Romanian or Bulgarian passport: what to choose in 2026

What the two routes share

Romania and Bulgaria have been members of the European Union since 2007. Since 1 January 2025 both countries have been full members of the Schengen Area on all borders, including land borders. A citizen of either country moves freely across 29 Schengen states, chooses any EU jurisdiction for permanent residence, opens accounts in European banks without visa restrictions, and passes citizenship to children by birth.

Visa-free travel is almost identical for the two passports: the Romanian one has 178 destinations (Henley index, 2026); the Bulgarian one is at a comparable level with minimal differences. The USA requires a visa from both countries. Canada, Australia and most countries of Asia and Latin America treat both passports equally. For comparison: a citizen of Ukraine has visa-free entry to around 147 countries, of Russia around 125, of Belarus around 95. EU citizenship removes the 90/180 rule entirely.

Where the passports diverge in 2026

The eurozone: the key shift of 2026. Bulgaria joined the eurozone on 1 January 2026, becoming the 21st member of the monetary union. Fixed rate: 1 euro = 1.95583 Bulgarian leva. A citizen and resident of Bulgaria works directly in euros: account, salary, lending, property, all without currency risk. Romania, according to statements by its leadership, is looking at a horizon of 3–4 years to meet the criteria, with a target window of 2029–2030. Until then the Romanian leu remains an independent currency.

Taxes: a serious divergence after the changes of 2026. Bulgaria is currently more tax-efficient at the start: 10% corporate tax and 5% dividend tax, one of the lowest combinations in the European Union. Romania raised its dividend tax from 10% to 16% on 1 January 2026, which increased the cost of extracting profit through a standard SRL. The 1% micro-enterprise with turnover up to 100 000 euros remains a competitive instrument for small business. Romania’s strength lies not in the headline tax rates but in strategic coherence: business plus property plus citizenship in a single structure. Rates are given as of June 2026: over the past two years they have changed in both countries, so we confirm the values current on the date of your enquiry at the consultation.

Naturalisation timeline. The standard path in Romania: 8 years of continuous lawful residence (5 years if married to a citizen). In Bulgaria, Article 12 of the Citizenship Act requires 5 years of permanent residence. Permanent residence is granted after 5 years of continuous residence. The practical result: around 10 years in Bulgaria. On paper Bulgaria looks faster, but on the standard route without Bulgarian roots Romania in fact offers the shorter path to a passport.

The language barrier. From March 2026 Romania requires a mandatory B1-level Romanian language certificate for most categories of naturalisation applicants. Romanian is a Romance language related to Italian and Spanish; a basic level is reached in 6–12 months of structured preparation. Bulgarian is a Slavic language written in Cyrillic, closer in logic for Russian speakers, but the exam includes, besides the language, a test on Bulgarian history. The required level is A2–B1.

Investment programmes. Bulgaria’s fast-track citizenship-by-investment route (1 million euros over 2 years) was abolished in 2022. The investment path is now the standard one: an investment of 512 000 euros plus 5 years of permanent residence. In Romania a direct programme of citizenship through investment has never existed. In both countries property works not as a basis for an immediate passport but as an asset that strengthens the residency case.

The property market and business environment. Romania is larger in the size of its economy, in the diversity of property transactions and in the availability of legal structures. The Black Sea (Constanța, Mamaia, Faleza Nord) is a premium location with a clear economics of seasonal letting. Bulgaria is more compact, with a lower entry threshold in the resort segment (Burgas, Varna, Nesebar), but also with a narrower infrastructure of professional support for foreign owners.

Comparison across 11 parameters

Which passport for which goal

There is no strict “better or worse” hierarchy between the two passports. There is a match between the route and the family’s strategy. In 2026 the emphasis has shifted, and this needs to be taken into account when choosing.

What to do if a mistake has already been made

Some clients come to Alliance not at the start, but after a first failed attempt. They filed documents in Bulgaria without proof of their language level, received a refusal, and the repeat filing is under heightened scrutiny. They entered Romania through a cheap company scheme with no real activity, the immigration service refused to renew the residence permit, and the years of residency were not counted. They chose the descent route without a complete documentary base, and the case drags on without movement. They made an investment contribution without clearing it with the bank, the account was blocked, and the funds are stuck. They failed to account for the 2026 tax increase when planning dividend distributions and paid more than planned.

Every such situation can be resolved. The Alliance legal department takes on a case at any stage: rebuilding the evidence base, switching to the optimal route, defence before the immigration services of both countries, unblocking bank accounts, revising the tax structure for the new 2026 legislation, restoring the route to citizenship. The sooner the situation is handed over, the higher the chance of not losing years.

The role of Alliance

Alliance is a consulting company with four years of work with foreign clients in three areas: property in Romania under the Armonia brand, Romanian citizenship, and Bulgarian citizenship. This is a rare position on the market: running both citizenship routes at once, with no commercial preference for one country over the other. The strategy is chosen for the client, not for the product. After the tax changes of 2026 the right choice of country and structure has become especially important: the tax difference between Romania and Bulgaria for business has become tangible.

Alliance has two products: full support for a property transaction in Romania, and obtaining EU residence or citizenship (Romanian or Bulgarian). These products can be taken separately, but together they work more strongly, because they are built around a single family strategy.

How this comparison was compiled. The material is based on: the current versions of the Romanian and Bulgarian citizenship laws, the tax legislation of both countries as of June 2026, decisions of the Council of the EU on the eurozone and Schengen, and Alliance’s practice with clients in both jurisdictions. Tax rates and naturalisation timelines are given as of 2026; the sources are listed at the end of the article.

Questions and answers