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Subject: Draft Ordinance on the terms and procedure for issuing, extending, and revoking a certificate for a high-tech and/or innovative project, called a “Startup Visa”
DEAR SIRS AND MADAMS,
In connection with the public consultation on the Draft Ordinance on the terms and procedure for issuing, extending, and revoking a certificate for a high-tech and/or innovative project, called a “Startup Visa,” we would like to present to your attention:
Opinion of BESCO – Bulgarian Startup Association
on the Draft Ordinance on the terms and procedure for issuing, extending, and revoking a certificate for a high-tech and/or innovative project, called a “Startup Visa”
1. More control should be introduced over the subsequent activities of companies
The procedure described in the ordinance currently provides some control over the activities of applicants, but it can be improved. The “Startup Visa” certificate is indefinite, but the residence permit (Visa D) is temporary and renewed every year. Applicants stay in Bulgaria on the basis of their residence permit, while the “Startup Visa” certificate is only the basis for issuing the residence documents. After 12 months in Bulgaria, applicants prepare an activity report every 6 months, which is reviewed by the Expert Council, and if there is a deviation from the declared activity, the Minister of Economy revokes the certificate, notifies the authorities, and the right of residence is withdrawn.
Our proposal is to add two more scenarios related to the activity report of the companies:
In this way, if they carry out activities different from those declared, fail to submit a report, or provide false information, their “Startup Visa” certificate will be withdrawn and proceedings for revoking their right of residence will begin. This would give us a functioning mechanism that guarantees that, no matter how wide the door to Bulgaria is opened, only those who are genuinely developing a high-tech and/or innovative business and meet the requirements will remain.
2. The portal https://edelivery.egov.bg/ cannot work for the needs of Startup Visa applicants
The “Startup Visa” is a procedure for attracting entrepreneurs who are citizens of countries outside the European Union. These people are not citizens of the Republic of Bulgaria, are not Bulgarian, and do not speak Bulgarian.
The edelivery.egov.bg portal has 5 access options:
a) NSSI personal identification code (PIC). Insured persons in Bulgaria receive a 10-character alphanumeric PIC from the National Social Security Institute (NSSI) personally or through an authorized person, without needing to submit a paper application in advance.
Foreign citizens from third countries are not insured in Bulgaria and it is completely impossible for them to obtain an NSSI PIC.
b) Electronic identifier.
a. NRA PIC. Provided by the National Revenue Agency (NRA) to citizens who have dealings with the Bulgarian NRA. An EGN is required. The NRA PIC is obtained in person, meaning by someone who can physically go to an NRA office or through an authorized representative. A foreign citizen from a non-EU country, who does not yet have a company in Bulgaria and has no right of residence in Bulgaria, cannot obtain an NRA PIC.
b. Borica cloud-based qualified electronic signature. Borica is a company operating in Bulgaria. There are no citizens of countries outside the European Union who have a Borica electronic signature.
c. Evrotrust cloud-based qualified electronic signature. Unlike Borica, Evrotrust has an international business presence, but only in several EU member states and in Macedonia. Perhaps the only possible case is that a Macedonian citizen with an Evrotrust e-signature wants to establish a startup company in Bulgaria. In all other cases, we can say that this access method is also entirely unworkable for citizens of countries that are not members of the European Union, and especially for those who are not Bulgarian citizens.
d. Qualified electronic signature (QES). Following the arguments from the previous two points, foreign citizens again do not have access to this type of service.
The portal proposed by the administration of the Ministry of Economy is accessible exclusively to citizens of the Republic of Bulgaria. The Startup Visa is a service for citizens of countries that are not members of the European Union.
The edelivery.egov.bg portal does not function properly in English. On the English version, pages are only half translated and half remain in Bulgarian. When moving from page to page, it automatically switches back to Bulgarian. Also, a large part of the information in English is not translated and is missing. We consider it extremely inappropriate for this portal even to be proposed as a tool for attracting business and investors, and this shows a serious misunderstanding of business needs.
