European institutions have opened an investigation into Bulgaria's "golden passport" programme, turning the country's investor-citizenship scheme into the latest test of how far EU member states can sell what is, in effect, Union-wide access.

The move puts Bulgaria in the same category as Malta and Cyprus, whose citizenship-by-investment programmes drew formal infringement procedures and, in Cyprus's case, cancellation after journalistic investigations. Bulgaria, which has run a residence-and-citizenship track for investors since 2009, now faces scrutiny over how it grants nationality — and to whom.

Why do 'golden passports' concern Brussels?

A Bulgarian passport is more than a national document. It confers the right to live, work and travel freely across the European Union, including in the Schengen area. When a member state hands that passport to a wealthy applicant in exchange for investment, critics argue, it effectively transfers EU citizenship rights without any meaningful test of attachment to the country.

European institutions — the Commission and the European Parliament chief among them — have pressed this point for years. Their stated worries include money laundering, security vetting gaps and the risk that sanctioned or criminal figures could buy their way into the bloc.

The Parliament has previously called for the phased-out abolition of all investor-citizenship schemes in the Union. The Commission has likewise taken the position that the "genuine link" requirement of EU law sits uneasily with passports sold for fixed sums.

What does the investigation change for investors?

For now, the practical question applicants will ask is what this means for pending and future files. Investigations of this kind typically precede one of three outcomes: tightened national rules, an infringement procedure before the Court of Justice of the EU, or voluntary suspension of the programme — the route Cyprus ultimately took in 2020 after its scheme was exposed in an undercover video investigation.

Bulgaria's route to citizenship through investment has historically required substantial, documented investment in the economy, with naturalisation available on an accelerated basis compared with the ordinary residence track. Applicants currently in the pipeline should track announcements from the Bulgarian Ministry of Justice and the European Commission's justice and home affairs dockets rather than rely on intermediaries' marketing.

No deadline for a decision has been announced. Anyone weighing an application should treat the programme's terms as unstable until the European institutions conclude their work.

Who is affected?

Three groups watch this file closely:

• Applicants and their families — those mid-process face the widest gap between what agents promise and what regulators may allow.
• Bulgarian authorities — Sofia must defend national competence over nationality law against Brussels' argument that EU citizenship rights are at stake.
• The wider investment-migration industry — each investigation narrows the map of EU programmes still open for business.

A slow squeeze on a shrinking market

The European trend is unambiguous. Cyprus cancelled its scheme outright. Malta's replacement programme is the subject of a Court of Justice case that could set a binding precedent for every member state. Bulgaria's investigation fits the pattern: Brussels cannot tell a member state whom to naturalise, but it can make selling passports legally expensive.

For readers of Passport File, the signal is straightforward. Investor citizenship inside the European Union is contracting programme by programme, and Bulgaria is the current frontier of that contraction. Official statements from the European Commission and the Bulgarian government — not promoters — are the only reliable guide to what remains open, on what terms, and for how long.