Written and reviewed by Adriana Melnikliyska, Attorney-at-law, Blagoevgrad Bar No. 1900000227. Last reviewed 27 September 2026.Who this page is for
This page is written for a foreign heir, executor or family member dealing with an estate that has a Bulgarian element: a deceased relative who held Bulgarian nationality, a deceased relative (of any nationality) who owned property or held assets in Bulgaria, or a Bulgarian-resident family member with heirs living abroad. It is also relevant if you are trying to establish, in advance, how a will or a lack of one would affect Bulgarian property you or a relative currently own.
It is not a substitute for reviewing the actual death certificate, the actual property documents, or the actual family situation. Succession is fact-specific: the number of heirs, their relationship to the deceased, whether a will exists, and what is registered against the property in Bulgaria all change the analysis. Nothing on this page should be read as advice on a specific estate.
Which law applies to a Bulgarian estate
For deaths on or after 17 August 2015, Regulation (EU) No. 650/2012 (the EU Succession Regulation) determines which country's law governs succession to a cross-border estate for most EU member states, including Bulgaria. The default connecting factor is the deceased's last habitual residence, unless the deceased had chosen the law of their nationality in a valid will, or unless the facts point clearly to a closer connection with another state. Bulgaria is not bound by every provision that applies in every other member state, and the Regulation itself preserves some specific national rules — including, in many legal systems, particular treatment of immovable property situated in the country where it is located.
In practice, this means the starting question for any Bulgarian estate is not "was the deceased Bulgarian?" but "what does Regulation 650/2012 say governs this succession, given where the deceased was habitually resident, what nationality they held, and whether they made a valid choice-of-law in a will?" Where Bulgarian law ends up governing the succession — which is common where the deceased was Bulgarian, was habitually resident in Bulgaria, or held Bulgarian immovable property with no valid contrary choice — the Bulgarian Inheritance Act supplies the substantive rules: who inherits, in what order, and what share each statutory heir receives.
The European e-Justice Portal's Bulgaria succession pages set out the current official summary of how these connecting factors and Bulgarian domestic law interact, and are a reasonable public starting point before any formal advice is obtained.
Statutory heirs and reserved shares under the Inheritance Act
Where Bulgarian law governs the succession, the Inheritance Act sets out a fixed order of statutory heirs: descendants (children, and their own descendants if a child has predeceased), then the surviving spouse (who inherits alongside descendants or other classes rather than displacing them), then parents, then more distant relatives, in a defined sequence. Where a valid will exists, Bulgarian law still reserves a protected minimum share — a "reserved portion" — for certain close relatives (broadly, children, spouse and, in some circumstances, parents), which a will cannot freely override. This is the "forced heirship" feature that surprises many foreign clients used to jurisdictions with full testamentary freedom.
What this means practically for a foreign heir: even a will drafted abroad, if Bulgarian law governs the succession, may not be able to disinherit a reserved-share heir entirely, and a reserved-share heir who has been left less than their protected minimum may have a claim against the estate or against other heirs who received more than their share. Working out exactly who is a statutory heir, what class they fall into, and what their reserved share would be requires the actual family tree and the actual will (if any) — this page describes the framework, not the outcome for any particular family.
Proving you are an heir: certificate of heirs and the European Certificate of Succession
Before a bank, the Property Register, or a buyer will treat you as entitled to deal with a Bulgarian asset, you generally need to document your status as an heir. Two routes exist, and foreign heirs often need to understand both:
- A Bulgarian certificate of heirs, issued through the domestic Bulgarian procedure (typically via the municipality or, where the matter is contested, established through the Bulgarian courts under the Civil Procedure Code), confirming who the statutory heirs of the deceased are under Bulgarian law.
