Comparing the Bulgaria Golden Visa–eligible funds.
The EUR 512,000 qualifying investment can be placed in a regulated Bulgarian Alternative Investment Fund (AIF) or an exchange-traded fund (ETF) — and it can be split across more than one fund for diversification. Here is how the funds compare on structure, fees, Bulgarian asset allocation and track record.
The three AIFs: Bulgaria AIF Fund, Elana Premium BG Selection, VF Alternative
All three are structured as regulated Alternative Investment Funds investing primarily in Bulgarian fixed income. Because each fund holds a different mix of issuers and is run by a separate management company, allocating across more than one is a genuine diversification — not duplication.
Badges below rank the five funds on this site across cost, transparency, government engagement and other metrics — see each fund's own page for the full basis.
| Bulgaria AIF Fund Lowest cost · Legal included |
Elana Premium BG Selection Monthly AUM total published Highest cost Smallest & newest |
VF Alternative (VFAL) Least transparent |
|
|---|---|---|---|
| Management company | Bulgaria Fund Management | Elana Fund Management | Self-managed |
| Structure | Open-ended AIF | Open-ended AIF | Likely closed-end — not explicitly stated, listed on BEAM (BSE) under VFALinferred from fixed-value share classes and minimum lot size, not a direct statement from VF Alternative's own site — conflicts with "open-ended" above; see correction note below |
| Subscription fee | 0% | 2.5% | Not publicly disclosed |
| Annual management fee | 1%starts 6 months after capital deposit | 3% | Not publicly disclosed |
| Redemption / exit fee | 0% | 0% after 5 years, 5% beforei.e. early-redemption penalty applies for 5 years | Not publicly disclosed |
| Bulgarian asset allocation | 100% | 100% | 100% |
| Investors onboarded (to date) | 8 per Bulgaria Fund Management's own records | 1 confirmed by Elana's own investment structure | Not publicly disclosed |
| Engagement on proposed programme changes | Filed statementtwo official standpoints filed with the National Assembly of Bulgaria: 23654 & 23396 | Filed statementofficial standpoint: 23657, filed under the name "Elana Bulgaria" — confirm this refers to Elana Premium BG Selection specifically | Filed statementofficial standpoint: 23739 |
| Golden Visa compliance status | Compliant | Compliant | Compliant |
| Russian-national clients | Accepted — conditions applyunder the EU sanctions framework applicable to every Bulgaria Golden Visa fund — a Russian national needs a second, non-Russian nationality or a valid EU residence permit, plus a clean sanctions-list and employment history, to subscribe | Not acceptedconfirmed with Elana Fund Management — excludes Russian citizens, dual nationals holding a Russian passport, and Russian citizens with EU residency. Stricter than the general EU sanctions baseline that applies to the other four funds. | Accepted — conditions applyunder the EU sanctions framework applicable to every Bulgaria Golden Visa fund — a Russian national needs a second, non-Russian nationality or a valid EU residence permit, plus a clean sanctions-list and employment history, to subscribe |
| Investor eligibility | Professional investors only | Professional investors only | Professional investors only |
| Can be split with other funds? | Yes — with other AIFsElana Premium BG Selection, VF Alternative. Combining with an ETF is not permitted under the Golden Visa programme's legislation. | Yes — with other AIFsBulgaria AIF Fund, VF Alternative. Combining with an ETF is not permitted under the Golden Visa programme's legislation. | Yes — with other AIFsBulgaria AIF Fund, Elana Premium BG Selection. Combining with an ETF is not permitted under the Golden Visa programme's legislation. |
← Swipe to see all three funds →
Click a fund name above for a full profile page with fees, track record and data-completeness detail for each fund individually.
Bulgarian asset allocation shown as 100% for all three AIFs because the Golden Visa programme's legislation requires it — an AIF's qualifying investment must be 100% Bulgarian assets. The ETF route is different: an ETF needs only a 51%+ Bulgarian-asset threshold (see the ETF comparison below).
Assets under management: Bulgaria AIF Fund vs. Elana Premium BG Selection
Monthly AUM totals for both funds are published on their own sites — Bulgaria AIF Fund's own Portfolio Structure reports (see Documents on the homepage) and Elana's own monthly disclosures, both sourced from official filings under Наредба № 44, чл. 72, ал. 4. Both report the fund's total AUM figure only, not a breakdown of specific holdings.
Capital preservation, and a seat at the table on programme changes.
Beyond their conservative, capital-growth-oriented strategies, all three AIF managers took an active role when the Bulgarian government consulted on potential changes to the Golden Visa programme.
Bulgaria Fund Management, Elana Fund Management, VF Alternative
All three AIF managers filed formal statements with the government addressing proposed changes to the programme — see the linked standpoints in the table above.
Expat Capital & Advance Invest
Neither ETF manager filed a statement with the government on proposed programme changes.