Bulgaria ranks 61st in the Ease of Doing Business index (behind Macedonia, Romania, Kosovo, Croatia, Belarus, Montenegro, Armenia, and many others), and the use of this portal would further worsen our position in that ranking.
The text in Art. 6(1) should be refined and the phrase “or through the Secure Electronic Delivery System (https://edelivery.egov.bg/)” should be removed.
3. The requirement to collect at least 12 points for an application to be reviewed should be revised
The maximum number of points a company can receive is 17. The Startup Visa is aimed both at recently established companies/projects/teams and those at idea stage. Some of the most valuable companies we could attract are those with a high degree of R&D. For such companies, it may take 1–2 years to attract an investor and then 5–7 or more years before generating sales.
The “Client Network” criterion gives 1 to 3 points depending on proven sales. If the company has not yet generated sales, as is the case for most startups—even Dronamics, of which we as Bulgarians are so proud—then the maximum remaining score is 14 points.
The “Investment” criterion gives 1 to 3 points based on attracted investment from a private equity or venture capital fund operating with funds from European Structural and Investment Funds and/or the European Investment Fund. Without these points, the maximum falls to 11, which is below the required 12.
Any company that has no sales and no investment from a fund operating with European public funds has no chance of even being reviewed. Also, if it is a startup in the service sector with nothing to patent, it loses another 3 points.
4. Art. 6, para. 5, item 6 must be fundamentally reworked
The criteria described in item 6 had been discussed in earlier working conversations as reasons why a company should receive a “fast track” and be directly approved. At present, however, they are criteria on the basis of which a decision is made whether the application should even be reviewed. In this way, the bar is raised to a level that would discourage even the few applicants who might decide to apply in Bulgarian and without a properly designed platform through which to do so.
We attach a comparison of the application criteria in different EU member states. We believe the team of the “Economic Policies” Directorate at the Ministry of Economy has already reviewed all these procedures and is familiar with them, and for us it is interesting why Bulgaria needs criteria many times stricter than any other EU member state.
Our proposal is to introduce a fast track and, more broadly, to move toward an approach where, following the better example of other countries, the evaluation focuses only on:
✔ whether the company has sufficient means to live in Bulgaria for 1 year
✔ whether they are obliged to register a company here
✔ whether they have a project with global market potential
✔ whether they commit to creating new jobs in Bulgaria over the next 5 years
✔ whether they commit to being able to generate at least BGN 500,000 in turnover after 5 years
✔ and a Startup Committee subjectively evaluates their idea
For most countries, it is enough to guarantee that a company will be registered in the country, to show that the team has minimal funds to live on during the first months, and to convince a Startup jury that their idea is innovative. For reasons that are unclear to us, Bulgaria is setting the bar higher than everyone else. Much higher. The country that is at the bottom of all rankings for innovation and business environment. The poorest country in the European Union, with the potential not to reach the standard of living of others by the end of the century. The country that periodically leads the ranking for the fastest-disappearing population on the planet. The country where barely 3% of people have any desire to start a business. This country has decided to create criteria that are higher than anything anyone else would imagine.
We can safely say that if Facebook, Apple, Microsoft, Amazon, and many others had applied in their early days for a Bulgarian Startup Visa, there would have been no way for them to be approved because they would not have met our criteria.
5. The composition of the Expert Commission evaluating candidates must be changed
There are three practices in other countries:
There is no practice where evaluation is carried out by a state body with no startup experience. We treat the proposed Expert Council in the ordinance as such, because more than 70% of its members are civil servants, and two of them have veto power.
There is no practice of deputy ministers evaluating startups. Here we are not only talking about the good practices of other countries, but also about the logic of governance in our own country. Deputy ministers rank 27th in the state hierarchy in Bulgaria. At times they temporarily replace ministers themselves, who rank 11th in the state hierarchy. These are senior public officials who should be dealing with macro-level management of their sectors. Education and the economy are among the sectors facing major reforms in the coming years. Against this background, it is unacceptable for these high-ranking officials to be occupied with evaluating the idea of some Bogdan or Vova from Ukraine and his group of friends. It is possible that, if the procedure works, thousands of applications may come in each year. That means a deputy minister may have to assess dozens of startups every week.
