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Tsvetkova Bebov & Partners: Advice to Ukrainians in Bulgaria

Tsvetkova Bebov & Partners: Advice to Ukrainians in Bulgaria

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This review was prepared for Ukrainian refugees by the law firm Tsvetkova Bebov & Partners upon request and in coordination with the international legal network Multilaw and Ukrainian law firm Arzinger. The review is as of March 11, 2022, will be updated as relevant, also Ukrainian translations will be added. The review is not a legal advice and is for informational purposes only. For updates, please follow www.multilaw.com and/or www.arzinger.ua

Цей огляд був підготований для українських біженців юридичною фірмою Tsvetkova Bebov & Partners на запит та під координацією міжнародної юридичної мережі Multilaw та української юридичної фірми Арцінгер. Огляд підготований станом на 11 березня 2022 року та буде оновлюватись відповідно, також будуть додаватись українські переклади. Цей огляд не є юридичною консультацією і має лише інформаційний характер. Слідкуйте, будь ласка за оновленнями на www.multilaw.com та/або www.arzinger.ua 

Tsvetkova Bebov & Partners

1. Entering the country

  • Is any mandatory quarantine applied for UA citizens? If yes, please provide details (duration, where to stay, who pays for the stay, any exceptions)?

TBP: People arriving from Ukraine are admitted to the territory of Bulgaria upon presentation of one of the following documents:

  • a valid EU digital COVID-19 vaccination certificate,
  • a valid EU digital COVID-19 recovery certificate,
  • a valid EU digital COVID certificate for conducted testing (a document showing a negative result from a polymerase chain reaction (PCR) test conducted up to 72 hours before entry into the country or a negative result from a rapid antigen test conducted up to 48 hours before entry into the country from the date of sampling entered in the document),
  • a similar or an equivalent document containing the same data as the EU digital COVID certificate (for vaccination/recovery/testing).

People who do not present any of the documents mentioned above are allowed on the territory of Bulgaria and placed under quarantine for 10 days at home or other place of accommodation where the individual has indicated that he/she will reside, with a prescription issued by the director of the relevant regional health inspectorate or his/her deputy authorized by him/her. The stay is covered by the UA citizen. However, there are many local groups of people that provide help and shelter. For more information, please refer to our response to Question 9 below.

The quarantined person may carry out a PCR test to detect COVID-19 or a rapid antigen test not earlier than 72 hours after his/her arrival in Bulgaria. In case of a negative result of the conducted examination, the quarantine of the person shall be considered terminated from the day of registration of the result in the National Information System for Combating COVID-19. PCR testing is widely available at sites across the country, including hospitals and private laboratories. The fee is generally approximately BGN 100 for PCR test and BGN 15 for rapid antigen tests and is fully covered by the UA citizen.

  • Is any visa required for UA citizen to enter the country? If yes, how UA citizen may obtain it under the circumstances?

TBP: UA citizens holding international biometric passports can enter and stay in Bulgaria without a visa for up to 90 days every 6 months.

If UA citizens wish to stay longer in Bulgaria (more than 90 days for every 6 months if they have a biometric passport), they should either (i) request for a protection status due to the current military situation in Ukraine (please refer to our reply to Question No 1.4. below) or (i) obtain a prolonged-term residence permit based on a visa type “D”.

Visa D entitling the UA citizen with the right to reside in Bulgaria up to 180 days is a prerequisite for obtaining a prolonged-term residence permit. In order to obtain a visa type “D”, the UA citizen must be outside the territory of Bulgaria applying in the Bulgarian consulate/ embassy in his/her country of residence. However, on exceptional basis foreign citizens legally residing in a third country other than his/her country of residence may exceptionally apply for visa “D” from that other country (for example Romania) after justifying the reasons for that.

In any case obtaining of visa “D” would require a certificate for clean criminal record which may be issued in Ukraine only. Currently, legislative changes are being considered to facilitate this process but there are none enforced yet. 

The decision for issue of visa D is taken within 35 business days as of the filing of the application.

Based on the visa type “D” issued the UA citizen may apply (before the expiration of the term of visa type “D”) for residing and access to the Bulgarian labor market on any of the most often applied grounds below for prolonged-term residence permit by submitting an application to the Migration Directorate, which has approximately 60-day deadline for a decision.