Splitting across AIFs
Because each AIF holds different issuers and allocations under separate management, an investor can split the EUR 512,000 across more than one fund for genuine diversification within the AIF route alone.
The ETF alternative — and what "Bulgarian assets" actually means there.
ETFs are permitted to hold at least 51% Bulgarian assets rather than 100% — AIFs cannot. That one rule produces a meaningfully different investment, even where the headline qualifying amount is identical.
| Expat Capital (Expat Bulgaria SOFIX) 100% Bulgarian allocation | Advance Invest Largest / longest track record | |
|---|---|---|
| Bulgarian asset allocation | 100% SOFIX index-tracking strategy | ~60%remainder in other markets (e.g. Romania, Greece); confirmed with Karoll Capital, updated from an earlier third-party estimate of ~51–59% |
| Listed | Bulgarian Stock Exchange | Not listedAdvance Invest is not a listed/exchange-traded fund |
| Engagement on proposed programme changes | No statement filed | No statement filed |
| Golden Visa compliance status | Compliant | Compliant |
| Russian-national clients | Accepted — conditions applyunder the EU sanctions framework applicable to every Bulgaria Golden Visa fund — a Russian national needs a second, non-Russian nationality or a valid EU residence permit, plus a clean sanctions-list and employment history, to subscribe | Accepted — conditions applyunder the EU sanctions framework applicable to every Bulgaria Golden Visa fund — a Russian national needs a second, non-Russian nationality or a valid EU residence permit, plus a clean sanctions-list and employment history, to subscribe |
| Can be split with other funds? | Yes — with other ETFsAdvance Invest. Combining with an AIF is not permitted under the Golden Visa programme's legislation. | Yes — with other ETFsExpat Capital. Combining with an AIF is not permitted under the Golden Visa programme's legislation. |
← Swipe to see both funds →
The practical difference is this: a 100%-Bulgaria ETF or AIF is a direct allocation into the Bulgarian capital market and economy. A fund that is only majority-Bulgarian (the minimum ETFs are allowed to hold) is, to that extent, an international diversification play wrapped around a Golden Visa–qualifying structure — it optimises the investor's own risk and return more than it supports Bulgaria specifically. Neither approach is wrong, but they are not the same decision, and the allocation percentage is the detail that tells you which one you're actually making.
Note on names — resolved: this draft previously referenced "Karoll" and "Advance Invest" as if they might be separate ETF managers. Confirmed directly from Karoll Capital's own site: Karoll Capital Management manages Advance Invest — they are the same entity, not two separate ones. See the full Advance Invest profile page for fees, AUM and allocation detail. One figure still needs reconciling: Karoll Capital's own page describes Advance Invest's allocation as Bulgarian and Romanian markets only, while an earlier third-party source also mentioned Greek exposure — worth confirming which is current.
On splitting your investment: within each route, the funds can be combined — Bulgaria AIF Fund, Elana Premium BG Selection and VF Alternative can be split between each other on the AIF side; Expat Capital and Advance Invest can be split between each other on the ETF side. Combining an AIF with an ETF in the same qualifying investment is not permitted under the Golden Visa programme's legislation.
Do they accept Russian-national clients?
This is governed by EU sanctions law, not individual fund policy. An ordinary Russian national — holding only Russian citizenship, with no other status — cannot subscribe to any Golden Visa–eligible fund in Bulgaria. A Russian citizen who holds a second, non-Russian nationality, or a valid EU residence permit, can subscribe to the funds below — provided they are not personally listed on an EU/UN sanctions list and have not worked for a sanctioned entity. Elana Premium BG Selection is the one exception on this site: it excludes Russian citizens outright, including dual nationals and those with EU residency, going further than the general EU sanctions baseline requires.
"Accepted — conditions apply" reflects the general EU sanctions framework applicable to every Bulgaria Golden Visa fund, not a policy separately confirmed with each fund's manager — a Russian national needs a second nationality or valid EU residence permit, plus a clean sanctions-list and employment history, to subscribe. Click any fund name for its full profile page.
Open-ended funds, not closed-end.
Portugal's Golden Visa route is dominated by closed-end venture capital and private equity funds with fixed terms and limited redemption windows. Bulgaria AIF Fund, Elana Premium BG Selection, Expat Capital and Advance Invest are, by contrast, open-ended — investors can typically subscribe and redeem on an ongoing basis (subject to each fund's own notice periods and any early-redemption fees), rather than being locked into a fund's full multi-year term.
Correction pending: VF Alternative's share structure and exchange listing suggest closed-end characteristics — see the correction note in the AIF section above. If this is confirmed as closed-end, Bulgaria's Golden Visa route is not exclusively open-ended as this section previously stated, and this paragraph will need updating before publication.
Not sure which structure fits your plans?
Fee load, lock-up terms, and how much of your capital actually supports the Bulgarian market all point in different directions depending on your priorities. We'll walk through the trade-offs directly.