- A European Certificate of Succession (ECS), created by Regulation (EU) 650/2012 specifically to let an heir, legatee, executor or administrator prove their status, rights and powers in any EU member state without needing to re-litigate the succession in each country where the deceased held assets. An ECS issued in one member state is, by design, recognised and used directly in another — which is why it matters for a foreign heir dealing with a Bulgarian bank account, a Bulgarian property, or a Bulgarian company shareholding from abroad, or conversely for a Bulgarian-issued ECS being used to deal with assets the deceased held outside Bulgaria.
Which certificate you need, and where it should be issued, depends on where the succession is being administered and what the receiving institution (a Bulgarian bank, the Property Register, a foreign registry) actually requires. We cover the ECS route itself — including how the Bulgarian version is issued, how a foreign-issued ECS is used to register Bulgarian property, and what translation is typically required — on a dedicated page: European Certificate of Succession in Bulgaria.
Accepting or renouncing an inheritance
Under Bulgarian law, becoming an heir in fact (rather than merely in theory) generally requires an act of acceptance, and an heir can instead renounce the inheritance. Acceptance can happen expressly (a formal declaration) or, in some circumstances, by conduct that is treated as accepting — for example, dealing with estate assets as an owner. Renunciation is also a formal step, not a default outcome of inaction, and Bulgarian law applies specific time limits to some of these choices that must be checked against the current statutory text and the actual date of death, rather than assumed from general knowledge.
This choice matters most where the estate may carry liabilities as well as assets — debts, tax exposure, or disputed claims — because accepting an inheritance can, depending on how it is accepted, expose the heir to the deceased's debts up to the value of what was inherited, or in some cases beyond it if the acceptance is unqualified. A foreign heir who is uncertain whether a Bulgarian estate is solvent should have this checked before formally accepting anything.
Co-heirs, disagreement, and partition of the estate
Where there is more than one heir, Bulgarian law treats the estate as co-owned by all heirs in the shares to which they are entitled, until it is formally divided. This is a common source of difficulty for foreign heirs: a Bulgarian property may be registered as jointly owned by several heirs, some in Bulgaria and some abroad, none of whom individually has the right to sell or fully use the whole property without the others' agreement or a formal partition.
Partition (division) of an estate between co-heirs can happen by agreement, where all heirs agree on how to split the assets or their value, or through the Bulgarian courts under the Civil Procedure Code where heirs cannot agree, where one heir is unreachable or uncooperative, or where the asset (typically real property) cannot practically be split and must instead be sold with the proceeds divided, or allocated to one heir who compensates the others. A foreign heir who wants to resolve their share — whether to keep it, sell it, or be bought out by other heirs — needs the partition question addressed as a distinct step from simply establishing heirship.
Wills and their recognition in Bulgaria
Bulgarian law recognises wills made in specific forms, and a will validly made abroad can, in many cases, still be given effect in Bulgaria — but its validity, its formal requirements, and how it interacts with Bulgarian forced-heirship rules on a reserved share all need to be checked against the actual document, not assumed. A will that would be perfectly valid and fully effective in the country where it was made does not automatically override a Bulgarian reserved-share heir's protected minimum where Bulgarian law governs the succession.
If you are trying to plan ahead — for example, a foreign national who owns Bulgarian property and wants clarity on how it will pass on death — that is a distinct, forward-looking piece of work from administering an estate that has already opened, and is scoped separately.
Tax and registering the inheritance
Bulgarian law generally requires an inheritance that includes Bulgarian assets to be declared to the relevant local tax authority, with inheritance tax (where due) assessed under the Local Taxes and Fees Act. Rates and exemptions vary by municipality and by the heir's relationship to the deceased, and by what other reliefs may apply — this needs to be checked against the current municipal ordinance and the actual facts, not treated as a fixed nationwide figure. Once heirship is established and any declaration/tax step is complete, an inherited property still needs to be registered in the heirs' names at the Bulgarian Property Register before it can be reliably sold, mortgaged, or otherwise dealt with by the new owners.