Unified residence and work permit

Unified residence and work permit is issued to non-EU citizens who apply for a residence permit for the purpose of work employed by a local employer. The permit is issued for a period of three years unless the validity term of the employment contract is less in which case it shall be granted in accordance with the term of the contract.

Intra-corporate transfer

Intra-corporate transfer is a temporary transfer for work or training of a non- EU citizen employed in a company with seat or registered address outside the Republic of Bulgaria, to a company or unit, with seat or registered address on the territory of the Republic of Bulgaria belonging to the same group of companies. The permit is granted solely for transfer of employees occupying the positions of manager, specialist or intern. It is issued for a period of one year. When the term of the employment contract is shorter than one year, the permit is issued for the duration of the contract. The period of validity of the permit may be extended to a maximum of three years for managers and specialists and one year for interns.

European Union Blue Card

A permit for prolonged-term stay and work of the EU Blue Card type may be granted to foreigners who meet the conditions to perform highly qualified work pursuant to Bulgarian legislation, which is proved by a diploma of higher education lasting at least 3 years in the field in which the employee will work. Such Blue card could be issued with validity of up to 4 years. Where the term of the relevant labor contract is shorter, the permit shall be issued for a period equal to the contract term.

To obtain a prolonged-term residence permit, the foreign citizens should present evidence of secured housing, mandatory health insurance, proof of sufficient means of subsistence so that they do not have to resort to the national social assistance system and documents of clean record. These are the general requirements, as for each type of permit there are additional characteristics to be observed, such as documents verifying education and experience of the applicant, documents that should be provided by the employer, etc.. Any social security payments and taxes shall be paid according to the Bulgarian legislation.

Foreigners with prolonged residence permit can enter the territory of Bulgaria without visa for the term of validity of the residence permit.

If an UA citizen does not have an international biometric passport, he/she shall request for a protection status due to the current military situation in Ukraine (please refer to our reply to Question No 1.4. below). It is worth noting that as an exception the application for visa type “D” (without international passport) may be accepted due to humanitarian reasons.

  • Is entry without passport allowed?

TBP: UA citizens can enter Bulgaria without passports only in exceptional situations such as requesting protection status (refugee status, etc.).

  • Shall UA citizen apply for any special status (refugee etc.) right after entering the country, or this can be done later? If yes, what is the further deadline to apply for special status?

TBP: The European Union has agreed on 3 March 2022 to trigger a never-before-used directive to grant temporary protection to UA citizens and people who have made Ukraine their home as well as their family members displaced by the conflict. Non-Ukrainian nationals and stateless people legally residing in Ukraine who cannot return to their country or region of origin, such as asylum seekers or beneficiaries of international protection and their family members, will also be granted protection in the EU. However, others who are legally present in Ukraine for a short-term and are able to return safely to their country of origins will fall outside the scope of this protection. Nevertheless, should be allowed access to the EU to transit prior to returning to their countries of origin.

The temporary protection was announces as granted for the territory of Bulgaria by the Bulgarian Council of Ministers on 9th of March, issued based on theresolution of the Council of the European Union. The resolution of the Council of Ministers is not officially accessible yet. Based on the above any foreign citizens meeting the criteria for temporary protection will be given residence permits to stay inside the EU for at least one year, a period that will be automatically extended by six monthly periods for a maximum of one year. It is worth noting that protection can be claimed in any EU country, not only by the first country reached by the refugee.

The Temporary Protection Directive circumvents the traditionally overburdened asylum procedure and offers a quick and simplified path to access protection across the EU. Besides the legal right to stay inside an EU Member state, temporary protection enables access to the education system, labour market, healthcare, housing, professional assistance and social welfare. UA citizens who fit the requirements for temporary protection may use this option in order to access labor market in Bulgaria immediately.

Other foreigners that do not fall under the resolution of the Council of the European Union, or who entered the territory of Bulgaria with no international biometric passport shall immediately apply for international protection or asylum except in cases where the delay is due to reasons beyond their control.

International protection can secure the foreigners any of the below status:

  • refugee status which shall be granted to a foreigner who for reasons of a well-founded fear of persecution due to his/her race, religion, nationality, political opinion or membership of a specific social group is outside his/her country of origin and who, for those reasons, is unable or unwilling to avail himself/herself of the protection of that country or return thereto, and
  • humanitarian status which shall be granted to a foreigner who is not eligible for refugee status and who does not wish or is unable to receive protection from his/her country of origin as he/she may face a real risk of suffering serious harm.

