Opening a Trade Representative Office in Bulgaria

A trade representative office of a foreign company in Bulgaria is not a legal entity and has no right to conduct economic activity. It is registered with the Bulgarian Chamber of Commerce and Industry (BCCI) under Article 24 of the Investment Promotion Act, and not in the Commercial Register, as companies are. The main practical value of this form is a basis for obtaining a residence permit for the representative, not a way to sell goods or issue invoices in Bulgaria.

International Law Firm "Zahist" advises clients on various forms of business presence in Bulgaria, including trade representative offices. In our practice, the most common mistake is expecting that a representative office can be used to start selling goods or services on the Bulgarian market. In fact, this form is designed precisely so that such activity is not conducted, but rather to represent the interests of the parent company.

We examine what a trade representative office is, which documents are required for registration with the BCCI, how much it costs, and how a representative office fundamentally differs from a branch or a company of one’s own.

What a trade representative office is and what it is not

A trade representative office exists at the expense of the parent company and is neither a branch, nor a subsidiary, nor a separate legal entity — under Bulgarian law it is more a registered presence than an independent economic operator.

A representative office is permitted to study the market, conduct advertising and marketing activities, and maintain contacts with existing or potential partners of the parent company — that is, to perform the functions of an intermediary and information hub.

What is prohibited is precisely what businesses are usually opened for — the sale of goods or services, conclusion of commercial contracts in its own name, issuing invoices, and generating profit in the territory of Bulgaria.

Due to the lack of a right to conduct economic activity, a representative office does not keep financial and employment reporting to the extent usual for a company — profit taxes typical of an EOOD or OOD simply do not apply to it.

Legal basis and registration authority — BCCI, not the Commercial Register

The obligation to register trade representative offices of foreign persons is established by Article 24(1) of the Investment Promotion Act — it is this law, not general company legislation, that governs this form of presence.

Unlike an EOOD, OOD or a branch, which are registered in the Commercial Register at the Registry Agency, a trade representative office is entered in the Unified Trade Register of the Bulgarian Chamber of Commerce and Industry itself.

The BCCI decision on registration has constitutive effect — the representative office officially comes into existence from the moment of that decision, not from the moment of filing the application or paying the fee.

After registration with the BCCI, the representative office is additionally entered in the BULSTAT register — this is the single identification code required for further interaction with Bulgarian authorities, including the migration service.

Documents for registering a representative office

1. An official document on the current status of the foreign legal entity from the competent authority of the country of registration — issued no earlier than 6 months before filing and valid for 6 months from the date of issue
2. The original specimen signature of the representative in Bulgaria, notarized or executed on a special BCCI declaration form
3. A completed information card according to the BCCI template
4. A document confirming payment of the prescribed registration fee
5. A lease agreement or other document confirming the right to use an office, for a term of at least one year from the date of filing the application

All documents of foreign origin must be translated into Bulgarian and the translation notarized — without this the BCCI will not accept the document package for review.

The office lease requirement is not a formality: without a confirmed address valid at least one year in advance, the registration application will be rejected already at the completeness check of the document package.

Timeframes and cost of registration

The basic cost of registering a representative office is approximately EUR 500-700 depending on the service provider chosen, and the BCCI certificate for a subsequent application to the migration service is charged separately, approximately EUR 48.

Entering each additional representative on the registration card is a separate paid action, approximately EUR 100 per person, and translation of each document usually costs from EUR 15.

Registration of a representative office is not a one-off expense: an annual fee must be paid to keep the entry in the BCCI register up to date, otherwise the representative office may lose its valid status.

A trade representative office as a basis for a residence permit

The most common practical purpose of registering a representative office is not commercial presence itself, but the possibility of obtaining a D visa and subsequently a residence permit for the representative of the parent company in Bulgaria.

With a valid D visa, the representative enters Bulgaria and submits documents for a temporary residence permit to the migration service at the place of intended residence — already in the country, not at a consulate.

This legalization path is separate from that described in articles on one’s own business: there the basis is ownership of more than 50% of the company’s capital or creation of at least 10 jobs, whereas here it is the very position of representative of a registered office.

A residence permit on this basis, like other temporary permits, must be regularly renewed, and the representative’s status remains tied to the validity of the representative office itself in the BCCI register — termination of registration also means loss of the basis for stay.

Trade representative office, branch and company — the fundamental difference

A branch of a foreign company, unlike a representative office, may conduct full commercial activity and is subject to taxation under general rules — that is, it is functionally closer to an EOOD or OOD than to a representative office.

The choice between a representative office, a branch and a separate company should be made in light of the real purpose: if it is necessary to sell goods or services in the territory of Bulgaria, a representative office is in principle unsuitable for this — a branch or a company of one’s own will be required.

Legal assistance with registering a representative office in Bulgaria

Correctly assessing whether a trade representative office is suitable for a specific purpose, and assembling the document package for the BCCI at the first attempt, is a task where an error in translation or in the term of the lease means a repeat filing.

Lawyers of International Law Firm "Zahist" help prepare documents for registration with the BCCI and BULSTAT, and also support the subsequent obtaining of a D visa and a residence permit for the representative.

We also advise on which form of presence in Bulgaria — a representative office, a branch or a company of one’s own — actually matches your business goals, so as to avoid choosing a form that does not allow what is needed.

If you plan to open a trade representative office in Bulgaria and want to check whether this is the right choice for your situation, contact International Law Firm "Zahist"— we will review your case at a consultation.