Handling a Bulgarian inheritance from abroad
Very little of this process strictly requires being physically present in Bulgaria. A foreign heir can typically act through a power of attorney, once its scope, its form (Bulgarian law has specific requirements for powers of attorney used in property and succession matters, including notarisation and, for documents executed abroad, an apostille or equivalent legalisation) and its intended use are confirmed. Original documents — death certificates, foreign wills, marriage/birth certificates establishing the family relationship — usually need to be apostilled and, where they are not already in Bulgarian, professionally translated before Bulgarian institutions will accept them.
What this means in practice: the estate can usually be assessed, the right certificate route decided, the paperwork prepared, and a power of attorney drafted and sent for signature and apostille, all before you need to travel — if travel becomes necessary at all, it is typically for a specific step (a notarial act that requires personal appearance, for example), not the whole process.
Selling inherited property afterward
Once heirship is established, any co-ownership resolved, tax obligations addressed and title registered, an inherited Bulgarian property can be sold in the same way as any other Bulgarian property — through a notarial deed, with the seller's identity, marital status and clean title (no undischarged mortgage or other encumbrance) confirmed beforehand. Where several heirs jointly inherited the property, all co-owners generally need to participate in or authorise the sale, which is one reason resolving co-ownership early avoids delay later.
Bulgarian certificate of heirs compared with a European Certificate of Succession
| Bulgarian certificate of heirs | European Certificate of Succession | |
|---|---|---|
| Issued by | The competent Bulgarian municipality, or established through the Bulgarian courts if contested | The competent authority of the EU member state handling the succession (courts, notaries or other bodies designated for this purpose under Regulation 650/2012) |
| Typical use | Dealing with Bulgarian institutions where only domestic recognition is needed | Proving heirship, legatee status, or executor/administrator powers in another EU member state without repeating the succession procedure there |
| Recognition abroad | Not automatically recognised outside Bulgaria | Recognised directly in other EU member states by design |
| Where it fits this estate | Usually sufficient if every asset and every heir is inside Bulgaria | Usually needed where the deceased, an heir, or an asset is in more than one EU country |
Foreign heirs sometimes assume the two are interchangeable, or that requesting one automatically produces the other. They are separate procedures with separate application routes, and the choice affects how quickly a Bulgarian bank, the Property Register, or an institution outside Bulgaria will accept the document. Getting this choice right before applying, rather than after a rejected submission, is one of the more common ways this matter is delayed unnecessarily.
Common mistakes foreign heirs make
- Assuming the estate follows the law of the heir's own country. It is the deceased's habitual residence, nationality-based choice in a will, and Regulation 650/2012's connecting rules that decide this — not where the heirs happen to live now.
- Dealing with estate assets before formally deciding to accept. Certain conduct can be treated under Bulgarian law as an implicit acceptance, which matters if the estate turns out to carry debts.
- Delaying because "nothing urgent is happening." Co-owned property left undivided, deadlines attached to certain choices, and other heirs or third parties acting on the property can all make an unresolved estate harder to sort out the longer it sits.
- Sending uncertified or untranslated documents. A death certificate, foreign will, or civil-status document that has not been apostilled and, where required, professionally translated is routinely rejected by Bulgarian institutions, costing time rather than saving it.
- Treating a foreign grant of probate as automatically effective in Bulgaria. A foreign court's grant of probate or letters of administration does not, by itself, register title to Bulgarian property; the Bulgarian route (certificate of heirs or ECS, then registration) still needs to be completed.
Fees and how an inheritance matter is scoped
The fee for an inheritance matter depends on what is actually needed: a document review and route assessment is a different scope from contested heirship proceedings, an ECS application, or a partition dispute between co-heirs. We do not quote a fee before reviewing the facts, and we do not promise a particular outcome, timeline, or tax result — succession matters depend on the family situation, what documents exist, and whether any heir disputes the position. The scope and the professional fee are set out in writing before any substantive work begins.