EU citizenship by descent: Bulgarian or Romanian — which route fits your family

Many families with roots in Eastern Europe have two possible routes to an EU passport, and the two are governed by different laws that ask different questions. Bulgarian citizenship by descent is based on origin: was your ancestor Bulgarian? Romanian citizenship by descent is based on citizenship: was your ancestor a Romanian citizen who later lost that citizenship? The two questions sound similar, but they look at different things, so the same family history can lead to different answers. A family may meet one test, the other, or both.

The two routes side by side

	Bulgaria	Romania
Law	Bulgarian Citizenship Act, Article 15	Law 21/1991, Articles 10 and 11
What the ancestor must be	of Bulgarian origin	a former Romanian citizen
How far back	parent, grandparent, great-grandparent	Article 11: up to great-grandchildren of former citizens who lost citizenship through no fault of their own; Article 10: up to grandchildren
Language	no exam; short interview in Bulgarian	B1 certificate in Romanian, with exemptions (e.g. 65 or over)
Residence in the country	not required	not required
Dual citizenship	allowed	allowed
Filing	in person: Ministry of Justice in Sofia or a Bulgarian consulate	in person: ANC in Bucharest or a Romanian consulate
Oath	none	oath of allegiance within one year of the order
Time, as of 2026	about 4–5 years, half of it in the appointment queue	Article 11: 3.28 years on average (ANC, June 2025); real waits 4–6 years

In the table, ANC is the National Citizenship Authority, the Romanian body that decides applications, and B1 is an intermediate level on the European scale of language ability. The “order” is the ANC’s decision granting citizenship, after which Romanian applicants take an oath of allegiance.

Origin or citizenship: the question that decides

Bulgaria looks at who your ancestor was. In the words of the Bulgarian Citizenship Act, a person of Bulgarian origin is one with at least one Bulgarian ascendant, meaning a direct ancestor such as a parent, grandparent or great-grandparent. Where the ancestor was born or which passport he held does not matter, and neither does where you live today: descendants in the United States, the United Kingdom, Canada or Germany apply on the same terms. What you file are official records that name the ancestor and show how he is connected to you. Our guide to Bulgarian citizenship by descent describes these records and the application in detail.

Romania looks at which state your ancestor belonged to. Article 11 of Law 21/1991 covers people who were Romanian citizens and lost that citizenship through no fault of their own, for example because the territory where they lived passed to another state, together with their descendants up to the third degree. Ethnicity is not part of the test, so a Jewish, Ukrainian or Bulgarian family that held Romanian citizenship qualifies on the same terms as an ethnically Romanian one. Which article applies to your family, and why the ancestor’s birthplace and year of birth matter, is explained in Article 10 or Article 11.

When one family has both

The two routes overlap in regions that belonged to Romania between the World Wars and had large Bulgarian communities:

• Bessarabia, Romanian from 1918 to 1940, with long-established Bulgarian villages in its south; the region is now divided between Moldova and Ukraine’s Odesa region;
• Southern Dobruja, also called the Cadrilater, which was Romanian from 1913 to 1940 and has been Bulgarian since the Treaty of Craiova of 7 September 1940, the agreement under which Romania returned the territory to Bulgaria.

An ancestor who was an ethnic Bulgarian and a Romanian citizen during those years can open both routes for his great-grandchildren. Each route, however, needs its own proof. The Bulgarian route needs a record that names him as Bulgarian, while the Romanian route needs proof that he was a Romanian citizen, which usually means a birth, marriage or other civil-status record made by the Romanian authorities at the time.

Imagine Anna, who lives in Munich. Her great-grandfather grew up in a Bulgarian village in southern Bessarabia while the region was part of Romania. If his birth record lists his nationality as Bulgarian and was issued by the Romanian civil registry, that one document points to both routes, and Anna can then decide which application suits her.

How to choose

You do not need both passports, because a single EU citizenship gives the same right to live and work anywhere in the EU. The choice therefore depends on what your records can prove and on what each process asks of you:

• Your records name the ancestor as Bulgarian, and you would rather not learn a language → the Bulgarian route. Plan for the interview in Bulgarian and for the two-year queue for a filing appointment.
• Your records show Romanian citizenship, but not Bulgarian origin → the Romanian route. It requires Romanian at level B1; see the B1 requirement and the 2027 deadline.
• Your records show both → compare the two queues and the language requirement. A family that qualifies for both can file both, and since Bulgaria and Romania both allow dual citizenship, one does not cancel the other.
• Your records show neither yet → neither route can be used for now. The first step is an archive search, and the choice can be made once its results are in.

What both routes have in common

• No residence. Neither country asks you to live there before, during or after the process.
• Personal filing. Both countries expect you to attend in person when you file, either in the capital or at a consulate.
• Documents decide. Family memory is a good starting point for the search, but the line itself is proved with official records.
• Full EU citizenship. Either passport gives the same rights in all 27 EU countries.

Common mistakes

A few misunderstandings come up regularly:

• Applying to Romania with proof of Bulgarian origin, or the other way round. Each country asks its own question, so the evidence has to match it. A record saying “Bulgarian” does not prove Romanian citizenship, and a Romanian birth record does not prove Bulgarian origin.
• Assuming that ethnicity rules you out. For Romania, ethnicity plays no role. For Bulgaria, on the other hand, origin is the whole test.
• Comparing headline timelines. Both routes take years, and the real difference is where the time is spent: in the appointment queue in Bulgaria and in the review queue in Romania.