PRACTICAL CASE: REGISTRATION OF A BULGARIAN COMPANY FOR A UKRAINIAN FOOD EXPORTER

INITIAL SITUATION

A client from Ukraine contacted us planning to sell food products from Ukraine to Bulgaria. The initial request was to register a Bulgarian company remotely, eliminating the need for a personal visit to the country.

However, according to current Bulgarian banking practices, it is not possible to open a temporary account remotely for depositing the authorized capital. Therefore, the client was offered a hybrid option: remote document preparation and an in-person visit only for those stages where in-person presence is required.

An analysis of Bulgarian banks and available options for Ukrainian citizens

We analyzed the options for opening a temporary bank account in Bulgaria for non-residents without residency status. Current data shows that only two banks currently accept applications:

1) Investbank

Application processing fee: 1,000 BGN
The client’s personal presence is mandatory.
There is no requirement for a Bulgarian citizen to be a contact person.

2) UniCredit Bulbank

Application processing fee: 300 BGN
Requirement: a contact person who is a Bulgarian citizen (the bank will contact them for administrative matters)
A personal visit by the client is required

Thus, remote company registration without the client’s presence turned out to be impossible, since all banks require a personal interview.

Action plan proposed to the client

We developed a detailed plan for company registration and bank account opening:

• We send the client a completed company registration application.
• The client signs it and pays for our services.
• We prepare a full package of banking documents.
• The client comes to Bulgaria for an interview at the bank.
• We await the bank’s decision (1-2 weeks, or 5-7 days in reality).
• If the decision is positive, the client visits the bank again and deposits the authorized capital.
• After depositing the capital, we formalize the documents with a notary.
• We submit the required documents to the Bulgarian Trade Register.
• Once the company appears in the register, we proceed to VAT registration.
• During the client’s second visit, the main bank account is opened.

Risks and features that we warned the client about

The bank may refuse the application; this is normal practice in Bulgaria.

If the decision is negative, we are prepared to:

• search for other banks,
• find a Bulgarian citizen as a hired director (which significantly expands the list of banks),
• resubmit the application to alternative financial institutions.

The processing timeframe may vary for each specific bank.

Factors that may lead to a bank refusing to open an account

1) Low economic ties to Bulgaria

The bank may refuse the application if:

• there are no suppliers or buyers in Bulgaria
• there is no office/warehouse lease agreement or local representative;
• the business appears “purely formal” for entry into EU law.

2) High-risk compliance profile

Refusal is possible if the business falls into the following categories:

• cryptocurrencies,
• fintech and payment services,
• dual-use goods,
• agricultural sector with high risk of product origin,
• logistics with gray routes.

3) Inconclusive proof of the origin of funds

The bank has the right to request the following documents: tax returns, income statements, and bank statements from the country of residence.

If the documents are missing or raise doubts, the application may be refused.

4) Incomplete documents and inaccuracies in the application form

Common reasons:

• Simplified description of activities,
• lack of document translation,
• inconsistency between the charter, business plan, and the bank application forms

5) Beneficiary’s negative credit or legal history

Bulgarian banks are integrated with EU due diligence systems and can obtain information on: litigation, sanctions, and account freezes in the EU.

6) Insufficient presence in Bulgaria

Some banks require the following information: a Bulgarian contact person, a local telephone number, a leased legal or physical address, a physical office, or a warehouse (especially for food retailers).

7) Lack of experience in the stated field of activity

If a client is engaged in food import/export for the first time, the bank may require the following information: experience working with goods, contracts, quality certificates, and proof of supply chain.

Refusal will be in the absence of evidence

How we reduce the risk of refusal

To increase the likelihood of a successful account opening, we:

• request documents to confirm income and source of funds in advance;
• prepare a description of the bank’s activities and business justification;
• select a bank that best suits the client’s specific profile;
• If necessary, we provide a Bulgarian contact person;
• We facilitate a personal interview at the bank.

This allows us to address compliance issues early and avoid rejections.

Practical implementation: how the process went

In the actual case, everything went as smoothly as possible.

Step 1 — Application Submission and Preparation
The documents were prepared in advance, the client paid for the services, and signed the application.

Step 2 — First Visit to Bulgaria

• The client arrived in Burgas for their first visit to the bank.
• The interview was attended by a bank manager, the client, and our representative.

Result: The bank approved the application and immediately opened a temporary account for depositing the authorized capital.
This is a rare situation: many banks first issue a preliminary decision and only open the account after a follow-up visit.

Step 3 — Depositing the authorized capital
The client deposited the capital on the same day.

Step 4 — Notarization of documents
After funding the account, we immediately visited a notary to have the articles of association and documents notarized.

Step 5 — Submission to the Commercial Register
The documents were submitted the next business day.

Step 6 — Company Appearance in the Register
Three days later, the company was registered in the Bulgarian Trade Register.

Step 7 — VAT Registration
Immediately after registering the company, we began the process of obtaining a Bulgarian VAT number.

Step 8 — Second Visit and Opening of the Main Current Account
We arranged the client’s second visit to Burgas in advance.
During this visit:

• The client underwent a follow-up interview at the bank,
• And the bank opened a working current account.

The opening period was four business days.

Final results of the case

The client’s company is officially registered in Bulgaria.
A temporary account was opened on the first try.
A main current account for business activities was opened within four days.
The client has begun import and export operations.
VAT registration has also been initiated.

Conclusion

This case demonstrates that, despite restrictions for Ukrainian citizens and the mandatory requirement for an in-person visit, company registration in Bulgaria can proceed quickly and smoothly—provided the documents are properly prepared and the bank is chosen wisely.

We handle the entire turnkey process:
from document preparation to opening all bank accounts and VAT registration.

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