Any foreigner who was granted refugee status has the rights and responsibilities of a Bulgarian national except for restrictions explicitly provided for by law, and one who has been granted humanitarian status has the rights and obligations of a permanent residence permit holder in the Republic of Bulgaria. For the duration of the procedure the foreigner shall be entitled to receive shelter and food, social welfare allowance, health care, access to medical help and gratuitous medical services according to requirements and procedures applicable to Bulgarian nationals, etc., and if proceedings are not completed within three months of filing the application for international protection due to reasons beyond the foreigner’s control the latter is entitled to access to the labor market.

Asylum is being granted by the President of the Republic of Bulgaria and foreigners who have been granted such have equal rights and obligations as those with a refugee status.

Any foreign citizen who has been granted international protection or asylum are entitled to (i) access the Bulgarian labor market without any permit required (ii) ask to be reunited with his/her family on the territory of the Republic of Bulgaria. The term of the granted international protection or asylum is assessed by the competent state authorities.

2) Stay in the country

  • For how long UA citizen may stay in the country if entered based on visa-free regime without any additional formalities?

TBP: Please refer to our responses to Question No 1.2. and Question No 1.4.

  • Are temporary residency permits available for UA citizens?

TBP: Foreigners can reside in Bulgaria:

  1. short-term - up to 90 days within each 180-day period from the date of entry into the country provided that they have an international biometric Ukrainian passport;
  2. on a prolonged basis - with an authorized period of up to one year, or more if so provided by the applicable law please refer to our responses to Question No 1.2;
  • Are permanent residency permits available for UA citizens?

TBP: Foreigners can reside in Bulgaria:

  • on a long-term basis - where the initial period authorized is 5 years, with a possibility of renewal after the submission of an application - Long-term resident status shall be granted to any foreigner who has legally and continually resided in the territory of the Republic of Bulgaria for 5 years prior to submitting the application for permission to stay on a long-term basis. In most of the cases this regime will not be applicable to the UA citizens.
  • on a permanent basis - where the period authorized is unlimited – it is granted to foreigners of Bulgarian origin; five years after contracting a marriage with a foreigner residing in Bulgaria on a permanent basis, provided that they have legally and continually resided in the territory of Bulgaria for 5 years; who have resided lawfully and continuously within the territory of the Republic of Bulgaria for 5 years immediately prior to the submission of the permanent residence application and, for the said period, have not been away for more than 30 months, etc. In most of the cases this regime will not be applicable to the UA citizens.

Applications are filed at the Migration Directorate.

  • Is refugee status available for UA citizens?

TBP: Please refer to our response to Question No 1.4.

  • Is there any other status except tourism, temporary/permanent residency permit, refugee available for UA citizens? If yes, please briefly describe the options.

TBP: No

3) If UA citizen entered the country based on no visa regime, or based on tourist visa

  • What is the maximum allowed duration of stay in the country?

TBP: UA citizens holding international biometric passports can enter and stay in Bulgaria without a visa for up to 90 days every 180 days

  • Are any formal procedures (registration etc.) required for the stay?

TBP: No

  • Is employment allowed?

TBP: UA citizens holders of international biometric passports but having no visa can be seconded or posted to Bulgaria by their foreign employer for up to 3 months out of every 12 month-period may to perform certain duties without a work permit, on the basis of a one-time registration with the Bulgarian Employment Agency.

UA citizens holders of international biometric passports or short stay visa “C” can also be employed by a local employer in the cases of seasonal work (in the agriculture, forestry and fisheries, hotels and restaurants sectors) up to 90 days on the basis of a one-time registration with the Bulgarian Employment Agency.  

If UA citizens are to be employed for a longer than 3 months period and not for the above reasons they will need to apply for prolonged-term residence permit after obtaining visa type “D” (please refer to our reply to Question No 1.2.) or to be under temporary protection (please refer to our reply to Question No 1.4.) or to apply for international protection or asylum if temporary protection is not applicable to them (please refer to our reply to Question No 1.4.).          UA citizens that enjoy international protection, temporary protection or asylum are entitled to access the Bulgarian labor market without any permit.

  • Is healthcare covered by the hosting state?

TBP: No. In case of a short-term stay and prolonged-term residence permit health contributions are not due.

  • What are main taxes, which shall be paid by UA citizen during the stay?

TBP: Income tax – 10%. This tax is paid by the employer.

