizenship of two or more states at the same time (Art. 1). Previously, an adult’s second citizenship was a ground for losing Ukrainian citizenship; now 4 rules apply:

• Recognition — Ukraine recognises a second citizenship of a state on the list (Art. 5-1, para. 6).

• Renunciation — renouncing Ukrainian citizenship is not required (Art. 18).

• Loss — a voluntarily acquired second citizenship leads to the loss of Ukrainian citizenship only for an aggressor state and for states not on the list (Art. 19, Part 1, para. 1).

• Status in Ukraine — in legal relations with Ukraine, you are only its citizen (Art. 2, para. 1).

The right to Romanian or Bulgarian citizenship is proven by documents — and we take that right through to the passport. The decision is made by the authority: the outcome cannot be guaranteed, but the dossier can be prepared so that it raises no questions. Timelines, fees and the working procedure are set out in the contract.

With which countries does Ukraine recognise dual citizenship?

With the 34 states on the Cabinet of Ministers’ list as of 13.10.2026. It includes all 27 EU countries, Romania and Bulgaria among them, as well as the United Kingdom, Iceland, Norway, Switzerland, Canada, the USA and Moldova.

The first list was Resolution No. 1412 of 05.11.2025 (5 states); Romania and Bulgaria were added by Resolution No. 589, in force since 12.05.2026, and Moldova by No. 826 of 24.06.2026. Russia and Belarus are not on the list.

For families with roots, the path to an EU passport is by descent:

• Romania — former citizens and their descendants up to the third degree (Art. 11 of Law No. 21/1991): most often families from the Chernivtsi and Odesa regions.

• Bulgaria — descendants of a Bulgarian up to the third degree (Art. 15 of the Bulgarian Citizenship Act): most often families from the south of the Odesa and Zaporizhzhia regions.

Do you have to renounce Ukrainian citizenship to get a Romanian or Bulgarian passport?

No. Neither Romania nor Bulgaria requires renunciation, and Ukraine does not require you to give up your citizenship if the second citizenship is that of a state on the list (Art. 18); Romania and Bulgaria have been on it since 12.05.2026.

• Romania — Arts. 10 and 11 of Law No. 21/1991 grant citizenship with the option to keep a foreign citizenship and residence abroad.

• Bulgaria — the Constitution provides a simplified procedure for persons of Bulgarian origin (Art. 25, Part 2), and Art. 15, Part 1 of the Bulgarian Citizenship Act (BCA) exempts them from the condition of Art. 12, Part 1, item 6 — renouncing their previous citizenship.

For Bulgaria, as for Ukraine, a citizen who holds another citizenship is only its citizen (Art. 3 BCA).

A ground based on ancestry is documented origin, not a waiting period: once the ground exists, the application is filed straight away.

Not sure which country you are eligible for? Write to us. We will check your line of descent free of charge and order any missing links under contract.

How do you get a Romanian or Bulgarian passport by descent, and how long does it take?

A passport by descent takes 6 steps: in Romania, the ANC opinion takes up to 2 years plus up to 6 more months to verify documents (Art. 15, Parts 10 and 11 of Law No. 21/1991); in Bulgaria, the Minister of Justice’s proposal takes up to 9 months (Art. 35, Part 1, item 2 BCA):

1. Eligibility check — against documents and archives, free of charge.

2. Choice of country — Romania under Art. 11 or Bulgaria under Art. 15.

3. Dossier — line of descent, translation, apostille for Romania.

4. Filing — with the ANC or a Romanian consulate; in Bulgaria — in person or through a lawyer.

5. Review — in Romania up to 2 years plus up to 6 months, in Bulgaria up to 9 months.

6. Two passports — oath or decree; the Ukrainian passport stays.

In Romania, applications are filed with the ANC or at a consulate (Art. 13), with biometric data collected (Art. 13²); the B1 certificate can be submitted until 14.03.2027 (OUG No. 16/2026). The first step: “Romanian citizenship for Ukrainians: where to start the eligibility check”.

In Bulgaria, filing is in person, with an interview, or through a lawyer, with identity verification and an interview within 6 months after the documents are accepted; citizenship is granted by decree of the President (Art. 36 BCA). In detail: “Bulgarian citizenship by origin in 2026: language, timelines and procedure”.

You already have a Romanian or Bulgarian passport: what should you do with your Ukrainian passport?

Keep it: an EU passport of a state on the list is not among the grounds for losing Ukrainian citizenship (Art. 19, Part 1, para. 1), and for Ukraine you are its citizen (Art. 2, para. 1). What to do now — 3 steps:

1. Check the dates — obtained before 12.05.2026: loss is not automatic; citizenship ends only from the date of a decree of the President of Ukraine (Art. 19, Part 3); submissions made before 16.01.2026 are considered under the previous procedure (Section II, para. 2 of Law No. 4502-IX).