6. The ordinance does not follow EU good practices on access to information and application procedures
There are three ways of applying for a Startup Visa in the European Union:
a) through a dedicated website
b) through an external website (such as www.f6s.com)
c) by sending documents via email
The ordinance provides for the third option, namely sending documents by email to e-docs@mi.government.bg or through the portal https://edelivery.egov.bg/. We believe it is clear why the edelivery.egov.bg portal would be useless for this procedure, leaving only the option of sending documents to the specified email address.
We believe Bulgaria should follow the best practices, not the most mediocre ones. We should strive to stand out when doing something new and to be evaluated as among the best in the world. During the working groups and meetings we proposed the second option—an external platform (F6S)—because the solution is free and can start without delay. After our proposal was rejected, we now propose the best possible solution: a dedicated platform to be built and linked to the domain www.startupvisabulgaria.com, so that the program can be presented at the highest global level.
Here are several examples of good practice from other countries:
Estonia: https://startupestonia.ee/visa
Lithuania: https://startupvisalithuania.com/
Denmark: https://startupdenmark.info/
Italy: http://italiastartupvisa.mise.gov.it/
Malta: https://startupvisamalta.com/
7. Applications should be possible in Bulgarian OR English
At the moment, the ordinance requires applications to be submitted in Bulgarian AND English. This does not follow the good example and practice of other EU member states. The text creates administrative burden and the need for entrepreneurs to seek translators to translate from their language into Bulgarian. This will make the procedure more difficult.
If we look at other EU countries that apply a Startup Visa, we see the following:
There is only one country that requires applications in the official language of the country—Spain. Spanish is an official language in 21 countries in the world and is spoken by nearly half a billion people.
The solution used by all other countries is correct and logical, because the goal is to attract investors and entrepreneurs, not to feed the business of local translation agencies and create additional burden for business. Even in France, one can apply in English without any issue.
Proposal: During the working process, BESCO proposed a solution that would make applications in English possible. Following the better practices of other countries, the Ministry of Economy could certify evaluators who would assess applicants. In this way, applicants could apply to evaluators in English, and only after approval submit documents to the state in Bulgarian, with those documents relating to the approval rather than to the application itself.
8. The criteria for financial forecasts and available capital should be separate
The criterion for financial forecasts and the criterion for available capital are each good on their own, but there is no logical reason why they should be combined into one criterion. In this way, an absurdity is created in which projected growth is equated with how many months of funds the company has in the bank. This is illogical, and we propose that the two criteria be separated and assessed independently.
9. The “Investment” criterion should be broadened
An increasing number of Bulgarian private equity and venture capital funds no longer operate with funds from European Structural and Investment Funds and/or the European Investment Fund. As currently written, the criterion completely excludes a venture capital fund operating with its own funds—which, in fact, is what all funds should eventually become. Today, we are investing public EU funds in funds in order for them to develop the ecosystem and later function entirely with private capital. The logic is not that public money should be spent forever.
Most funds in Europe do not operate with EIF money or European public funds. There are also many investment funds in the US, Asia, and around the world that are far better than European ones. If a startup has received funding from Sequoia Capital (where a Bulgarian is one of the partners), which is one of the largest funds in the world, that startup would not be able to receive points to come to Bulgaria because of this criterion.
If we want Bulgaria to have a functioning Startup Visa, this criterion must be corrected and opened up to funds that are not necessarily tied to European structures.
Conclusion
In conclusion, we express the position that the proposed text of the Ordinance is unworkable. There is no startup company in the world that would want to come to Bulgaria and be able to meet these criteria, and if by chance there is even one such company, it would have to go through such a burdensome procedure that it would be discouraged. We call for the texts to be corrected.
In conclusion, we propose a solution that would work, along with a comparison to the unworkable concept presented by this draft ordinance.
Sincerely,
Dobromir Ivanov
Chairman
BESCO
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