Please note that an independent tax analysis is required on a case-by-case bases.

  • What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

TBP: After entering Bulgaria UA citizens may continue working for Ukraine initial employer companies for the period of their legitimate stay in the country. In that case it shall be considered that the more beneficial provisions of the Bulgarian labor code may prevail even though employment will remain governed by the Ukraine law.

Furthermore, it shall be considered that payment of any taxes and social security payments will be subject to the Convention between the governments of the Republic of Bulgaria and of Ukraine for the avoidance of double taxation (hereinafter the “Convention”) and the Treaty between the Republic of Bulgaria and Ukraine on social security (hereinafter the “Treaty”).

According to the Convention remuneration derived by a Ukrainian resident in respect of an employment exercised in Bulgaria shall be taxable only in Ukraine if:

1)     the recipient is present in Bulgaria for a period (or periods) not exceeding a total of 183 days in any 12-month period; and

2)     the remuneration is paid by, or on behalf of, an employer who is not a Bulgarian resident; and

3)     the remuneration is not borne by a permanent establishment or a fixed base which the employer has in Bulgaria.

In order for the above to be applicable, these conditions must be met simultaneously. However, if the work is to be performed in Bulgaria for a longer period then 183 days the UA citizen should be withheld taxes according to the Bulgarian legislation.

As regards to social security, according to the Treaty persons employed in the territory of Ukraine but working on the territory of Bulgaria shall be subject to the Bulgarian social security legislation unless they are sent on a business trip by their employer in Bulgaria to carry out activities for the benefit of that employer in which case, they shall continue to be subject to the Ukrainian legislation for the first 24 months.

However, a case-by-case analysis is required when the employer is a company situated in a country different from Ukraine (a careful review of the specific treaties for avoidance of double taxation (if such are executed) is required).

  • Is it possible to open and use banking account?

TBP: Yes, as far as the UA citizen has a residence permit or refugee status, humanitarian status or is afforded a right of asylum. Otherwise, some of the banks may refuse to open a bank account. And now Ukrainian citizens can use their debit and credit cards Visa or MasterCard within the daily limit set by Ukrainian banks and until the warranty limit for the particular card.

  • What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

TBP: According to the Bulgarian Anti Money Laundering Act when opening a bank account, the banks shall apply customer due diligence measures. Part of those measures is clarifying the source of the funds, which may be done with a declaration of the UA citizen.

  • Is UA driving license accepted? If yes, for how long?

TBP: Driving license issued in another country is valid on the territory of Bulgaria if this country is party to the Convention on Road Traffic (Ukraine is a party to the convention) and the license meets the requirements of Appendix 6 to the Convention or it is translated into Bulgarian by a certified translator whose signature is notary certified. 

UA citizens staying in Bulgaria for more than 1 year can drive in Bulgaria with their UA driving license for 1 year as of the date on which the residence status was issued. After that the UA driving license shall be replaced by a Bulgarian driving license at the Ministry of Interior, Traffic Police (https://www.mvr.bg/opp/en/home).

  • What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

TBP: Document for Civil Liability Insurance in force and Vehicle registration certificate.

Up to 6 months a temporary admission regime with a total relief from import duties is allowed for vehicles which are intended for personal use by individuals established outside the customs territory of the European Union. Following the 6th month, the car must leave the EU or an import procedure must be applied. When the vehicle is an individual’s property intended for personal use only, it could be released for free circulation and exempt from customs duties and VAT upon import if the owner moves his/her usual place of residence from a third country in the EU.

The foreign registration numbers of the vehicle of the EU citizen shall be changed in Traffic Police if the EU citizen is permitted to stay in Bulgaria more than 3 months. Customs import document will be required for the registration procedure.

  • What is required to sell a car brought from Ukraine in your country?

TBP:  If the car has never been registered in Bulgaria it can be transferred with a written agreement. The seller shall provide a receipt for the received payment from the buyer as well as the vehicle registration certificate.

If the car is registered in Bulgaria it can be transferred with an agreement with notary certified signatures of the seller and the buyer. The seller shall provide the following documents to the notary public:

  1. ID document;
  2. Vehicle registration certificate;
  3. Document for concluded Civil Liability Insurance;
  4. Certificate of insurance value of the vehicle. It must be issued by an insurance company
  5. Receipt for paid local tax
  • Are there any special regulations applied to kids under 5yo? At what terms kindergartens are available?