2. Check your position — persons holding the citizenship of another state are not admitted to the civil service (Art. 19, Part 2, para. 6 of the Law “On Civil Service”), and for a civil servant a second citizenship is a ground for ending service (Art. 84, Part 1, para. 2); Law No. 4502-IX does not introduce a duty to report a second citizenship.

3. File for the family — we check the eligibility of parents, brothers and sisters along the same line of descent using the documents already collected.

The case is still pending and a request for documents has arrived: the ANC allows up to 4 months to supplement the file (Art. 15¹, Part 3 of Law No. 21/1991), the Bulgarian Minister of Justice — 14 days (Art. 29, Part 4 BCA); we close the gaps through archives — “Archives for Romanian citizenship”.

Already have an EU passport, or received a request? Write to us. We will check the dates and your family’s eligibility free of charge, and prepare the reply to the authority on time under contract.

How does Alliance Consulting handle Romanian or Bulgarian citizenship and a residence permit for the duration of the case?

For 4 years, Alliance Consulting has been handling clients’ cases in Romania under a contract that sets out timelines, fees and the working procedure; the company’s licences are publicly available on the website. Alliance is responsible for strategy, the bank, financial monitoring and coordination; all documents are prepared by a lawyer licensed in the European Union, and accounting by audit firms.

We handle a Romanian case through to the oath, and a Bulgarian one — together with a lawyer in Sofia — through to the decree. While the ANC reviews the case, temporary protection remains in force until 4 March 2028 (EU Council decision 2026/1912), and your own residence permit gives you the right to live in Romania after it ends.

For Ukrainian citizens under temporary protection, the ground is “four elements and the result”: an SRL company, an apartment owned by the company, official rental income, an employment contract with your own company — and a permit from the General Inspectorate for Immigration (IGI), about 4 months. A separate contract: “Residence permit in Romania for Ukrainians through a company and real estate”.

With an EU passport, a residence permit is not needed — an apartment by the sea in a completed building with a 30 % down payment, for yourself or your family, is selected by Armonia, our real estate agency: a notarised sale and purchase agreement, the balance over 36 months interest-free from the apartment owner, no bank loan needed.

Armonia shows the properties. Alliance protects the money and builds the structure. You take part in the transaction in person, by power of attorney, or through Alliance’s management company under the client’s power of attorney.

How can you check your eligibility for dual citizenship with Romania or Bulgaria free of charge?

Write to us: under Alliance’s support terms as of 13.10.2026, the eligibility check is free — a reply within 1 working day, a written opinion within 5 working days from a complete set of documents, a conversation of up to 30 minutes.

We check against documents and archives: Romania (Art. 11) or Bulgaria (Art. 15), and which links are missing; if you already have an EU passport, we check the dates and your family’s eligibility.

If you need a residence permit for the duration of the case, we will add a calculation of the route through your own company and a free selection of 3–5 apartments within your budget, with the down payment and monthly payment calculated.

The check is free and places you under no obligation.

Sources

• Закон України № 4502-IX «Про внесення змін до деяких законів України щодо забезпечення реалізації права на набуття та збереження громадянства України» — ст. 1, 2, 5-1, 18, 19 Закону «Про громадянство України», розд. II — of 18.06.2025, in force since 16.01.2026; Verkhovna Rada of Ukraine

• Постанова КМУ № 589 «Про внесення змін до переліку держав, громадяни (піддані) яких набувають громадянство України у спрощеному порядку» — 08.05.2026, in force since 12.05.2026; Cabinet of Ministers of Ukraine

• ДМС: перелік держав, громадяни яких набувають громадянство України у спрощеному порядку — as amended by Resolutions No. 589 and No. 826, checked on 13.10.2026; State Migration Service of Ukraine

• Legea cetățeniei române nr. 21/1991, republicată — ст. 10, 11, 13, 13², 15, 15¹, 20 — current version; Portal Legislativ

• Закон за българското гражданство — ст. 3, 12, 15, 17, 29, 35, 36 — as amended, State Gazette (DV) No. 55 of 16.06.2026; Министерство на правосъдието

• Council Implementing Decision (EU) 2026/1912 — extension of temporary protection until 04.03.2028 — 30.07.2026, in force since 05.08.2026

Author: Sergey Valentinovich Kononov, Head of Alliance Consulting. Published: 17.10.2026. Updated: 17.10.2026.

Checked as of 14.10.2026. Legal points, amounts and timelines are current as of this date; the page is updated when they change.

Sergey Valentinovich Kononov is the head of the consulting company Alliance Consulting (Constanța, Năvodari). He has more than 30 years of management experience; the company has run a licensed practice in Romania for four years and supports clients from the first consultation to the issue of documents. The company’s licences and documents are publicly available on the website.