TBP: No. Kindergartens are not available for short-term stay in Bulgaria.  

  • Are there any special regulations applied to kids 6 to 18yo? At what terms schools are available?

TBP: No. Schools are not available for short-term stay in Bulgaria. 

  • Are there any special regulations applied to juniors 19 to 22yo? At what terms universities are available?

TBP: No. Universities are not available for short-term stay in Bulgaria.

  • Are there any special regulations applied to elderly people at 60+ age?

TBP: No

  • Are there any special regulations applied to disabled persons?

TBP: No

  • Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

TBP: We are not familiar with such a state program.

  • Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

TBP: We are not familiar with such a state program.

  • Any other important information.

TBP: No

4) If UA citizen entered the country aiming to get temporary residency permit

  • When and where UA citizen shall apply to obtain a temporary residency permit? Please briefly describe main steps required and respective timelines.

TBP: Please refer to our reply to Question No 1.2. regarding prolonged-term residence permit.

Assuming the temporary residency permit is granted:

  • What is the maximum allowed duration of stay in the country?

TBP: Please refer to our reply to Question No 1.2. regarding prolonged-term residence permit.

  • Are any formal procedures (registration etc.) required for the stay?

TBP: Please refer to our reply to Question No 1.2. regarding prolonged-term residence permit.

  • Is employment allowed?

TBP: Yes

  • Is healthcare covered by the hosting state? Is it covered for kids and other dependent relatives?

TBP: No. However, the local employer company must insure health coverage for the employee. The health services (if such are used) shall be paid by the UA citizen.

Emergency medical care is free.

  • What are main taxes, which shall be paid by UA citizen during the stay?

TBP: Please refer to our answer to Question No 3.5.

  • What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

TBP: Please refer to our answer to Question No 3.6.

  • Is it possible to open and use banking account?

TBP: Yes

  • What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

TBP: Please refer to our answer to Question No 3.8.

  • Is UA driving license accepted? If yes, for how long?

TBP: Please refer to our answer to Question No 3.9.

  • What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

TBP: Please refer to our answer to Question No 3.10.

  • What is required to sell a car brought from Ukraine in your country?

TBP: Please refer to our answer to Question No 3.11.

  • Are there any special regulations applied to kids under 5yo whose parent obtained the temporary residency permit? At what terms kindergartens are available?

TBP:  No.

Kindergarten are available for children of parents legally residing more than 1 year (prolonged and long-term stay) or have a protection status (international protection or asylum). It is expected to be available also for all the foreigners subject to temporary protection.

In Bulgaria kindergartens are available for children aged from 10 months, where preschool education is obligatory starting from the age of 4. The application and admission to the municipal kindergartens is regulated by the respective municipality, starting from April 2022 these will be free of charge. However, in the big cities there has been a shortage of place and application process may take up to a few months. As an alternative there are “private” kindergartens where the monthly fee is determined based on the market practices.

  • Are there any special regulations applied to kids 6 to 18yo whose parent obtained the temporary residency permit? At what terms schools are available?

TBP: No.

Schools are available for children of parents legally residing more than 1 year (prolonged and long-term stay) or have a protection status (international protection or asylum). It is expected to be available also for all the foreigners subject to temporary protection.

School education is mandatory from age of 7 on or from age of 6 according to parents’ assessment to age of 16. As a rule, school year in Bulgaria begins on September 15th and is divided in two terms. Schools are state, municipal, private. State/municipal schools are in general free of charge, the application and admission rules are determined on a local level. Private schools (incl. foreign language schools) are also available in Bulgaria.

  • Are there any special regulations applied to juniors 19 to 22yo whose parent obtained the temporary residency permit? At what terms universities are available?

TBP: The universities are available for children if they are up to 21 or older but supported of parents legally residing more than 1 year (prolonged and long-term stay) or have a protection status (international protection or asylum). It is expected to be available also for all the foreigners subject to temporary protection.

 The general age of majority in Bulgaria is 18 years. There are no specific rules for individuals aged 19 to 22 years.

The institutional management is performed according to the rights for an academic autonomy of the higher education institutions. Again, there are educational institutions which are state funded (semester fees vary depending on the institutions, level and type of education), as well as private ones.

  • Are there any special regulations applied to elderly people at 60+ age?

TBP: We are not familiar with any special regulations applied to elderly people at 60+ age in terms, apart from the long-term care (LTC) system and certain benefits/ discount entitlements in the public sector (e.g., public transport discounts, lower administrative burden for driving license renewal, etc.)

Bulgaria’s LTC services are delivered by a variety of care institutions and programs, regulated by various laws. The services provided by these institutions are of limited coverage and are often reported to be inefficient. This places a significant financial and practical responsibility on the family.

  • Are there any special regulations applied to disabled persons?

TBP: Employee, who by reason of a disease or employment injury is unable to execute the work assigned thereto, but who may execute another suitable work or the same work under relaxed conditions without hazard to his or her health, shall become an occupational rehabilitee, being transferred to another work or to the same work under suitable conditions at a prescription of the health authorities.

Employers are encouraged by the state to hire unemployed people with permanent disabilities.

  • Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

TBP: We are not familiar with such a state program.

  • Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

TBP: We are not familiar with such a state program.

  • Are there any restrictions to leave the country?

TBP: No

  • Any other important information.

TBP: No 

5) If UA citizen entered the country aiming to get permanent residency permit

  • When and where UA citizen shall apply to obtain a permanent residency permit? Please briefly describe main steps required and respective timelines.

TBP: Please refer to our reply to Question No 2.3.

Assuming the permanent residency permit is granted:

  • What is the maximum allowed duration of stay in the country?

TBP: Please refer to our reply to Question No 2.3.

  • Are any formal procedures (registration etc.) required for the stay?

TBP: Please refer to our reply to Question No 2.3.

  • Is employment allowed?

TBP: Yes

  • Is healthcare covered by the hosting state? Is it covered for kids and other dependent relatives?

TBP: Health contributions are due by the employer of UA citizens with long-term or permanent residence permit. If they are self-employed, health contributions are due by the UA citizens.

Emergency medical care is free.

  • What are main taxes, which shall be paid by UA citizen during the stay?

TBP:  Please refer to our reply to Question No 3.5.

  • What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

TBP: Please refer to our reply to Question No 3.6.

  • Is it possible to open and use banking account?

TBP: Yes

  • What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

TBP: Please refer to our reply to Question No 3.8.

  • Is UA driving license accepted? If yes, for how long?

TBP: Please refer to our reply to Question No 3.9.

  • What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

TBP: Please refer to our reply to Question No 3.10.

  • What is required to sell a car brought from Ukraine in your country?

TBP: Please refer to our reply to Question No 3.11.

  • Are there any special regulations applied to kids under 5yo whose parent obtained the permanent residency permit? At what terms kindergartens are available?

TBP: Please refer to our reply to Question No 4.13.

  • Are there any special regulations applied to kids 6 to 18yo whose parent obtained the permanent residency permit? At what terms schools are available?

TBP: Please refer to our reply to Question No 4.14.

  • Are there any special regulations applied to juniors 19 to 22yo whose parent obtained the permanent residency permit? At what terms universities are available?

TBP: Please refer to our reply to Question No 4.15.

  • Are there any special regulations applied to elderly people at 60+ age?

TBP: Please refer to our reply to Question No 4.16.

  • Are there any special regulations applied to disabled persons?

TBP: People with confirmed long-term disability are generally entitled to allowances and invalidity pensions due to sickness, as well as supplement for external care in the event of more than 90% degree of disability. Application procedures are rather burdensome and take time.

  • Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

TBP: We are not familiar with a state program.

  • Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

TBP: We are not familiar with a state program.

  • Are there any restrictions to leave the country?

TBP: No

  • Any other important information.

TBP: No

6) If UA citizen entered the country aiming to get refugee status

  • When and where UA citizen shall apply to obtain a refugee status? Please briefly describe main steps required and respective timelines.

TBP: Please refer to our reply to Question No 1.4.

Assuming the refugee status is granted:

  • What is the maximum allowed duration of stay in the country?

TBP: Please refer to our reply to Question No 1.4.

  • Are any formal procedures (registration etc.) required for the stay?

TBP: Please refer to our reply to Question No 1.4.

  • Is employment allowed?

TBP: Yes

  • Is healthcare covered by the hosting state? Is it covered for kids and other dependent relatives?

TBP: UA citizens in respect of whom a procedure for recognition of refugee status or for affording a right of asylum has been initiated is health insured where he/she is exempt from payment of health contributions. UA citizens that are recognized a refugee status, humanitarian status, temporary protection or who has been afforded a right of asylum are health insured. Since they are allowed to work the health contributions are paid by the employer. If they are self-employed, they shall pay the health contributions by themselves.

Children until 18 years of age if attending school as full-time students until completion of secondary education, but not later than the attainment of the age of 22 years; students until 26 years of age at universities and full-time doctoral candidates; any parents, adopters, spouses or one of the parents of the mother or father taking care of disabled persons with a type and degree of disability of 50 percent and more or with permanently reduced capacity for work for whom attendance has been approved, are health insured, where they are exempt from payment of health contributions.

Emergency medical care is free.

  • What are main taxes, which shall be paid by UA citizen during the stay?

TBP: Please refer to our reply to Question No 3.5.

  • What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

TBP: Please refer to our reply to Question No 3.6.

  • Is it possible to open and use banking account?

TBP: Yes

  • What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

TBP: Please refer to our reply to Question No 3.8.

  • Is UA driving license accepted? If yes, for how long?

TBP: Please refer to our reply to Question No 3.9.

  • What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

TBP: Please refer to our reply to Question No 3.10.

  • What is required to sell a car brought from Ukraine in your country?

TBP: Please refer to our reply to Question No 3.11.

  • Are there any special regulations applied to kids under 5yo? At what terms kindergartens are available?

TBP: Please refer to our reply to Question No 4.13.

The country's regional education departments accept applications from Ukrainians seeking or receiving international protection who want to enroll their children in kindergarten or school. The application is available on the website of the Ministry of Education and Science (https://www.mon.bg/bg/news/4708). In the application they must indicate the mother tongue of the child, whether he/ she speaks to some extent Bulgarian or other European languages, where and which class he/ she graduated in his/ her country. Consultations can be obtained on the Hotline of the Ministry of Education and Science 0800 16 111.

  • Are there any special regulations applied to kids 6 to 18yo? At what terms schools are available?

TBP: Please refer to our reply to Question No 4.14 and 6.13.

  • Are there any special regulations applied to juniors 19 to 22yo? At what terms universities are available?

TBP: Please refer to our reply to Question No 4.15.

  • Are there any special regulations applied to elderly people at 60+ age?

TBP: Please refer to our reply to Question No 4.16.

  • Are there any special regulations applied to disabled persons?

TBP: Please refer to our reply to Question No 5.17.

  • Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

TBP: We are not familiar with a state program at this stage, although there are on-going discussions in the public sector.

  • Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

TBP: At the suggestion of the Minister of Tourism, Ukrainians will be entitled to assistance in the total amount of BGN 40 (EUR 20) per person per night and one meal for up to three months from the submission of an application for protection. However, we are expecting the resolution of Council of Ministers that can provide further details.

  • Are there any limitations to leave the country?

TBP: No

  • Any other important information.

TBP: No

7) Language issues

7.1. What languages can be used for communication in your country?

TBP: The official language for communication with the state authorities is Bulgarian. Therefore, all documents provided to state authorities shall be translated into Bulgarian (i) by a certified translator whose signature shall be notary certified or (ii) by a Bulgarian consulate. However, most of the institutional websites are translated in English and there are some public services available in English language. Also, most people understand Russian.  

8) Upcoming or expected legislative changes

8.1. Do you expect any major changes to the relevant legislation?

TBP: Public discussions are on-going, legislative changes, if any, may be expected in the area of facilitating the access to the Bulgarian labour market, educational and health system.

9) Local help resources

9.1. Please provide links and brief descriptions to any local helpful resources.

TBP: The Association of Ukrainian Organizations in Bulgaria “Mati Ukraina” has created a group to help refugees from Ukraine in Bulgaria and announced an account to which people can donate funds. The group‘s link: https://www.facebook.com/groups/338927668246444

The mobile operators Vivacom and A1 are making international calls to Ukraine free, and Telenor is also providing free-roaming.

A team of volunteers supported by business partners and NGOs has developed a web-based platform to coordinate evacuation, relocation, and accommodation efforts: https://www.bg4ua.com/.

General Information on the rights and obligations of newly recognized refugees and humanitarian status holders in English is also available on the institutional website of the Bulgarian UN Refugee Agency:  https://refugee.bg/en/.

The Sofia Bar Association announced a hotline providing free of charge legal advisory in English/ Russian: +359 879 292 230; +359 879 292 231.

Unlike any other news items in CEELM, these are published as received with no other edits than outlined in this editorial note.